UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM 10-K

☑ ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, 2020 

or

☐ Transition Report Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934

For the transition period from to

Commission File No. 000-08185

TCF Financial Corporation

(Exact name of registrant as specified in its charter)

Michigan	38-2022454
(State or other jurisdiction of incorporation or organization)	(I.R.S. Employer Identification No.)

333 W. Fort Street, Suite 1800

Detroit, Michigan 48226

(Address and Zip Code of principal executive offices)

(866) 258-1807

(Registrant's telephone number, including area code)

Securities registered pursuant to Section 12(b) of the Act:

Title of each class	Trading Symbol(s)	Name of each exchange on which registered
Common Stock (par value $1 per share)	TCF	The NASDAQ Stock Market
Depositary shares, each representing a 1/1000th interest in a share of the 5.70% Series C Non-Cumulative Perpetual Preferred Stock	TCFCP	The NASDAQ Stock Market

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.     Yes ☑    No ☐

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act.    Yes ☐    No ☑

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.    Yes ☑    No ☐

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).    Yes ☑    No ☐

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or an emerging growth company. See the definitions of "large accelerated filer," "accelerated filer," "smaller reporting company," and "emerging growth company" in Rule 12b-2 of the Exchange Act.

Large accelerated filer	☑	Accelerated filer	☐
Non-accelerated filer	☐	Smaller reporting company	☐	Emerging growth company	☐

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act.     ☐

Indicate by check mark whether the registrant has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit report. ☑

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act).    Yes ☐    No ☑

The aggregate market value of the voting and non-voting common equity held by non-affiliates computed by reference to the close price of such common equity, as of the last business day of the registrant's most recently completed second fiscal quarter as reported by The NASDAQ Stock Market, was approximately $4.3 billion.

As of February 19, 2021, there were 152,604,938 shares outstanding of the registrant's common stock, par value $1 per share, its only outstanding class of common stock.

DOCUMENTS INCORPORATED BY REFERENCE

Specific portions of the Registrant's definitive Proxy Statement for the 2021 Annual Meeting of Shareholders or of the Registrant’s amendment to the Annual Report on Form 10-K/A to be filed with the SEC not later than 120 days after December 31, 2020 are incorporated by reference into Part III hereof.

TABLE OF CONTENTS

Description		Page
Part I
Item 1.	Business	1
Item 1A.	Risk Factors	11
Item 1B.	Unresolved Staff Comments	11
Item 2.	Properties	26
Item 3.	Legal Proceedings	26
Item 4.	Mine Safety Disclosures	27
Part II
Item 5.	Market for Registrant's Common Equity, Related Shareholder Matters and Issuer Purchases of Equity Securities	28
Item 6.	Selected Financial Data	31
Item 7.	Management's Discussion and Analysis of Financial Condition and Results of Operations	33
Item 7A.	Quantitative and Qualitative Disclosures About Market Risk	73
Item 8.	Financial Statements and Supplementary Data	76
	Report of Independent Registered Public Accounting Firm	76
	Consolidated Financial Statements	79
	Notes to Consolidated Financial Statements	85
	Other Financial Data	158
Item 9.	Changes in and Disagreements With Accountants on Accounting and Financial Disclosure	159
Item 9A.	Controls and Procedures	159
	Management's Report on Internal Control Over Financial Reporting	160
	Report of Independent Registered Public Accounting Firm	161
Item 9B.	Other Information	162
Part III
Item 10.	Directors, Executive Officers and Corporate Governance	162
Item 11.	Executive Compensation	163
Item 12.	Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters	163
Item 13.	Certain Relationships and Related Transactions, and Director Independence	163
Item 14.	Principal Accounting Fees and Services	163
Part IV
Item 15.	Exhibits, Financial Statement Schedules	164
Signatures		168

Table of Contents

Part I

Item 1. Business

General

TCF Financial Corporation, formerly known as Chemical Financial Corporation, ("TCF") is a financial holding company incorporated in Michigan in 1973 and headquartered in Detroit, Michigan. We had total assets of $47.8 billion at December 31, 2020 and were the 31st largest publicly traded bank holding company in the United States based on total assets at December 31, 2020.

Through our wholly-owned bank subsidiary, TCF National Bank, a national banking association ("TCF Bank") with its main office in Sioux Falls, South Dakota, we provide a full range of consumer-facing and commercial services, including consumer and commercial banking, trust and wealth management, and specialty leasing and lending products and services to consumers, small businesses and commercial customers. As of December 31, 2020, TCF had 478 branches primarily located in Michigan, Illinois and Minnesota, and with locations in Colorado, Ohio, Wisconsin and South Dakota (our "primary banking markets"). We also conduct business across all 50 states, Canada, New Zealand and Australia through our specialty lending and leasing businesses.

References herein to "TCF Financial" or the "Holding Company" refer to TCF Financial Corporation on an unconsolidated basis. TCF Financial Corporation (together with its direct and indirect subsidiaries), are referred to as "we," "us," "our," "TCF" or the "Corporation".

Proposed Merger with Huntington Bancshares Incorporated

TCF and Huntington Bancshares Incorporated ("Huntington") have entered into an Agreement and Plan of Merger, dated as of December 13, 2020, which we refer to as the "TCF/Huntington Merger Agreement". Under the TCF/Huntington Merger Agreement, TCF will merge with and into Huntington, with Huntington continuing as the surviving entity, in a transaction we refer to as "the TCF/Huntington Merger." Immediately following the TCF/Huntington Merger, TCF Bank will merge with and into Huntington's wholly owned banking subsidiary, The Huntington National Bank, with The Huntington National Bank as the surviving bank. The TCF/Huntington Merger Agreement was approved by the boards of directors of TCF and Huntington, and is subject to shareholder and regulatory approval and other customary closing conditions. The transaction is anticipated to close in the second quarter of 2021. The transaction is discussed in more detail in "Note 3. Business Combinations" of the Notes to Consolidated Financial Statements under Item 8 of this Annual Report.

Reportable Segments

Our reportable segments are Consumer Banking, Commercial Banking and Enterprise Services.

Consumer Banking Segment

Consumer Banking is comprised of all of our consumer and small business-facing businesses and includes Retail Banking, Wealth Management, Residential and Consumer Lending, and Business Banking. Our consumer banking strategy is primarily to generate deposits and originate high credit quality loans for investment and sale. Deposits are generated from consumers and small businesses to provide a source of low-cost funds, with a focus on building and maintaining quality customer relationships.

Retail Banking We offer an array of solutions for consumers and small businesses through our physical and digital distribution channels. We offer a broad selection of deposit and lending services including (i) checking and savings accounts, (ii) debit and credit cards, (iii) check cashing and remittance services and (iv) residential, consumer and small business lending.

Deposits are our primary source of funds for use in lending and for other general business purposes. Deposit inflows and outflows are significantly influenced by general interest rates, market and competitive conditions and other economic factors. We acquire deposits from within our primary banking markets through (i) checking, savings and money market accounts, (ii) certificates of deposit, and (iii) individual retirement accounts. Such deposit accounts provide fee income, including fees and service charges.

1

Table of Contents

At December 31, 2020, we had 478 branches, consisting of 373 traditional branches, 102 supermarket branches and three campus branches. We operate 219 branches in Michigan, 107 in Illinois, 80 in Minnesota, 32 in Colorado, 23 in Ohio, 16 in Wisconsin and one in South Dakota. We also offer 1,062 ATMs across our primary banking markets.

Providing a wide range of retail banking services is an integral component of our business philosophy. Primary drivers of our fees and service charges include the number of customers we attract, our customers' level of engagement and the frequency with which our customers use our solutions. Our business philosophy is to offer our customers an "easy-to-bank-with" experience, with multiple solutions that benefit the customer and are consistent with our business philosophy. Our customers have convenient access to funds through their credit and debit cards, as well as by utilizing our enhanced digital channels. Our card programs are supported by interchange fees paid by merchants.

Wealth Management Services offered through the Wealth Management department of TCF Bank include investment management and custodial services; trust services; financial and estate planning; and retirement planning and employee benefit programs. The Wealth Management department earns revenue largely from fees based on the market value of those assets under our management, which can fluctuate as the market fluctuates. Our Wealth Management department had assets under custodial and management arrangements of $4.3 billion at December 31, 2020. Through the Wealth Management department, we also sell investment products (largely annuity products and mutual funds) through the TCF Financial Advisors program. Customer assets within the TCF Financial Advisors program were $1.9 billion at December 31, 2020.

Residential and Consumer Lending We originate residential and other consumer loans for personal, family or household purposes, such as home purchases, debt consolidation and financing of home improvements. Our retail lending origination activity primarily consists of consumer real estate secured lending. It also includes originating loans secured by personal property and, to a limited extent, unsecured personal loans. Consumer loans are originated for investment and for sale, either on a fixed-term basis or as a revolving line of credit.

We also service loans for investors under contracts where we receive a fee for performing servicing activities on consumer loans that are not owned by us and are not included on our balance sheet. This process involves collecting monthly loan payments on behalf of investors, reporting information to those investors on a timely basis and maintaining custodial escrow accounts for remitting principal and interest payments to investors, and for paying property taxes and insurance premiums on behalf of borrowers.

Business Banking We offer small businesses, corporations and governmental entities various products and services, including loans and lines of credit, deposits, cash management, capital market products, international trade finance, letters of credit, foreign exchange management services and loan syndication services.

Commercial Banking Segment

Commercial Banking is comprised of commercial and industrial, commercial real estate banking and lease financing. Our commercial banking strategy focuses on building full-service commercial relationships including originating high credit quality loans and leases and providing deposit and treasury services. 

Commercial and Industrial The commercial and industrial loans we originate are secured by various types of business assets including inventory, receivables, equipment or financial instruments, and may also be backed by personal guarantees of the owner or other sources of repayment. Commercial and industrial loans are used for a variety of purposes, including working capital and financing the purchase of equipment.

TCF Bank's wholly-owned subsidiary, TCF Inventory Finance, Inc. ("TCFIF") originates commercial, primarily variable-rate loans which are secured by the underlying floorplan equipment and supported by repurchase agreements from original equipment manufacturers. TCFIF focuses on establishing relationships with distributors, dealer buying groups and manufacturers, giving us access to thousands of independent retailers primarily in the areas of powersports equipment and lawn and garden equipment. TCFIF's portfolio balances are impacted by seasonal shipments and sales activities as dealers receive inventory shipments in anticipation of the upcoming selling season while carrying current season product. In 2009, TCFIF formed a joint venture with The Toro Company ("Toro") called Red Iron Acceptance, LLC ("Red Iron"). Red Iron provides U.S. distributors and dealers and select Canadian distributors of the Toro® and Exmark® brands with reliable, cost-effective sources of financing. We maintain a 55% ownership interest in Red Iron, with Toro owning the other 45%.

2

Table of Contents

Commercial Real Estate The commercial real estate loans we originate are primarily secured by multi-family housing, office buildings, health care facilities, warehouse and industrial buildings, hotel and motel buildings, self-storage buildings and retail services buildings. The commercial real estate portfolio represented 40.5% and 39.3% of our total commercial portfolio at December 31, 2020 and 2019, respectively.

Lease Financing TCF Capital Solutions, a division of TCF Bank, delivers comprehensive lease and equipment finance products addressing the diverse financing needs of small to large companies in a growing number of select market segments including specialty vehicles, construction equipment, golf cart and turf equipment, manufacturing equipment, medical equipment, trucks and trailers, furniture and fixtures, technology and data processing equipment, and agricultural equipment.

Enterprise Services

Enterprise Services is comprised of (i) corporate treasury, which includes our investment and borrowing portfolios and management of capital, debt and market risks, (ii) corporate functions, such as information technology, risk and credit management, bank operations, finance, investor relations, corporate development, internal audit, legal and human capital management that provide services to the operating segments, (iii) TCF Financial and (iv) eliminations. Our investment portfolio accounts for the earning assets within this segment. Borrowings may be used to offset reductions in deposits or to support lending activities. This segment also includes residual revenues and expenses representing the difference between actual amounts incurred by Enterprise Services and amounts allocated to the operating segments, including interest rate risk residuals such as funds transfer pricing mismatches.

Corporate Treasury Corporate treasury's primary responsibility is management of our liquidity, capital, interest rate risk, and investment and borrowing portfolios. Corporate treasury has authority to invest in various types of liquid assets including, but not limited to, U.S. Department of the Treasury obligations and debt securities of various federal agencies and U.S. Government sponsored enterprises, obligations of states and political subdivisions, deposits of insured banks, bankers' acceptances and federal funds. Corporate treasury also has the authority to enter into wholesale borrowing transactions which may be used to compensate for reductions in deposit inflows or net deposit outflows, or to support lending, leasing and other expansion activities. These borrowings may include Federal Home Loan Bank ("FHLB") advances, brokered deposits, repurchase agreements, federal funds and other permitted borrowings from counterparties.

See "Item 7. Management's Discussion and Analysis - Consolidated Results of Operations Analysis - Reportable Segments" and "Note 27. Reportable Segments" of Notes to Consolidated Financial Statements for further information.

Other Information

Activities of Subsidiaries of TCF Our business operations include those conducted by direct and indirect subsidiaries of TCF Financial, all of which are consolidated for purposes of preparing our consolidated financial statements. TCF Bank's subsidiaries principally engage in inventory finance activities. See "Commercial Banking" above for further information.

Competition We compete with a number of depository institutions and financial service providers primarily based on price and service and we face significant competition in attracting and retaining deposits and in lending activities. Direct competition for deposits comes primarily from banks, savings institutions, credit unions and investment banks. Additional significant competition for deposits comes from institutions selling money market mutual funds and corporate and government securities. We compete for the origination of loans with banks, mortgage bankers, mortgage brokers, consumer and commercial finance companies, credit unions, insurance companies and savings institutions. We also compete nationwide with other companies and banks in the financing of equipment and inventory, leasing of equipment and origination of residential mortgage loans. The growth of financial technology companies, disintermediation and lowered barriers to entry through technology have increased competition for loan, lease and deposit products as non-banks now offer products and services traditionally provided by banks.

3

Table of Contents

Human Capital Resources and Management As of December 31, 2020, we had 7,123 employees, including 580 part-time employees. We are a purpose-driven organization dedicated to championing our customers and building stronger individuals, businesses, and communities. We deliver on this mission first by putting our values into practice. Our core beliefs guide our daily interactions with customers and between team members. They are:

•Care Like a Neighbor We are passionate about people. Treating our customers and team members with respect, care, and generosity has always — and will always — define our bank. We demonstrate our commitment through small acts and big gestures.

•Take Initiative on all Fronts We are motivated by our entrepreneurial spirit. We value technology and actively implement features that will make our customers’ lives easier and internal processes more efficient.

•Strive for Excellence Every day we show up to work and give it our all. Integrity, honesty, and fairness are the foundations of who we are. They enable us to deliver what our customers and team members need when they need it.

•Win as a Team Our greatest power is collaboration. To create exceptional solutions, we lean on one another’s strengths and lean-in to diversity of all kinds. We value all perspectives because it makes us a stronger, more unified team.

We believe that by investing in our team member experience and thoughtfully developing our culture, we simultaneously invest in our customers and shareholders and increase the long-term value of our business. 2020 was a year of change and integration for TCF following our 2019 merger of equals. We integrated and enhanced our human capital management programs that drive positive team member experience, shape our culture, and enhance our employee value proposition to attract and retain highly engaged team members who put our values into action, while caring for team members who were impacted by an unexpected pandemic, historic flooding in our Midland, Michigan area, and the destruction of banking center properties during civil unrest.

Compensation and Benefits

We provide our employees with comprehensive benefits, some of which are provided on a contributory basis, including medical and dental plans, a 401(k) savings plan with a company matching contribution, life insurance and short- and long-term disability coverage. To compete for increasingly mobile banking center talent and to improve the financial well-being of team members, we implemented a $15 per hour minimum wage for all team members in the fourth quarter of 2020. Additionally, we maintained full wage payments through “emergency pay” to banking center team members when they were not able to work due to pandemic-related banking center closures and we provided extra “premium pay” to team members who staffed banking centers in-person during the height of the pandemic.

Health and Well-being

We made several enhancements to benefits and health and well-being programs in 2020, both prior to the pandemic and in response to it. We implemented a flexible Paid Time Off program for a large portion of our professional workforce, under which time off usage is self-directed and not centrally monitored except in states where required. We found that the majority of team members were not generally using their full PTO allotments, and decided to trust managers and team members to locally manage PTO usage to alleviate burnout and enhance productivity. We adopted a market-forward, gender-neutral parental leave program to improve work/home balance for new parents regardless of their family circumstance. We also provided team members with new home fitness and childcare and educational support resources to help them cope with the stressors created by the pandemic and working from home.

4

Table of Contents

Culture

We made significant progress towards integrating cultures following the TCF/Chemical Merger. This work began with articulating our purpose and beliefs in the beginning of the year, a process that included listening to and gathering feedback from diverse stakeholders across all levels of jobs in the organization. We conducted regular pulse surveys and “journey mapping” sessions to gauge employee attitudes towards human capital management endeavors, including return-to-work and COVID-19 vaccination strategies. We also established eight employee resource groups to provide a forum through which team members of similar backgrounds and life circumstances, or team members wishing to learn more about others’ experiences, could engage with each other and with external thought leaders. As the country was coming to terms with racial injustice, we ensured that our team members’ voices were heard. We also hosted a panel discussion for all team members, consisting of notable academics, community and religious leaders and the Michigan State Police Commissioner, to discuss racial injustice, and made our executive leaders available during "office hours" for team members to share their perspective. When Midland area flooding unexpectedly displaced team members from their homes, we provided economic and temporary housing support.

Talent Management

In 2020, we expanded our recruiting presence and collaboration with targeted universities to include historically black colleges and universities, and continued to strengthen an innovative intern program to attract high-quality talent from a diverse array of communities and to ensure equality and fairness of representation in our candidate pool. We introduced a new set of “leadership behaviors” and coached team members to better understand the types of actions and behaviors that promote our Purpose and Beliefs. We implemented a talent assessment and calibration process to focus on the growth and development of our leadership pipeline and developed resources to support our diversity initiatives. We also introduced a workforce analytics function to measure talent retention effectiveness, team member engagement, and diversity, equity, and inclusion progress.

Transitional Support

With a robust history of merger activity and a track-record of meeting financial synergy targets and shareholder commitments, we know well how disruptive job loss or job change is to displaced team members. We invest generously in our displaced team members to ease their transition and facilitate better future business and customer connections. Every team member is treated with respect as a member of the TCF community through their termination date and beyond. Displaced team members are offered competitive severance packages, outplacement support services and COBRA subsidies.

Supervision and Regulation

As a financial institution, we operate in a highly regulated environment. The regulatory framework under which we operate is intended primarily for the protection of depositors and the Federal Deposit Insurance Corporation’s (the “FDIC’s”) Deposit Insurance Fund and not for the protection of our shareholders and creditors. The following is a general summary of the material aspects of certain statutes and regulations applicable to us. These summary descriptions are not complete, and you should refer to the full text of the statutes, regulations, and corresponding guidance for more information. These statutes and regulations are subject to change, and additional statutes, regulations, and corresponding guidance may be adopted. We are unable to predict these future changes or the effects, if any, that these changes could have on our business, revenues, and results of operations.

5

Table of Contents

Examinations and Regulatory Sanctions  TCF Financial is a financial holding company registered under the Bank Holding Company Act of 1956 (the “BHC Act”) and is subject to supervision and regulation by the Federal Reserve. Federal laws subject financial holding companies to restrictions on the types of activities in which they may engage and to a range of supervisory requirements and activities, including regulatory enforcement actions, for violation of laws and policies. TCF Financial is required to file annual and quarterly reports with the Federal Reserve and such additional information as the Federal Reserve may require pursuant to the BHC Act. The Federal Reserve may examine a bank holding company or any of its subsidiaries and charge the company for the cost of such an examination. TCF Bank is a national banking association, which is subject to primary regulation and supervision by the Office of the Comptroller of the Currency ("OCC") and the Consumer Financial Protection Bureau (“CFPB”) for many consumer-related laws and regulations, and secondarily by the Federal Reserve and the FDIC. Both the OCC and CFPB regularly examine TCF Bank. The FDIC may also periodically examine and evaluate insured banks. TCF Bank is subject to requirements and restrictions under federal law, including capital requirements restrictions on the types and amounts of loans that may be granted and the interest that may be charged thereon and limitations on the types of investments that may be made and the types of services that may be offered. Various consumer laws and regulations also affect the operations of TCF Bank.

Federal banking regulators may impose a number of restrictions or new requirements on institutions, including, but not limited to, growth limitations, dividend restrictions, increased regulatory capital requirements, increased loan and lease loss reserve requirements, increased supervisory assessments, activity limitations or other restrictions that could have an adverse effect on such institutions, their holding companies or holders of their debt and equity securities. Various enforcement remedies, including civil money penalties, may be assessed against an institution or an institution's directors, officers, employees, agents or independent contractors. Certain enforcement actions may not be publicly disclosed by us or our federal banking regulators. Subsidiaries of TCF Bank are also subject to state and/or self-regulatory organization licensing, regulation and examination requirements in connection with certain activities.

Regulatory Capital Requirements TCF Financial and TCF Bank are subject to various minimum regulatory capital requirements administered by the Federal Reserve and the OCC. These requirements include quantitative measures that assign risk weightings to assets and off-balance sheet items, as well as define and set minimum regulatory capital requirements. Failure to meet minimum capital requirements can initiate certain mandatory, and possible additional discretionary, actions by the federal banking regulators that, if undertaken, could have a material adverse effect on our financial condition and results of operations.

The Basel III capital standards impose minimum capital requirements for bank holding companies and banks. The rules apply to all national and state banks and savings associations regardless of size and bank holding companies and savings and loan holding companies with more than $3 billion in total consolidated assets. More stringent requirements are imposed on “advanced approaches” banking organizations which are organizations with $250 billion or more in total consolidated assets, $10 billion or more in total foreign exposures, or that have opted into the Basel III capital regime. In addition, in order to avoid restrictions on capital distributions or discretionary bonus payments to executives, under Basel III, a banking organization must maintain a “capital conservation buffer” on top of its minimum risk-based capital requirements. This buffer must consist solely of common equity Tier 1 capital, but the buffer applies to all three risk-based measurements (common equity Tier 1 capital, Tier 1 capital and total capital). The 2.5% capital conservation buffer was phased in incrementally over time, and became fully effective for us on January 1, 2019, resulting in the following effective minimum capital plus capital conservation buffer ratios: (i) a common equity Tier 1 capital ratio of 7.0%, (ii) a Tier 1 risk-based capital ratio of 8.5%, and (iii) a total risk-based capital ratio of 10.5%. TCF Financial and TCF Bank made the one-time permanent election permitted under the Basel III capital standards to not include accumulated other comprehensive income (loss) in regulatory capital. TCF Financial and TCF Bank exceeded the Basel III capital standard at December 31, 2020. See "Note 18. Regulatory Capital Requirements" of the Notes to Consolidated Financial Statements for further information.

In addition to the capital rules applicable to both banks and bank holding companies discussed above, under the prompt corrective action regulations, the federal bank regulators are required and authorized to take supervisory actions against undercapitalized banks. For this purpose, a bank is placed in one of five categories based on the bank’s capital: well-capitalized, adequately capitalized, undercapitalized, significantly undercapitalized and critically undercapitalized. Currently, the quantitative requirements for being well-capitalized are (at least 5% leverage capital, 6.5% common equity Tier 1 capital, 8% Tier 1 capital and 10% total capital). TCF Bank was considered well-capitalized at December 31, 2020.

6

Table of Contents

On December 21, 2018, the federal banking agencies issued a joint final rule to revise their regulatory capital rules to (i) address the upcoming implementation of a new credit impairment model, the Current Expected Credit Loss, or CECL model, an accounting standard under GAAP; (ii) provide an optional three-year phase-in period for the day-one adverse regulatory capital effects that banking organizations were expected to experience upon adopting CECL; and (iii) require the use of CECL in stress tests beginning with the 2020 capital planning and stress testing cycle for certain banking organizations that are subject to stress testing. In response to the COVID-19 pandemic, the federal banking agencies published a final rule in 2020 that provides the option to delay the cumulative effect of the day 1 impact of CECL adoption on regulatory capital, along with 25% of the change in the adjusted allowance for credit losses, for two years, followed by a three-year phase-in period. We elected the 5-year transition period consistent with the final rule issued by the federal banking agencies. See "Note 2. Summary of Significant Accounting Policies" of the Notes to the Consolidated Financial Statements for further information.

In addition to the capital rules applicable to both banks and bank holding companies discussed above, under the prompt corrective action regulations, the federal bank regulators are required and authorized to take supervisory actions against undercapitalized banks. For this purpose, a bank is placed in one of five categories based on the bank’s capital: well-capitalized, adequately capitalized, undercapitalized, significantly undercapitalized and critically undercapitalized. Currently, the quantitative requirements for being well-capitalized are (at least 5% leverage capital, 6.5% common equity Tier 1 capital, 8% Tier 1 capital and 10% total capital). TCF Bank was considered well-capitalized at December 31, 2020.

Federal banking regulators are required to take various mandatory supervisory actions and are authorized to take other discretionary actions with respect to institutions in the three undercapitalized categories. The severity of the action depends upon the capital category in which the institution is placed. Generally, subject to a narrow exception, banking regulators must appoint a receiver or conservator for an institution that is “critically undercapitalized.” The federal banking agencies have specified by regulation the relevant capital level for each category. An institution that is categorized as “undercapitalized,” “significantly undercapitalized,” or “critically undercapitalized” is required to submit an acceptable capital restoration plan to its appropriate federal banking agency, which, for TCF Bank, is the OCC. Failure to meet capital guidelines could subject TCF Bank to a variety of enforcement remedies, including issuance of a capital directive, the termination of deposit insurance by the FDIC, a prohibition on accepting brokered deposits and other restrictions on our business.

Restrictions on Distributions  TCF Financial's ability to pay dividends is subject to limitations imposed by the Federal Reserve. In general, Federal Reserve regulatory guidelines require the board of directors of a bank holding company to consider a number of factors in determining the payment of dividends, including the quality and level of current and future earnings. See "Note 17. Equity" of Notes to Consolidated Financial Statements for further information on restricted retained earnings.

Dividends or other capital distributions from TCF Bank to TCF Financial are the primary source of funds to enable TCF Financial to pay dividends on its preferred and common stock, to pay TCF Financial's obligations, to repurchase common stock or to meet other cash needs. The ability of TCF Financial and TCF Bank to pay dividends depends on regulatory policies and regulatory capital requirements and may be subject to regulatory approval. TCF Financial and TCF Bank must also maintain the common equity Tier 1 capital conservation buffer of 2.5% to avoid becoming subject to restrictions on capital distributions (as discussed above).

In general, TCF Bank may not declare or pay a dividend to TCF Financial in excess of 100% of its net retained earnings for the current year combined with its net retained earnings for the preceding two calendar years without prior approval of the OCC. The OCC also has the authority to prohibit the payment of dividends by a national bank when it determines such payments would constitute an unsafe and unsound banking practice. TCF Bank's ability to make capital distributions in the future may require regulatory approval and may be restricted by the OCC. TCF Bank's ability to make any such distributions will also depend on its earnings and ability to meet minimum regulatory capital requirements in effect during future periods. In the future, these capital adequacy standards may be higher than existing minimum regulatory capital requirements. See "Note 18. Regulatory Capital Requirements" of Notes to Consolidated Financial Statements for further information.  

Restricted retained earnings represent earnings legally appropriated to thrift bad debt reserves and deducted for federal income tax purposes in prior years and is generally not available for payment of cash dividends or other distributions to shareholders. In addition, income tax considerations may limit the ability of TCF Bank to make dividend payments in excess of its current and accumulated tax earnings. Annual dividend distributions in excess of earnings could result in a tax liability based on the amount of excess earnings distributed and current tax rates.

7

Table of Contents

Regulation of TCF and Affiliates and Insider Transactions  TCF Financial is subject to Federal Reserve regulations, examinations and reporting requirements applicable to bank holding companies. Subsidiaries of bank holding companies, like TCF Bank, are subject to certain restrictions in their dealings with holding company affiliates.

Source of Strength A holding company must serve as a source of strength for its subsidiary banks and the Federal Reserve may require a holding company to contribute additional capital to an undercapitalized subsidiary bank. In addition, the OCC may assess TCF Financial if it believes the capital of TCF Bank has become impaired. If TCF Financial were to fail to pay such an assessment within three months, the Board of Directors would be required to cause the sale of TCF Bank's stock to cover a deficiency in the capital. In the event of a bank holding company's bankruptcy, any commitment by the bank holding company to a federal banking regulator to maintain the capital of a subsidiary bank would be assumed by the bankruptcy trustee and may be entitled to priority over other creditors.

Restrictions on Acquisitions and Changes in Control  Under federal and state law, merger and branch acquisition transactions may be subject to certain restrictions, including certain nationwide and statewide insured deposit maximum concentration levels or other limitations. In addition, federal and state laws and regulations contain a number of provisions which impose restrictions on changes in control of financial institutions such as TCF Financial or TCF Bank and which require regulatory approval prior to any such changes in control.

Under the BHA Act, Federal Reserve approval is required before acquiring more than 5% control, or substantially all of the assets, of another bank or bank holding company, or merging or consolidating with such a bank or bank holding company. The BHCA also generally prohibits a bank holding company, with certain exceptions, from acquiring direct or indirect ownership or control of more than 5% of the voting shares of any company which is not a bank or bank holding company, or from engaging directly or indirectly in activities other than those of banking, managing or controlling banks, providing services for its subsidiaries or conducting activities permitted by the Federal Reserve as being closely related to the business of banking. Further restrictions or limitations on acquisitions or establishing financial subsidiaries may also be imposed by our regulators or examiners.

Insurance of Accounts  TCF Bank is a member of the FDIC, which maintains the Deposit Insurance Fund (the "DIF"). The FDIC insures deposits up to prescribed limits for each depositor through the DIF, which is funded through assessments on member institutions. To maintain the DIF, member institutions are assessed an insurance premium based on an assessment base and an assessment rate.

The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the "Dodd-Frank Act") gave the FDIC much greater discretion to manage the DIF and also changed the assessment base from domestic deposits to average total assets less tangible equity. Additionally, the Dodd-Frank Act raised the minimum designated reserve ratio (the "DRR") to 1.35% of estimated insured deposits from 1.15% and required this new minimum be reached by September 30, 2020. After having reached 1.35% percent, if the reserve ratio falls below 1.35%, or if the FDIC projects that the reserve ratio will, within 6 months, fall below 1.35%, the FDIC must adopt a restoration plan that provides that the DIF will return to 1.35% within 8 years (or longer if the FDIC finds it necessary due to extraordinary circumstances) which can include a surcharge assessment. As of September 30, 2018, the DIF reserve ratio was 1.36%. Subsequently, the reserve ratio fell to 1.30% as a result of the unprecedented inflow of more than $1 trillion in estimated insured deposits in the first half of 2020. The DIF ratio calculated by the FDIC using estimated insured deposits as of September 30, 2020 was 1.30%. On September 15, 2020, the FDIC adopted a restoration plan, but did not adopt a surcharge as part of the plan. The FDIC stated that the DIF would return to 1.35% without further action by the FDIC during the eight-year period based on a range of reasonable estimates of future losses and assuming a return to normal insured deposit growth rates.

In 2020, insurance premiums on bank deposits insured by the FDIC for banks with at least $10.0 billion in total assets ranged from 1.5 cents to 40 cents per $100 of the institution's assessment base. Our FDIC insurance expense was $23.9 million, $18.3 million and $15.1 million in 2020, 2019 and 2018, respectively.

In addition to deposit insurance premium assessments from the FDIC, additional assessments may be imposed by the Financing Corporation, a separate U.S. government agency affiliated with the FDIC, to pay for the interest cost of Financing Corporation bonds. The final collection for this assessment was on March 29, 2019.

8

Table of Contents

Community Reinvestment Act TCF Bank is subject to certain requirements and reporting obligations under the Community Reinvestment Act (“CRA”), which requires federal banking regulators to evaluate the record of each financial institution in meeting the credit needs of its local community, including low- and moderate- income neighborhoods. The CRA further requires these criteria to be considered in evaluating mergers, acquisitions and applications to open a branch or facility. Failure to adequately meet these criteria could result in the imposition of additional requirements and limitations on TCF Bank. Additionally, financial institutions must publicly disclose the terms of various CRA‑related agreements. In its most recent CRA examination, TCF Bank received an “outstanding” rating.

In December 2019, the FDIC and the OCC proposed changes to the regulations implementing the CRA, which, if adopted will result in changes to the current CRA framework. On May 20, 2020, the OCC issued its final rule. The rule was effective October 1, 2020, but TCF Bank will have until January 1, 2023 before it would be evaluated using the new performance standards and tests, and any examination conducted before that date would use the prior performance standards and tests. The OCC stated that the revisions will benefit communities, businesses and banks by: (i) clarifying what qualifies for CRA consideration; (ii) updating how banks define assessment areas; (iii) evaluating bank CRA performance more objectively through quantitative measures; (iv) making reporting more transparent and timelier; (v) providing greater support for small business, small and family-owned farms, and Indian Country; and (vi) thoroughly evaluating banks' CRA performance in all their assessment areas, not just a limited evaluation in some of them. The FDIC has not adopted a final rule and the Federal Reserve Board issued an advance notice of proposed rulemaking on September 21, 2020.

CFPB Examination The Dodd-Frank Act created the CFPB, which is granted broad rulemaking, supervisory and enforcement powers under various federal consumer financial protection laws, including the Equal Credit Opportunity Act, Truth in Lending Act, Real Estate Settlement Procedures Act, Fair Credit Reporting Act, Fair Debt Collection Practices Act, the Consumer Financial Privacy provisions of the Gramm-Leach-Bliley Act and certain other statutes. The CFPB has examination and primary enforcement authority with respect to depository institutions with $10 billion or more in assets, such as TCF Bank. The CFPB has authority to prevent unfair, deceptive or abusive practices in connection with the offering of consumer financial products.

The CFPB has issued a number of regulations related to the origination of mortgages, foreclosures, and overdrafts as well as many other consumer issues. Additionally, the CFPB has proposed, or may propose, additional regulations or modify existing regulations that directly relate to our business. Although it is difficult to predict at this time the extent to which the CFPB’s proposed and yet to be proposed regulations impact the operations and financial condition of the TCF Bank, such rules may have a material impact on our compliance costs, compliance risk and fee income.

Anti-Money Laundering As a financial institution, TCF Bank must maintain anti‑money laundering programs that include established internal policies, procedures and controls; a designated compliance officer; an ongoing employee training program; and testing of the program by an independent audit function. Financial institutions are also prohibited from entering into specified financial transactions and account relationships and must meet enhanced standards for due diligence and “knowing your customer” in their dealings with foreign financial institutions, foreign customers and other high-risk customers. Financial institutions must take reasonable steps to conduct enhanced scrutiny of account relationships to guard against money laundering and to report any suspicious transactions, and recent laws provide law enforcement authorities with increased access to financial information maintained by banks. Anti‑money laundering obligations have been substantially strengthened as a result of the USA PATRIOT Act (the “Patriot Act”), as described below. Bank regulators routinely examine institutions for compliance with these obligations, and this area has become a particular focus of the regulators in recent years. In addition, the regulators are required to consider compliance in connection with the regulatory review of applications. The regulatory authorities have been active in imposing “cease and desist” orders and money penalty sanctions against institutions found to be violating these obligations.

9

Table of Contents

USA Patriot Act The Patriot Act became effective on October 26, 2001 and amended the Bank Secrecy Act. The Patriot Act provides, in part, for the facilitation of information sharing among governmental entities and financial institutions for the purpose of combating terrorism and money laundering by enhancing anti‑money laundering and financial transparency laws, as well as enhanced information collection tools and enforcement mechanics for the U.S. government, including:

•requiring standards for verifying customer identification at account opening;

◦rules to promote cooperation among financial institutions, regulators and law enforcement entities in identifying parties that may be involved in terrorism or money laundering;

◦reports by nonfinancial trades and businesses filed with the Treasury Department’s Financial Crimes Enforcement Network for transactions exceeding $10,000; and

◦filing suspicious activities reports by brokers and dealers if they believe a customer may be violating U.S. laws and regulations.

The Patriot Act requires financial institutions to undertake enhanced due diligence of private bank accounts or correspondent accounts for non‑U.S. persons that they administer, maintain, or manage. Bank regulators routinely examine institutions for compliance with these obligations and are required to consider compliance in connection with the regulatory review of applications.

Under the Patriot Act, the Financial Crimes Enforcement Network (“FinCEN”) can send TCF Bank a list of the names of persons suspected of involvement in terrorist activities or money laundering. TCF Bank may be requested to search its records for any relationships or transactions with persons on the list. If TCF Bank finds any relationships or transactions, it must report those relationships or transactions to FinCEN.

Consumer Protection Regulations Interest and other charges that TCF Bank collects or contracts for are subject to state usury laws and federal laws concerning interest rates. TCF Bank’s loan operations also are subject to federal laws applicable to credit transactions, such as:

◦the Truth in Lending Act, governing disclosures of credit terms to consumer borrowers;

◦the Home Mortgage Disclosure Act, requiring financial institutions to provide information to enable the public and public officials to determine whether a financial institution is fulfilling its obligation to help meet the housing needs of the community it serves;

◦the Equal Credit Opportunity Act, prohibiting discrimination on the basis of race, creed or other prohibited factors in extending credit;

◦the Fair Credit Reporting Act, governing the use and provision of information to credit reporting agencies;

◦the Fair Debt Collection Practices Act, governing the manner in which consumer debts may be collected by collection agencies; and

◦the rules and regulations of the various governmental agencies charged with the responsibility of implementing these federal laws.

In addition, TCF Bank’s deposit operations are subject to the Electronic Funds Transfer Act and Regulation E issued by the Federal Reserve to implement that act, which govern automatic deposits to and withdrawals from deposit accounts and customers’ rights and liabilities arising from the use of ATMs and other electronic banking services.

National Bank Investment Limitations  Permissible investments by national banks are limited by the National Bank Act of 1864, as amended, and by rules of the OCC. Non-traditional bank activities permitted by the Gramm-Leach-Bliley Act of 1999 will subject a bank to additional regulatory limitations or requirements, including a required regulatory capital deduction and application of transactions with affiliates limitations in connection with such activities.

Taxation 

Federal Taxation  Our federal income tax returns are open and subject to examination for 2017 and later tax return years.

10

Table of Contents

State Taxation  TCF and/or its subsidiaries currently file tax returns in all state and local taxing jurisdictions which impose corporate income, franchise or other taxes. Our various state income tax returns are generally open for 2016 and later tax return years based on individual state statutes of limitation. The methods of filing and the methods for calculating taxable and apportionable income vary depending on the laws of each taxing jurisdiction.

Foreign Taxation TCF and/or its subsidiaries currently file tax returns in Australia, New Zealand, Canada and certain Canadian provinces. Our various foreign tax returns are open and subject to examination for 2016 and later tax return years. The methods of filing and the methods for calculating taxable and apportionable income vary depending on the laws of each taxing jurisdiction.

See "Item 7. Management's Discussion and Analysis - Consolidated Results of Operations Analysis - Income Taxes", "Note 2. Summary of Significant Accounting Policies" and "Note 26. Income Taxes" of Notes to Consolidated Financial Statements for further information regarding TCF's income taxes.

Available Information

Our website, www.tcfbank.com, includes free access to our news releases, investor presentations, conference calls to discuss published financial results, our Annual Report and periodic filings required by the U.S. Securities and Exchange Commission (the "SEC"), including annual reports on Form 10-K, quarterly reports on Form 10-Q, current reports on Form 8-K, proxy statements, and amendments to those reports, as soon as reasonably practicable after electronic filing of such material with, or furnishing it to, the SEC. Our periodic filings required by the SEC are also available on the SEC's website, www.sec.gov. Our Compensation and Pension Committee, Corporate Governance, Nominating and ESG Committee and Audit Committee charters, Corporate Governance and Director Standards, Codes of Ethics and information on all of our securities are also available on our website. Shareholders may request these documents in print free of charge by contacting the Corporate Secretary at TCF Financial Corporation, 333 West Fort Street, Suite 1800, Detroit, MI 48226.

Item 1B. Unresolved Staff Comments

None.

11

Table of Contents

Item 1A. Risk Factors.

There are risks, many beyond our control, which could cause our results to differ significantly from management’s expectations. Some of these significant risks and uncertainties are described below. Any factor described in this Annual Report on Form 10-K could, by itself or together with one or more other factors, adversely affect our business, results of operations and/or financial condition, and the market price of our common stock could decline significantly. Additional risks and uncertainties not currently known to us or that we currently consider to not be material also may materially and adversely affect us. In assessing these risks, you should also refer to other information disclosed in our SEC filings, including the financial statements and notes thereto. The risks discussed below also include forward-looking statements, and actual results may differ substantially from those discussed or implied in these forward-looking statements.

Credit Risks

If we fail to effectively manage credit risk, our business and financial condition will suffer.

We must effectively manage credit risk. As a lender, we are exposed to the risk that our borrowers will be unable to repay their loans according to their terms, and that the collateral securing repayment of their loans, if any, may not be sufficient to ensure repayment. In addition, there are risks inherent in making any loan, including risks relating to proper loan underwriting, risks resulting from changes in economic and industry conditions and risks inherent in dealing with individual borrowers, including the risk that a borrower may not provide information to us about its business in a timely manner, and/or may present inaccurate or incomplete information to us, and risks relating to the value of collateral. Collateral values are adversely affected by changes in prevailing economic, environmental and other conditions, including declines in the value of real estate, changes in interest rates, changes in monetary and fiscal policies of the federal government, terrorist activity, environmental contamination and other external events. In order to manage credit risk successfully, we must, among other things, maintain disciplined and prudent underwriting standards and ensure that our lenders follow those standards. The weakening of these standards for any reason, such as an attempt to attract higher yielding loans, a lack of discipline or diligence by our employees in underwriting and monitoring loans, the inability of our employees to adequately adapt policies and procedures to changes in economic or any other conditions affecting borrowers and the quality of our loan portfolio, may result in loan defaults, foreclosures and additional charge-offs and may necessitate that we significantly increase our allowance for loan losses, each of which could adversely affect our net income. As a result, our inability to successfully manage credit risk could have a material adverse effect on our business, financial condition or results of operations.

Our allowance for loan and lease losses, and fair value adjustments with respect to loans and leases acquired in our acquisitions, may prove to be insufficient to absorb actual losses in our loan and lease portfolio, which may adversely affect our business, financial condition and results of operations.

We maintain an allowance for loan and lease losses, which is a reserve established through a provision for loan and lease losses charged to net income that represents management's estimate of expected losses over the life of the existing loan and lease portfolio. The level of the allowance for loan and lease losses reflects management's continuing evaluation of specific credit risks, loan and lease loss experience, current loan portfolio quality, the value of real estate, economic forecasts, political and regulatory conditions and unidentified losses inherent in the current loan and lease portfolio. The determination of the appropriate level of the allowance for loan and lease losses inherently involves a high degree of subjectivity and requires us to make significant estimates of current credit risks and future trends, all of which may undergo material changes. Deterioration in economic forecasted conditions and declines in real estate values, new information regarding existing loans and leases, and identification of additional problem loans and other factors, all may require an increase in the allowance for loan and lease losses.

The application of the purchase method of accounting to loans and leases acquired via acquisitions will impact our allowance for loan and lease losses. Under the purchase method of accounting, all acquired loans and leases are recorded in our Consolidated Financial Statements at their estimated fair value at the time of acquisition, and any related allowance for loan and lease loss is eliminated. Credit quality, among other factors, is considered in the determination of the fair value of loans and leases acquired. Subsequent to acquisition an allowance is recorded on the new amortized cost basis, based on the expected credit losses on the acquired loans and leases. To the extent that our estimates of fair value of acquired loans and leases were too high, or the allowance based on estimates of future expected credit losses is too low, we will incur losses associated with the acquired loans and leases.

12

Table of Contents

If our analysis or assumptions prove to be incorrect, our current allowance may not be sufficient, and adjustments may be necessary to allow for different economic conditions or adverse developments in our loan and lease portfolio. Material additions to the allowance for loan and lease losses would materially decrease our net income and adversely affect our general financial condition.

In addition, our regulators review our allowance for loan and lease losses as part of their periodic examinations, and may require an increase in the allowance for loan and lease losses or the recognition of further loan charge-offs, based on judgments and assumptions different than those of management.

Market Risks

We continue to face risks and uncertainties related to the outbreak of COVID-19.

Our operations and profitability are impacted by business and economic conditions generally, as well as those in the primary banking markets in which we operate. The COVID-19 pandemic first declared in March 2020 by the World Health Organization resulted in historic job losses and decreases in economic activity, which have improved, but have not returned to pre-pandemic levels. Although we have taken steps such as offering loan deferrals to attempt to mitigate the adverse consequences to our businesses, these steps may not be sufficient, and the effects of the pandemic may impact the ability of individuals and businesses to make payments, the value of underlying collateral, and the ability of guarantors to make payments in the case of default, and may reduce our ability to access capital, subject us to increased liability, and otherwise adversely impact the financial condition, results of operations, prospects of our businesses and our credit ratings. While the United States and various state and local governments have implemented various programs designed to aid individuals and businesses, the duration of such programs and the impact of, and extent to which these efforts will be successful, remain uncertain.

Many of our customers and counterparties have been and may continue to be adversely impacted by the COVID-19 pandemic and resulting economic downturn. As a result, we have faced and may continue to face a decrease in demand for certain products, and disruptions in the operations of our branch network and our vendors. The pandemic could also result in the recognition of additional credit losses in our loan and lease portfolios and increase our allowance for credit losses as both businesses and consumers are negatively impacted by the economic downturn. Additionally, customers that continue to work remotely and may not have appropriately secured remote networks may be more vulnerable to cyber-attacks or phishing schemes. Any of these occurrences could have a material adverse effect on our financial condition, results of operations and prospects. The extent to which the pandemic impacts our results will depend on future developments, which are highly uncertain and cannot be predicted, including new information which may emerge concerning its severity and the actions necessary to contain it or address its impact, among others. Although certain pharmaceutical companies have received emergency approval for and released vaccines, the pace of distribution and administration of the vaccine has been uneven and slower than anticipated, and the duration of COVID-related impact on economic activity and customer behavior continue to be unknown and may not be temporary.

In addition, the COVID-19 outbreak has caused, and will continue to cause, substantial disruption to our employees as a result of illness, increased family responsibilities, self-isolation, travel limitations, and otherwise. Most areas within the United States have imposed business and other restrictions, and the duration of such restrictions remains uncertain. These restrictions have affected many of our customers and businesses through which we sell our products and services, and the increased reliance on remote work may result in increased vulnerabilities through heavy dependence on remote networks.

Any of the foregoing factors, or other cascading effects of the COVID-19 pandemic that are not currently known, could materially impact our team members and decrease our ability to serve customers, increase our costs, negatively impact our sales and adversely affect our results of operations and our liquidity position, possibly to a significant degree.

13

Table of Contents

Our financial results are significantly affected by general economic and political conditions.

Our operations and profitability are impacted by both business and economic conditions generally, as well as those in the primary banking markets in which we operate. Economic conditions have a significant impact on the demand for our products and services, as well as the ability of our customers to repay loans and leases, the value of the collateral securing loans and leases, our ability to sell loans and leases, the stability of our deposit funding sources and sales revenue at the end of contractual lease terms. A significant decline in general economic conditions caused by inflation, recession, unemployment, changes in debt securities markets, government shutdowns, defaults, anticipated defaults or rating agency downgrades of sovereign debt (including debt of the U.S.), changes in housing market prices, depressed oil prices, trade disputes and related tariffs or other factors could impact economic conditions or may have a destabilizing effect on the financial markets and, in turn, could have a material adverse effect on our financial condition and results of operations.

For example, tariffs or other trade restrictions on products and materials that our customers import or export could cause the prices of our customers’ products to increase which could reduce demand for such products, or reduce their margins and revenue, financial results and ability to service debt; which, in turn, could adversely affect our financial condition and results of operations. It remains unclear what the U.S. Administration or foreign governments will or will not do with respect to tariffs already imposed, additional tariffs that may be imposed, or international trade agreements and policies. In addition, coronavirus and concerns regarding the extent to which it may spread have affected, and may increasingly affect, international trade (including supply chains and export levels), travel, employee productivity and other economic activities.

Additionally, adverse economic conditions may result in a decline in demand for equipment that we lease or finance, which could result in a decline in the amount of new equipment being placed in service, as well as declines in the values of collateral already in service. Adverse economic conditions and supply chain disruptions may also impact the ability of dealers to obtain product from manufacturers, resulting in decreased borrowing needs. Any such difficulties could have a material adverse effect on our financial condition and results of operations.

Our financial results are subject to interest rate risk.

Our earnings and cash flows largely depend on our net interest income. Interest rates are highly sensitive to many factors that are beyond our control, including general economic conditions and policies of various governmental and regulatory agencies, including the Federal Reserve. Changes in monetary policy, including changes in interest rates, could influence the amount of interest we receive on loans, leases and other investments and the amount of interest we pay on deposits and other borrowings, as well as: (i) our ability to originate loans and leases and attract or retain deposits; (ii) the fair value of our financial assets and liabilities and (iii) the average life of our interest-earning assets. A significant portion of our loans, including certain consumer, commercial real estate and commercial and industrial loans, bear interest at variable- and adjustable-rates. Increases in market interest rates can have a negative impact on our business, including reducing the amount of money our customers borrow or adversely impacting their ability to make increased payments caused by any increase in interest rates. In addition, as interest rates increase, in order to compete for deposits in our primary banking markets, we may have to offer higher interest rates to depositors, or pursue other sources of liquidity, such as wholesale funding. If the interest rates paid on deposits and other borrowings increase at a faster rate than the interest rates received on loans, leases and other investments, our net interest income and earnings could be adversely affected due to the increase in interest expense without a corresponding increase in interest income. Earnings could also be adversely affected if the interest rates received on loans, leases and other investments decrease more quickly than the interest rates paid on deposits and other borrowings. In addition, we have an investment security portfolio that could decline substantially in value if interest rates increase materially or if obligations of states and political subdivisions become subject to less favorable tax treatment. Although management believes it has implemented effective asset and liability management strategies, any substantial, unexpected or prolonged change in market interest rates could have a material adverse effect on our financial condition and results of operations.

14

Table of Contents

We are subject to certain risks related to originating and selling loans that could have a material adverse effect on our financial condition and results of operations.

We sell loans to generate earnings and manage our liquidity and capital levels, as well as to create geographical and product diversity in our loan portfolio. Disruptions in the financial markets, a decrease in demand for these loans, or changes to laws or regulations that reduce the attractiveness of such loans to purchasers of the loans could require us to decrease our lending activities or retain a greater portion of the loans we originate. Selling fewer loans would result in a decrease in the gains recognized on the sale of loans, could increase our capital needs as a result of the increased assets, and result in decreased liquidity and increased credit risk as our loan portfolios increased in size, any of which could have a material adverse effect on our financial condition and results of operations.

The structure of certain loan sales may result in the retention of credit or financial risks. We may receive interest-only strips or retain loan servicing rights in connection with certain of our loan sales. The interest-only strip is recorded at fair value, which represents the present value of future cash flows expected to be received by us. The value of these interest-only strips may be affected by factors such as changes in the behavior patterns of customers (including defaults and prepayments), changes in the strength of the economy and developments in the interest rate markets; therefore, actual performance may differ from our expectations. Loan servicing rights, the right to service a loan and receive servicing income over the life of the loan, are recognized as assets or liabilities at estimated fair value. The value of loan servicing rights is affected by prepayment speeds of mortgage loans and changes; therefore, actual performance may differ from our expectations. The impact of such factors could have a material adverse effect on the value of these interest-only strips and loan servicing rights and on our financial condition and results of operations.

When loans are sold or securitized, it is customary to make representations, warranties and covenants to the purchaser or investors about the loans, including the manner in which they were originated and will be serviced. These agreements generally require the repurchase of loans or indemnification in the event we breach these representations, warranties or covenants and such breaches are not cured. In addition, some agreements contain a requirement to repurchase loans as a result of early payoffs by the borrower, early payment default of the borrower or defects affecting the security interest in the collateral. We have not been obligated to make significant repurchases of sold loans in the past. A material increase in the amount of loans repurchased could have a material adverse effect on our financial condition and results of operations.

Some of our loan sales involve long-term residential mortgage loans. Purchasers of residential mortgage loans, such as government sponsored entities, require sellers of residential mortgage loans to either repurchase loans previously sold or reimburse purchasers for losses related to loans previously sold when losses are incurred on a loan due to actual or alleged failure to strictly conform to the purchaser's purchase criteria. As a result, we may face increased pressure from purchasers of our residential mortgage loans to repurchase those loans or reimburse purchasers for losses related to those loans and we may face increasing expenses to defend against such claims. If we are required in the future to repurchase loans, reimburse purchasers of loans for losses related to them, or if we incur increasing expenses to defend against such claims, our financial condition and results of operations could be adversely affected.

We operate in a highly competitive industry and market areas.

We face substantial competition in all areas of our operations from a variety of different competitors, both within and beyond our primary banking markets, many of which are larger and may have more financial resources than us. We compete with commercial banks, credit unions, savings and loan associations, mortgage banking firms, other financial service businesses, including investment advisory and wealth management firms, mutual fund companies, and securities brokerage and investment banking firms, as well as super-regional, national and international financial institutions that operate offices in our primary market areas and elsewhere.

The financial services industry could become even more competitive as a result of legislative, regulatory and technological changes and continued consolidation. In addition, as customers' preferences and expectations continue to evolve, technology has lowered barriers to entry and made it possible for banks to expand their geographic reach by providing services over the Internet and for non-banks to offer products and services traditionally provided by banks, such as automatic transfer and automatic payment systems. For example, consumers can now pay bills and transfer funds directly without banks, resulting in the loss of fee income, the loss of customer deposits and income generated from those deposits and lending opportunities.

15

Table of Contents

We compete with these institutions both in attracting deposits and assets under management, and in making new loans. Many of our competitors have fewer regulatory constraints and may have lower cost structures. Additionally, due to their size, many competitors may be able to achieve economies of scale and, as a result, may offer a broader range of products and services as well as better pricing for those products and services than we can. To compete with these institutions, we may have to pay higher interest rates to attract deposits, accept lower yields on loans to attract loans and pay higher wages for new employees, resulting in lower net interest margin and reduced profitability. In addition, the loss of deposits to competitors may require us to address our liquidity needs in ways that increase our funding costs.

Our ability to compete successfully also depends on a number of other factors, including, among other things: our ability to develop, maintain and build long-term customer relationships based on quality service, high ethical standards and safe, sound assets; customer satisfaction with our service; and the ability to expand our market position. Failure to perform in any of these areas could significantly weaken our competitive position, which could adversely affect our growth and profitability and have a material adverse effect on our financial condition and results of operations.

Failure to keep pace with technological changes could adversely affect our business.

The financial services industry is continually undergoing rapid technological change with frequent introductions of new technology‑driven products and services. The effective use of technology increases efficiency and enables financial institutions to better serve customers and to reduce costs. Our future success depends, in part, upon our ability to address the needs of our customers by using technology to provide products and services that will satisfy customer demands, as well as to create additional efficiencies in our operations. Implementation of new technology may, if not properly executed, result in service interruptions, errors, and delays which could damage our reputation and lead to the loss of customer relationships.

Although we are committed to keeping pace with technological advances and investing in new technology, our competitors, many of which have greater resources than we do, may be able to offer additional or superior products to those that we will be able to provide, which would put us at a competitive disadvantage. Failure to successfully keep pace with and implement technological changes could have a material adverse effect on our business, financial condition, results of operations and future prospects.

Our earnings are significantly affected by the fiscal and monetary policies of the federal government and its agencies, as well as other legal changes affecting businesses and consumers.

The policies of the Federal Reserve impact us significantly. The Federal Reserve regulates the supply of money and credit in the U.S. Its policies directly and indirectly influence the rate of interest earned on loans and leases and paid on borrowings and interest-bearing deposits, and also affect the value of financial instruments that we hold. Changes in those policies are difficult to predict. In addition, legal changes affecting consumers and businesses, including the deductibility or other tax attributes associated with certain products, may significantly decrease the demand for certain products that we offer. Any changes to the fiscal and monetary policies, including those by the Federal Reserve or the federal government, could have a material adverse effect on our financial condition and results of operations.

16

Table of Contents

Uncertainty relating to the London Inter-bank Offered Rate, or LIBOR, calculation process and potential phasing out of LIBOR may adversely affect us.

On July 27, 2017, the Chief Executive of the United Kingdom Financial Conduct Authority, which regulates LIBOR, announced that it intends to stop persuading or compelling banks to submit rates for the calibration of LIBOR to the administrator of LIBOR. It is impossible to predict whether and to what extent banks will continue to provide LIBOR submissions to the administrator of LIBOR until the official cessation of publication of LIBOR rates. The Federal Reserve System, in conjunction with the Alternative Reference Rates Committee, has recommended the replacement of LIBOR with a new index, calculated by short-term repurchase agreements collateralized by U.S. Treasury securities, called the Secured Overnight Financing Rate (“SOFR”). At this time, it is impossible to predict the effect of transition from LIBOR on the value of LIBOR-based securities and variable rate loans, or other securities or financial arrangements. If LIBOR rates are no longer available, and we are required to implement a substitute index for the calculation of interest rates under our loan agreements with our borrowers, we may experience significant expenses in effecting the transition, and may be subject to disputes or litigation with customers and creditors over the appropriateness or comparability to LIBOR of the substitute index, which could have an adverse effect on our results of operations.

Severe weather, natural disasters, acts of war or terrorism and other external events could significantly impact our business.

Severe weather, natural disasters, acts of war or terrorism and other adverse external events could have a significant impact on our ability to conduct business. Such events could affect the stability of our deposit base, impair the ability of borrowers to repay outstanding loans, impair the value of collateral securing loans, cause significant property damage, result in loss of revenue and/or cause us to incur additional expenses and could have a material adverse effect on our business, financial condition and results of operations.

Liquidity Risks

We are subject to liquidity risk in our operations, which could adversely affect our ability to fund our various obligations and jeopardize our business, financial condition and results of operations.

Liquidity risk is the possibility that we will not be able to meet our obligations as they come due or capitalize on growth opportunities as they arise because of an inability to liquidate assets or obtain adequate funding on a timely basis, at a reasonable cost and within acceptable risk tolerances. Liquidity is required to fund various obligations, including credit obligations to borrowers, loan originations, withdrawals by depositors, repayment of debt, dividends to shareholders, operating expenses and capital expenditures. Liquidity is derived primarily from retail deposits, principal and interest payments on loans and investment securities, net cash provided from operations and access to other funding. If we are unable to continue to attract and retain core deposits, to obtain third-party financing on favorable terms, or to have access to interbank or other liquidity sources, we may not be able to grow our assets as quickly as planned. If customers move money out of bank deposits into other investments, we would need to seek other funding alternatives, including wholesale funding, in order to continue to grow, thereby increasing our funding costs, if such funding was available at all, and reducing our net interest income and net income.

Our liquidity could also be limited by an inability to access the capital markets or by unforeseen outflows of cash, which could arise due to circumstances outside of our control, including those related to market, credit, operational, and other risks discussed in these risk factors. Our credit rating is important to our liquidity. A reduction or anticipated reduction in our credit ratings could adversely affect the ability of TCF Bank and its subsidiaries to lend by adversely affecting liquidity and our competitive position, increasing our borrowing costs, limiting our access to the capital markets or triggering unfavorable contractual obligations, such as termination of or the requirement that we provide additional collateral pursuant to our derivative contracts.

Furthermore, we are required by federal and state regulatory authorities to maintain specified levels of capital to support our operations. We may need to raise additional capital, in the form of debt or equity, in the future to have sufficient capital resources to meet our commitments and to fund our business needs and future growth, and we may not be able to raise additional capital in the future on terms acceptable to us or at all. Limitations on our access to capital, may adversely affect our capital costs and our ability to raise capital, subject us to increased regulatory supervision and restrictions on our business, and have a material adverse effect on our business, financial condition and results of operations and could be dilutive to both tangible book value and our share price.

17

Table of Contents

Operational Risks

A failure in or breach of our operational or security systems or infrastructure, or those of third-parties, including as a result of cyberattacks, could disrupt our businesses, result in the disclosure or misuse of confidential or proprietary information, damage our reputation, increase our costs and cause losses.

Our operations rely on the secure processing, storage and transmission of confidential and other sensitive business and consumer information on our computer systems and networks and those of third-party providers. Under various federal and state laws, we are responsible for safeguarding such information, and ensuring that our collection, use, transfer and storage of personal information complies with all applicable laws and regulations can increase our costs.

Although we take protective measures to maintain the confidentiality, integrity and availability of information across all geographic and product lines, and endeavor to modify these protective measures as circumstances (including changes in our size and complexity) warrant, the nature of the threats continues to evolve. As a result, our computer systems, software and networks may be vulnerable to unauthorized access, loss or destruction of data (including confidential customer information), account takeovers, unavailability of service, computer viruses or other malicious code, cyber-attacks and other adverse events. Threats may originate externally from third-parties such as foreign governments, organized crime and other hackers, including as a result of attacks on infrastructure-support providers and application developers, or may originate internally from within our organization. We may not be able to ensure that all of our customers, suppliers, counterparties and other third-parties have appropriate controls in place to protect the confidentiality of the information that they exchange with us. In addition, the increasing reliance on technology systems and networks and the occurrence and potential adverse impact of attacks on such systems and networks, both generally and in the financial services industry, have enhanced government and regulatory scrutiny of the measures taken by companies to protect against cyber-security threats. As these threats, and government and regulatory oversight of associated risks, continue to evolve, we may be required to expend additional resources to enhance or expand upon the security measures we currently maintain and may be subject to regulatory actions if we fail to take sufficient measures or experience breaches.

In particular, information pertaining to us and our customers is maintained, and transactions are executed, on our networks and systems, as well as those of our customers and certain of our third-party partners, such as our online banking or reporting systems. The secure maintenance and transmission of confidential information, as well as execution of transactions over these systems, are essential to protect us and our customers against fraud and security breaches and to maintain our customers’ confidence. While to the best of our knowledge we have not experienced any material breaches of information security, such breaches may occur through intentional or unintentional acts by those having or gaining access to our systems or our customers’ or counterparties’ confidential information, including employees. Vulnerabilities in third-party technologies (and technology, including browsers and operating systems used by our customers) or other developments could result in a compromise or breach of the technology, processes and controls that we use to protect data. Furthermore, our customers' devices may become the target of cyber-attacks or information security breaches that could result in the unauthorized release, gathering, monitoring, misuse, loss or destruction of our or our customers' confidential, proprietary and other information, or otherwise disrupt our operations or those of our customers or third parties. For example, various retailers have reported they were victims of cyber-attacks in which large amounts of their customers' data, including debit and credit card information, was obtained. In these situations, we may incur costs related to preventative actions or fraudulent transaction activity affecting our customers.

Any breach of our systems, or those of third-parties, could result in losses to us or our customers; loss of business and/or customers; damage to our reputation; expenses (including the cost of notification to consumers, credit monitoring and forensics, and fees and fines imposed by card networks); disruption to our business; our inability to grow our online services or other businesses; additional regulatory scrutiny or penalties; or our exposure to civil litigation and possible financial liability, any of which could have a material adverse effect on our business, financial condition and results of operations.

18

Table of Contents

We depend on information technology, information and data, and telecommunications systems of third-parties, and systems failures, interruptions involving these systems could have an adverse effect on our operations, financial condition and results of operations.

Our business is highly dependent on the successful and uninterrupted functioning of our information technology and telecommunications systems, third-party servicers accounting systems and mobile and online banking platforms. We outsource some of our major systems, such as payment processing systems, and online banking platforms. While we select these third-party vendors carefully and attempt to monitor ongoing compliance with any arrangements with TCF, we do not control their actions. The failure of these systems, or the termination of a third-party software license or service agreement on which any of these systems is based, could interrupt our operations. Because our information technology and telecommunications systems interface with and depend on third-party systems, we could experience service denials if demand for such services exceeds capacity or such third-party systems fail or experience interruptions. If sustained or repeated, a system failure or service denial could result in a deterioration of our ability to process new and renewal loans, gather deposits and provide customer service, compromise our ability to operate effectively, damage our reputation, result in a loss of customer business and/or subject us to additional regulatory scrutiny and possible financial liability, any of which could have a material adverse effect on our financial condition and results of operations. In addition, failure of third-parties to comply with applicable laws and regulations, or fraud or misconduct on the part of employees of any of these third-parties could disrupt our operations or adversely affect our reputation. Furthermore, concentration among larger third-party providers servicing large segments of the banking industry can also potentially affect wide segments of the financial industry.

It may be difficult for us to replace some of our third-party vendors, particularly vendors providing our core banking, debit card services and information services in a timely manner if they are unwilling or unable to provide us with these services in the future for any reason, and even if we are able to replace them, it may be at higher cost or result in operational disruptions. Any such events could result in the loss of customers and have a material adverse effect on our business, financial condition or results of operations. In addition, any future implementation of technological changes and upgrades to maintain current systems (such as the conversion of Legacy TCF’s business to our core operating system) represent significant undertakings that may result in operational and customer challenges during and after implementation. Key challenges include service interruptions, transaction processing errors and system conversion delays, which may cause us to alienate customers or fail to comply with applicable laws, and may cause us to incur additional expenses, which may be substantial.

We rely on quantitative models to manage certain accounting, risk management and capital planning functions.

We use quantitative models to help manage certain aspects of our business and to assist with certain business decisions, including estimating probable loan losses, measuring the fair value of financial instruments when reliable market prices are unavailable, estimating the effects of changing interest rates and other market measures on our financial condition and results of operations, risk management and for capital planning purposes. Our modeling methodologies rely on many assumptions, historical analyses and correlations. These assumptions may be incorrect, particularly in times of market distress, and the historical correlations on which we rely may no longer be relevant. As businesses and markets evolve, our measurements may not accurately reflect this evolution. Even if the underlying assumptions and historical correlations used in our models are adequate, our models may be deficient due to errors in computer code, bad data, misuse of data, or the use of a model for a purpose outside the scope of the model’s design.

All models have certain limitations. Reliance on models presents the risk that our business decisions based on information incorporated from models will be adversely affected due to incorrect, missing or misleading information. In addition, our models may not capture or fully express the risks we face, may suggest that we have sufficient capitalization when we do not, or may lead us to misjudge the business and economic environment in which we will operate. If our models fail to produce reliable results on an ongoing basis, we may not make appropriate risk management, capital planning, or other business or financial decisions. Strategies that we employ to manage and govern the risks associated with our use of models may not be effective or fully reliable, and as a result, we may realize losses or other lapses. Also, information that we provide to the public or regulators based on poorly designed models could be inaccurate or misleading.

19

Table of Contents

The implementation and adoption of new accounting standards may result in changes to our current methodologies and cause us to incur transition costs. For example, in January 2020, we implemented the Current Expected Credit Loss ("CECL") model in accordance with Financial Accounting Standards Board ("FASB") accounting standards. The CECL model differs significantly from the "incurred loss" model required under GAAP. Accordingly, the adoption of the CECL model has and will continue to materially affect how we determine our allowance for loan and lease losses. At times, the model may require us to significantly increase our allowance, increasing our capital needs, and may create more volatility in the level of our provision for credit losses, either of which may adversely affect our business, financial condition and results of operations.

Banking regulators continue to focus on the models used by financial institutions in their businesses. If our regulators believe that the quality of the models used to generate the relevant information is insufficient, they may restrict certain actions, including distributions to shareholders, expansion of our products or services or place other limitations on us, or may take enforcement action against us by one of our regulators.

Our controls and framework for managing risks may fail or not be effective in mitigating risk and any resulting loss.

Our risk management framework seeks to mitigate risk and any resulting loss. We have established processes intended to identify, measure, monitor, report and analyze the types of risk to which we are subject, including legal and compliance, operational, reputational, strategic and market risk such as interest rate, credit, liquidity and foreign currency risk. However, as with any risk management framework, there are inherent limitations to our risk management strategies, and any system of controls, however well designed and operated, is based in part on certain assumptions and can provide only reasonable, not absolute, assurances that the objectives of the system are met. Any significant failure, circumvention, or breakdowns in our risk management framework or failure to comply with regulations related to controls and procedures could have a material adverse effect on our financial condition and results of operations.

We may be required to recognize an impairment of our goodwill or core deposit intangible assets, or to establish a valuation allowance against our deferred income tax assets, which could have a material adverse effect on our financial condition and results of operations.

Goodwill represents the excess of the amounts paid to acquire assets over their fair value at the date of acquisition. We test goodwill at least annually for impairment. All of our goodwill at December 31, 2020 was recorded on the books of TCF Bank. The fair value of TCF Bank is impacted by the performance of its business and other factors. Core deposit intangible ("CDI") assets represent the estimated value of stable customer deposits, excluding time deposits, acquired in business combinations that provide a source of funds below market interest rates. We amortize our CDI assets over the estimated period the corresponding customer deposits are expected to exist. We test our CDI assets periodically for impairment. If we experience higher than expected deposit run-off, our CDI assets could be impaired. If we determine that our goodwill or CDI assets have been impaired, we must recognize a write-down by the amount of the impairment, with a corresponding charge to net income. Such write-downs could have a material adverse effect on our financial condition and results of operations. At December 31, 2020, we had $1.3 billion of goodwill, representing 23.1% of shareholders' equity, and $111.3 million of CDI assets.

Deferred income tax represents the tax effect of the differences between the book and tax basis of assets and liabilities. Deferred tax assets are assessed periodically by management to determine if they are realizable. Factors in management's determination include our performance, including the ability to generate taxable net income. If, based on available information, it is more-likely-than-not that the deferred income tax asset will not be realized, then a valuation allowance must be established with a corresponding charge to net income. As of December 31, 2020, we carried a valuation allowance against our deferred tax assets of $10.8 million. Charges to establish a valuation allowance with respect to our deferred tax assets could have a material adverse effect on the financial condition and results of operations.

20

Table of Contents

We depend on the accuracy and completeness of information about our customers and counterparties.

In deciding whether to extend credit or enter into other transactions, and in evaluating and monitoring our loan and lease portfolio on an ongoing basis, we rely on information provided to us by or on behalf of our customers and counterparties, including financial statements, credit reports and other financial information. We may also rely on representations of those customers and counterparties or of other third-parties, such as independent auditors, as to the accuracy and completeness of that information. Reliance on inaccurate, incomplete, fraudulent or misleading financial statements, credit reports or other financial or business information, or the failure to receive such information on a timely basis, could result in loan and lease losses, regulatory enforcement actions, reputational damage or other effects that could have a material adverse effect on our business, financial condition or results of operations.

The soundness of other financial institutions could adversely affect us.

Our ability to engage in routine funding transactions could be adversely affected by the actions and commercial soundness of other financial institutions. Financial services institutions are interrelated as a result of trading, clearing, counterparty or other relationships. We have exposure to many different industries and counterparties, and we routinely execute transactions with counterparties in the financial services industry. As a result, defaults by, or even rumors or questions about, one or more financial services institutions, or the financial services industry generally, could lead to losses or defaults by us or by other institutions. Many of these transactions expose us to credit risk in the event of default of our counterparty or client. Diminished availability of counterparties which satisfy our credit quality requirements could negatively impact our business. In addition, our credit risk may be exacerbated when the collateral that we hold cannot be realized or is liquidated at prices insufficient to recover the full amount of the loan. Any such losses could materially and adversely affect our business, financial condition or results of operations.

Our evaluation of investment securities for credit losses involves subjective determinations and could materially impact our financial condition and results of operations.

Our evaluation of impairment in our investment securities portfolio involves a quantitative and qualitative process, which is subject to risks and uncertainties and is intended to determine whether declines in the fair value of such investments should be recognized in current period earnings. The risks and uncertainties include changes in general economic conditions, the issuer's net income, projected net income and financial condition or future recovery prospects, the effects of changes in interest rates or credit spreads and the expected recovery period. The determination of the amount of credit loss recorded in a period is based upon our evaluation and assessment of known and inherent risks associated with the respective asset class. Such evaluations and assessments are revised as conditions change and new information becomes available.

Management considers a wide range of factors about the security issuer and uses judgment in evaluating the cause of the decline in the estimated fair value of the security and in assessing the prospects for recovery. Inherent in management's evaluation of the security are assumptions and estimates about the operations of the issuer and its future earnings potential which may prove to be erroneous and may result in future impairments to the value of securities which could have a material adverse effect on our financial condition and results of operations.

We are exposed to risk of environmental liabilities with respect to real properties that we may acquire.

In the course of our business, we may acquire properties securing loans we have originated or purchased through the foreclosure of loans that are in default. Particularly in commercial real estate lending, there is a risk that hazardous substances could be discovered on these properties. In this event, we might be required to remove these substances from the affected properties at our sole cost and expense. The cost of this removal could substantially exceed the value of the affected properties. In addition, if we are the owner or former owner of a contaminated site, we may be subject to common law claims by third-parties seeking damages for environmental contamination emanating from the site. We may not have adequate remedies against the prior owner or other responsible parties and could find it difficult or impossible to sell the affected properties. If we were to become subject to significant environmental liabilities or costs, our business, results of operations and financial condition could be materially and adversely affected.

21

Table of Contents

Strategic Risks

We face risks and uncertainties related to our proposed merger with Huntington.

Before the transactions contemplated in the TCF/Huntington Merger Agreement can be completed, various approvals must be obtained, including approval of the Federal Reserve Bank and the Office of the Comptroller of the Currency. The terms and conditions of the approvals that are granted may impose conditions, limitations, obligations or costs, or place restrictions on the conduct of the combined company’s business or require changes to the terms of the transactions contemplated by the TCF/Huntington Merger Agreement. There can be no assurance that regulators will not impose any such conditions, limitations, obligations or restrictions and that such conditions, limitations, obligations or restrictions will not have the effect of delaying the completion of any of the transactions contemplated by the TCF/Huntington Merger Agreement, imposing additional material costs on or materially limiting the revenues of the combined company following the merger or otherwise reduce the anticipated benefits of the merger if the TCF/Huntington Merger were consummated successfully within the expected timeframe. In addition, there can be no assurance that any such conditions, terms, obligations or restrictions will not result in the delay or abandonment of the TCF/Huntington Merger.

Huntington and TCF have operated and, until the completion of the TCF/Huntington Merger, will continue to operate independently, and we may experience unexpected difficulties integrating our businesses following the TCF/Huntington Merger. It is possible that the integration could result in the loss of key employees, the loss of customers, the disruption of either company’s or both companies’ ongoing businesses, inconsistencies in standards, controls, procedures and policies, unexpected integration issues, higher than expected integration costs and an overall post-completion integration process that takes longer than originally anticipated. The success of the TCF/Huntington Merger will depend on, among other things, the ability to the businesses in a manner that facilitates growth opportunities and realizes cost savings.

In addition, the TCF/Huntington Merger Agreement contains provisions that restrict TCF’s ability to, among other things, initiate, solicit, knowingly encourage or knowingly facilitate, inquiries or proposals with respect to, or, subject to certain exceptions generally related to its board of directors’ exercise of its fiduciary duties, engage in any negotiations concerning, or provide any confidential information relating to, any alternative acquisition proposals. These provisions, which include a $238.8 million termination fee payable under certain circumstances, might discourage a potential competing acquirer that might have an interest in engaging in a superior transaction from considering or proposing that acquisition, or might result in lower value received by TCF shareholders than would have otherwise been received.

Failure to complete our proposed merger with Huntington could negatively impact our business, financial results and stock price.

If the TCF/Huntington Merger is not completed for any reason, our ongoing business may be adversely affected, and, without realizing any of the benefits of having completed the merger, we will be subject to a number of risks, including the following:

•we may be required, under certain circumstances, to pay Huntington a termination fee of $238.8 million under the TCF/Huntington Merger Agreement;

•we will be required to pay certain costs relating to the merger, whether or not the TCF/Huntington Merger is completed, such as legal, accounting, financial advisor and printing fees;

•the TCF/Huntington Merger Agreement places certain restrictions on the conduct of our business prior to completion of the TCF/Huntington Merger, which may adversely affect our ability to execute certain of our business strategies; and

•matters relating to the TCF/Huntington Merger may require substantial commitments of time and resources by our management, which could otherwise have been devoted to other opportunities that may have been beneficial to us, as an independent company.

In addition, if the TCF/Huntington Merger is not completed, we may experience negative reactions from the financial markets and from our customers and employees. For example, we may be impacted adversely by the failure to pursue other beneficial opportunities due to the focus of management on the TCF/Huntington Merger, without realizing any of the anticipated benefits of completing the TCF/Huntington Merger. The market price of our common stock could decline to the extent that the current market prices reflect a market assumption that the TCF/Huntington Merger will be completed. We also could be subject to litigation related to any failure to complete the TCF/Huntington Merger or to proceedings commenced against us to perform our obligations under the TCF/Huntington Merger Agreement. Any of the above risks could materially affect our business, financial results and stock price.

22

Table of Contents

New lines of business or new products and services may subject us to additional risk.

From time to time, we may develop new lines of business, offer new products and services within existing lines of business, and expand into new markets or pursue new distribution channels. There are substantial risks and uncertainties associated with these efforts, particularly where the markets are new or not fully developed. In developing and marketing new lines of business and new products or services, we may invest significant time and resources. Initial timetables for the introduction and development of, or anticipated level of growth or profitability for new lines of business and new products or services, may not be achieved. External factors such as compliance with regulations, competitive alternatives and shifting market preferences may also impact the success of implementation of a new line of business or a new product or service. Any new line of business or new product or service could have a significant impact on the effectiveness of our system of internal controls. Failure to successfully manage these risks in the development and implementation of new lines of business and new products or services could have a material adverse effect on our financial condition and results of operations.

We depend on our executive officers and other key employees to continue the implementation of our long-term business strategy, and we could be harmed by the unexpected loss of their services.

We believe that our continued growth and future success will depend in large part on the skills of our executive officers and other key employees and our ability to motivate and retain these individuals, as well as our ability to attract, motivate and retain highly skilled employees. Competition for employees is intense, and uncertainty surrounding our planned merger may result in increased attrition. If we are unable to retain personnel, including our key management, who are critical to our future operations, we could face disruptions in our operations, loss of existing customers, loss of key information, expertise or know-how, and unanticipated additional recruitment costs, all of which could have a material adverse effect on our business, financial condition, results of operation and future prospects.

Our ability to maintain our reputation is critical to the success of our business, including our ability to attract and retain customer relationships, and failure to do so may materially adversely affect our performance.

The reputation of TCF Bank is one of the most valuable components of our business. As such, we strive to conduct our business in a manner that enhances our reputation. Damage to our reputation could undermine the confidence of our current and potential customers in our ability to provide financial services. Such damage could also impair the confidence of our investors, counterparties and business partners, and ultimately affect our ability to effect transactions or maintain or hire qualified management and personnel. Maintaining our reputation depends not only on our success in controlling and mitigating the various risks described herein, but also on our success in identifying and appropriately addressing issues that may arise in areas such as potential conflicts of interest, anti-money laundering, client personal information and privacy issues, recordkeeping, regulatory investigations and any litigation that may arise from the failure or perceived failure of us to comply with legal and regulatory requirements. If our reputation is negatively affected, by the actions of our employees or otherwise, the resulting negative public opinion and potential regulatory action could adversely affect our business, financial condition and results of operations.

23

Table of Contents

Compliance Risks

We face risk of noncompliance with the Bank Secrecy Act and other anti-money laundering statutes and regulations and corresponding enforcement proceedings.

The federal Bank Secrecy Act, the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the "PATRIOT Act") and other laws and regulations require financial institutions, among other duties, to institute and maintain effective anti-money laundering programs and to file suspicious activity and currency transaction reports as appropriate. Financial Crimes Enforcement Network, established by the U.S. Treasury Department to administer the Bank Secrecy Act, is authorized to impose significant civil money penalties for violations of those requirements and has engaged in coordinated enforcement efforts with the individual federal banking regulators, as well as the U.S. Department of Justice, Drug Enforcement Administration and Internal Revenue Service. There is also increased scrutiny of compliance with the rules enforced by the Office of Foreign Assets Control. Regulators also have focused on compliance with Bank Secrecy Act and anti-money laundering regulations. If our policies, procedures and systems are deemed deficient, we would be subject to liability, including fines and regulatory actions such as restrictions on our ability to pay dividends and the necessity to obtain regulatory approvals to proceed with certain aspects of our business plan, including our growth plans. Sanctions that the regulators have imposed on banks that have not complied with all requirements have been especially severe. Failure to maintain and implement adequate programs to combat money laundering and terrorist financing could also have serious reputational consequences for us. Any of these results could materially and adversely affect our business, financial condition and results of operations.

We are subject to extensive laws and government regulation and supervision and these laws or regulations, or changes to them or their enforcement could have a material adverse effect on our financial results.

We are subject to extensive federal and state laws, regulation and supervision. Banking regulations are primarily intended to protect bank customers, depositors' funds, federal deposit insurance funds and the banking system as a whole, not shareholders. These regulations affect our revenues, lending practices, capital structure, investment practices, dividend policy and growth, among other things. Congress and federal regulators continually review banking laws, regulations and policies for possible changes and the implementation of banking laws or regulations may change depending on leadership at federal banking agencies.

For example, the Community Reinvestment Act, the Equal Credit Opportunity Act and the Fair Housing Act impose nondiscriminatory lending requirements on financial institutions. The Federal Reserve, the CFPB, the Department of Justice, and other federal and state agencies are responsible for enforcing these laws and regulations. Private parties may also have the ability to challenge an institution’s performance under fair lending laws in private class action litigation. A successful challenge to our performance under the fair lending laws and regulations could adversely impact our rating under the Community Reinvestment Act and result in a wide variety of sanctions, including the required payment of damages and civil money penalties, injunctive relief, imposition of restrictions on merger or other growth activity.

Many aspects of the banking business involve a substantial risk of legal liability. From time to time, we are, or may become, the subject of reviews, investigations and proceedings, and other forms of regulatory inquiry, including by bank regulatory agencies, self-regulatory agencies, the SEC and law enforcement authorities. The results of such proceedings could lead to significant civil or criminal penalties, including monetary penalties, damages, adverse judgements, settlements, fines, injunctions, restrictions on the way we conduct our business or reputational harm.

24

Table of Contents

Future changes in regulations, regulatory policies, interpretation and enforcement of statutes, regulations or policies could reduce revenues and increase compliance burdens and limit the types of financial services and products we may offer, or increase competition from non-banks offering competing financial services and products, among other things. Future legislative and regulatory initiatives cannot be fully or accurately predicted. Such proposals may impose higher standards than currently applicable or anticipated with respect to capital and liquidity requirements, leverage, deposit insurance and risk management requirements for depository institutions. For example, the CFPB has examination and enforcement authority over TCF Bank and its subsidiaries, and broad rulemaking authority to administer and carry out the purposes and objectives of the federal consumer financial laws with respect to all financial institutions that offer financial products and services to consumers. The CFPB is authorized to make rules identifying and prohibiting acts or practices that are unfair, deceptive or abusive in connection with any transaction with a consumer for a consumer financial product or service, or the offering of a consumer financial product or service. Since many new banking rules are issued with limited interpretive guidance, we may not sufficiently comply with or anticipate the full impact of such new rules. The term "abusive" may be interpreted in changing or inconsistent ways over time. Regulatory actions that adversely impact our deposit, lending, loan collection, campus banking programs or customer opt-in preferences with respect to overdrafts could have a material adverse effect on our financial condition and results of operations. In recent years there has been an increase in the frequency of enforcement actions brought by federal banking regulators, such as the CFPB, dealing with matters such as fair lending, account fees, loan servicing and other products and services provided to customers.

While we have policies and procedures designed to prevent violations of laws, regulations and regulatory policies, and to ensure compliance with new or changed laws, regulations and regulatory policies, violations and compliance failures may still occur, and could result in reputational damage, remediation, disgorgement, regulatory enforcement actions, penalties, increased capital requirements, higher deposit insurance assessments, other monetary relief, injunctive relief or changes to our business practices or operations, any of which could have a material adverse effect on our financial condition and results of operations.

We are periodically named as a defendant in a variety of litigation and other actions, which may have a material adverse effect on our financial condition and results of operations.

We are periodically subject to claims and legal actions related to our operations. These claims and legal actions could result in large, unpredictable monetary awards or penalties, as well as significant defense costs. While we maintain insurance coverage in amounts and with deductibles that we believe are appropriate for our operations, such insurance does not cover all types of liability, including regulatory fines or penalties and may not continue to be available to us at a reasonable cost, or at all. As a result, we may be exposed to substantial uninsured liabilities, which could have a material adverse effect on our financial condition and results of operations.

In addition, customers may make claims and take legal action pertaining to our deposit products and sale and servicing of our loan and lease products, account opening/origination practices, fees, employment practices, checking account overdraft program “opt in” requirements, or fiduciary responsibilities. The COVID-19 pandemic has also resulted in novel legal and regulatory risks, including in the area of workplace safety, and related emergency lending programs have been associated with increased fraud and related oversight and law enforcement activities.

The financial services industry has also increasingly been targeted by lawsuits alleging infringement of patent rights, often from patent holding companies seeking to monetize patents they have purchased or otherwise obtained. Regardless of the scope or validity of such patents or other intellectual property rights, or the merits of any claims by potential or actual litigants, we may have to engage in protracted and costly litigation which may be time consuming and disruptive to our operations and management. If we are found to infringe on one or more patents or other intellectual property rights, we may be required to pay substantial damages or royalties to a third-party, or it may be subject to a temporary or permanent injunction prohibiting us from utilizing certain technologies.

Whether or not such claims and legal actions have merit, they may result in significant financial liability and could adversely affect the market perception of TCF Bank and our products and services, as well as impact customer demand for those products and services. Any financial liability or reputational damage from these claims or legal action could have a material adverse effect on our financial condition and results of operations.

25

Table of Contents

We are subject to examinations, challenges and rates set by tax authorities that could adversely affect our results of operations and financial condition.

We are subject to federal, state and foreign income tax regulations, which often require interpretation due to their complexity. Changes in income tax regulations or tax rates, including those resulting from the enactment of tax law changes or in how the regulations are interpreted could have a material adverse effect on our results of operations. In the normal course of business, we are routinely subject to examinations and challenges from taxing authorities regarding our tax positions. Taxing authorities have been aggressive in challenging tax positions taken by financial institutions. These tax positions may relate to tax compliance, sales and use, franchise, gross receipts, payroll, property and income tax issues, including tax base, apportionment and tax credit planning. These challenges may result in adjustments to the timing or amount of taxable income or deductions, or the allocation of income among tax jurisdictions. If any such challenges are made and are not resolved in our favor, they could have a material adverse effect on our financial condition and results of operations.

Item 2. Properties

Our headquarters is located in Detroit, Michigan, in an office building that is leased. We also operate regional offices located in the Minneapolis-St. Paul area of Minnesota, Midland, Michigan and Chicago. At December 31, 2020, we leased or licensed 157 of our bank branch offices, owned the buildings and land for 296 of our bank branch offices and owned the buildings and leased the land for the remaining 25 of our bank branch offices, all of which are functional and appropriately maintained and are utilized by both our Consumer Banking and Commercial Banking reportable segments. These branch offices are located in Michigan, Illinois, Minnesota, Colorado, Ohio, Wisconsin and South Dakota. For further information on premises and equipment, see "Note 9. Premises and Equipment, Net" of Notes to Consolidated Financial Statements.

Item 3. Legal Proceedings

From time to time, we are a party to legal proceedings arising out of our lending, leasing and deposit operations, including foreclosure proceedings and other collection actions as part of our lending and leasing collections activities. We may also be subject to regulatory examinations and enforcement actions brought by federal regulators, including the SEC, the Federal Reserve, the OCC and the CFPB which may impose sanctions in the event of a regulatory violation. The COVID-19 pandemic has resulted in novel legal and regulatory risks, including risks in the area of workplace safety, risks related to emergency lending programs and the associated risk of fraud and regulatory activity. From time to time, borrowers and other customers, and employees and former employees have also brought actions against us, in some cases claiming substantial damages. We, like other financial services companies are subject to the risk of class action litigation. Litigation is often unpredictable and the actual results of litigation cannot be determined, and therefore the ultimate resolution of a matter and the possible range of loss associated with certain potential outcomes cannot be established. Based on our current understanding of our pending legal proceedings, management does not believe that judgments or settlements arising from pending or threatened legal matters, individually or in the aggregate, would have a material adverse effect on our consolidated financial position, operating results or cash flows.

On February 2, 2021, a complaint, captioned Shiva Stein v. TCF Financial Corporation et al., No. 1:21-cv-00273-JKB (D. Md.), was filed by a purported shareholder of TCF in the U.S. District Court for the District of Maryland. The complaint names TCF, the TCF board of directors and Huntington as defendants. The complaint alleges, among other things, that the defendants caused a materially incomplete and misleading registration statement relating to the proposed merger to be filed with the SEC in violation of Section 14(a) and Section 20(a) of the Exchange Act and Rule 14a-9 promulgated thereunder. The complaint seeks, among other relief, an injunction preventing the closing of the merger unless and until defendants disclose the allegedly omitted material information, rescission of the merger to the extent already implemented or awarding of rescissory damages, damages and an award of attorneys’ and experts’ fees. TCF and Huntington believe the claims asserted in the lawsuit are without merit.

26

Table of Contents

On February 6, 2021, a complaint captioned Maegon Cassell v. Huntington Bancshares Incorporated et al., No. 1:21-cv-00161-MN, was filed by a purported shareholder of Huntington in the U.S. District Court for the District of Delaware. The complaint names Huntington, the Huntington board of directors and TCF as defendants. The complaint alleges, among other things, that the defendants caused a materially incomplete and misleading registration statement relating to the proposed merger to be filed with the SEC in violation of Section 14(a) and Section 20(a) of the Exchange Act and Rule 14a-9 promulgated thereunder. The complaint seeks, among other relief, an injunction preventing the closing of the merger, rescission of the merger in the event consummated or awarding of rescissory damages, dissemination of a registration statement that does not contain any allegedly untrue statements of material fact, a declaration that defendants violated Section 14(a) and Section 20(a) of the Exchange Act as well as Rule 14a-9 promulgated thereunder and an award of attorneys’ and experts’ fees. TCF and Huntington believe the claims asserted in the lawsuit are without merit.

On February 9, 2021, a complaint captioned Joe Osterhout v. TCF Financial Corporation et al., No. 1:21-cv-00403-SKC, was filed by a purported shareholder of TCF in the U.S. District Court for the District of Colorado. The complaint names TCF and the TCF board of directors as defendants. The complaint alleges, among other things, that the defendants caused a materially incomplete and misleading registration statement relating to the proposed merger to be filed with the SEC in violation of Section 14(a) and Section 20(a) of the Exchange Act and Rule 14a-9 promulgated thereunder. The complaint seeks, among other relief, an injunction preventing the closing of the merger and any vote on the merger unless and until defendants disclose the allegedly omitted material information, rescission of the merger in the event consummated or awarding of rescissory damages, a declaration that defendants violated Section 14(a) and Section 20(a) of the Exchange Act and Rule 14a-9 promulgated thereunder and an award of attorneys’ fees and experts’ fees. TCF and Huntington believe the claims asserted in the lawsuit are without merit.

There can be no assurances that additional complaints or demands will not be filed or made with respect to the merger. If additional similar complaints or demands are filed or made, absent new or different allegations that are material, neither TCF and Huntington will necessarily announce them.

Item 4. Mine Safety Disclosures

Not applicable.

27

Table of Contents

Part II

Item 5. Market for Registrant's Common Equity, Related Shareholder Matters and Issuer Purchases of Equity Securities

Our common stock trades on the NASDAQ Stock Market® under the symbol "TCF." As of February 19, 2021, there were 8,458 holders of record of our common stock.

Dividends

The Board of Directors of TCF Financial and TCF Bank have each adopted a Capital Adequacy and Dividend Policy. The policies define how enterprise risk related to capital will be managed, how the adequacy of capital will be measured and the process by which capital strategy, capital management and preferred and common stock dividend recommendations will be presented to TCF's Board of Directors. Our management is charged with ensuring that capital strategy actions, including the declaration of preferred and common stock dividends, are prudent, efficient and provide value to our shareholders, while ensuring that past and prospective earnings retention is consistent with our capital needs, asset quality, risk profile and overall financial condition.

The Board of Directors currently intends to continue its practice of paying quarterly cash dividends on our common stock as justified by our financial condition. The declaration and amount of future dividends will depend on circumstances existing at the time, including our earnings, financial condition and capital requirements, the cash available to pay such dividends (derived mainly from dividends and distributions from TCF Bank which may be limited by its dividend paying capacity), alternative uses of capital, and regulatory and contractual limitations and such other factors as the Board of Directors may deem relevant. In addition, the ability of TCF Financial and TCF Bank to pay dividends depends on regulatory policies and capital requirements and may be subject to regulatory approval. See "Item 1. Business - Regulation - Regulatory Capital Requirements", "Item 1. Business - Regulation - Restrictions on Distributions", "Note 18. Regulatory Capital Requirements" and "Note 29. Parent Company Financial Information" of Notes to Consolidated Financial Statements. Dividends for the current dividend period on all outstanding shares of preferred stock must be declared and paid or declared and a sum sufficient for the payment thereof must be set aside before any dividend may be declared or paid on our common stock.

28

Table of Contents

Total Return Performance

The following chart compares the cumulative total shareholder return on our common stock over the last five fiscal years with the cumulative total return of the KBW NASDAQ Regional Banking Index and the Standard and Poor's ("S&P") 500 Stock Index (assuming the investment of $100 in each index on December 31, 2015 and reinvestment of all dividends). As a result of the merger of equals between TCF and Chemical Financial Corporation (the "TCF/Chemical Merger") in which Chemical Financial Corporation was the legal acquirer and subsequently changed its name to TCF Financial Corporation, the total shareholder return shown below for TCF Financial Corporation reflects Chemical Financial Corporation's stock price and dividends paid for the period of December 31, 2015 through the closing of the TCF/Chemical Merger on August 1, 2019, and the combined company's stock price and dividends paid for the period of August 1, 2019 through December 31, 2020.

TCF Total Stock Return Performance Chart(1)

    u TCF Financial Corporation(1) l KBW NASDAQ Regional Banking Index     n S&P 500 Index

	At December 31,
Index	2015		2016		2017		2018		2019		2020
TCF Financial Corporation	$	100.00	$	162.12	$	163.60	$	114.70	$	151.61	$	125.67
KBW NASDAQ Regional Banking Index	100.00		139.02		141.45		116.70		144.49		131.91
S&P 500 Index	100.00		111.96		136.40		130.42		171.49		203.04

Source: S&P Global Market Intelligence

(1)Prior to the TCF/Chemical Merger, the shares were traded under the symbol "CHFC".

29

Table of Contents

Repurchases of TCF Common Stock

Share repurchase activity for the quarter ended December 31, 2020 was as follows:

Period	Total Number of Shares Purchased	Average Price Paid Per Share		Total Number of Shares Purchased as Part of Publicly Announced Plan	Approximate Dollar Value of Shares that May Yet Be Purchased Under the Plan
October 1 to October 31, 2020
Share repurchase program(1)	—	$	—	—	$	89,419,941
Employee transactions(2)	17,350	25.73		N.A.	N.A.
November 1 to November 30, 2020
Share repurchase program(1)	—	$	—	—	$	89,419,941
Employee transactions(2)	—	—		N.A.	N.A.
December 1 to December 31, 2020
Share repurchase program(1)	—	$	—	—	$	89,419,941
Employee transactions(2)	104	36.03		N.A.	N.A.
Total
Share repurchase program(1)	—	$	—	—	$	89,419,941
Employee transactions(2)	17,454	25.79		N.A.	N.A.

 N.A. Not Applicable

(1)On October 24, 2019, the Board of Directors approved an authorization to repurchase up to $150.0 million of our common stock. Repurchases will be based on market conditions, the trading price of our shares and other factors including prior approval in accordance with the TCF/Huntington Merger Agreement. The ability to repurchase shares in the future may be adversely affected by new legislation or regulations or by changes in regulatory policies.

(2)Represents restricted stock withheld pursuant to the terms of awards granted under the Legacy TCF Financial Omnibus Incentive Plan to offset tax withholding obligations that occur upon vesting and release of restricted stock. The plan provides that the value of shares withheld shall be the average of the high and low prices of common stock of TCF Financial Corporation on the date the relevant transaction occurs.

30

Table of Contents

Item 6. Selected Financial Data

The selected five-year financial summary presented below should be read in conjunction with the Consolidated Financial Statements and related notes thereto, which are included elsewhere in this report. Our financial results were significantly impacted by the TCF/Chemical Merger, and periods before August 1, 2019 reflect financial data of Legacy TCF, while periods after the TCF/Chemical Merger reflect financial data for the combined company. Certain reclassifications have been made to prior period financial statements to conform to the current period presentation. Earnings per share and share quantities of TCF have been retrospectively adjusted to reflect the equivalent number of shares issued in the TCF/Chemical Merger. Our Consolidated Financial Statements are prepared in accordance with United States generally accepted accounting principles ("GAAP"). As noted in the following table, we have included certain non-GAAP financial measures, which should be read in conjunction with the section entitled, "Non-GAAP Financial Measures" and the accompanying table entitled "Reconciliation of Non-GAAP Operating Results," for an explanation of the use of the non-GAAP financial measures and a reconciliation of non-GAAP measures to the most directly comparable GAAP financial measure. Historical data is not necessarily indicative of our future results of operations or financial condition. See "Item 1A. Risk Factors" for more discussion of factors that could cause our results to differ significantly from management's expectation.

	For the Year Ended December 31,
(Dollars in thousands, except per share data)	2020			2019			2018			2017			2016
Consolidated Income:
Interest income	$1,765,662			$1,587,261			$1,159,329			$1,031,745			$942,681
Interest expense	227,261			298,229			150,834			94,271			82,956
Net interest income	1,538,401			1,289,032			1,008,495			937,474			859,725
Noninterest income	516,063			465,532			454,397			436,063			454,281
Total revenue	2,054,464			1,754,564			1,462,892			1,373,537			1,314,006
Provision for credit losses(1)	257,151			65,282			46,768			68,443			65,874
Noninterest expense	1,527,371			1,332,115			1,014,400			1,059,934			909,887
Income before income tax expense	269,942			357,167			401,724			245,160			338,245
Income tax expense (benefit)	39,901			50,241			86,096			(33,624)			116,528
Income attributable to non-controlling interest	7,282			11,458			11,270			10,147			9,593
Net income attributable to TCF	222,759			295,468			304,358			268,637			212,124
Preferred stock dividends	9,975			9,975			11,588			19,904			19,388
Impact of preferred stock redemption	—			—			3,481			5,779			—
Net income available to common shareholders	$	212,784		$	285,493		$	289,289		$	242,954		$	192,736
Earnings per common share:
Basic	$	1.40		$	2.56		$	3.44		$	2.83		$	2.27
Diluted	1.40			2.55			3.43			2.83			2.27
Dividends declared	1.40			1.29			1.18			0.59			0.59
Financial Ratios:
Return on average assets ("ROAA")	0.48		%	0.92		%	1.37		%	1.26		%	1.05		%
Return on average common equity ("ROACE")	3.88			7.67			12.42			10.80			9.13
Return on average tangible common equity ("ROATCE")(2)	5.73			9.81			13.56			15.73			10.29
Net interest margin	3.47			4.17			4.66			4.52			4.33
Net interest margin (FTE)(3)(4)	3.50			4.20			4.69			4.59			4.34
Dividend payout ratio	100.00			50.41			34.33			20.83			26.09
Efficiency ratio	74.34			75.92			69.34			77.17			69.25
Credit Quality Ratios:
Net charge-offs as a percentage of average loans and leases	0.13			0.27			0.29			0.24			0.26
Adjusted Financial Results (non-GAAP):
Adjusted net income attributable to TCF(2)	$	389,467		$	461,232		$	329,867		$	211,025		$	212,124
Adjusted diluted earnings per common share(2)	$	2.50		$	4.04		$	3.73		$	2.16		$	2.27
Adjusted ROAA(2)	0.82		%	1.41		%	1.48		%	1.00		%	1.05		%
Adjusted ROACE(2)	6.92			12.13			13.51			8.24			9.13
Adjusted ROATCE(2)	9.88			15.34			14.74			9.25			10.29
Adjusted efficiency ratio (2)	60.95			60.58			64.77			69.71			67.59

(1)Effective January 1, 2020, TCF adopted Accounting Standard Update ("ASU") No. 2016-13, Financial Instruments - Credit Losses (Top 326): Measurement of Credit Losses on Financial Instruments and related ASUs on a modified retrospective basis. Financial information at and for the year ended December 31, 2020 is reflected as such. The historical information disclosed is in accordance with ASC Topic 310 and ASC Topic 450.

(2)See "Item 7. Management's Discussion and Analysis - Consolidated Financial Condition Analysis - Non-GAAP Financial Measures" for further information.

(3)Net interest income on a fully tax-equivalent ("FTE") basis divided by average interest-earning assets.

(4)Presented on a tax-equivalent basis using the federal statutory tax rate in effect for each period presented.

31

Table of Contents

	At December 31,
(Dollars in thousands, except per share data)	2020			2019			2018			2017			2016
Consolidated Financial Condition:
Loans and leases	$	34,466,408		$	34,497,464		$	19,073,020		$	19,105,284		$	17,844,716
Total assets	47,802,487			46,651,553			23,699,612			23,002,159			21,441,326
Deposits	38,856,319			34,468,463			18,903,686			18,335,002			17,242,522
Borrowings	1,992,095			5,023,593			1,449,472			1,249,449			1,077,572
Total equity	5,689,297			5,727,241			2,556,260			2,680,584			2,444,645
Financial Ratios:
Common equity to assets	11.51		%	11.87		%	9.99		%	10.42		%	10.09		%
Tangible common equity as a percent of tangible assets (non-GAAP)(1)	8.72			9.01			9.32			9.72			9.13
Total risk-based capital ratio	14.03			12.70			13.38			13.90			13.69
Book value per common share	$	36.06		$	36.20		$	28.44		$	27.48		$	24.91
Tangible book value per common share (non-GAAP)(1)	26.49			26.60			26.33			25.43			22.29
Credit Quality Ratios:
Nonaccrual loans and leases as a percentage of total loans and leases(2)	1.97		%	0.49		%	0.56		%	0.62		%	1.02		%
Nonperforming assets as a percentage of total loans and leases and other real estate owned(2)	2.06			0.59			0.65			0.72			1.28
Allowance for loan and lease losses as a percentage of total nonaccrual loans and leases(2)	77.64			66.64			148.65			144.24			88.33
Allowance for credit losses as a percentage of total nonaccrual loans and leases(2)	81.08			68.71			150.00			145.49			88.94
Allowance for loan and lease losses as a percentage of total loans and leases(2)	1.53			0.33			0.83			0.90			0.90
Allowance for credit losses as a percentage of total loans and leases(2)	1.59			0.34			0.83			0.90			0.90

(1)See "Item 7. Management's Discussion and Analysis - Consolidated Financial Condition Analysis - Non-GAAP Financial Measures" for further information.

(2)Effective January 1, 2020, TCF adopted Accounting Standard Update ("ASU") No. 2016-13, Financial Instruments - Credit Losses (Top 326): Measurement of Credit Losses on Financial Instruments and related ASUs on a modified retrospective basis. Financial information at and for the year ended December 31, 2020 is reflected as such. The historical information disclosed is in accordance with ASC Topic 310 and ASC Topic 450.

32

Table of Contents

Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations

Table of Contents

Description	Page
Forward-looking Information	34
Overview	35
Critical Accounting Policies and Estimates	38
Results of Operations	40
Performance Summary	40
Consolidated Results of Operations Analysis	41
Net Interest Income	41
Provision for Credit Losses	44
Noninterest Income	45
Noninterest Expense	47
Income Taxes	48
Reportable Segment Results	48
Consolidated Financial Condition Analysis	50
Investment Securities	50
Loans and Leases	51
Credit Quality	55
Liquidity Management	63
Deposits	63
Borrowings	64
Contractual Obligations and Commitments	65
Capital Management	66
Non-GAAP Financial Measures	67
Recent Accounting Developments	73

33

Table of Contents

Forward-looking Information

Any statements contained in this Annual Report on Form 10-K regarding the outlook for the Corporation's businesses and their respective markets, such as projections of future performance, targets, guidance, statements of the Corporation's plans and objectives, forecasts of market trends and other matters are forward-looking statements based on the Corporation's assumptions and beliefs. Such statements may be identified by such words or phrases as "will likely result," "are expected to," "will continue," "outlook," "will benefit," "is anticipated," "estimate," "project," "management believes" or similar expressions. These forward-looking statements are subject to certain risks and uncertainties that could cause actual results to differ materially from those discussed in such statements and no assurance can be given that the results in any forward-looking statement will be achieved. For these statements, TCF claims the protection of the safe harbor for forward-looking statements contained in the Private Securities Litigation Reform Act of 1995. Any forward-looking statement speaks only as of the date on which it is made and we disclaim any obligation to subsequently revise any forward-looking statement to reflect events or circumstances after such date or to reflect the occurrence of anticipated or unanticipated events.

These statements include, among others, statements related to: our strategic plan to develop customer relationships that will drive core deposit growth and stability, management's belief that our commercial and commercial real estate loan portfolios are generally well-secured, the impact of projected changes in net interest income assuming changes to short-term market interest rates, statements regarding our risk exposure, statements related to our planned merger with Huntington Bancshares Incorporated ("Huntington"), including statements related to the anticipated effects on results of operations and financial condition from expected developments. All statements referencing future time periods are forward-looking.

Furthermore, management's determination of the allowance for credit losses and related provision; the carrying value of goodwill and loan servicing rights; the fair value of investment securities (including whether there is any credit impairment); and management's assumptions concerning postretirement benefit plans involve judgments that are inherently forward-looking. There can be no assurance that future loan losses will be limited to the amounts estimated. All of the information concerning interest rate sensitivity is forward-looking. The future effect of changes in the financial and credit markets and the national and regional economies on the banking industry, generally, and on us, specifically, are also inherently uncertain.

Certain factors could cause the Corporation's future results to differ materially from those expressed or implied in any forward-looking statements contained herein. These factors include the factors discussed in Part I, Item 1A of this Annual Report on Form 10-K under the heading "Risk Factors", the factors discussed below and any other cautionary statements, written or oral, which may be made or referred to in connection with any such forward-looking statements. Since it is not possible to foresee all such factors, these factors should not be considered as complete or exhaustive: macroeconomic and other challenges and uncertainties resulting from the COVID-19 pandemic, such as the extent and duration of the impact on public health, the U.S. and global economies, financial markets and consumer and corporate customers and clients, including economic activity, employment levels and market liquidity, as well as the various actions taken in response to the challenges and uncertainties by governments, central banks and others, including TCF; a failure to manage credit risk; cyber-security breaches involving us or third parties, hacking, denial of service, loss or theft of information, or other cyber-attacks that disrupt TCF's business operations or damage its reputation; adverse developments affecting TCF's banking centers; inability to successfully execute on TCF's growth strategy through acquisitions or expanding existing business relationships; calculating an allowance for loan and lease losses insufficient to absorb actual losses in our loan and lease portfolio; adverse effects related to competition from traditional competitors, non-bank providers of financial services and new technologies; technological difficulties, including those related to system upgrades or the failure to keep pace with technological changes in response to customer demands; risks related to developing new products, markets or lines of business; adverse political or economic conditions; risks related to TCF's loan origination and sales activity; lack of access to liquidity or ability to raise capital that isn’t dilutive; adverse changes in monetary, fiscal or tax policies; litigation or government enforcement actions; heightened consumer protection, supervisory or regulatory practices or requirements; deficiencies in TCF's compliance programs, risk mitigation frameworks or ineffective internal controls; dependence on accurate and complete information from customers and counterparties; the failure to attract and retain key employees; soundness of other financial institutions and other counterparty risk, including the risk of default, operational disruptions, or diminished availability of counterparties who satisfy our credit quality requirements; inability to grow deposits, increase earnings and revenue, manage operating expenses, or pay and receive dividends; interruptions, systems failures in information technology and telecommunications systems failures of third-party services; deficiencies in TCF's quantitative models; the effect of any negative publicity or reputational damage; changes in accounting standards or interpretations of existing standards; adverse federal, state or foreign tax assessments; and the effects of man-made and natural disasters, any of which may negatively affect our operations and/or our customers.

34

Table of Contents

This report also contains forward-looking statements regarding TCF's outlook or expectations with respect to the planned merger with Huntington. Examples of forward-looking statements include, but are not limited to, statements regarding the outlook and expectations of TCF and Huntington with respect to the planned merger, the strategic benefits and financial benefits of the merger, including the expected impact of the merger on the combined corporation's future financial performance, and the timing of the closing of the transaction. Such risks, uncertainties and assumptions, include, among others, the following:

•the failure to obtain necessary regulatory approvals when expected or at all (and the risk that such approvals may result in the imposition of conditions that could adversely affect TCF or Huntington or the expected benefits of the merger);

•the failure of either TCF or Huntington to obtain shareholder approval, or to satisfy any of the other closing conditions to the merger on a timely basis or at all;

•the occurrence of any event, change or other circumstances that could give rise to the right of one or both of the parties to terminate the merger agreement;

•the possibility that the anticipated benefits of the transaction, including anticipated cost savings and strategic gains, are not realized when expected or at all, including as a result of the impact of, or problems arising from, economic weakness, competitive factors in the areas where TCF and Huntington do business, or as a result of other unexpected factors or events;

•the impact of purchase accounting with respect to the transaction, or any change in the assumptions used regarding the assets purchased and liabilities assumed to determine their fair value;

•diversion of management's attention from ongoing business operations and opportunities;

•potential adverse reactions or changes to business or employee relationships, including those resulting from the announcement or completion of the transaction;

•the ability of either TCF or Huntington to repurchase their stock and the prices at which such repurchases may be made;

•the outcome of any current or future legal proceedings against TCF or Huntington related to the merger;

•the integration of the businesses and operations of TCF and Huntington, which may take longer than anticipated or be more costly than anticipated or have unanticipated adverse results relating to our existing businesses;

•business disruptions following the merger; and

•other factors that may affect future results of TCF and Huntington including changes in asset quality and credit risk; the inability to grow revenue and earnings; changes in interest rates and capital markets; inflation; customer borrowing, repayment, investment and deposit practices; the impact, extent and timing of technological changes; capital management activities; and other actions of the Federal Reserve Board and legislative and regulatory actions and reforms.

Additional factors that could cause results to differ materially from those described above can be found in the risk factors described in Part I, Item 1A of this Annual Report on Form 10-K under the heading "Risk Factors" and Huntington’s Annual Report on Form 10-K filed with the SEC for the year ended December 31, 2020. Annualized, pro forma, projected and estimated numbers are used for illustrative purpose only, are not forecasts and may not reflect actual results. TCF disclaims any obligation to update or revise any forward-looking statements contained in this communication, which speak only as of the date hereof, whether as a result of new information, future events or otherwise, except as required by law.

Overview

TCF Financial Corporation, formerly known as Chemical Financial Corporation, ("TCF") is a financial holding company incorporated in Michigan in 1973 and headquartered in Detroit, Michigan.

Through our wholly-owned bank subsidiary, TCF National Bank, a national banking association ("TCF Bank") with its main office in Sioux Falls, South Dakota, we provide a full range of consumer-facing and commercial services, including consumer and commercial banking, trust and wealth management, and specialty leasing and lending products and services to consumers, small businesses and commercial customers. As of December 31, 2020, TCF had 478 branches primarily located in Michigan, Illinois and Minnesota, with additional locations in Colorado, Ohio, South Dakota and Wisconsin (our "primary banking markets"). We also conduct business across all 50 states, Canada, New Zealand and Australia through our specialty lending and leasing businesses.

35

Table of Contents

References herein to "TCF Financial" or the "Holding Company" refer to TCF Financial Corporation on an unconsolidated basis. TCF Financial Corporation (together with its direct and indirect subsidiaries, are referred to as "we," "us," "our," "TCF" or the "Corporation".

Supporting Team Members, Customers and Communities

To support our team members we have:

•Implemented health and safety policies, protocols and guidelines while ensuring adequate PPE and cleaning supplies are available at all locations in response to the COVID-19 pandemic;

•provided company-paid time off for team members not able to work for reasons related to COVID-19 and enhanced compensation for team members required to work in the office for a period of time;

•offered reimbursement to eligible team member who, due to COVID-19, had to find back-up care for their child or dependent with health/developmental needs for a period of time;

•provided equipment and resources to allow nearly all of our middle and back office employees to work from home and developed a thoughtful return to work approach where team members are returning in phases based on safety guidelines and local restrictions while evaluating lessons learned and opportunities for a more flexible workspace strategy in the future; and

•established various internal initiatives to increase awareness of diversity and inclusion issues including launching the Executive Diversity and Inclusion Council, providing executive office hours for team members to have candid discussions with leaders regarding diversity issues, required unconscious bias training for all team members, and organizing Employee Resource Groups to serve as a resource to positively influence the culture, support efforts to attract, develop and attract diverse team members.

To support our customers we have:

•Assisted customers in response to the COVID-19 pandemic via loan and lease deferrals, evaluated under the CARES Act, with $329.8 million on deferral status as of December 31, 2020 ($246.5 million of commercial balance and $83.3 million of consumer balance); and

•assisted business and commercial customers via $1.9 billion of total loans funded through the Paycheck Protection Program ("PPP"), of which $1.6 billion of PPP loan balance was outstanding at December 31, 2020.

To support our communities we have:

•Established a $1 billion loan commitment for minority communities and minority- and women-owned small businesses over 5 years;

•expanded closing costs assistance program through the Heart and Home Lending Program providing up to $10 million of grants to help cover closing costs for qualified low-to-moderate income home buyers over 5 years;

•partnered with Wayne County, Michigan to provide fast relief through low-interest loans to help small businesses in the Detroit area; and

•committed $250 thousand for relief efforts supporting Great Lakes Bay Region community organizations and a $10 million Hardship Lending Program to support residents and business impacted by dam failures and historic flooding in the Midland, Michigan area.

36

Table of Contents

The COVID-19 pandemic has resulted in historic job losses and decreases in economic activity. While the duration and full extent of job losses and magnitude of economic dislocation are not yet known, it is clear that they have impacted, and may impact in the future, the ability of individuals and small businesses to make payments, the value of underlying collateral and the ability of guarantors to make payments in the case of default, which may decrease consumer demand for our products and services and reduce our ability to access capital. As a result of the decrease in economic activity and restrictions on certain activities, we have faced and may continue to face a decrease in demand for certain products, reduced access to our banking centers by our customers, and disruptions in the operations of our vendors. The pandemic could also result in the recognition of additional credit losses in our loan and lease portfolios and increase our allowance for credit losses as both businesses and consumers are negatively impacted by the economic downturn. In addition, reduced origination volumes and credit losses triggered by COVID-19 may impact significant estimates included within our fair valuation analyses. The extent of such impact will depend on the outcome of certain developments, including but not limited to, the duration and spread of the outbreak as well as its continuing impact on our customers, vendors, employees and the financial markets all of which are uncertain. See Part I, Item 1A, "Risk Factors - Market Risks - We continue to face risks and uncertainties related to the outbreak of COVID-19" for further discussion.

Merger of Equals between TCF and Chemical Financial Corporation

On August 1, 2019 (the "TCF/Chemical Merger Date"), TCF Financial Corporation, a Delaware corporation ("Legacy TCF"), merged with and into Chemical Financial Corporation, a Michigan corporation ("Chemical"), with Chemical surviving the merger (the "TCF/Chemical Merger") and being renamed TCF Financial Corporation. Immediately following the TCF/Chemical Merger, Chemical’s wholly owned bank subsidiary, Chemical Bank, a Michigan state-chartered bank, merged with and into TCF Bank, with TCF Bank surviving the TCF/Chemical Merger. Upon completion of the TCF/Chemical Merger, Chemical was renamed TCF Financial Corporation.

The TCF/Chemical Merger was accounted for as a reverse merger using the acquisition method of accounting, therefore, Legacy TCF was deemed the acquirer for financial reporting purposes, even though Chemical was the legal acquirer. Accordingly, Legacy TCF's historical financial statements are the historical financial statements of the combined company for all periods before the TCF/Chemical Merger Date. Our results of operations for the periods before August 1, 2019 reflect financial data of Legacy TCF, while periods after the TCF/Chemical Merger reflect financial data for the combined company. Accordingly, comparisons of our results for the year ended December 31, 2020 with those of prior periods may not be meaningful. The number of shares issued and outstanding, earnings per share, additional paid-in-capital, dividends paid and all references to share quantities of TCF have been retrospectively adjusted to reflect the equivalent number of shares issued in the TCF/Chemical Merger. See "Note 3. Business Combinations" of the Notes to Consolidated Financial Statements for further information.

Business Overview

Net interest income, the difference between interest income earned on loans and leases, investment securities and other earning assets (interest income) and interest paid on deposits and borrowings (interest expense), represented 74.9% of our total revenue for 2020, compared with 73.5% for 2019 and 68.9% for 2018. Net interest income can change significantly from period to period based on interest rates, customer prepayment patterns and the volume and mix of interest earning assets, noninterest-bearing deposits and interest-bearing liabilities. We manage the risk of changes in interest rates on our net interest income through TCF's Asset & Liability Committee ("ALCO") and through related interest rate risk monitoring and management policies. See "Part I, Item 1A. Risk Factors" and "Item 7A. Quantitative and Qualitative Disclosures about Market Risk" for further discussion.

Noninterest income is a significant source of our revenue and an important component of our results of operations. The significant components of noninterest income are leasing revenue, fees and service charges on deposit accounts, net gains on sales of loans and leases, card and ATM revenue, wealth management revenue and servicing fee revenue. Leasing revenue generates noninterest income primarily from operating and sales-type leases. Primary drivers of fees and service charges on deposit accounts include the number of customers we attract, the customers' level of engagement and the frequency with which the customer uses our solutions. Providing a wide range of consumer banking services is an integral component of our business philosophy. We sell loans, primarily secured by consumer real estate, which results in gains on sales, as well as servicing fee income. Primary drivers of gains on sales include our ability to originate loans, identify loan buyers and execute loan sales.

37

Table of Contents

Proposed Merger with Huntington Bancshares Incorporated

TCF and Huntington Bancshares Incorporated ("Huntington") have entered into an Agreement and Plan of Merger, dated as of December 13, 2020. Under the merger agreement, TCF will merge with and into Huntington, with Huntington continuing as the surviving entity. Immediately following the merger, TCF Bank will merge with and into The Huntington National Bank, with The Huntington National Bank as the surviving bank. The merger agreement was approved by the boards of directors of TCF and Huntington, and is subject to shareholder and regulatory approval and other customary closing conditions. The transaction is anticipated to close in the second quarter of 2021. The transaction is discussed in more detail in "Note 3. Business Combinations" of the Notes to Consolidated Financial Statements under Item 8 of this Annual Report. See Part I, Item 1A, "Risk Factors - Strategic Risks - We face risks and uncertainties related to our proposed merger with Huntington and Failure to complete our proposed merger with Huntington could negatively impact our business, financial results and stock price" for further discussion.

The following portions of this Management's Discussion and Analysis of Financial Condition and Results of Operations ("Management's Discussion and Analysis") focus in more detail on the results of operations for 2020, 2019 and 2018 and on information about TCF's financial condition, loan and lease portfolio, liquidity, funding resources, capital and other matters.

Critical Accounting Policies and Estimates

Our Consolidated Financial Statements are prepared in accordance with GAAP, Securities and Exchange Commission ("SEC") rules and interpretive releases and general practices within our industry. Application of these principles requires management to establish accounting policies and make estimates, assumptions and complex judgments that affect the amounts reported in our Consolidated Financial Statements and accompanying notes. The estimates, assumptions and judgments are based on historical experience and various assumptions that we believe to be reasonable as of the date of the financial statements; accordingly, as this information changes, our Consolidated Financial Statements could reflect different estimates, assumptions and judgments. Actual results could differ significantly from those estimates.

Certain accounting measurements inherently have a greater reliance on the use of estimates, assumptions and judgments and, as such, have a greater possibility of producing results that could be materially different than originally reported. We use third-party sources to assist us with developing certain estimates, assumptions and judgments regarding certain amounts reported in our Consolidated Financial Statements and accompanying notes. When using third-party sources, management remains responsible for complying with GAAP. To meet management's responsibilities, we have processes in place to develop an understanding of the third-party methodologies used and to design and implement internal controls.

We have identified the determination of the allowance for credit losses (loans and leases and unfunded lending commitments), accounting for business combinations (including fair value of acquired loans and leases and core deposit intangibles), and the evaluation of goodwill impairment to be the accounting areas that require the most subjective or complex judgments and, as such, could be most subject to revision as new or additional information becomes available or circumstances change, including overall changes in the economic climate and/or market interest rates. Therefore, we consider these to be critical accounting policies and estimates and discuss them directly with the Audit Committee of our Board of Directors.

See "Note 2. Summary of Significant Accounting Policies" of Notes to Consolidated Financial Statements for further discussion of our significant accounting policies.

38

Table of Contents

Allowance for Credit Losses

The allowance for credit losses ("ACL") represents management's estimate of current credit losses expected to be incurred in the loan and lease portfolios over the remaining expected life of each financial asset at the balance sheet date, including known or anticipated problem loans and leases, as well as for loans and leases which are not currently known to require specific allowances. The ACL includes the allowance for loan and lease losses ("ALLL") and a reserve for unfunded lending commitments ("RULC"). Determining the amount of the ACL is considered a critical accounting estimate because it requires significant judgment and the use of estimates related to the amounts and timing of expected future cash flows, adjustments for forward-looking information, estimates of losses based on measurement date credit risk characteristics and consideration of other qualitative factors, all of which may be susceptible to significant change.

Events that are not within our control, such as changes in economic conditions, could change and could cause the ACL to be overstated or understated. The amount of ACL is affected by net charge-offs or recoveries and the provision or benefit for credit losses charged to earnings, which increase or decrease the ACL.

The amount of the ACL significantly depends on management's estimates of key factors and assumptions affecting valuation, appraisals of collateral, evaluations of performance and status, the amounts and timing of future cash flows expected to be received, forecasts of future economic conditions and reversion periods. Such estimates, appraisals, evaluations, cash flows and forecasts may be subject to frequent adjustments due to changing economic prospects of borrowers, lessees, properties or economic conditions. These estimates are reviewed quarterly and adjustments, if necessary, are recorded in the provision for credit losses in the periods in which they become known.

See "Note 2. Summary of Significant Accounting Policies" and "Note 8. Allowance for Credit Losses and Credit Quality" of the Consolidated Financial Statements for additional disclosure regarding our ACL.

Accounting for Business Combinations

In determining the estimated fair value of assets acquired as part of the TCF/Chemical Merger, including the estimated fair value of acquired loans and leases and a core deposit intangible, management relied on a framework of internal controls in place to evaluate the relevance and reliability of key inputs and assumptions used in the fair value and to ensure the mathematical accuracy used to determine an appropriate fair value. Acquired loans and leases were valued using a discounted cash flow methodology with adjustments to contractual cash flows for probability of default, loss given default, market rates and prepayments speeds. Management based the assumptions used on historical data or available market information. The fair value of the core deposit intangible was estimated under the income approach based on discounted net cash flows. This estimate was determined by projecting net cash flow benefits derived from estimating costs to carry deposits compared to alternative funding costs, and includes key assumptions related to deposit interest rates, servicing costs, customer attrition rates, costs of alternative funding, discount rate, and net maintenance costs.

These assumptions were based on both internal data and available market information. Management reviewed the relevance and reliability of key valuation inputs used to support key assumptions. In cases where management utilized a third-party to assist with the valuation, management assessed the qualifications of the third-party and reviewed all outputs provided by the third-party for reasonableness. See "Note 3. Business Combinations" and "Note 2. Summary of Significant Accounting Policies" for further information.

Goodwill

Goodwill represents the excess of the purchase price of our business acquisitions and purchases of banking centers over the fair value of the net assets acquired. Goodwill is not amortized, but rather is tested by management annually in the fourth quarter for impairment, or more frequently if triggering events occur and indicate potential impairment, in accordance with ASC Topic 350-20, Goodwill (ASC 350-20). ASC 350-20 allows an entity to assess qualitative factors to determine whether it is more-likely-than-not that the fair value of a reporting unit is less than its carrying amount. ASC 350-20 also allows an entity to bypass the qualitative assessment approach and determine if goodwill is impaired utilizing a quantitative assessment approach.

39

Table of Contents

During each quarter of 2020 we evaluated if there were any goodwill impairment triggering events and whether it was more-likely-than-not that the fair value of any reporting unit was less than its carrying amount. We assessed economic conditions, including projections of the duration of current conditions and timing of a potential recovery; industry and market considerations; government intervention and regulatory updates; the impact of recent events to financial performance and cost factors of the reporting units including TCF/Chemical Merger synergies; the market price of our common stock and other relevant events. At the conclusion of each assessment, we determined that it was not more-likely-than-not that the fair value of each reporting unit was less than its carrying amount. During the fourth quarter we completed our annual impairment test, which did not indicate impairment for any reporting unit, nor were any reporting units at risk. If economic conditions deteriorate, or the pandemic’s effects prolong or worsen, it may be more-likely-than-not that the fair value of one or more of TCF's reporting units falls below its respective carrying amount and would need to be evaluated for impairment.

Results of Operations

Performance Summary We reported net income of $222.8 million for 2020, compared with $295.5 million for 2019 and $304.4 million for 2018. Merger-related expenses included in net income totaled $203.9 million for the year ended December 31, 2020 and $172.0 million for the year ended December 31, 2019. Notable items, on a pre-tax basis, for the year ended December 31, 2020, included $17.6 million of loan servicing rights impairment, $14.2 million of gains on sales of branches, net of expense related to branch exit costs and $4.0 million of expense related to the sale of the Legacy TCF auto finance portfolio. Notable items, on a pre-tax basis, for the year ended December 31, 2019, included a $32.1 million loss on sale and expenses related to the Legacy TCF auto finance portfolio, a $17.3 million loss on termination of interest rate swaps, $9.4 million of expense associated with the write-down of company-owned vacant land parcels due to an intent to sell and branch exit costs, $6.3 million of expense related to pension fair valuation adjustment on plans with previously announced terminations, and $3.9 million of loan servicing rights impairment, partially offset by $5.9 million of gain on sales of certain investment securities. The year ended December 31, 2019, also included $11.8 million of tax basis adjustment benefits considered a notable item. For the year ended December 31, 2018, net income included a $32.0 million pre-tax charge related to the settlement to resolve certain matters with the Consumer Financial Protection Bureau (the "CFPB") and Office of the Comptroller of the Currency (the "OCC") considered a notable item. Adjusted net income, a non-GAAP financial measure that excludes merger-related expenses and the identified notable items, net of tax, was $389.5 million for the year ended December 31, 2020, compared to $461.2 million for 2019 and $329.9 million for 2018. See "Non-GAAP Financial Measures" in this Management's Discussion and Analysis for further information.

We reported diluted earnings per common share of $1.40 for 2020, compared with $2.55 for 2019 and $3.43 for 2018. Adjusted diluted earnings per common share, a non-GAAP financial measure that excludes merger-related expenses and the identified notable items, was $2.50 for the year ended December 31, 2020, compared to $4.04 for 2019 and $3.73 for 2018. See "Non-GAAP Financial Measures" in this Management's Discussion and Analysis for further information.

The following table provides our financial ratios and adjusted ratios (non-GAAP), which exclude merger-related expenses and the identified notable items.

Summary of Financial Ratios
	Year Ended December 31,						Change From
	2020		2019		2018		2020/
							2019
Return on average assets ("ROAA")	0.48	%	0.92	%	1.37	%	(44)	bps
Return on average common equity ("ROACE")	3.88		7.67		12.42		(379)
Return on average tangible common equity ("ROATCE')(1)	5.73		9.81		13.56		(408)
Efficiency ratio	74.34		75.92		69.34		(158)
Adjusted Financial Results (non-GAAP)
Adjusted ROAA(1)	0.82	%	1.41	%	1.48	%	(59)	bps
Adjusted ROACE(1)	6.92		12.13		13.51		(521)
Adjusted ROATCE(1)	9.88		15.34		14.74		(546)
Adjusted efficiency ratio(1)	60.95		60.58		64.77		37

(1)See section entitled "Non-GAAP Financial Measures" in this Management's Discussion and Analysis for further information.

40

Table of Contents

Consolidated Results of Operations Analysis

Net Interest Income  Net interest income was $1.5 billion for 2020, compared with $1.3 billion for 2019 and $1.0 billion for 2018. Net interest income, our largest source of revenue (revenue is comprised of net interest income and noninterest income), represented 74.9% of our total revenue for 2020, compared with 73.5% for 2019 and 68.9% for 2018. The increases in net interest income in 2020, compared to 2019, as well as 2019, compared to 2018, was primarily attributable to the increase in interest-earning assets acquired in the TCF/Chemical Merger, partially offset by the increase in interest-bearing liabilities acquired in the TCF/Chemical Merger.

Purchase accounting accretion and amortization included in net interest income was $84.2 million for 2020, compared to $58.9 million for 2019. At December 31, 2020, the remaining fair value discount from purchase accounting on acquired loans totaled $108.1 million. Additionally, 2020 net interest income recorded included $43.4 million of interest and fee income from PPP loans less funding costs. Fully taxable equivalent ("FTE") adjustments to net interest income totaled $12.1 million for 2020, compared to $8.4 million for 2019 and $3.6 million for 2018. Adjusted net interest income, including FTE adjustments and excluding purchase accounting accretion and amortization and the impact from PPP loans, a non-GAAP financial measure, was $1.4 billion for 2020, compared to $1.2 billion for 2019 and $1.0 billion for 2018. See "Non-GAAP Financial Measures" in this Management's Discussion and Analysis for further information. Net interest income (FTE), a non-GAAP financial measure, was $1.6 billion for 2020, compared with $1.3 billion for 2019 and $1.0 billion for 2018. Net interest income (FTE), a non-GAAP financial measure, is the difference between interest income and interest expense adjusted for the tax benefit received on tax-exempt loans, leases and investment securities. The presentation of net interest income (FTE) is not in accordance with GAAP but is customary in the banking industry. For further information on the calculation of net interest income (FTE), see the tables below.

Net interest margin was 3.47% for 2020, compared to 4.17% for 2019 and 4.66% for 2018. Net interest margin (FTE), a non-GAAP financial measure, is calculated by dividing net interest income (FTE) by average interest-earning assets, expressed as a percentage. Net interest income and net interest margin are affected by (i) changes in prevailing short- and long-term interest rates, (ii) loan, lease and deposit pricing strategies and competitive conditions, (iii) the volume and mix of interest-earning assets, noninterest-bearing deposits and interest-bearing liabilities, (iv) the level of nonaccrual loans and leases and other real estate owned and (v) the impact of modified loans and leases. Net interest margin (FTE) was 3.50% for 2020, compared with 4.20% for 2019 and 4.69% for 2018. The decrease in both net interest margin and net interest margin (FTE) for the year ended December 31, 2020, compared to 2019, was primarily due to a decrease in the yield earned on loans and leases as result of the lower average yields added to the portfolio through the TCF/Chemical Merger in addition to the impact of the Federal Reserve's rate cuts and higher cash balances, partially offset by lower cost of funds. The decrease in both net interest margin and net interest margin (FTE) for the year ended December 31, 2019, compared to 2018, was primarily driven by a decrease in loan and lease yields due to the impact of the lower overall yield earned on loans and leases we acquired through the TCF/Chemical Merger, the impact of the Federal Reserve's interest rate cuts on our variable-rate loans and an increase in our cost of funds. The presentation of net interest margin (FTE) is not in accordance with GAAP but is customary in the banking industry. For further information on the calculation of net interest income (FTE), see the tables below.

The following tables present the average balances of our major categories of assets and liabilities, interest income and expense (FTE), average interest rates earned and paid on assets and liabilities, net interest income (FTE), net interest spread and net interest margin for the years ended December 31, 2020, 2019 and 2018. The presentation of net interest income (FTE) is not in accordance with GAAP but is customary in the banking industry and ensures comparability of net interest income arising from both taxable and tax-exempt loans and investment securities.

41

Table of Contents

	Year Ended December 31,
	2020						2019						Change
(Dollars in thousands)	Average Balance		Interest		Yields and Rates		Average Balance		Interest		Yields and Rates		Average Balance		Interest		Yields and Rates (bps)
Assets:
Federal Home Loan Bank and Federal Reserve Bank stocks	$	379,482	$	13,356	3.52	%	$	210,001	$	6,030	2.87	%	$	169,481	$	7,326	65
Investment securities held-to-maturity	141,604		1,842		1.30		144,318		2,950		2.04		(2,714)		(1,108)		(74)
Investment securities available-for-sale:
Taxable	6,050,684		142,620		2.36		3,516,413		103,077		2.93		2,534,271		39,543		(57)
Tax-exempt(1)(2)	713,658		20,470		2.87		541,525		14,746		2.72		172,133		5,724		15
Loans and leases held-for-sale	351,898		11,394		3.24		336,292		18,599		5.53		15,606		(7,205)		(229)
Loans and leases(1)(2)(3)
Commercial and industrial	11,924,867		559,783		4.66		8,371,066		519,506		6.18		3,553,801		40,277		(152)
Commercial real estate	9,547,701		405,173		4.17		5,523,347		298,414		5.33		4,024,354		106,759		(116)
Lease financing	2,693,493		133,272		4.95		2,570,109		131,547		5.12		123,384		1,725		(17)
Residential mortgage	6,053,036		233,723		3.86		3,902,959		170,706		4.37		2,150,077		63,017		(51)
Home equity	3,405,718		179,628		5.27		3,272,760		101,687		5.51		132,958		77,941		(24)
Consumer installment	1,412,510		71,392		5.05		1,844,714		214,116		6.54		(432,204)		(142,724)		(149)
Total loans and leases	35,037,325		1,582,971		4.49		25,484,955		1,435,976		5.61		9,552,370		146,995		(112)
Interest-bearing deposits with banks and other	1,352,825		5,096		0.38		534,979		14,326		2.66		817,846		(9,230)		(228)
Total interest-earning assets	44,027,476		1,777,749		4.01		30,768,483		1,595,704		5.17		13,258,993		182,045		(116)
Other assets	4,373,462						2,758,447						1,615,015
Total assets	$	48,400,938					$	33,526,930					$	14,874,008
Liabilities and Equity:
Noninterest-bearing deposits	$	9,844,485					$	5,622,092					$	4,222,393
Interest-bearing deposits:
Savings	9,093,600		28,408		0.31		7,203,987		52,087		0.72		1,889,613		(23,679)		(41)
Certificates of deposit	6,812,648		89,835		1.32		6,086,251		122,494		2.01		726,397		(32,659)		(69)
Checking	6,676,803		11,947		0.18		3,920,613		13,961		0.36		2,756,190		(2,014)		(18)
Money market	5,289,371		36,796		0.70		2,729,156		37,615		1.38		2,560,215		(819)		(68)
Total interest-bearing deposits	27,872,422		166,986		0.60		19,940,007		226,157		1.13		7,932,415		(59,171)		(53)
Total deposits	37,716,907		166,986		0.44		25,562,099		226,157		0.88		12,154,808		(59,171)		(44)
Borrowings:
Short-term borrowings	2,023,374		17,279		0.84		1,279,073		20,836		1.61		744,301		(3,557)		(77)
Long-term borrowings	1,459,004		42,996		2.93		1,592,915		51,236		3.19		(133,911)		(8,240)		(26)
Total borrowings	3,482,378		60,275		1.72		2,871,988		72,072		2.49		610,390		(11,797)		(77)
Total interest-bearing liabilities	31,354,800		227,261		0.72		22,811,995		298,229		1.30		8,542,805		(70,968)		(58)
Total deposits and borrowings	41,199,285		227,261		0.55		28,434,087		298,229		1.05		12,765,198		(70,968)		(50)
Other liabilities	1,528,080						1,177,805						350,275
Total liabilities	42,727,365						29,611,892						13,115,473
Total TCF Financial Corp. shareholders' equity	5,649,567						3,889,204						1,760,363
Non-controlling interest in subsidiaries	24,006						25,834						(1,828)
Total equity	5,673,573						3,915,038						1,758,535
Total liabilities and equity	$	48,400,938					$	33,526,930					$	14,874,008
Net interest spread (FTE)					3.46						4.12						(66)
Net interest income (FTE) and net interest margin (FTE)			$	1,550,488	3.50				$	1,297,475	4.20	%			$	253,013	(70)
Reconciliation of Net Interest Income (FTE) and Net Interest Margin (FTE)
Net interest income and net interest margin (GAAP)			$	1,538,401	3.47	%			$	1,289,032	4.17	%			$	249,369	(70)
Adjustments for taxable equivalent interest
Loans and leases(1)(3)			7,785						5,348						2,437
Tax-exempt investment securities(1)(3)			4,302						3,095						1,207
Total FTE adjustments			12,087						8,443						3,644
Net interest income (FTE) and net interest margin (FTE)			$	1,550,488	3.50	%			$	1,297,475	4.20	%			$	253,013	(70)

(1)Interest and yields are presented on a FTE basis.

(2)The yield on tax-exempt loans, leases and available-for-sale investment securities is computed on a FTE basis using a statutory federal income tax rate of 21%.

(3)Average balances of loans and leases include nonaccrual loans and leases and are presented net of unearned income

42

Table of Contents

	Year Ended December 31,
	2019						2018						Change
(Dollars in thousands)	Average Balance		Interest		Yields and Rates		Average Balance		Interest		Yields and Rates		Average Balance		Interest		Yields and Rates (bps)
Assets:
Federal Home Loan Bank and Federal Reserve Bank stocks	$	210,001	$	6,030	2.87	%	$	89,774	$	3,618	4.03	%	$	120,227	$	2,412	(116)
Investment securities held-to-maturity	144,318		2,950		2.04		154,619		3,970		2.57		(10,301)		(1,020)		(53)
Investment securities available-for-sale:
Taxable	3,516,413		103,077		2.93		1,390,016		37,436		2.69		2,126,397		65,641		24
Tax-exempt(1)(2)	541,525		14,746		2.72		815,540		21,694		2.66		(274,015)		(6,948)		6
Loans and leases held-for-sale	336,292		18,599		5.53		103,240		6,686		6.48		233,052		11,913		(95)
Loans and leases(1)(2)(3)
Commercial and industrial	8,371,066		519,506		6.18		6,171,331		386,541		6.25		2,199,735		132,965		(7.00)
Commercial real estate	5,523,347		298,414		5.33		2,799,523		135,791		4.78		2,723,824		162,623		55.00
Lease financing	2,570,109		131,547		5.12		2,459,823		125,185		5.09		110,286		6,362		3.00
Residential mortgage	3,902,959		170,706		4.37		1,788,729		95,375		5.33		2,114,230		75,331		(96.00)
Home equity	3,272,760		101,687		5.51		2,579,271		142,700		5.53		693,489		(41,013)		(2.00)
Consumer installment	1,844,714		214,116		6.54		3,028,370		200,356		6.62		(1,183,656)		13,760		(8.00)
Total loans and leases	25,484,955		1,435,976		5.61		18,827,047		1,085,948		5.75		6,657,908		350,028		(14.00)
Interest-bearing deposits with banks and other	534,979		14,326		2.66		229,698		8,346		3.63		305,281		5,980		(97)
Total interest-earning assets	30,768,483		1,595,704		5.17		21,609,934		1,167,698		5.39		9,158,549		428,006		(22)
Other assets	2,758,447						1,452,214						1,306,233
Total assets	$	33,526,930					$	23,062,148					$	10,464,782
Liabilities and Equity:
Noninterest-bearing deposits	$	5,622,092					$	3,843,494					$	1,778,598
Interest-bearing deposits:
Savings	7,203,987		52,087		0.72		5,621,723		20,009		0.36		1,582,264		32,078		36
Certificates of deposit	6,086,251		122,494		2.01		4,897,937		75,385		1.54		1,188,314		47,109		47
Checking	3,920,613		13,961		0.36		2,438,040		714		0.03		1,482,573		13,247		33
Money market	2,729,156		37,615		1.38		1,553,255		11,582		0.75		1,175,901		26,033		63
Total interest-bearing deposits	19,940,007		226,157		1.13		14,510,955		107,690		0.74		5,429,052		118,467		39
Total deposits	25,562,099		226,157		0.88		18,354,449		107,690		0.59		7,207,650		118,467		29
Borrowings:
Short-term borrowings	1,279,073		20,836		1.61		3,288		77		2.33		1,275,785		20,759		(72)
Long-term borrowings	1,592,915		51,236		3.19		1,412,186		43,067		3.03		180,729		8,169		16
Total borrowings	2,871,988		72,072		2.49		1,415,474		43,144		3.02		1,456,514		28,928		(53)
Total interest-bearing liabilities	22,811,995		298,229		1.30		15,926,429		150,834		0.94		6,885,566		147,395		36
Total deposits and borrowings	28,434,087		298,229		1.05		19,769,923		150,834		0.76		8,664,164		147,395		29
Accrued expenses and other liabilities	1,177,805						761,723						416,082
Total liabilities	29,611,892						20,531,646						9,080,246
Total TCF Financial Corp. shareholders' equity	3,889,204						2,506,179						1,383,025
Non-controlling interest in subsidiaries	25,834						24,323						1,511
Total equity	3,915,038						2,530,502						1,384,536
Total liabilities and equity	$	33,526,930					$	23,062,148					$	10,464,782
Net interest spread (FTE)					4.12						4.63						(51)
Net interest income (FTE) and net interest margin (FTE)			$	1,297,475	4.20	%			$	1,016,864	4.69				$	280,611	(49)
Reconciliation of Net Interest Income (FTE) and Net Interest Margin (FTE)
Net interest income and net interest margin (GAAP)			$	1,289,032	4.17	%			$	1,008,495	4.66	%			$	280,537	(49)
Adjustments for taxable equivalent interest
Loans and leases(1)(3)			5,348						3,813						1,535
Tax-exempt investment securities(1)(3)			3,095						4,556						(1,461)
Total FTE adjustments			8,443						8,369						74
Net interest income (FTE) and net interest margin (FTE)			$	1,297,475	4.20	%			$	1,016,864	4.69	%			$	280,611	(49)

(1)Interest and yields are presented on a FTE basis.

(2)The yield on tax-exempt loans, leases and available-for-sale investment securities is computed on a FTE basis using a statutory federal income tax rate of 21%.

(3)Average balances of loans and leases include nonaccrual loans and leases and are presented net of unearned income.

43

Table of Contents

Volume and Rate Variance Analysis

	Year Ended December 31, 2020 vs. 2019						Year Ended December 31, 2019 vs. 2018
	Increase (Decrease) Due to Changes in						Increase (Decrease) Due to Changes in
(Dollars in thousands)	Average Volume		Average Yield/Rate		Total Change		Average Volume		Average Yield/Rate		Total Change
Changes in Interest Income on Interest-Earning Assets:
Federal Home Loan Bank and Federal Reserve Bank stocks	$	5,699	$	1,627	$	7,326	$	3,699	$	(1,287)	$	2,412
Investment securities held-to-maturity	(54)		(1,054)		(1,108)		(251)		(769)		(1,020)
Investment securities available-for-sale:
Taxable	62,845		(23,302)		39,543		62,055		3,586		65,641
Tax-exempt(1)	4,901		823		5,724		(7,450)		502		(6,948)
Loans and leases held-for-sale	827		(8,032)		(7,205)		13,023		(1,110)		11,913
Loans and leases(1)	471,293		(324,298)		146,995		377,736		(27,708)		350,028
Interest-bearing deposits with banks and other	9,813		(19,043)		(9,230)		8,746		(2,766)		5,980
Total interest-earning assets	$	555,324	$	(373,279)	$	182,045	$	457,558	$	(29,552)	$	428,006
Changes in Interest Expense on Interest-Bearing Liabilities:
Interest-bearing deposits:
Savings	11,186		(34,865)		(23,679)		6,877		25,201		32,078
Certificates of deposit	13,241		(45,900)		(32,659)		20,769		26,340		47,109
Checking	$	6,936	$	(8,950)	(2,014)		$	684	$	12,563	13,247
Money market	23,783		(24,602)		(819)		12,275		13,758		26,033
Interest-bearing deposits	55,146		(114,317)		(59,171)		40,605		77,862		118,467
Short-term borrowings	8,993		(12,550)		(3,557)		20,791		(32)		20,759
Long-term borrowings	(4,176)		(4,064)		(8,240)		5,721		2,448		8,169
Total interest-bearing liabilities	$	59,963	$	(130,931)	$	(70,968)	$	67,117	$	80,278	$	147,395
Total change in net interest income (FTE)(2)	$	495,361	$	(242,348)	$	253,013	$	390,441	$	(109,830)	$	280,611

(1)Changes attributable to the combined impact of volume and rate have been allocated proportionately to the change due to volume and the change due to rate.

(2)Computed on a FTE basis using a federal income tax rate of 21%.

Provision for Credit Losses  The provision for credit losses was $257.2 million for 2020, compared with $65.3 million for 2019 and $46.8 million for 2018. The provision for credit losses is comprised of the provision for credit losses related to loans and leases and the provision (benefit) for credit losses related unfunded lending commitments as follows:

	Year Ended December 31,
(In thousands)	2020		2019		2018
Provision for credit losses
Provision for credit losses related to loans and leases	$	252,073	$	65,282	$	46,768
Provision (benefit) for credit losses related to unfunded lending commitments(1)	5,078		233		(51)
Total provision for credit losses(1)	$	257,151	$	65,515	$	46,717

(1)Provision for credit losses related to loans and leases and the provision (benefit) for credit losses related to unfunded lending commitments are included within provision for credit losses in the Consolidated Statements of Income beginning January 1, 2020 as a result of the adoption of CECL.

44

Table of Contents

The increase in provision for credit losses related to loans and leases of $186.8 million in 2020, compared to 2019, reflects a build to the overall allowance for loans and leases primarily due to the impact of COVID-19 and additionally impacted by the adoption of CECL. During 2020, the COVID-19 pandemic had a negative impact on current and forecasted macroeconomic conditions and created uncertainty around the performance of certain sectors that have been more heavily impacted, including motor coach, shuttle bus, hotel, retail commercial real estate, franchise, retail trade and fitness. Prior to the adoption of CECL on January 1, 2020, the allowance for credit losses was calculated under an incurred loss model which delayed recognition of loss until it was probable the loss had been incurred. The accounting under CECL considers current credit losses expected to be incurred in the loan and lease portfolios over the remaining expected life of each financial asset and considers expected future changes in macroeconomic conditions. In addition, as a result of the adoption of CECL, the provision for credit losses now includes the provision (benefit) for unfunded lending commitments that was previously included within other noninterest expense. The increase in provision for credit losses in 2019, compared to 2018, was primarily due to an increase in originated loan growth driven by increased activity in the loan and lease portfolio as a result of the TCF/Chemical Merger, and to a lesser extent, an increase in commercial and industrial net charge-offs, primarily due to one loan relationship, and a decrease in recoveries on previous charge-offs related to sales of consumer nonaccrual and TDR loans. The increase in provision for credit losses related to unfunded lending commitments of $4.8 million in 2020, compared to 2019, was primarily due to macroeconomic conditions impacted by the COVID-19 pandemic, partially offset by a decline in the total unfunded commitment balance. The provision for credit losses is predominantly a function of our reserving methodology used to determine the appropriate level of the allowance for credit losses, which is a critical accounting estimate.

For further information, see "Consolidated Financial Condition Analysis — Credit Quality" in this Management's Discussion and Analysis and "Note 8. Allowance for Credit Losses and Credit Quality" of Notes to Consolidated Financial Statements.

Noninterest Income  The components of noninterest income were as follows:

	Year Ended December 31,									Change
										2020 / 2019				2019 / 2018
(Dollars in thousands)	2020			2019			2018			$		% / bps		$		% / bps
Leasing revenue	$	142,723		$	163,718		$	172,603		$	(20,995)	(12.8)	%	$	(8,885)	(5.1)	%
Fees and service charges on deposit accounts	112,681			127,860			113,242			(15,179)		(11.9)		14,618		12.9
Card and ATM revenue	88,699			87,221			78,406			1,478		1.7		8,815		11.2
Net gains on sales of loans and leases	86,776			26,308			33,695			60,468		N.M.		(7,387)		(21.9)
Wealth management revenue	25,701			10,413			—			15,288		146.8		10,413		N.M.
Servicing fee revenue	10,603			20,776			27,334			(10,173)		(49.0)		(6,558)		(24.0)
Net gains on investment securities	2,338			7,425			348			(5,087)		(68.5)		7,077		N.M.
Other	46,542			21,811			28,769			24,731		113.4		(6,958)		(24.2)
Total noninterest income	$	516,063		$	465,532		$	454,397		$	50,531	10.9		$	11,135	2.5
Total noninterest income as a percentage of total revenue	25.1		%	26.5		%	31.1		%			-140 bps				-460 bps

N.M. Not Meaningful

Noninterest income was $516.1 million for 2020, compared to $465.5 million for 2019 and $454.4 million for 2018. Noninterest income for the year ended December 31, 2020 included notable items of $17.6 million of loan servicing rights impairment and a $14.7 million gain on the sale of our Arizona branches, and for the year ended December 31, 2019 notable items included a $27.5 million net loss on sale of the Legacy TCF auto finance portfolio, a $17.3 million loss on termination of interest rate swaps and $3.9 million of loan servicing rights impairment, and $5.9 million of gains on sales of certain investment securities. Adjusted noninterest income, a non-GAAP financial measure that excludes the identified notable items, was $519.0 million for 2020, compared to $508.3 million for 2019 and $454.4 million for 2018. See "Non-GAAP Financial Measures" in this Management's Discussion and Analysis for further information.

Leasing revenue Leasing revenue was $142.7 million for 2020, compared with $163.7 million for 2019 and $172.6 million for 2018. Leasing revenue is impacted by changes in our operating lease revenue and sales-type lease revenue through our equipment financing activity. The decrease in leasing revenue for 2020, compared to 2019 was primarily due to a decrease in sales-type lease revenue through our equipment financing activity impacted by the COVID-19 pandemic.

45

Table of Contents

Fees and service charges on deposit accounts Fees and service charges on deposit accounts were $112.7 million for 2020, compared with $127.9 million for 2019 and $113.2 million for 2018. The decrease in 2020, compared to 2019, was primarily attributable to customer account balances maintaining excess liquidity through the COVID-19 pandemic resulting in a decline in fees charged, partially offset by incremental fees resulting from the TCF/Chemical Merger. The increase in 2019, compared to 2018, was primarily attributable to incremental fees resulting from the TCF/Chemical Merger.

Card and ATM revenue Card and ATM revenue was $88.7 million for 2020, compared with $87.2 million for 2019 and $78.4 million for 2018. The increase in 2020, compared to 2019, was primarily attributable to incremental revenue resulting from the TCF/Chemical Merger, partially offset by the decline in debit card and ATM activity related to the COVID-19 pandemic. The increase in 2019, compared to 2018, was primarily due to incremental revenue resulting from the TCF/Chemical Merger.

Net gains on sales of loans and leases  Net gains on sales of loans and leases were $86.8 million for 2020, compared with $26.3 million for 2019 and $33.7 million for 2018. The increase in 2020, compared to 2019, was primarily due the higher volume of consumer loans sold resulting from the TCF/Chemical Merger and the $27.5 million loss related to the sale of the Legacy TCF auto finance portfolio during 2019. The decrease in 2019 from 2018 was primarily due to the $27.5 million loss related to the sale of the Legacy TCF auto finance portfolio, partially offset by the higher volume of consumer loans sold resulting from the TCF/Chemical Merger and the recognition of a $3.7 million gain on sale of loans and leases related to a nonaccrual and TDR loan sale. We sold $2.4 billion of loans and leases in 2020, compared with $2.9 billion in 2019, or $1.8 billion excluding the sale of the Legacy TCF auto finance portfolio, and $1.2 billion in 2018.

Wealth management Wealth management revenue is comprised of investment fees that are generally based on the market value of assets within a trust account, custodial fees and fees from the sale of investment products and is a revenue stream added as a result of the TCF/Chemical Merger. Revenues from wealth management were $25.7 million for 2020, compared with $10.4 million for 2019. The increase in 2020, compared to 2019, was primarily attributable to it being a new revenue stream as a result of the TCF/Chemical Merger.

Servicing fee revenue  Servicing fee revenue was $10.6 million for 2020, compared with $20.8 million for 2019 and $27.3 million for 2018. The decreases in 2020, compared to 2019, and in 2019, compared to 2018, were primarily due to the continued run-off in the auto finance serviced for others portfolio, partially offset by revenue added as a result of the servicing portfolio acquired in the TCF/Chemical Merger.

Net gains on investment securities Net gains on investment securities were $2.3 million for 2020, compared to $7.4 million for 2019 and $348 thousand for 2018. Net gains on investment securities decreased in 2020, compared to 2019 due to lower sales activity and increased in 2019, compared to 2018, due to increased sales activity. In 2019, we sold $1.6 billion of investment securities as a result of balance sheet repositioning following the TCF/Chemical Merger resulting in $5.9 million of net gains.

Other Other noninterest income was $46.5 million for 2020, compared to $21.8 million for 2019 and $28.8 million for 2018. The increase in 2020, compared to 2019, was primarily due to the $17.3 million loss on termination of interest rate swaps recognized in 2019 and the $14.7 million gain on the sale of our Arizona branches recognized in 2020, partially offset by an increase in loan servicing rights impairment. The increase in 2019, compared to 2018, was primarily due to a $17.3 million loss related to the termination of interest rate swaps and the recognition of $3.9 million of loan servicing rights impairment, partially offset by an increase in incremental revenue resulting from the TCF/Chemical Merger.

46

Table of Contents

Noninterest Expense  The components of noninterest expense were as follows:

	Year Ended December 31,									Change
										2020 / 2019				2019 / 2018
(Dollars in thousands)	2020			2019			2018			$		% / bps		$		% / bps
Compensation and employee benefits	$	702,702		$	576,922		$	502,196		$	125,780	21.8	%	$	74,726	14.9	%
Occupancy and equipment	209,690			189,560			165,839			20,130		10.6		23,721		14.3
Lease financing equipment depreciation	73,204			76,426			73,829			(3,222)		(4.2)		2,597		3.5
Net foreclosed real estate and repossessed assets	5,136			13,523			17,050			(8,387)		(62.0)		(3,527)		(20.7)
Merger-related expenses	203,888			171,968			—			31,920		18.6		171,968		N.M.
Other	332,751			303,716			255,486			29,035		9.6		48,230		18.9
Total noninterest expense	$	1,527,371		$	1,332,115		$	1,014,400		$	195,256	14.7		$	317,715	31.3
Full-time equivalent staff (at period end)	6,881			7,762			5,278			(881)		(11.4)		2,484		47.1
Efficiency ratio	74.34		%	75.92		%	69.34		%			(158) bps				658 bps
Adjusted efficiency ratio (non-GAAP)(1)	60.95			60.58			64.77					37				(419)

N.M. Not Meaningful

(1)See "Consolidated Financial Condition Analysis - Non-GAAP Financial Measures" in this Management's Discussion and Analysis for further information.

Noninterest expense was $1.5 billion for 2020, compared to $1.3 billion for 2019 and $1.0 billion for 2018. Noninterest expense included merger-related expenses of $203.9 million in 2020 and $172.0 million in 2019. Noninterest expense for 2020 included $4.0 million of expenses related to the sale of the Legacy TCF auto finance portfolio ($1.6 million included in occupancy and equipment, $1.4 million included in other noninterest expense and $1.0 million included in compensation and employee benefits) and $0.6 million of expense related to branch exit costs, included in other noninterest expense, considered notable items. Noninterest expense for 2019 included $9.4 million of expense associated with the write-down of company-owned vacant land parcels and branch exit costs, included in other noninterest expense, and $4.7 million of expenses related to the sale of the Legacy TCF auto finance portfolio ($2.2 million included in other noninterest expense, $1.5 million included in occupancy and equipment and $930 thousand included in compensation and employee benefits) and $6.3 million of expense related to a pension fair value adjustment on plans with previously announced terminations, included in other noninterest expense, considered notable items. Noninterest expense for 2018 included a $32.0 million charge related to the settlement with the CFPB and the OCC, included in other noninterest expense, considered a notable item. Adjusted noninterest expense, a non-GAAP financial measure that excludes merger-related expenses and the identified notable items, was $1.3 billion for 2020, compared to $1.1 billion for 2019 and $982.4 million for 2018. During 2020 we achieved our committed merger expense synergies on schedule while completing our integration activities by our target delivery date. See "Non-GAAP Financial Measures" in this Management's Discussion and Analysis for further information.

Compensation and employee benefits Compensation and employee benefits expense was $702.7 million for 2020, compared with $576.9 million for 2019 and $502.2 million for 2018. The increase in 2020, compared to 2019, was primarily due to the staff additions beginning August 1, 2019 resulting from the TCF/Chemical Merger. In 2020, compensation and employee benefits expense also included $21.6 million of executive severance expense and $1.0 million of expense related to the sale of the Legacy TCF auto finance portfolio. The increase in 2019, compared to 2018, was primarily due to the staff additions resulting from the TCF/Chemical Merger. In 2019, compensation and employee benefits expense also included $930 thousand of expense related to the sale of the Legacy TCF auto finance portfolio.

Occupancy and equipment Occupancy and equipment expense was $209.7 million for 2020, compared with $189.6 million for 2019 and $165.8 million for 2018. The increase in 2020, compared to 2019, was primarily due to the incremental operating costs associated with the TCF/Chemical Merger in addition to expenses related to COVID-19 safety protocols. The increase in 2019, compared to 2018, was primarily due to the incremental operating costs associated with the TCF/Chemical Merger in addition to $1.5 million of expense related to the sale of the Legacy TCF auto finance portfolio. Depreciation and amortization expense related to premises and equipment was $76.0 million, $75.3 million and $48.6 million for 2020, 2019 and 2018, respectively.

Lease financing equipment depreciation Lease financing equipment depreciation was $73.2 million for 2020, compared with $76.4 million for 2019 and $73.8 million for 2018. Shifts in lease financing equipment depreciation are the result of changes in balances of leased equipment.

47

Table of Contents

Net foreclosed real estate and repossessed assets  Net foreclosed real estate and repossessed assets expense was $5.1 million for 2020, compared with $13.5 million for 2019 and $17.1 million for 2018. The decrease in 2020, compared to 2019, was primarily due to a decrease in repossessed asset expense, partially offset by a reduction in gains on sales of repossessed assets. The decrease in 2019, compared to 2018, was primarily due to an increase in gains on sales of repossessed assets.

Merger-related expenses Merger-related expenses were $203.9 million for 2020, compared to $172.0 million for 2019. Merger-related expenses consisted primarily of employment related expenses, professional fees and merger-related branch closing expenses. Merger-related expenses for 2020 included $5.2 million related to our pending merger with Huntington, while the remainder of merger-related expenses in 2020 and all in 2019 related to the TCF/Chemical Merger. We had no merger-related expense in 2018.

Other noninterest expense Other noninterest expense was $332.8 million for 2020, compared with $303.7 million for 2019 and $255.5 million for 2018. The increase in 2020, compared to 2019, was primarily due to incremental costs associated with the TCF/Chemical Merger. Other noninterest expense for 2020 also included $7.0 million of impairment, or $5.6 million after tax, of historic tax credits placed into service, which is offset by income tax benefit within income tax expense related to the same tax credits. The increase in 2019, compared to 2018, was primarily due to incremental costs associated with the TCF/Chemical Merger and notable items including: $9.4 million of expense related to write-downs of company-owned vacant land parcels and branch exit costs, $6.3 million of expense related to pension fair value adjustments on plans with previously announced terminations and $2.2 million of expense related to the sale of the Legacy TCF auto finance portfolio, partially offset by the settlement with the CFPB and the OCC of $32.0 million that was recognized in 2018. Other noninterest expense for 2019 also included a $4.0 million impairment, or $3.2 million after tax, of historic tax credits placed into service. See "Note 25. Other Noninterest Income and Expense" of Notes to Consolidated Financial Statements for further information.

Income Taxes  Income tax expense was $39.9 million, or 14.8% of income before income tax expense, for 2020, compared with $50.2 million, or 14.1%, for 2019 and $86.1 million, or 21.4%, for 2018. The decrease in income tax expense for 2020, compared to 2019, was primarily due to a decrease in pre-tax income. Income tax expense for 2020 included a benefit of $16.0 million attributable to tax net operating loss ("NOL") carryback benefits associated with the Coronavirus Aid, Relief and Economic Security (“CARES" Act). The $16.0 million benefit included a $9.0 million benefit associated with pre-2020 depreciation method changes and a $7.0 million benefit related to estimated current year activity. The decrease in income tax expense for 2019, compared to 2018, was primarily due to the inclusion of $11.8 million of tax basis adjustment benefits, a $5.7 million benefit provided by the repricing of our net deferred tax position in connection with the completion of the TCF/Chemical Merger and a $4.6 million income tax benefit related to federal historic tax credits. The remaining fluctuations in our effective income tax rate reflect changes for each period in the proportion of tax-exempt interest income, nondeductible expenses and credits relative to income before income tax expense. See "Note 2. Summary of Significant Accounting Policies" and "Note 26. Income Taxes" of Notes to Consolidated Financial Statements for further information.

The CARES Act was enacted in March 2020 in response to the COVID-19 pandemic. The CARES Act, among other things, permits NOLs from 2018, 2019 and 2020 to be carried back five years to generate refunds of previously paid income taxes. Additionally, it provides retroactive changes in depreciation rules for certain qualified improvement property. Guidance implementing the CARES Act’s provisions provided retroactive choices to opt into or out of the full expensing of equipment purchases in the year of acquisition. During 2020, we implemented these and other options provided by the CARES Act, which resulted in a forecasted full year 2020 federal tax NOL. Carrying back 2020 federal tax NOLs to pre-2018 years results in tax refunds and a permanent tax benefit associated with the difference between the 21% federal tax rate in 2020 and the 35% federal tax rate before 2018.

Reportable Segment Results Our reportable segments are Consumer Banking, Commercial Banking and Enterprise Services. See "Note 27. Reportable Segments" of Notes to Consolidated Financial Statements for further information regarding net income (loss), revenues and assets for each of our reportable segments.

48

Table of Contents

Consumer Banking

Consumer Banking is comprised of all of our consumer and small business-facing businesses and includes Retail Banking, Wealth Management, Residential and Consumer Lending, and Business Banking. Our consumer banking strategy is primarily to generate deposits and originate high credit quality loans for investment and sale. Deposits are generated from consumers and small businesses to provide a source of low cost funds, with a focus on building and maintaining quality customer relationships.

	Year Ended December 31,
(In thousands)	2020		2019		2018
Consumer Banking
Net interest income	$	834,106	$	676,552	$	569,220
Provision for credit losses	16,945		16,550		24,661
Net interest income after provision for credit losses	817,161		660,002		544,559
Noninterest income	318,029		273,915		262,797
Noninterest expense	852,733		753,904		669,967
Income before income tax expense	282,457		180,013		137,389
Income tax expense	62,654		38,353		31,645
Net income available to common shareholders	219,803		141,660		105,744
Total assets (at period end)	$	13,663,990	$	14,224,545	$	6,414,228

Consumer Banking generated net income available to common shareholders of $219.8 million for 2020, compared with $141.7 million for 2019 and $105.7 million for 2018. The increase in 2020, compared to 2019, was primarily due to the incremental income resulting from the TCF/Chemical Merger and lower cost of funds, partially offset by an increase in incremental operating costs and a decrease in fees and service charges on deposit accounts primarily attributable to customer account balances maintaining excess liquidity resulting in a decline in fees charged. The increase in 2019, compared to 2018, was primarily due to the incremental income resulting from the TCF/Chemical Merger and the 2018 expense associated with the settlement with the CFPB and the OCC of $32.0 million, partially offset by an increase in incremental operating costs.

Commercial Banking Commercial Banking is comprised of commercial and industrial, commercial real estate banking and lease financing. Our commercial banking strategy focuses on building full commercial relationships including originating high credit quality loans and leases and providing deposit and treasury services.

	Year Ended December 31,
(In thousands)	2020		2019		2018
Commercial Banking
Net interest income	$	697,190	$	536,154	$	383,031
Provision for credit losses	240,206		48,732		22,107
Net interest income after provision for credit losses	456,984		487,422		360,924
Noninterest income	186,304		198,898		190,442
Noninterest expense	430,158		383,390		308,727
Income before income tax expense	213,130		302,930		242,639
Income tax expense	35,128		50,581		52,675
Income after income tax expense	178,002		252,349		189,964
Income attributable to non-controlling interest	7,282		11,458		11,270
Net income available to common shareholders	170,720		240,891		178,694
Total assets (at period end)	$	24,063,599	$	20,395,308	$	9,086,125

Commercial Banking generated net income available to common shareholders of $170.7 million for 2020, compared with $240.9 million for 2019 and $178.7 million for 2018. The decrease in 2020, compared to 2019, was primarily due to an increase in provision for credit losses and a decrease in leasing revenue, partially offset by the incremental income resulting from the TCF/Chemical Merger and lower cost of funds. The provision increase in 2020, compared to 2019, reflects a build to the overall allowance for loans and leases primarily due to the impact of COVID-19 and additionally impacted by the adoption of CECL. The increase in 2019, compared to 2018, was primarily due to the incremental income resulting from the TCF/Chemical Merger.

49

Table of Contents

Enterprise Services

Enterprise Services is comprised of (i) corporate treasury, which includes our investment and borrowing portfolios and management of capital, debt and market risks, (ii) corporate functions, such as information technology, risk and credit management, bank operations, finance, investor relations, corporate development, internal audit, legal and human capital management that provide services to the operating segments, (iii) TCF Financial and (iv) eliminations. Our investment portfolio accounts for the earning assets within this segment. Borrowings may be used to offset reductions in deposits or to support lending activities. This segment also includes residual revenues and expenses representing the difference between actual amounts incurred by Enterprise Services and amounts allocated to the operating segments, including interest rate risk residuals such as funds transfer pricing mismatches.

	Year Ended December 31,
(In thousands)	2020		2019		2018
Enterprise Services
Net interest income	$	7,105	$	76,326	$	56,244
Noninterest income	11,730		(7,281)		1,158
Noninterest expense	244,480		194,821		35,706
Income (loss) before income tax (benefit) expense	(225,645)		(125,776)		21,696
Income tax (benefit) expense	(57,881)		(38,693)		1,776
Income (loss) after income tax (benefit) expense	(167,764)		(87,083)		19,920
Preferred stock dividends	9,975		9,975		11,588
Impact of preferred stock call	—		—		3,481
Net (loss) income available to common shareholders	(177,739)		(97,058)		4,851
Total assets (at period end)	$	10,074,898	$	12,031,700	$	8,199,259

Enterprise Services generated net loss available to common shareholders of $177.7 million for 2020, compared with net loss available to common shareholders of $97.1 million for 2019 and net income available to common shareholders of $4.9 million for 2018. The increase in net loss in 2020, compared to 2019, was primarily due to increases in merger-related expenses and compensation and employee benefits and a decrease in net interest income. The increase in net loss in 2019, compared to 2018, was primarily due to an increase in merger-related expenses, partially offset by an increase in net interest income driven by investment securities acquired in the TCF/Chemical Merger.

Consolidated Financial Condition Analysis

Investment Securities Total investment securities available-for-sale, at fair value, were $8.3 billion at December 31, 2020, compared with $6.7 billion at December 31, 2019. Our investment securities available-for-sale are debt securities consisting primarily of fixed-rate mortgage-backed securities issued by the Federal National Mortgage Association ("FNMA") and the Federal Home Loan Mortgage Corporation ("FHLMC"), and obligations of states and political subdivisions. The increase in investment securities was primarily due to purchases of additional residential mortgage-backed securities.

From time to time, we sell investment securities available-for-sale and utilize the proceeds to reduce borrowings, fund growth in loans and leases or for other corporate purposes. We sold $48.5 million of investment securities during the year ended 2020, $2.0 billion during the year ended 2019 and $251.3 million during the year ended 2018.

Total investment securities held-to-maturity were $184.4 million at December 31, 2020, compared with $139.4 million at December 31, 2019. Our investment securities held-to-maturity portfolio consists primarily of fixed-rate mortgage-backed securities issued by the FNMA. The increase in debt securities held to maturity was primarily due to purchases of residential mortgage-backed securities.

50

Table of Contents

The amortized cost and fair value of investment securities available-for-sale and held-to-maturity were as follows:

	At December 31,
	2020				2019				2018
(In thousands)	Amortized Cost		Fair value		Amortized Cost		Fair value		Amortized Cost		Fair value
Investment securities available-for-sale
Debt securities:
Residential mortgage-backed securities	$	6,308,376	$	6,467,760	$	4,866,473	$	4,929,717	$	1,930,700	$	1,913,194
Obligations of states and political subdivisions	827,191		870,181		852,096		863,855		566,304		556,871
Commercial mortgage-backed securities	708,593		750,381		685,212		691,614		—		—
Government and government-sponsored enterprises	196,560		195,900		235,045		234,385		—		—
Corporate debt and trust preferred securities	453		501		451		430		—		—
Total investment securities available-for-sale	8,041,173		8,284,723		6,639,277		6,720,001		2,497,004		2,470,065
Investment securities held-to-maturity
Residential mortgage-backed securities	180,946		190,141		135,769		141,168		146,052		146,467
Corporate debt and trust preferred securities	3,413		3,413		3,676		3,676		2,800		2,800
Total investment securities held-to-maturity	184,359		193,554		139,445		144,844		148,852		149,267
Total investment securities	$	8,225,532	$	8,478,277	$	6,778,722	$	6,864,845	$	2,645,856	$	2,619,332

The carrying value and FTE yield of investment securities available-for-sale and investment securities held-to-maturity by final contractual maturity were as follows. The final contractual maturities do not consider possible prepayments and therefore expected maturities may differ because borrowers may have the right to call or prepay obligations with or without call or prepayment penalties.

	At December 31, 2020
	Residential mortgage-backed Securities				Obligations of States and Political Subdivisions				Commercial mortgage-backed Securities				Government and Government-sponsored Enterprises				Corporate Debt And Trust Preferred Securities				Total
(Dollars in thousands)	Amount		Yield (1)		Amount		Yield (1)		Amount		Yield (1)		Amount		Yield (1)		Amount		Yield (1)		Amount		Yield (1)
Investment securities available-for-sale
Due in one year or less	$	—	—	%	$	46,163	2.66	%	$	—	—	%	$	—	—	%	$	—	—	%	$	46,163	2.66	%
Due in 1-5 years	14,287		1.88		141,458		2.87		12,380		1.56		—		—		—		—		168,125		2.69
Due in 5-10 years	124,363		2.02		246,743		2.53		331,349		1.95		17,784		1.60		—		—		720,239		2.15
Due after 10 years	6,329,110		1.96		435,817		2.73		406,652		2.51		178,116		1.76		501		4.74		7,350,196		2.03
Total	$6,467,760		1.96	%	$	870,181	2.69	%	$	750,381	2.25	%	$	195,900	1.75	%	$	501	4.74	%	$	8,284,723	2.06	%
Investment securities held-to-maturity
Due in one year or less	$	—	—	%	$	—	—	%	$	—	—	%	$	—	—	%	$	400	3.00	%	$	400	3.00	%
Due in 1-5 years	—		—		—		—		—		—		—		—		2,150		3.00		2,150		3.00
Due in 5-10 years	46		6.50		—		—		—		—		—		—		—		—		46		6.50
Due after 10 years	180,900		1.86		—		—		—		—		—		—		863		6.00		181,763		1.88
Total	$	180,946	1.86	%	$	—	—	%	$	—	—	%	$	—	—	%	$	3,413	3.76	%	$	184,359	1.90	%

(1)Interest and yields are presented on a FTE basis.

See "Note 6. Investment Securities" of Notes to Consolidated Financial Statements for further information regarding our investment securities available-for-sale and investment securities held-to-maturity.

Loans and Leases Held-for-Sale Our loans and leases held-for-sale were $222.0 million at December 31, 2020, an increase of $22.2 million, compared to $199.8 million at December 31, 2019.

Loans and Leases Our commercial loan and lease portfolio is comprised of commercial and industrial loans, commercial real estate loans, and lease financing. Our consumer loan portfolio is comprised of residential mortgages, home equity loans and lines of credit and consumer installment loans. Our lending markets primarily consist of communities throughout our primary banking markets in addition to Florida, Texas, New York, California and Canada.

51

Table of Contents

Total loans and leases were $34.5 billion at both December 31, 2020 and December 31, 2019. At December 31, 2020, commercial and industrial loans included $1.6 billion of PPP loans outstanding. Loans and leases excluding PPP loans, a non-GAAP financial measure, decreased $1.6 billion from December 31, 2019 primarily due to a decrease in the commercial and industrial portfolio, primarily inventory finance, related to strong dealer activity and the lack of backfill from manufacturers as a result of logistical issues and the economic slowdown, in addition to a decrease in our consumer loan portfolio, partially offset by increases in our commercial real estate and lease financing portfolios and loan and lease purchases. See "Non-GAAP Financial Measures" in this Management's Discussion and Analysis for further information.

Information about our loans and leases was as follows:

											Compound Annual
											Growth Rate
	At December 31,										1-Year		5-Year
(Dollars in thousands)	2020		2019		2018		2017		2016		2020 / 2019		2020 / 2016
Commercial loan and lease portfolio:
Commercial and industrial	$	11,422,383	$	11,439,602	$	6,298,240	$	5,920,423	$	5,180,864	(0.2)	%	17.1	%
Commercial real estate	9,702,587		9,136,870		2,830,705		2,681,827		2,593,409		6.2		30.2
Lease financing	2,817,231		2,699,869		2,530,163		2,461,182		2,319,579		4.3		4.0
Total commercial loan and lease portfolio	23,942,201		23,276,341		11,659,108		11,063,432		10,093,852		2.9		18.9
Consumer loan portfolio:
Residential mortgage	6,182,045		6,179,805		2,335,835		1,826,988		2,131,839		—		23.7
Home equity	3,108,736		3,498,907		3,074,505		2,992,708		2,952,514		(11.2)		1.0
Consumer installment	1,233,426		1,542,411		2,003,572		3,222,156		2,666,511		(20.0)		(14.3)
Total consumer loan portfolio	10,524,207		11,221,123		7,413,912		8,041,852		7,750,864		(6.2)		6.3
Total loans and leases	$	34,466,408	$	34,497,464	$	19,073,020	$	19,105,284	$	17,844,716	(0.1)		14.1

The contractual maturities of loans and leases outstanding were as follows:

	At December 31, 2020(1)
(in thousands)	Commercial and industrial		Commercial real estate		Lease Financing		Residential mortgage		Home equity		Consumer installment		Total
Amounts due:
Within 1 year	$	3,483,409	2,007,581		$	239,312	$	11,912	$	68,294	$	35,415	$	5,845,923
1 to 5 years	6,727,751		5,410,955		2,255,665		59,061		407,616		493,638		15,354,686
Over 5 years	1,211,223		2,284,051		322,254		6,111,072		2,632,826		704,373		13,265,799
Total	11,422,383		9,702,587		2,817,231		6,182,045		3,108,736		1,233,426		34,466,408
Amounts due after 1 year:
Fixed-rate loans and leases	5,453,114		2,233,537		2,577,919		3,781,885		306,012		1,172,105		15,524,572
Variable- and adjustable-rate loans and leases	2,485,860		5,461,469		—		2,388,248		2,734,430		25,906		13,095,913
Total after 1 year	$	7,938,974	$	7,695,006	$	2,577,919	$	6,170,133	3,040,442		$	1,198,011	28,620,485

(1)This table does not include the effect of prepayments, which is an important consideration in management's interest-rate risk analysis. Our experience indicates that loans and leases remain outstanding for significantly shorter periods than their contractual terms.

Commercial Loan and Lease Portfolio

Our commercial loan and lease portfolio was $23.9 billion at December 31, 2020, an increase of $665.9 million, or 2.9%, compared to $23.3 billion at December 31, 2019. We believe that our commercial loan and lease portfolio is well diversified across business lines and has no concentration in any one industry.

52

Table of Contents

Commercial and industrial Commercial and industrial ("C&I") loans and lines of credit include loans to varying types of businesses, municipalities, school districts and nonprofit organizations, for the purpose of supporting working capital and operational needs and financing equipment. C&I loans are secured by various types of business assets including inventory, floorplan equipment, receivables, equipment or financial instruments. Origination levels related to equipment dealers are impacted by the velocity of fundings and repayments with dealers. C&I loans were $11.4 billion at December 31, 2020, a decrease of $17.2 million, compared to $11.4 billion at December 31, 2019. At December 31, 2020, C&I loans included $1.6 billion of PPP loans.

Our C&I portfolio by North American Industry Classification System ("NAICS") code was as follows:

	At December 31, 2020
(In thousands)	Balance		Percent of total loan and lease portfolio
Retail trade	$	2,174,624	6.3	%
Transportation and warehouse	1,446,765		4.2
Manufacturing	1,258,285		3.7
Real estate rental and leasing	924,979		2.7
Wholesale trade	850,500		2.5
Construction	730,346		2.1
Health care and social assistance	634,868		1.8
Finance and insurance	463,336		1.3
Administration and Support and Waste Management and Remediation	422,708		1.2
All other	2,515,972		7.3
Total	$	11,422,383	33.1	%

Commercial real estate Commercial real estate loans include loans that are secured by real estate occupied by the borrower for ongoing operations, non-owner occupied real estate leased to one or more tenants and construction and development loans primarily originated for construction of commercial properties. Construction and development loans often convert to a commercial real estate loan at the completion of the construction period. Commercial real estate loans were $9.7 billion at December 31, 2020, an increase of $565.7 million, compared to $9.1 billion at December 31, 2019.

Our commercial real estate loan portfolio by property and loan type was as follows:

	At December 31,
	2020				2019
(In thousands)	Balance		Percent of total loan and lease portfolio		Balance		Percent of total loan and lease portfolio
Multifamily	$	1,900,898	5.5	%	$	1,799,949	5.2	%
Office	1,383,043		4.0		1,219,618		3.5
Retail	1,256,064		3.6		1,323,773		3.8
Warehouse	1,121,502		3.3		1,081,165		3.1
Hotel	799,365		2.3		759,773		2.2
Senior housing	776,505		2.3		729,169		2.1
Self‐storage	532,256		1.5		436,415		1.3
Mixed use	432,764		1.3		450,782		1.3
Other	1,500,190		4.4		1,336,226		4.0
Total	$	9,702,587	28.2	%	$	9,136,870	26.5	%

Lease financing We provide a broad range of comprehensive lease products addressing the diverse financing needs of small to large companies. Lease financing loans were $2.8 billion at December 31, 2020, an increase of $117.4 million, compared to $2.7 billion at December 31, 2019.

53

Table of Contents

Our lease financing portfolio by market type was as follows:

	At December 31,
	2020				2019
(Dollars in thousands)	Balance		Percent of total loan and lease portfolio		Balance		Percent of total loan and lease portfolio
Specialty vehicles	$	613,941	1.7	%	$	554,543	1.6	%
Golf	547,716		1.6		469,451		1.4
Healthcare	507,170		1.5		523,244		1.5
Construction	300,370		0.9		246,750		0.7
Manufacturing	224,062		0.7		298,187		0.9
Material handling	219,340		0.6		131,367		0.4
Technology	194,703		0.6		221,152		0.6
Agricultural	127,008		0.4		117,198		0.3
Other	82,921		0.2		137,977		0.4
Total	$	2,817,231	8.2	%	$	2,699,869	7.8	%

Consumer Loan Portfolio

Our consumer loan portfolio was $10.5 billion at December 31, 2020, a decrease of $696.9 million, or 6.2%, compared to $11.2 billion at December 31, 2019.

Residential mortgage Residential mortgage loans consist primarily of one- to four-family residential loans with fixed and adjustable interest rates, with amortization periods generally from 15 to 30 years. The loan-to-value ratio at the time of origination is generally 90% or less. Loans with more than an 80% loan-to-value ratio generally require private mortgage insurance. Residential mortgage loans also include loans to consumers for the construction of single family residences that are secured by these properties. Residential mortgage loans were $6.2 billion at both December 31, 2020 and December 31, 2019.

Home equity Home equity loans and lines of credit are comprised of loans to consumers who utilize equity in their personal residence, including junior lien mortgages, as collateral to secure the loan or line-of-credit. Our home equity portfolio totaled $3.1 billion at December 31, 2020 (consisting of $2.8 billion of home equity lines of credit and $332.0 million of amortizing home equity loans), a decrease of $390.2 million, compared to $3.5 billion at December 31, 2019 (consisting of $3.0 billion of home equity lines of credit and $474.7 million of amortizing home equity loans). At December 31, 2020, $2.3 billion of our home equity lines of credit were loans with a 10-year interest-only draw period and a 20-year amortization repayment period, of which all were within the 10-year interest-only draw period and will not convert to amortizing loans until 2021 or later. At December 31, 2020, $505.2 million of the home equity line of credits were interest-only revolving draw loans with no defined amortization period and original draw periods of 0 to 40 years. Home equity lines of credit mostly include junior lien mortgages where the first lien mortgage is held by a unaffiliated financial institution.

Consumer installment Consumer installment loans consist of relatively small loan amounts to consumers to finance personal items (primarily automobiles, recreational vehicles and marine vehicles) and are primarily indirect loans purchased from dealerships. Consumer rates are both fixed and variable, with negotiated terms. Our consumer installment loans typically amortize over periods up to 60 months. Consumer loans not secured by real estate are generally considered to have greater risk than first or second mortgages on real estate because they may be unsecured, or, if they are secured, the value of the collateral may be difficult to assess and more likely to decrease in value, and more difficult to control, than real estate. Consumer installment loans were $1.2 billion at December 31, 2020, a decrease of $309.0 million, or 20.0%, compared to $1.5 billion at December 31, 2019.

54

Table of Contents

Credit Quality  The following summarizes our loan and lease portfolio based on the credit quality factors that we believe are the most important and should be considered to understand the overall condition of the portfolio. The following items should be considered throughout this section:

•Loans and leases that are over 90-days delinquent and accruing generally are a leading indicator for future charge-off trends.

•Nonaccrual loans and leases have been charged down to the estimated fair value of the collateral less estimated selling costs, or reserved for expected loss upon workout.

•Within the performing loans and leases, we classify customers within regulatory classification guidelines. Loans and leases that are "classified" are loans or leases that management has concerns regarding the ability of the borrowers to meet existing loan or lease terms and conditions, but may never become nonaccrual or result in a loss.

Past due loans and leases  Delinquent balances are determined based on the contractual terms of the loan or lease. See "Note 8. Allowance for Credit Losses and Credit Quality" of Notes to Consolidated Financial Statements for further information. Over 90-day delinquent loans and leases by type, excluding nonaccrual loans and leases, were as follows.

	90 Days or More Delinquent and Accruing										Percentage of Period-end Loans and Leases
	At December 31,
(Dollars in thousands)	2020		2019		2018		2017		2016		2020		2019		2018		2017		2016
Commercial loan and lease portfolio:
Commercial and industrial	$	1,458	$	331	$	760	$	1,216	$	75	0.01	%	—	%	0.01	%	0.02	%	—	%
Commercial real estate	22		1,440		—		—		—		—		0.02		—		—		—
Lease financing	3,935		1,901		1,882		918		1,009		0.14		0.07		0.07		0.04		0.04
Total commercial loan and lease portfolio	5,415		3,672		2,642		2,134		1,084		0.02		0.02		0.02		0.02		0.01
Consumer loan portfolio:
Residential mortgage	1,965		559		1,275		593		2,144		0.03		0.01		0.06		0.03		0.11
Home equity	63		—		—		—		—		—		—		—		—		—
Consumer installment	—		108		3,349		3,005		2,323		—		0.01		0.17		0.09		0.09
Total consumer loan portfolio	2,028		667		4,624		3,598		4,467		0.02		0.01		0.06		0.05		0.06
Portfolios acquired with deteriorated credit quality(1)	—		25,737		178		1,200		—		—		10.43		4.65		10.13		—
Total	$	7,443	$	30,076	$	7,444	$	6,932	$	5,551	0.02	%	0.09	%	0.04	%	0.04	%	0.03	%

(1)Prior to the adoption of CECL as of January 1, 2020, purchased credit impaired loans were not classified as nonaccrual loans because they were recorded at their net realizable value based on the principal and interest expected to be collected on the loans.

55

Table of Contents

Nonperforming assets  Nonperforming assets, consisting of nonaccrual loans and leases and other real estate owned, were as follows:

	At December 31,
(Dollars in thousands)	2020			2019			2018			2017			2016
Commercial loan and lease portfolio:
Commercial and industrial	$	259,439		$	53,812		$	26,061		$	10,958		$	10,587
Commercial real estate	154,439			29,735			4,518			6,785			5,564
Lease financing	90,822			10,957			7,993			10,247			5,782
Total commercial loan and lease portfolio	504,700			94,504			38,572			27,990			21,933
Consumer loan portfolio:
Residential mortgage	97,653			38,577			33,111			61,951			106,124
Home equity	69,383			35,863			25,654			21,274			46,346
Consumer installment	5,566			714			8,581			7,367			7,042
Total consumer loan portfolio	172,602			75,154			67,346			90,592			159,512
Total nonaccrual loans and leases	677,302			169,658			105,918			118,582			181,445
Other real estate owned	33,192			34,256			17,403			18,225			46,797
Total nonperforming assets	$	710,494		$	203,914		$	123,321		$	136,807		$	228,242
Nonaccrual loans and leases as a percentage of total loans and leases	1.97		%	0.49		%	0.56		%	0.62		%	1.02		%
Nonperforming assets as a percentage of total loans and leases and other real estate owned	2.06			0.59			0.65			0.72			1.28
Allowance for loan and lease losses as a percentage of nonaccrual loans and leases	77.64			66.64			148.65			144.24			88.33
Allowance for credit losses as a percentage of nonaccrual loans and leases	81.08			68.71			66.67			68.73			112.43

Nonperforming assets were $710.5 million at December 31, 2020, compared with $203.9 million at December 31, 2019. The increase in nonperforming assets reflected an increase in nonaccrual balances in our commercial loan and lease portfolio, the adoption of CECL ($73.4 million of loans previously accounted for as purchased credit impaired were reclassified to nonaccrual loans as of January 1, 2020 due to the adoption of CECL) and an increase in nonaccrual balances in our consumer loan portfolio. The increase within the commercial portfolio was primarily driven by certain portfolios more heavily impacted by COVID-19, including the motor coach, shuttle bus, hotel, franchise, retail commercial real estate, fitness and retail trade sectors, the majority of which have been on deferral for over 180 days. At December 31, 2020, nonaccrual loans and leases included $219.0 million within travel-related sectors ($104.0 million in motor coach, $36.5 million in shuttle bus and $78.5 million in hotel) in addition to, $25.5 million in the franchise sector, $18.7 million in the retail commercial real estate sector, $5.3 million in the fitness sector and $1.3 million in the retail trade sector. Due to the prolonged recovery of revenues for borrowers in these sectors given the dependency on travel and related activity levels highly impacted by COVID-19, we have taken a proactive approach by working with borrowers to extend deferrals into 2021 where necessary, many of which have been moved to nonaccrual status.

Loans and leases are generally placed on nonaccrual status when the collection of interest or principal is 90 days or more past due unless, in the case of commercial loans, they are well secured and in process of collection. Delinquent consumer home equity loans with a junior lien are also placed on nonaccrual status when there is evidence that the related third-party first lien mortgage may be 90 days or more past due, or foreclosure, charge-off or collection action has been initiated. TDR loans are placed on nonaccrual status prior to the past due thresholds outlined above if repayment under the modified terms is not likely after performing a well-documented credit analysis. In addition, under the CARES Act, loans and leases that have been granted a deferral of greater than 180 days are generally placed on nonaccrual status. Loans on nonaccrual status are generally reported as nonaccrual loans until there is sustained repayment performance for six consecutive months, with the exception of loans not reaffirmed upon discharge in Chapter 7 bankruptcy, which remain on nonaccrual status until a well-documented credit analysis indicates full repayment of the remaining pre-discharged contractual principal and interest is likely.

Commercial real estate, residential mortgage and home equity nonaccrual loans are secured by real estate. Given the nature of these assets and the related mortgage foreclosure, property sale and, if applicable, mortgage insurance claims processes, it can take 18 months or longer for a loan to migrate from initial delinquency to final disposition. This resolution process generally takes much longer for loans secured by real estate than for unsecured loans or loans secured by other property primarily due to state real estate foreclosure laws.

56

Table of Contents

Changes in the amount of nonaccrual loans and leases were as follows:

	At or For the Year Ended December 31, 2020
(in thousands)	Consumer Loan Portfolio		Commercial Loan and Lease Portfolio		Total
Balance, beginning of period	$	75,154	$	94,504	$	169,658
Transfer in of loans previously accounted for as purchased credit impaired(1)	20,560		52,825		73,385
Adjusted balance, beginning of period	95,714		147,329		243,043
Additions	143,178		624,427		767,605
Charge-offs	(10,619)		(61,887)		(72,506)
Transfers to other assets	(6,931)		(17,332)		(24,263)
Return to accrual status	(19,903)		(67,639)		(87,542)
Payments received	(28,849)		(119,172)		(148,021)
Other, net	12		(1,026)		(1,014)
Balance, end of period	$	172,602	$	504,700	$	677,302
	At or For the Year Ended December 31, 2019
(in thousands)	Consumer Loan Portfolio		Commercial Loan and Lease Portfolio		Total
Balance, beginning of period	$	67,346	$	38,572	$	105,918
Acquired in the TCF/Chemical Merger	16,414		64,830		81,244
Additions	77,841		156,436		234,277
Charge-offs	(9,580)		(36,208)		(45,788)
Transfers to other assets	(17,126)		(19,779)		(36,905)
Return to accrual status	(7,770)		(39,356)		(47,126)
Payments received	(25,126)		(72,979)		(98,105)
Sales	(26,722)		—		(26,722)
Other, net	(123)		2,988		2,865
Balance, end of period	$	75,154	$	94,504	$	169,658

(1)Prior to the adoption of CECL as of January 1, 2020, purchased credit impaired loans were not classified as nonaccrual loans because they were recorded at their net realizable value based on the principal and interest expected to be collected on the loans.

Interest income recognized on loans and leases in nonaccrual status and contractual interest that would have been recorded had the loans and leases performed in accordance with their original contractual terms were as follows:

	Year Ended December 31,
(in thousands)	2020		2019		2018
Contractual interest due on nonaccrual loans and leases	$	58,002	$	17,310	$	10,921
Interest income recognized on nonaccrual loans and leases	31,768		5,514		1,351
Unrecognized interest income	$	26,234	$	11,796	$	9,570

See "Note 2. Summary of Significant Accounting Policies" and "Note 8. Allowance for Credit Losses and Credit Quality" of Notes to Consolidated Financial Statements for further information.

Loan and lease credit classifications We assess the risk of our loan and lease portfolio utilizing numerous risk characteristics as outlined in the previous sections. Credit classifications are an additional characteristic monitored in the overall credit risk process. Loan and lease credit classifications are derived from standard regulatory rating definitions, which include: non-classified (pass and special mention) and classified (substandard). Classified loans and leases have well-defined weaknesses, but may never result in a loss.

57

Table of Contents

Loans and leases by portfolio and regulatory classification were as follows:

	At December 31, 2020
	Non-classified				Classified		Total
(In thousands)	Pass		Special Mention		Substandard
Commercial loan and lease portfolio:
Commercial and industrial	$	10,710,654	$	267,585	$	444,144	$	11,422,383
Commercial real estate	8,807,045		531,016		364,526		9,702,587
Lease financing	2,681,307		34,084		101,840		2,817,231
Total commercial loan and lease portfolio	22,199,006		832,685		910,510		23,942,201
Consumer loan portfolio:
Residential mortgage	6,078,865		112		103,068		6,182,045
Home equity	3,028,765		—		79,971		3,108,736
Consumer installment	1,227,061		—		6,365		1,233,426
Total consumer loan portfolio	10,334,691		112		189,404		10,524,207
Total loans and leases	$	32,533,697	$	832,797	$	1,099,914	$	34,466,408

	At December 31, 2019
	Non-classified				Classified		Total
(In thousands)	Pass		Special Mention		Substandard
Commercial loan and lease portfolio:
Commercial and industrial	$	10,930,939	$	315,097	$	193,566	$	11,439,602
Commercial real estate	8,891,361		170,114		75,395		9,136,870
Lease financing	2,646,874		28,091		24,904		2,699,869
Total commercial loan and lease portfolio	22,469,174		513,302		293,865		23,276,341
Consumer loan portfolio:
Residential mortgage	6,135,096		565		44,144		6,179,805
Home equity	3,457,292		456		41,159		3,498,907
Consumer installment	1,541,524		—		887		1,542,411
Total consumer loan portfolio	11,133,912		1,021		86,190		11,221,123
Total loans and leases	$	33,603,086	$	514,323	$	380,055	$	34,497,464

Total classified loans and leases were $1.1 billion at December 31, 2020, compared with $380.1 million at December 31, 2019. The increase was primarily due to downgrades in our commercial loan and lease portfolio, largely occurring due to economic impacts caused by COVID-19. We have identified certain sectors within our commercial loan and lease portfolio that have been more heavily impacted by COVID-19 including motor coach, shuttle bus, hotel, retail commercial real estate, franchise, retail trade and fitness, excluding any PPP loans within these sectors as they are guaranteed by the Small Business Administration. At December 31, 2020, these previously identified higher COVID-19 impacted sectors represent $725.3 million of the total commercial loan and lease portfolio classified balance, of which $269.8 million are on nonaccrual status. Sectors identified as having a higher impact due to COVID-19 may change in future periods depending on how economic environment conditions develop over time.

58

Table of Contents

Loan modifications  Troubled debt restructuring ("TDR") loans are loans to financially troubled borrowers that have been modified such that we have granted a concession in terms to improve the likelihood of collection of all principal and modified interest owed. TDR loans were as follows:

	At December 31,
(Dollars in thousands)	2020			2019			2018			2017			2016
Accruing TDR Loans:
Commercial loan and lease portfolio	$	35,697		$	12,986		$	12,665		$	22,512		$	25,106
Consumer loan portfolio	16,658			12,403			85,794			91,559			100,935
Total	52,355			25,389			98,459			114,071			126,041
Nonaccrual TDR Loans:
Commercial loan and lease portfolio	23,575			5,356			6,153			1,972			3,877
Consumer loan portfolio	22,804			14,875			22,554			39,634			77,465
Total	46,379			20,231			28,707			41,606			81,342
Total TDR loans:
Commercial loan and lease portfolio	59,272			18,342			18,818			24,484			28,983
Consumer loan portfolio	39,462			27,278			108,348			131,193			178,400
Total	$	98,734		$	45,620		$	127,166		$	155,677		$	207,383
Over 90-day delinquency as a percentage of total accruing TDR loans	0.99		%	0.52		%	0.14		%	—		%	0.30		%

Total TDRs were $98.7 million at December 31, 2020, compared with $45.6 million at December 31, 2019.

Loan modifications to borrowers who have not been granted concessions are not considered TDR loans and therefore are not included in the table above. In addition, Section 4013 of the CARES Act and the Interagency Statement on Loan Modifications provide banks the option to temporarily suspend certain TDR accounting guidance for loans modified due to the effects of COVID-19 when certain conditions are met. On December 27, 2020, this provision of the CARES Act was extended to the earlier of January 1, 2022 or 60 days after the President of the United States declares a termination of the COVID-19 national emergency. In March 2020, TCF began providing assistance to customers in response to the COVID-19 pandemic, predominantly in the form of payment deferrals. As of December 31, 2020, $329.8 million of loan and lease balance was on deferral status, of which $218.0 million are on nonaccrual status, the majority of which have been on deferral for over 180 days. TCF additionally granted certain other loan modifications which provide temporary customer assistance predominantly in the form of financial covenant concessions and modification of borrowing base. As of December 31, 2020, other loan modifications balance was $401.6 million. See "Note 2. Summary of Significant Accounting Policies" of the Notes to Consolidated Financial Statements for information regarding recent updated guidance on TDR accounting provided by the CARES Act and Interagency Regulatory guidance. TDR loans with an interest rate consistent with market rates on loans with comparable risk at the time of restructuring and performing based on the restructured terms are no longer disclosed as TDR loans in the calendar years after modification; however, these loans are still considered impaired and follow our impaired loan reserve policies.

TDRs typically involve a deferral of the principal balance of the loan, a reduction of the stated interest rate of the loan or, in certain limited circumstances, a reduction of the principal balance of the loan or the loan's accrued interest.

Interest income recognized on TDR loans and contractual interest that would have been recorded had the TDR loans performed in accordance with their original contractual terms were as follows:

	Year Ended December 31,
(in thousands)	2020		2019		2018
Contractual interest due on TDR loans	$	4,929	$	6,157	$	6,842
Interest income recognized on TDR loans	1,448		4,325		4,673
Unrecognized interest income	$	3,481	$	1,832	$	2,169

See "Note 8. Allowance for Credit Losses and Credit Quality" of Notes to Consolidated Financial Statements for further information regarding our loan modifications.

59

Table of Contents

Allowance for credit losses  The ACL includes the ALLL and the RULC. The ALLL is a valuation account presented separately on the Consolidated Statements of Financial Condition that is deducted from or added to loans' amortized cost basis to present the net amount expected to be collected. The RULC for letters of credit, financial guarantees and binding unfunded loan commitments is recorded in other liabilities on the Consolidated Statements of Financial Condition. The Corporation's reserve methodology used to determine the appropriate level of the ACL is a critical accounting estimate. The ACL is maintained at a level believed to be appropriate to provide for the current credit losses expected to be incurred in the loan and lease portfolios over the remaining expected life of each financial asset at the balance sheet date, including known or anticipated problem loans and leases, as well as for loans and leases which are not currently known to require specific allowances. The collective evaluation of expected losses in these portfolios is based on their probability of default multiplied by historical loss rates, as well as adjustments for forward-looking information, including industry and macroeconomic conditions. Factors utilized in the determination of the amount of the allowance include historic loss experience and measurement date credit risk characteristics such as product type, lien position, delinquency, collateral value, credit bureau scores and financial statement ratios. The various quantitative and qualitative factors used in the methodologies are reviewed quarterly.

We consider our ACL of $549.2 million, or 1.59% of total loans and leases, appropriate to cover current credit losses expected to be incurred in the loan and lease portfolios over the remaining expected life of each financial asset at December 31, 2020, including loans and leases which are not currently known to require specific allowances. The increase in ACL and the ACL as a percentage of total loans and leases from December 31, 2019 was primarily due to the adoption of CECL at January 1, 2020, and the impact of COVID-19. During 2020 the COVID-19 pandemic had a negative impact on current and forecasted macroeconomic conditions and created uncertainty around the performance of certain sectors that have been more heavily impacted, including motor coach, shuttle bus, hotel, retail commercial real estate, franchise, retail trade and fitness. In the fourth quarter of 2020, we began to see improvement in current and forecasted macro-economic conditions, however, these improvements were offset by continued uncertainty around the performance of sectors more heavily impacted by COVID-19. The ACL as a percentage of total loans and leases, excluding PPP loans was 1.67%, a non-GAAP financial measure. PPP loans are individually guaranteed by the Small Business Administration and therefore the accounting under CECL does not require reserves to be recorded on such loans. No assurance can be given that we will not, in any particular period, sustain loan and lease losses that are sizable in relation to the amount reserved or will not require significant changes in the balance of the ACL due to subsequent evaluations of the loan and lease portfolios, in light of factors then prevailing, including economic conditions, information obtained during our ongoing credit review process or regulatory requirements. Among other factors, economic slowdown, increasing levels of unemployment, declines in collateral values and/or rising interest rates may have an adverse impact on the current adequacy of our ACL by increasing credit risk and the risk of potential loss. See "Non-GAAP Financial Measures" in this Management's Discussion and Analysis for further information.

The total ACL is expected to absorb losses from any segment of the portfolio. The allocation of our ACL disclosed in the following table is subject to change based on changes in the criteria used to evaluate the allowance.

Prior to the adoption of CECL on January 1, 2020, the ACL was calculated under an incurred loss model which delayed recognition of loss until it was probable the loss had been incurred, in contrast to the accounting under CECL which considers current credit losses expected to be incurred in the loan and lease portfolios over the remaining expected life of each financial asset.

60

Table of Contents

In conjunction with "Note 8. Allowance for Credit Losses and Credit Quality" of Notes to Consolidated Financial Statements, detailed information regarding our allowance for loan and lease losses was as follows:

	ACL(1)												Reserve Rate
	At December 31,												At December 31,
(Dollars in thousands)	2020		CECL(2)		2019		2018		2017		2016		2020		CECL(2)		2019	2018	2017	2016
Commercial loan and lease portfolio:
Commercial and industrial	$	155,665	$	93,884	$	42,430	$	41,103	$	35,451	$	33,193	1.36	%	0.82	%	0.38%	0.66%	0.61%	0.65%
Commercial real estate	192,331		67,620		27,308		22,877		24,842		22,785		1.98		0.74		0.29	0.79	0.90	0.86
Lease financing	40,978		21,631		14,742		13,449		12,663		11,999		1.45		0.80		0.55	0.53	0.51	0.52
Total commercial loan and lease portfolio	388,974		183,135		84,480		77,429		72,956		67,977		1.62		0.79		0.36	0.66	0.66	0.67
Consumer loan portfolio:
Residential mortgage	72,315		72,939		8,099		21,436		26,698		33,829		1.17		1.18		0.13	0.92	1.46	1.59
Home equity	45,761		47,003		17,795		23,430		20,470		25,620		1.47		1.34		0.51	0.76	0.68	0.87
Consumer Installment	18,818		15,967		2,678		35,151		50,917		32,843		1.53		1.04		0.17	1.75	1.58	1.23
Total consumer loan portfolio	136,894		135,909		28,572		80,017		98,085		92,292		1.30		1.21		0.25	1.08	1.22	1.19
Total allowance for loan and lease losses	525,868		319,044		113,052		157,446		171,041		160,269		1.53		0.92		0.33	0.83	0.90	0.90
Other credit loss reserves:
Reserves for unfunded commitments	23,313		18,235		3,528		1,428		1,479		1,115		N.A.		N.A.		N.A.	N.A.	N.A.	N.A.
Total credit loss reserves	$	549,181	$	337,279	$	116,580	$	158,874	$	172,520	$	161,384	1.59	%	0.98	%	0.34%	0.83%	0.90%	0.90%

N.A. Not Applicable

(1) Allowance for credit losses effective January 1, 2020 are calculated under the guidance of CECL. At December 31, 2019 allowance for credit losses were calculated under the guidance of ASC Topic 310 and ASC Topic 450 prior to adoption of CECL, See "Note 2. Summary of Significant Accounting Policies" and "Note 8. Allowance for Credit Losses and Credit Quality" of Notes to Consolidated Financial Statements for further information.

(2) Balances at December 31,2019 adjusted for the adoption of CECL as of January 1, 2020.

61

Table of Contents

The rollforwards of the allowance for credit losses were as follows:

	Year Ended December 31,
(Dollars in thousands)	2020		2019		2018		2017		2016
Allowance for loan and lease losses
Balance, beginning of period	$	113,052	$	157,446	$	171,041	$	160,269	$	156,054
Impact of CECL adoption	205,992		—		—		—		—
Adjusted balance, beginning of period	319,044		157,446		171,041		160,269		156,054
Charge-offs:
Commercial loan and lease portfolio:
Commercial and industrial	(48,816)		(39,566)		(16,005)		(8,840)		(7,450)
Commercial real estate	(8,105)		(302)		—		(3,608)		(752)
Lease financing	(6,324)		(7,587)		(4,203)		(6,813)		(2,912)
Total commercial loan and lease portfolio	(63,245)		(47,455)		(20,208)		(19,261)		(11,114)
Consumer loan portfolio:
Residential mortgage	(2,131)		(3,456)		(3,417)		(5,592)		(9,710)
Home equity	(4,346)		(3,219)		(3,710)		(6,270)		(8,915)
Consumer installment	(16,793)		(43,805)		(57,393)		(47,969)		(34,346)
Total consumer loan portfolio	(23,270)		(50,480)		(64,520)		(59,831)		(52,971)
Total charge-offs	(86,515)		(97,935)		(84,728)		(79,092)		(64,085)
Recoveries:
Commercial loan and lease portfolio:
Commercial and industrial	21,930		5,120		1,606		1,840		1,924
Commercial real estate	1,830		322		183		777		308
Lease financing	2,145		1,289		1,427		1,119		1,343
Total commercial loan and lease portfolio	25,905		6,731		3,216		3,736		3,575
Consumer loan portfolio:
Residential mortgage	2,634		4,271		5,261		6,100		1,115
Home equity	3,346		5,689		6,488		14,681		5,949
Consumer installment	9,547		13,693		14,738		10,135		8,211
Total consumer loan portfolio	15,527		23,653		26,487		30,916		15,275
Total recoveries	41,432		30,384		29,703		34,652		18,850
Net charge-offs	(45,083)		(67,551)		(55,025)		(44,440)		(45,235)
Provision for credit losses related to loans and leases(1)	252,073		65,282		46,768		68,443		65,874
Other(2)	(166)		(42,125)		(5,338)		(13,231)		(16,424)
Balance, end of period	$	525,868	$	113,052	$	157,446	$	171,041	$	160,269
Reserve for unfunded lending commitments
Balance, beginning of period	$	3,528	$	1,428	$	1,479	$	1,115	$	1,044
Impact of CECL adoption	14,707		—		—		—		—
Adjusted balance, beginning of period	18,235		1,428		1,479		1,115		1,044
Provision (benefit) for credit losses related to unfunded lending commitments(1)	5,078		233		(51)		364		71
Addition due to the TCF/Chemical Merger	—		1,867		—		—		—
Balance, end of period	23,313		3,528		1,428		1,479		1,115
Total allowance for credit losses	$	549,181	$	116,580	$	158,874	$	172,520	$	161,384

(1)Provision for credit losses related to loans and leases and the provision for credit losses related to unfunded lending commitments are included within Provision for Credit Losses.

(2)Primarily includes the transfer of the allowance for loan and lease losses to loans and leases held-for-sale.

Net loan and lease charge-offs for 2020 were $45.1 million, or 0.13% of average loans and leases, compared with $67.6 million, or 0.27% of average loans and leases, for 2019 and $55.0 million, or 0.29% of average loans and leases, for 2018. The decrease in net loan and lease charge-offs in 2020 was primarily due to a decrease in consumer installment loans, partially offset by an increase in the commercial loan and lease portfolio. The increase in net loan and lease charge-offs in 2019, compared to 2018, was primarily due to an increase in charge-offs in commercial and industrial net charge-offs, partially offset by $4.7 million of recoveries of previous charge-offs related to the sale of consumer nonaccrual and TDR loans.

62

Table of Contents

Investment Securities Held-to-Maturity The investment securities held-to-maturity portfolio consist primarily of fixed-rate mortgage-backed securities issued and guaranteed by FNMA, GNMA and FHLMC which significantly decreases credit risk. The most important credit quality factor we consider to understand the condition of the residential agency mortgage-backed securities is that all are AAA rated and agency-guaranteed.

Liquidity Management We manage our liquidity to ensure that our funding needs are met both promptly and in a cost-effective manner. Asset liquidity arises from liquid assets that can be sold or pledged as collateral, amortization, prepayment or maturity of assets and from our ability to sell loans. Liability liquidity results from our ability to maintain a diverse set of funding sources to promptly meet funding requirements.

The TCF Financial Board of Directors have adopted a Liquidity Management Policy for TCF Bank to direct management of the Corporation's liquidity risk and a Holding Company Investment and Liquidity Management Policy, which establishes a minimum target amount of cash or liquid investments TCF Financial will hold. See "Item 7A. Quantitative and Qualitative Disclosures about Market Risk" for further information.

TCF Bank had $434.3 million of net liquidity qualifying interest-bearing deposits at the Federal Reserve Bank at December 31, 2020, compared with $489.7 million at December 31, 2019. Certain investment securities held-to-maturity and investment securities available-for-sale provide the ability to liquidate or pledge unencumbered securities as needed. At December 31, 2020, $1.0 billion of our securities were pledged as collateral to secure certain deposits and borrowings.

TCF Financial had net liquidity qualifying cash of $173.0 million at December 31, 2020, compared with $156.0 million at December 31, 2019.

Deposits are the primary source of our funds for use in lending and for other general business purposes. In addition to deposits, we receive funds from loan and lease repayments, loan sales and borrowings. Borrowings may be used to compensate for reductions in normal sources of funds, such as deposit inflows at less than projected levels, net deposit outflows or to fund balance sheet growth. We primarily borrow from the Federal Home Loan Bank (the "FHLB") of Des Moines. We had $6.5 billion of additional borrowing capacity at the FHLB of Des Moines at December 31, 2020, as well as access to the Federal Reserve Discount Window. In addition, we maintain a diversified set of unsecured and uncommitted funding sources, including access to overnight federal funds purchased lines, brokered deposits and capital markets. Lending activities, such as loan originations, loan purchases and equipment purchases for lease financing, are the primary uses of our funds.

On June 29, 2020, TCF Financial voluntarily prepaid the outstanding $80.0 million on its $150.0 million unsecured 364-day revolving credit facility with an unaffiliated bank and subsequently closed the credit facility.

Our wholly-owned subsidiary TCF Commercial Finance Canada, Inc. ("TCFCFC") maintains a $20.0 million Canadian dollar-denominated line of credit facility with an unaffiliated bank, which is guaranteed by TCF Bank. TCFCFC had no outstanding borrowings under the line of credit with the counterparty at both December 31, 2020 and December 31, 2019.

Deposits  Deposits were $38.9 billion at December 31, 2020, compared with $34.5 billion at December 31, 2019. The increase in deposits was primarily due to increases in noninterest-bearing deposits of $3.1 billion, interest-bearing checking account balances of $1.3 billion, savings account balances of $1.0 billion and money market deposits of $1.0 billion, reflecting PPP funding, federal stimulus program infusions and lower consumer spending impacted by the COVID-19 pandemic, partially offset by the continued run-off of certificates of deposit which declined $1.9 billion.

Noninterest-bearing checking accounts represented 28.3% of total deposits at December 31, 2020, compared with 23.1% of total deposits at December 31, 2019. Our weighted-average interest rate for deposits, including noninterest-bearing deposits, was 0.44% for 2020 compared with 0.88% for 2019.

63

Table of Contents

Certificates of deposit, including Certificate of Deposit Account Registry Service ("CDARS") deposits, IRA deposits and brokered deposits, were $5.5 billion at December 31, 2020, compared with $7.5 billion at December 31, 2019. The maturities of certificates of deposit with denominations equal to or greater than $100,000 at December 31, 2020 were as follows:

(in thousands)
Three months or less	$	969,469
Over three through six months	971,200
Over six through 12 months	620,115
Over 12 months	218,482
Total	$	2,779,266

Borrowings Borrowings were $2.0 billion at December 31, 2020, compared with $5.0 billion at December 31, 2019. The decrease in borrowings was primarily due to a decrease in long and short-term FHLB advances, partially offset by the issuance of $150.0 million of fixed-to-floating rate subordinated notes.

Information regarding short-term borrowings (borrowings with an original maturity of less than one year) was as follows:

	At or For the Year Ended December 31,
(Dollars in thousands)	2020			2019			2018
FHLB advances
Maximum outstanding at any month-end	$	3,200,000		$	2,450,000		$	—
Balance outstanding at end of period	400,000			2,450,000			—
Weighted average interest rate at end of period	0.33		%	1.85		%	—		%
Average balance outstanding	$	1,781,421		$	1,173,879		$	—
Weighted average interest rate	0.88		%	1.69		%	—		%
Federal funds purchased
Maximum outstanding at any month-end	$	—		$	—		$	—
Balance outstanding at end of period	—			—			—
Weighted average interest rate at end of period	—		%	—		%	—		%
Average balance outstanding	$	57		$	156		$	156
Weighted average interest rate	1.78		%	2.51		%	1.91		%
Collateralized deposits
Maximum outstanding at any month-end	$	253,960		$	271,249		$	—
Balance outstanding at end of period	217,363			219,145			—
Weighted average interest rate at end of period	0.11		%	0.64		%	—		%
Average balance outstanding	$	218,745		$	103,931		$	1,977
Weighted average interest rate	0.32		%	0.67		%	2.19		%
Line-of-credit: TCF Financial Corporation
Maximum outstanding at any month-end	80,000			—			—
Balance outstanding at end of period	—			—			—
Weighted average interest rate at end of period	—		%	—		%	—		%
Average balance outstanding	22,568			—			—
Weighted average interest rate	2.40		%	—		%	—		%
Line-of-credit: TCF Commercial Finance Canada, Inc.
Maximum outstanding at any month-end	$	3,066		$	10,455		$	8,565
Balance outstanding at end of period	—			—			—
Weighted average interest rate at end of period	—		%	—		%	—		%
Average balance outstanding	$	583		$	1,107		$	1,155
Weighted average interest rate	1.93		%	3.00		%	2.63		%

64

Table of Contents

Long-term borrowings were as follows:

	At December 31,
(in thousands)	2020		2019
FHLB advances	$	709,848	$	1,822,058
Subordinated debt obligations	586,145		428,470
Discounted lease rentals	75,770		100,882
Finance lease obligation	2,969		3,038
Total long-term borrowings	$	1,374,732	$	2,354,448

On May 6, 2020, TCF Bank issued $150.0 million of fixed-to-floating rate subordinated notes (the “2030 Notes”), at par. The 2030 Notes, due May 6, 2030, bear an initial fixed interest rate of 5.50% per annum until May 6, 2025, payable semi-annually in arrears on May 6 and November 6, commencing on November 6, 2020, resetting quarterly thereafter to the then-current three-month LIBOR rate plus 509 basis points.

See "Note 15. Borrowings" of Notes to Consolidated Financial Statements for further information regarding our long-term borrowings.

Contractual Obligations and Commitments As discussed in the Notes to Consolidated Financial Statements, we have certain obligations and commitments to make future payments under contracts.

At December 31, 2020, the aggregate contractual obligations and commitments were as follows:

	Payments Due by Period
(in thousands)	Total		Less than 1 year		1-3 years		3-5 years		More than 5 years
Contractual Obligations:
Certificates of deposit	$	5,524,381	$	5,012,121	$	444,023	$	58,827	$	9,410
Long-term borrowings	1,363,757		186,318		495,908		352,590		328,941
Lease obligations(1)	366,073		27,808		58,739		50,480		229,046
IT related contracts	265,966		52,887		91,207		88,781		33,091
Investments in affordable housing	107,764		83,393		23,341		417		613
Marketing related contracts	51,451		6,105		10,332		6,756		28,258
Construction contracts and land purchase commitments for future branch sites	23,294		16,760		6,534		—		—
Liabilities related to acquisition and portfolio purchase (2)	5,203		4,149		1,054		—		—
Other contractual obligations (3)	122,503		22,409		35,999		37,667		26,428
Total	$	7,830,392	$	5,411,950	$	1,167,137	$	595,518	$	655,787

(1)Includes obligations for leases that have not yet commenced.

(2)Relates to acquisition of a leasing business in 2017.

(3)Includes card contracts, certain tax investment projects, private equity capital investments and other similar types of investments.

	Amount of Commitment - Expiration by Period
(in thousands)	Total		Less than 1 year		1-3 years		3-5 years		More than 5 years
Commitments:
Commitments to extend credit:
Commercial	$	4,396,191	$	2,001,118	$	1,564,168	$	647,046	$	183,859
Consumer	2,126,327		119,426		142,046		153,502		1,711,353
Total commitments to extend credit	6,522,518		2,120,544		1,706,214		800,548		1,895,212
Standby letters of credit and guarantees on industrial revenue bonds	114,636		78,825		27,022		8,638		151
Total	$	6,637,154	$	2,199,369	$	1,733,236	$	809,186	$	1,895,363

Unrecognized tax benefits, projected benefit obligations, demand deposits with indeterminate maturities and discretionary credit facilities that do not obligate us to lend have been excluded from the contractual obligations table above.

65

Table of Contents

Capital Management  We are committed to managing capital to maintain protection for shareholders, depositors and creditors. We employ a variety of capital management tools to achieve our capital goals, including, but not limited to, dividends, public offerings of preferred and common stock, common stock repurchases, redemption of preferred stock and the issuance or redemption of subordinated debt and other capital instruments. We maintain a Capital Planning and Dividend Policy which applies to TCF Financial and incorporates TCF Bank's Capital Planning and Dividend Policy. These policies are intended to ensure that capital strategy actions, including the addition of new capital, if needed, common stock repurchases, redemption of preferred stock or the declaration of preferred stock, common stock and bank dividends are prudent, efficient and provide value to our shareholders, while ensuring that past and prospective earnings retention is consistent with our capital needs for growth, as well as asset quality and overall financial condition. TCF Financial and TCF Bank manage capital levels to exceed all regulatory capital requirements.

On October 24, 2019, our board of directors approved an authorization to repurchase up to $150 million of our common stock. The repurchase program has no expiration, and permits shares to be repurchased in compliance with Rule 10b-18 of the Exchange Act, through one or more broker-dealers as part of “block purchases” made by TCF, and/or through privately negotiated purchases, accelerated stock repurchase agreements, or Rule 10b5-1 plans at our discretion. During the year ended December 31, 2020, we repurchased 873,376 shares of our common stock totaling $33.1 million, all of which occurred during the first quarter. Between October 24, 2019 and December 31, 2019, we repurchased 657,817 shares of our common stock totaling $27.5 million. We have $89.4 million available for repurchase under the repurchase program. In accordance with the TCF/Huntington Merger Agreement, we are not permitted to repurchase shares of common stock without Huntington's prior approval.

Effective January 1, 2020, the Corporation adopted CECL. Consistent with the treatment of the ACL under the capital rule’s standardized approach, the ALLL (excluding PCD loans) and RULC are eligible for inclusion in TCF’s Tier 2 capital up to 1.25 percent of standardized total risk weighted assets. In response to the COVID-19 pandemic, the regulatory agencies published a final rule that provides the option to delay the cumulative effect of the day 1 impact of CECL adoption on regulatory capital, along with 25% of the change in the adjusted allowance for credit losses (as computed for regulatory capital purposes which excludes PCD loans), for two years, followed by a three-year phase-in period. Management elected the 5-year transition period consistent with the final rule issued by the regulatory agencies.

At December 31, 2020 and December 31, 2019, TCF Bank's capital ratios exceeded the quantitative capital ratios required for an institution to be considered "well-capitalized." Significant factors that may affect capital adequacy include, but are not limited to, economic uncertainty, deteriorating economic conditions, a disproportionate growth in assets versus capital and a change in mix or credit quality of assets. There are no conditions or events since December 31, 2020 that management believes have changed TCF Bank's status as well-capitalized. See "Note 18. Regulatory Capital Requirements" of Notes to Consolidated Financial Statement for further information.

Equity  Total equity was $5.7 billion, or 11.9% of total assets, at December 31, 2020, compared with $5.7 billion, or 12.3% of total assets, at December 31, 2019.

Preferred Stock Preferred stock was $169.3 million at both December 31, 2020 and December 31, 2019. See "Note 17. Equity" of Notes to Consolidated Financial Statements for further information regarding our preferred stock.

Other Other equity was a reduction to total equity of $26.7 million at December 31, 2020, compared with a reduction of $28.0 million at December 31, 2019. Other equity was comprised of shares held in trust for deferred compensation plans. See "Note 17. Equity" of Notes to Consolidated Financial Statements for further information.

Common Stock Dividends Dividends to common shareholders on a per share basis were $1.40 for the year ended December 31, 2020. Dividends to common shareholders on a per share basis, adjusted to reflect the exchange ratio in the TCF/Chemical Merger Exchange for dividends paid prior to the completion of the TCF/Chemical Merger, were $1.29 for the year ended December 31, 2019. Our common stock dividend payout ratio was 100.0% for the year ended December 31, 2020, compared with 50.4% for the year ended December 31, 2019 and 34.3% for the year ended December 31, 2018. TCF Financial's primary funding sources for dividends are dividends received from TCF Bank.

66

Table of Contents

On January 26, 2021, our board of directors declared a regular quarterly cash dividend of $0.35 per common share payable on March 1, 2021 to shareholders of record at the close of business on February 12, 2021, and declared a quarterly cash dividend of $0.35625 per depositary share representing a 1/1,000th interest in a share of the 5.70% Series C Non-Cumulative Perpetual Preferred Stock, payable on March 1, 2021 to shareholders of record at the close of business on February 12, 2021.

Common Shareholders' Equity Total common shareholders' equity was $5.5 billion, or 11.51% of total assets, at December 31, 2020, compared with $5.5 billion, or 11.87%, at December 31, 2019. Tangible common equity was $4.0 billion, or 8.72% of total tangible assets, at December 31, 2020, compared with $4.1 billion, or 9.01%, at December 31, 2019. Book value per common share was $36.06 at December 31, 2020, compared with $36.20 at December 31, 2019. Tangible book value per common share was $26.49 at December 31, 2020, compared with $26.60 at December 31, 2019. Tangible common equity and tangible book value are non-GAAP measures that exclude goodwill and other intangible assets. See "Consolidated Financial Condition Analysis — Non-GAAP Financial Measures" in this Management's Discussion and Analysis for further information.

Non-GAAP Financial Measures This Annual Report on Form 10-K contains references to financial measures that are not defined in GAAP. Such non-GAAP financial measures include our tangible book value per common share; tangible common shareholders' equity; presentation of net interest income and net interest margin on a fully tax-equivalent ("FTE") basis; our adjusted efficiency ratio (which excludes merger-related expenses, sale of legacy TCF auto finance portfolio and related expenses, gains on sales of branches, termination of interest rate swaps, write-down of company-owned vacant land parcels and branch exit costs, gain on sale of certain investment securities, pension fair valuation adjustment, loan servicing rights and goodwill impairment, the impact of the Tax Cuts and Jobs Act, CFPB/OCC settlement adjustment, lease financing equipment depreciation, net interest income FTE adjustment, amortization of intangible assets and historic tax credit amortization); composition of loans and leases, excluding PPP loans, the adjusted allowance for credit losses as a percentage of loans and leases, excluding PPP loans; adjusted net interest income and margin (which excludes purchased accounting accretion and amortization and the impact of PPP loans); and other adjusted information presented excluding merger-related expenses and notable items (defined as sale of legacy TCF auto finance portfolio and related expenses, gains on sales of branches, termination of interest rate swaps, write-down of company-owned vacant land parcels and branch exit costs, gain on sales of certain investment securities, pension fair valuation adjustment, loan servicing rights and goodwill impairment and CFPB/OCC settlement adjustment) including net income, diluted earnings per share, return on average assets, return on average common shareholders' equity and return on average tangible common shareholders' equity), tangible book value per common share and tangible common equity to tangible assets. Management believes that the presentation of these non-GAAP financial measures (i) provides important supplemental information that contributes to a proper understanding of our operating performance, (ii) enables a more complete understanding of factors and trends affecting our business and (iii) allows investors to evaluate our performance in a manner similar to management, the financial services industry, bank stock analysts, and bank regulators. Management uses non-GAAP financial measures internally in the preparation of our operating budgets, monthly financial performance reporting, and in our presentation to investors of our performance. Non-GAAP financial measures are not defined by GAAP and other entities may calculate them differently than we do. Non-GAAP financial measures have inherent limitations and are not required to be uniformly applied. Although these non-GAAP financial measures are frequently used by stakeholders in the evaluation of a company, they have limitations as analytical tools and should not be considered in isolation or as a substitute for analyses of results as reported under GAAP.

The following tables provide a reconciliation of each non-GAAP financial measure to the most directly comparable GAAP financial measure. A reconciliation of net interest income and net interest margin (FTE) to the most directly comparable GAAP financial measure can be found within the Net Interest Income subheading of this Annual Report on Form 10-K.

67

Table of Contents

The computation of the adjusted diluted earnings per common share and adjusted net income attributable to TCF was as follows:

		Year Ended December 31,
(Dollars in thousands, except per share data)		2020		2019		2018		2017		2016
Net income available to common shareholders		$	212,784	$	285,493	$	289,289	$	242,954	$	192,736
Earnings allocated to participating securities		—		(20)		(42)		(42)		(49)
Earnings allocated to common shareholders	(a)	212,784		285,473		289,247		242,912		192,687
Merger-related expenses		203,888		171,968		—		—		—
Notable items:
Sale of Legacy TCF auto finance portfolio and related expenses(1)		3,964		32,128		—		—		—
Termination of interest rate swaps(2)		—		17,302		—		—		—
Gain on sale of certain investment securities(3)		—		(5,869)		—		—		—
Gains on sales of branches, write-down of company-owned vacant land parcels and branch exit costs, net(4)		(14,166)		9,384		—		—		—
Loan servicing rights impairment(2)		17,605		3,882		—		—		—
Pension fair valuation adjustment(5)		—		6,341		—		—		—
CFPB/OCC settlement adjustment(5)		—		—		32,000		—		—
Re-measurement of net deferred tax liability(6)		—		—		—		(130,653)		—
Goodwill impairment(5)		—		—		—		73,041
Total notable items		7,403		63,168		32,000		(57,612)		—
Total merger-related items and notable items		211,291		235,136		32,000		(57,612)		—
Related income tax expense, net of benefits(7)		(44,583)		(69,372)		(6,491)		—		—
Total adjustments, net of tax		166,708		165,764		25,509		(57,612)		—
Adjusted earnings allocated to common stock	(b)	$	379,492	$	451,237	$	314,756	$	185,300	$	192,687
Weighted-average common shares outstanding used in diluted earnings per common share calculation(8)	(c)	151,887,559		111,818,365		84,324,686		85,734,575		85,006,293
Diluted earnings per common share	(a) / (c)	$	1.40	$	2.55	$	3.43	$	2.83	$	2.27
Adjusted diluted earnings per common share	(b) / (c)	2.50		4.04		3.73		2.16		2.27
Net income attributable to TCF		$	222,759	$	295,468	$	304,358	$	268,637	$	212,124
Total adjustments, net of tax		166,708		165,764		25,509		(57,612)		—
Adjusted net income attributable to TCF		$	389,467	$	461,232	$	329,867	$	211,025	$	212,124

(1)Year ended December 31, 2020 amount included within occupancy and equipment ($1.6 million), other noninterest expense ($1.4 million) and compensation and employee benefits ($1.0 million). Year ended December 31 2019 amount included within net gains on sales of loans and leases ($27.5 million) (inclusive of the transfer of the Legacy TCF auto finance portfolio in the third quarter of 2019), other noninterest expense ($2.2 million), occupancy and equipment ($1.5 million) and compensation and employee benefits ($930 thousand).

(2)Included within other noninterest income.

(3)Included within net gains on investment securities.

(4)Year ended December 31, 2020 amount included within other noninterest income ($14.7 million net gain) and other noninterest expense ($0.6 million). Year ended December 31, 2019 amount included within other noninterest expense.

(5)Included within other noninterest expense.

(6)Includes the impact of the re-measurement of our estimated net deferred tax liability as a result of the enactment of the Tax Cuts and Jobs Act.

(7)Included within income tax expense.

(8)Assumes conversion of common shares, as applicable.

68

Table of Contents

The computation of the adjusted net interest income and margin was as follows:

	Year Ended December 31,
(Dollars in thousands, except per share data)	2020			2019			2018
Net Interest Income	$	1,538,401		$	1,289,032		$	1,008,495
Adjustments for taxable equivalent interest (FTE)	12,087			8,443			8,369
Net interest income (FTE)	1,550,488			1,297,475			1,016,864
Purchase accounting accretion and amortization	(84,174)			(58,934)			—
Net fees recognized on PPP loans	(35,762)			—			—
Interest recognition on PPP loans(1)	(7,634)			—			—
Total PPP loans impact	(43,396)			—			—
Adjusted net interest income, including FTE adjustments and excluding purchase accounting accretion and amortization and PPP impact	$	1,422,918		$	1,238,541		$	1,016,864
Net interest margin (GAAP)	3.47		%	4.17		%	4.66		%
FTE impact	0.03			0.03			0.03
Net interest margin (FTE)	3.50			4.20			4.69		%
Purchase accounting accretion and amortization	(0.29)			(0.26)			—
PPP loans impact(2)	—			—			—
Adjusted net interest margin, excluding purchase accounting accretion and amortization and PPP loans impact (FTE)	3.21		%	3.94		%	4.69		%

(1)Interest income on PPP loans less funding costs.

(2)The exclusion of PPP loans additionally reduces average earning assets by $1.2 billion in the year ended December 31, 2020.

69

Table of Contents

The computation of the adjusted return on average assets, common equity and average tangible common equity was as follows:

		Year Ended December 31,
(Dollars in thousands)		2020			2019			2018			2017			2016
Adjusted net income after tax expense:
Income after tax expense	(a)	$	230,041		$	306,926		$	315,628		$	278,784		$	221,717
Merger-related expenses		203,888			171,968			—			—			—
Notable items		7,403			63,168			32,000			(57,612)			—
Related income tax expense, net of tax benefits		(44,583)			(69,372)			(6,491)			—			—
Adjusted net income after tax expense for ROAA calculation	(b)	$	396,749		$	472,690		$	341,137		$	221,172		$	221,717
Net income available to common shareholders	(c)	$	212,784		$	285,493		$	289,289		$	242,954		$	192,736
Other intangibles amortization		21,992			11,660			3,417			2,345			1,388
Related income tax expense		(4,678)			(2,752)			(799)			(1,046)			(493)
Net income available to common shareholders used in ROATCE calculation	(d)	$	230,098		$	294,401		$	291,907		$	244,253		$	193,631
Adjusted net income available to common shareholders:
Net income available to common shareholders		$	212,784		$	285,493		$	289,289		$	242,954		$	192,736
Notable items		7,403			63,168			32,000			(57,612)			—
Merger-related expenses		203,888			171,968			—			—			—
Related income tax expense, net of tax benefits		(44,583)			(69,372)			(6,491)			—			—
Net income available to common shareholders used in adjusted ROACE calculation	(e)	379,492			451,257			314,798			185,342			192,736
Other intangibles amortization		21,992			11,660			3,417			2,345			1,388
Related income tax expense		(4,678)			(2,752)			(799)			(1,046)			(493)
Net income available to common shareholders used in adjusted ROATCE calculation	(f)	$	396,806		$	460,165		$	317,416		$	186,641		$	193,631
Average balances:
Average assets	(g)	$	48,400,938		$	33,526,930		$	23,062,148		$	22,051,967		$	21,075,415
Total average equity		5,673,573			3,915,038			2,530,502			2,535,938			2,394,701
Non-controlling interest in subsidiaries		(24,006)			(25,834)			(24,323)			(22,514)			(21,525)
Total TCF Financial Corporation shareholders' equity		5,649,567			3,889,204			2,506,179			2,513,424			2,373,176
Preferred stock		(169,302)			(169,302)			(176,971)			(264,474)			(263,240)
Average total common shareholders' equity used in ROACE calculation	(h)	$	5,480,265		$	3,719,902		$	2,329,208		$	2,248,950		$	2,109,936
Average goodwill, net		(1,310,071)			(620,253)			(154,757)			(219,144)			(225,640)
Average other intangibles, net		(157,824)			(99,038)			(22,136)			(12,799)			(2,379)
Average tangible common shareholders' equity used in ROATCE calculation	(i)	$	4,012,370		$	3,000,611		$	2,152,315		$	2,017,007		$	1,881,917
ROAA	(a)/(g)	0.48		%	0.92		%	1.37		%	1.26		%	1.05		%
Adjusted ROAA	(b)/(g)	0.82			1.41			1.48			1.00			1.05
ROACE	(c)/(h)	3.88			7.67			12.42			10.80			9.13
Adjusted ROACE	(e)/(h)	6.92			12.13			13.51			8.24			9.13
ROATCE	(d)/(i)	5.73			9.81			13.56			12.11			10.29
Adjusted ROATCE	(f)/(i)	9.88			15.34			14.74			9.25			10.29

70

Table of Contents

The computation of the adjusted efficiency ratio, noninterest income and noninterest expense was as follows:

		Year Ended December 31,
(Dollars in thousands)		2020			2019			2018			2017			2016
Noninterest expense	(a)	$	1,527,371		$	1,332,115		$	1,014,400		$	1,059,934		$	909,887
Merger-related expenses		(203,888)			(171,968)			—			—			—
Expenses related to the sale of Legacy TCF auto finance portfolio		(3,964)			(4,670)			—			—			—
CFPB/OCC settlement adjustment		—			—			(32,000)			—			—
Write-down of company-owned vacant land parcels and branch exit costs		(551)			(9,384)			—			—			—
Pension fair valuation adjustment		—			(6,341)			—			—
Goodwill impairment		—			—			—			(73,041)			—
Adjusted noninterest expense		$	1,318,968		$	1,139,752		$	982,400		$	986,893		$	909,887
Lease financing equipment depreciation		(73,204)			(76,426)			(73,829)			(55,901)			(40,359)
Amortization of intangibles		(21,992)			(11,660)			(3,417)			(2,345)			(1,388)
Historic tax credit amortization		(7,050)			(4,030)			—			—			—
Adjusted noninterest expense, efficiency ratio	(b)	$	1,216,722		$	1,047,636		$	905,154		$	928,647		$	868,140
Net interest income		$	1,538,401		$	1,289,032		$	1,008,495		$	937,474		$	859,725
Noninterest income		516,063			465,532			454,397			436,063			454,281
Total revenue	(c)	$	2,054,464		$	1,754,564		$	1,462,892		$	1,373,537		$	1,314,006
Noninterest income		$	516,063		$	465,532		$	454,397		$	436,063		$	454,281
Loss on transfer of Legacy TCF auto finance portfolio to held-for-sale		—			27,458			—			—			—
Termination of interest rate swaps		—			17,302			—			—			—
Gain on sales of certain investment securities		—			(5,869)			—			—			—
Gain on sales of branches		(14,717)			—			—			—			—
Loan servicing rights impairment		17,605			3,882			—			—			—
Adjusted noninterest income		518,951			508,305			454,397			436,063			454,281
Net interest income		1,538,401			1,289,032			1,008,495			937,474			859,725
Net interest income FTE adjustment		12,087			8,443			8,369			14,542			10,813
Adjusted net interest income		1,550,488			1,297,475			1,016,864			952,016			870,538
Lease financing equipment depreciation		(73,204)			(76,426)			(73,829)			(55,901)			(40,359)
Adjusted total revenue, efficiency ratio	(d)	$	1,996,235		$	1,729,354		$	1,397,432		$	1,332,178		$	1,284,460
Efficiency ratio	(a)/(c)	74.34		%	75.92		%	69.34		%	77.17		%	69.25		%
Adjusted efficiency ratio	(b)/(d)	60.95			60.58			64.77			69.71			67.59

71

Table of Contents

The computations of tangible common equity to tangible assets and tangible book value per common share were as follows:

		At December 31,
(Dollars in thousands, except per share data)		2020			2019			2018			2017			2016
Total equity		$	5,689,297		$	5,727,241		$	2,556,260		$	2,680,584		$	2,444,645
Non-controlling interest in subsidiaries		(18,484)			(20,226)			(18,459)			(17,827)			(17,162)
Total TCF Financial Corporation shareholders' equity		5,670,813			5,707,015			2,537,801			2,662,757			2,427,483
Preferred stock		(169,302)			(169,302)			(169,302)			(265,821)			(263,240)
Total common shareholders' equity	(a)	5,501,511			5,537,713			2,368,499			2,396,936			2,164,243
Goodwill, net		(1,313,046)			(1,299,878)			(154,757)			(154,757)			(225,640)
Other intangibles, net		(146,377)			(168,368)			(20,496)			(23,662)			(1,708)
Tangible common shareholders' equity	(b)	$	4,042,088		$	4,069,467		$	2,193,246		$	2,218,517		$	1,936,895
Total assets	(c)	$	47,802,487		$	46,651,553		$	23,699,612		$	23,002,159		$	21,441,326
Goodwill, net		(1,313,046)			(1,299,878)			(154,757)			(154,757)			(225,640)
Other intangibles, net		(146,377)			(168,368)			(20,496)			(23,662)			(1,708)
Tangible assets	(d)	$	46,343,064		$	45,183,307		$	23,524,359		$	22,823,740		$	21,213,978
Common stock shares outstanding	(e)	152,565,504			152,965,571			83,289,382			87,225,232			86,881,005
Common equity to assets	(a)/(c)	11.51		%	11.87		%	9.99		%	10.42		%	10.09		%
Tangible common equity to tangible assets	(b)/(d)	8.72			9.01			9.32			9.72			9.13
Book value per common share	(a)/(e)	$	36.06		$	36.20		$	28.44		$	27.48		$	24.91
Tangible book value per common share	(b)/(e)	26.49			26.60			26.33			25.43			22.29

The computations of loans and leases and the related allowance for credit losses excluding PPP loans were as follows:

	At December 31,				Change from December 31, 2019
(Dollars in thousands)	2020		2019		$		%
Commercial and industrial	$	11,422,383	$	11,439,602	$	(17,219)	(0.2)%
Commercial real estate	9,702,587		9,136,870		565,717		6.2
Lease financing	2,817,231		2,699,869		117,362		4.3
Total commercial loan and lease portfolio	23,942,201		23,276,341		665,860		2.9
Residential mortgage	6,182,045		6,179,805		2,240		—
Home equity	3,108,736		3,498,907		(390,171)		(11.2)
Consumer installment	1,233,426		1,542,411		(308,985)		(20.0)
Total consumer loan portfolio	10,524,207		11,221,123		(696,916)		(6.2)
Total loans and leases	34,466,408		34,497,464		(31,056)		(0.1)
PPP (Commercial and industrial)	1,553,908		—		1,553,908		N.M.
Loans and leases excluding PPP loans
Commercial and industrial	9,868,475		11,439,602		(1,571,127)		(13.7)
Commercial real estate	9,702,587		9,136,870		565,717		6.2
Lease financing	2,817,231		2,699,869		117,362		4.3
Total commercial loan and lease portfolio	22,388,293		23,276,341		(888,048)		(3.8)
Residential mortgage	6,182,045		6,179,805		2,240		—
Home equity	3,108,736		3,498,907		(390,171)		(11.2)
Consumer installment	1,233,426		1,542,411		(308,985)		(20.0)
Total consumer loan portfolio	10,524,207		11,221,123		(696,916)		(6.2)
Total loans and leases, excluding PPP loans	$	32,912,500	$	34,497,464	$	(1,584,964)	(4.6)%
Allowance for credit losses	$	549,181	$	116,580	$	432,601	N.M.
Allowance for credit losses as a % of total loans and leases	1.59%		0.34%		125		bps
Allowance for credit losses as a % of loans and leases, excluding PPP loans	1.67		0.34		133

72

Table of Contents

Recent Accounting Developments

For a description of new accounting standards issued, but not yet adopted, see "Note 2. Summary of Significant Accounting Policies" of Notes to Consolidated Financial Statements.

Item 7A. Quantitative and Qualitative Disclosures About Market Risk

Our results of operations depend, to a large degree, on our net interest income and our ability to manage interest rate risk. Although we manage other risks in the normal course of business, such as credit risk, liquidity risk and foreign currency risk, we consider interest rate risk to be one of our more significant market risks.

Interest Rate Risk

Our ALCO and the Finance Committee of our Board of Directors have established interest rate risk policy limits. Interest rate risk is defined as the exposure of net interest income and fair value of financial instruments (interest earning assets, deposits and borrowings) to movements in interest rates. The major sources of our interest rate risk are timing differences in the maturity and repricing characteristics of assets and liabilities, changes in the shape of the yield curve, changes in consumer behavior and changes in relationships between rate indices (basis risk). Management measures these risks and their impact in various ways, including through the use of simulation and valuation analyses. The interest rate scenarios may include gradual or rapid changes in interest rates, spread narrowing and widening, yield curve twists and changes in assumptions about consumer behavior in various interest rate scenarios. A mismatch between maturities, interest rate sensitivities and prepayment characteristics of assets and liabilities results in interest rate risk. We, like most financial institutions, have material interest rate risk exposure to changes in both short- and long-term interest rates, as well as variable interest rate indices (e.g., the prime rate or London Interbank Offered Rate).

Our ALCO is responsible for reviewing our interest rate sensitivity position and establishing policies to monitor and limit exposure to interest rate risk. ALCO manages our interest rate risk based on interest rate expectations and other factors. The principal objective in managing our assets and liabilities is to provide maximum levels of net interest income and facilitate our funding needs, while maintaining acceptable levels of interest rate risk and liquidity risk.

ALCO primarily uses two interest rate risk tools with policy limits to evaluate our interest rate risk: net interest income simulation and economic value of equity ("EVE") analysis.

Management utilizes net interest income simulation models to estimate the near-term effects of changing interest rates on our net interest income. Net interest income simulation involves forecasting net interest income under a variety of scenarios, including the level of interest rates, the shape of the yield curve and the spreads between market interest rates. Management exercises best judgment in making assumptions regarding events that management can influence, such as non-contractual deposit repricings and events outside management's control, including consumer behavior on loan and deposit activity and the effect that competition has on both loan and deposit pricing. These assumptions are subjective and, as a result, net interest income simulation results will differ from actual results due to the timing, magnitude and frequency of interest rate changes and changes in market conditions, consumer behavior and management strategies, among other factors. We perform various sensitivity analyses on new loan spreads, prepayment rates, basis risk and deposit assumptions.

The following table presents changes in our net interest income over a twelve month period if short- and long-term interest rates were to sustain an immediate change. These projections were based on our assets and liabilities remaining static over the next twelve months and factored into the simulation model.

	Impact on Net Interest Income
(Dollars in thousands)	December 31, 2020				December 31, 2019
Immediate change in interest rates:
+200 basis points	$	61,700	4.2	%	$	32,200	2.1	%
+100 basis points	32,700		2.2		20,900		1.4
-100 basis points(1)	(39,500)		(2.7)		(60,900)		(4.0)

(1) Sensitivity measure is calculated assuming market rates do not decline below 0%.

73

Table of Contents

The increases in sensitivity to rising rates at December 31, 2020, compared to December 31, 2019, was primarily driven by increased deposits, lower wholesale borrowing and overall lower rate environment. The decrease in sensitivity to a declining rate at December 31, 2020, compared to December 31, 2019, is primarily driven by a lower rate environment. The sensitivity measure is calculated assuming market rates do not decline below 0%. It is expected that a rate below 0% could cause further net interest income compression.

Management also uses EVE to measure risk in the balance sheet that might not be taken into account in the net interest income simulation analysis. Net interest income simulation highlights exposure over a relatively short time period, while EVE analysis incorporates all cash flows over the estimated remaining life of all balance sheet positions. The valuation of the balance sheet, at a point in time, is defined as the discounted present value of asset cash flows minus the discounted present value of liability cash flows. EVE analysis addresses only the current balance sheet and does not incorporate the planned changes to assets or liabilities. As with the net interest income simulation model, EVE analysis is based on key assumptions about the timing and variability of balance sheet cash flows and does not take into account any potential responses by management to anticipated changes in interest rates.

Credit Risk

Credit risk is defined as the risk to our current or anticipated earnings or capital arising from an obligor's failures to meet the terms of any contract with us or otherwise failing to perform as agreed, such as the failure of customers and counterparties to meet their contractual obligations, as well as contingent exposures from unfunded loan commitments and letters of credit.

Our Enterprise Risk Management Committee meets at least quarterly and is responsible for monitoring the loan and lease portfolio composition and risk tolerance within the various segments of the portfolio. The Enterprise Risk Management Committee and TCF Financial's Board of Directors have adopted a Risk Appetite Statement to manage our credit risk by setting (i) a desired balance between asset classes, (ii) concentration limits based on loan type and business line and (iii) maximum tolerances for credit performance. To manage credit risk arising from lending and leasing activities, management has adopted and maintains underwriting policies and procedures and periodically reviews the appropriateness of these policies and procedures. Customers and guarantors or recourse providers are evaluated as part of initial underwriting processes and through periodic reviews. For consumer loans, credit scoring models are used to help determine eligibility for credit and terms of credit. These models are periodically reviewed to verify that they are predictive of borrower performance. Limits are established on the exposure to a single customer (including affiliates) and on concentrations for certain categories of customers. Loan and lease credit approval levels are established so that larger credit exposures receive managerial review at the appropriate level through the credit committees.

Management continuously monitors asset quality in order to manage our credit risk and to determine the appropriateness of valuation allowances, including, in the case of commercial loans, inventory finance loans and equipment finance loans and leases, a risk rating methodology under which a rating of one through nine is assigned to each loan or lease. The rating reflects management's assessment of the potential impact on repayment of the customer's financial and operational condition. Asset quality is monitored separately based on the type or category of loan or lease. The rating process allows management to better define our loan and lease portfolio risk profile. Management also uses various risk models to estimate probable impact on payment performance under various scenarios, both expected and unexpected.

We also have credit risk in our investment securities available-for-sale portfolio related to obligations of states and political subdivisions and non-agency collateralized mortgage obligations. We maintain a set of underwriting criteria and regularly monitor credit performance under the direction and supervision of the TCF Bank Credit Committee to manage this risk. The remainder of the investment securities available-for-sale portfolio and the investment securities held-to-maturity portfolio consist primarily of fixed-rate mortgage-backed securities issued and guaranteed by the FNMA and the FHLMC, and therefore credit risk is minimal. All investment related counterparties and transaction limits are reviewed and approved annually by both ALCO and the TCF Bank Credit Committee.

74

Table of Contents

Liquidity Risk

Liquidity risk is defined as the risk to earnings or capital arising from our inability to meet our obligations when they come due without incurring unacceptable losses.

TCF Financial's primary source of cash flow is capital distributions from TCF Bank. TCF Bank may be required to receive regulatory approval prior to making any such distributions in the future and such distributions may be restricted by its federal banking regulators. TCF Bank's ability to make any such distributions will also depend on its earnings and ability to meet minimum regulatory capital requirements in effect during future periods. See "Item 1. Business - Regulation - Restrictions on Distributions", "Note 18. Regulatory Capital Requirements" and "Note 29. Parent Company Financial Information" of Notes to Consolidated Financial Statements for further information.

TCF Financial's Board of Directors have adopted a Liquidity Management Policy for TCF Bank to direct management of TCF's liquidity risk. The objective of the Liquidity Management Policy is to ensure that TCF Bank meets its cash and collateral obligations promptly, in a cost-effective manner and with the highest degree of reliability. The maintenance of adequate levels of asset and liability liquidity will provide us with the ability to meet both expected and unexpected cash flows and collateral needs. Key liquidity ratios, asset liquidity levels and the amount available from funding sources are reported to ALCO on a monthly basis. TCF Bank's Liquidity Management Policy defines liquidity stress scenarios and establishes asset liquidity target ranges based on those stress scenarios that are deemed appropriate for its risk profile.

Our asset liquidity may be held in the form of on-balance sheet cash invested with the Federal Reserve Bank or other highly liquid marketable securities that are not pledged and can be sold or pledged to various counterparties under established agreements. Our liability liquidity is sourced primarily through deposits and other secured sources of funding. See "Item 7. Management's Discussion and Analysis - Consolidated Results of Operations Analysis - Liquidity Management" for further information.

Foreign Currency Risk

We are also exposed to foreign currency risk as changes in the exchange rates of the Canadian, New Zealand and Australian dollars may impact our investment in TCFCFC. We enter into forward foreign exchange contracts in order to minimize the risk of changes in foreign exchange rates on its investment in and loans to TCFCFC. The values of forward foreign exchange contracts vary over their contractual lives as the related currency exchange rates fluctuate. We may also experience realized and unrealized gains or losses on forward foreign exchange contracts as a result of changes in foreign exchange rates. See "Note 2. Summary of Significant Accounting Policies" and "Note 19. Derivative Instruments" of Notes to Consolidated Financial Statements for further information.

LIBOR Transition

In 2017, the U.K. Financial Conduct Authority (the “FCA”) noted that market conditions raised serious questions about the future sustainability of LIBOR benchmarks. Many financial products, including mortgages and other consumer loans, commercial loans, corporate loans, various types of debt, derivatives and other securities, reference LIBOR to determine their applicable interest rate. As part of the expected upcoming cessation of publication of LIBOR rates, TCF created a company-wide LIBOR transition plan and has already taken several important steps to ensure TCF’s operational readiness for the transition, including completing an inventory of existing LIBOR-indexed products and developing LIBOR fallback language for inclusion in loans that contemplates the transition away from LIBOR. As part of our plan, we have and will continue to engage with industry working groups and regulators in order to monitor and respond to risks associated with the discontinuation, unavailability, or non-representativeness of LIBOR, and will continue to actively engage with our clients to facilitate the transition to alternative reference rates.

75

Table of Contents

Item 8. Financial Statements and Supplementary Data

Report of Independent Registered Public Accounting Firm

To the Shareholders and Board of Directors

TCF Financial Corporation:

Opinion on the Consolidated Financial Statements

We have audited the accompanying consolidated statements of financial condition of TCF Financial Corporation and subsidiaries (the Corporation) as of December 31, 2020 and 2019, the related consolidated statements of income, comprehensive income, equity, and cash flows for each of the years in the three-year period ended December 31, 2020, and the related notes (collectively, the consolidated financial statements). In our opinion, the consolidated financial statements present fairly, in all material respects, the financial position of the Corporation as of December 31, 2020 and 2019, and the results of its operations and its cash flows for each of the years in the three-year period ended December 31, 2020, in conformity with U.S. generally accepted accounting principles.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), the Corporation’s internal control over financial reporting as of December 31, 2020, based on criteria established in Internal Control – Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission, and our report dated February 26, 2021 expressed an unqualified opinion on the effectiveness of the Corporation’s internal control over financial reporting.

Change in Accounting Principle

As discussed in Note 2 to the consolidated financial statements, the Corporation has changed its method of accounting for the recognition and measurement of credit losses as of January 1, 2020 due to the adoption of ASU No. 2016-13, Financial Instruments - Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments.

Basis for Opinion

These consolidated financial statements are the responsibility of the Corporation’s management. Our responsibility is to express an opinion on these consolidated financial statements based on our audits. We are a public accounting firm registered with the PCAOB and are required to be independent with respect to the Corporation in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the consolidated financial statements are free of material misstatement, whether due to error or fraud. Our audits included performing procedures to assess the risks of material misstatement of the consolidated financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the consolidated financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the consolidated financial statements. We believe that our audits provide a reasonable basis for our opinion.

Critical Audit Matter

The critical audit matter communicated below is a matter arising from the current period audit of the consolidated financial statements that was communicated or required to be communicated to the audit committee and that: (1) relates to accounts or disclosures that are material to the consolidated financial statements and (2) involved our especially challenging, subjective, or complex judgments. The communication of a critical audit matter does not alter in any way our opinion on the consolidated financial statements, taken as a whole, and we are not, by communicating the critical audit matter below, providing a separate opinion on the critical audit matter or on the accounts or disclosures to which it relates.

76

Table of Contents

Allowance for loan and lease losses evaluated on a collective basis

As discussed in Notes 2 and 8 to the consolidated financial statements, the Corporation adopted Topic 326 as of January 1, 2020. The total allowance for credit losses (ACL) as of January 1, 2020 and December 31, 2020 was $337.3 million and $549.2 million, respectively; a portion of which related to the allowance for loan and lease losses evaluated on a collective basis (together, the collective ALLL). The Corporation’s estimate of the collective ALLL uses a current expected credit losses methodology that consists of both quantitative and qualitative loss components. The Corporation estimates the quantitative component by segmenting the loan and lease portfolio into pools of loans and leases with similar risk characteristics. Expected credit losses for the quantitative component of the collective ALLL are calculated as the product of (i) probability of default (PD), (ii) loss given default (LGD), and (iii) exposure at default (EAD) on an undiscounted basis. The PD and LGD incorporate a single economic forecast scenario and macroeconomic assumptions over a reasonable and supportable forecast period. Following the reasonable and supportable forecast period, the Corporation reverts on a straight-line basis over the reversion period to its historical loss rates for the remaining life of the respective loans and leases. The historical loss rates are determined based on loss data evaluated over the historical observation periods. The Corporation estimates the EAD using a prepayment methodology which projects prepayments over the life of the loans and leases. The qualitative component of the collective ALLL is comprised of adjustments for economic conditions and asset-specific risk characteristics to the extent they do not exist in the historical loss information. These adjustments are based on qualitative factors not reflected in the quantitative component and impact the measurement of expected credit losses.

We identified the assessment of the January 1, 2020 collective ALLL and December 31, 2020 collective ALLL as a critical audit matter. A high degree of audit effort, including specialized skills and knowledge, and subjective and complex auditor judgment was involved in the assessment due to measurement uncertainty. Specifically, the assessment encompassed the evaluation of the collective ALLL methodology, including the (1) models used to estimate the PD and LGD, (2) determination of portfolio segmentation, (3) credit risk rating assumptions for commercial loans and leases, (4) selection of the economic forecast scenario and macroeconomic assumptions, (5) determination of the length of the reasonable and supportable forecast and reversion periods, and (6) qualitative adjustments. The assessment also included an evaluation of the conceptual soundness and performance of the PD and LGD models. In addition, auditor judgment was required to evaluate the sufficiency of audit evidence obtained.

The following are the primary procedures we performed to address this critical audit matter. We evaluated the design and tested the operating effectiveness of certain internal controls related to the Corporation’s measurement of the collective ALLL estimates, including controls over the:

–development of the collective ALLL methodology

–development of the PD and LGD models

–performance monitoring of the PD and LGD models for the December 31, 2020 collective ALLL

–identification and determination of the assumptions used in the quantitative component of the collective ALLL methodology

–development of the adjustments for qualitative factors

–analysis of the ACL results, trends, and ratios.

We evaluated the Corporation’s process to develop the collective ALLL estimates by testing certain sources of data and assumptions that the Corporation used, and we considered the relevance and reliability of such data and assumptions. In addition, we involved credit risk professionals with specialized skills and knowledge, who assisted in:

–evaluating the Corporation’s collective ALLL methodology for compliance with U.S. generally accepted accounting principles

–evaluating judgments made by the Corporation relative to the development and performance testing of the PD and LGD models by comparing them to relevant Corporation specific metrics and trends and the applicable industry and regulatory practices

–assessing the conceptual soundness of the PD and LGD models by inspecting the model documentation to determine whether the models are suitable for their intended use

–evaluating the selection of the economic forecast scenario and related macroeconomic assumptions by comparing it to the Corporation’s business environment, relevant industry practices and publicly available forecasts

77

Table of Contents

–evaluating the length of the reasonable and supportable forecast and reversion periods by comparing them to specific portfolio risk characteristics and trends

–determining whether the loan and lease portfolios are segmented by similar risk characteristics by comparing to the Corporation’s business environment and relevant industry practices

–testing individual credit risk ratings for a selection of certain commercial loan and lease borrower relationships by evaluating the financial performance of the borrower, sources of repayment, and any relevant guarantees or underlying collateral

–evaluating the methodology used to develop the adjustments for qualitative factors and the effect of those factors on the collective ALLL compared with relevant credit risk factors and consistency with credit trends and identified limitations of the underlying quantitative models.

We also assessed the sufficiency of the audit evidence obtained related to the January 1, 2020 collective ALLL and December 31, 2020 collective ALLL by evaluating the:

–cumulative results of the audit procedures

–qualitative aspects of the Corporation’s accounting practices

–potential bias in the accounting estimates.

/s/ KPMG LLP

We have served as the Corporation's auditor since 1991.

Detroit, Michigan

February 26, 2021

78

Table of Contents

TCF FINANCIAL CORPORATION AND SUBSIDIARIES

Consolidated Statements of Financial Condition

(Dollars in thousands, except per share data)	At December 31, 2020		At December 31, 2019
ASSETS
Cash and cash equivalents:
Cash and due from banks	$	531,918	$	491,787
Interest-bearing deposits with other banks	728,677		736,584
Total cash and cash equivalents	1,260,595		1,228,371
Federal Home Loan Bank and Federal Reserve Bank stocks, at cost	320,436		442,440
Investment securities:
Available-for-sale, at fair value (amortized cost of $8,041,173 and $6,639,277)	8,284,723		6,720,001
Held-to-maturity, at amortized cost (fair value of $193,554 and $144,844)	184,359		139,445
Total investment securities	8,469,082		6,859,446
Loans and leases held-for-sale (includes $221,784 and $91,202 at fair value)	222,028		199,786
Loans and leases	34,466,408		34,497,464
Allowance for loan and lease losses	(525,868)		(113,052)
Loans and leases, net	33,940,540		34,384,412
Premises and equipment, net	470,131		533,138
Goodwill	1,313,046		1,299,878
Other intangible assets, net	146,377		168,368
Loan servicing rights	38,303		56,313
Other assets	1,621,949		1,479,401
Total assets	$	47,802,487	$	46,651,553
LIABILITIES AND EQUITY
Liabilities
Deposits:
Noninterest-bearing	$	11,036,086	$	7,970,590
Interest-bearing	27,820,233		26,497,873
Total deposits	38,856,319		34,468,463
Short-term borrowings	617,363		2,669,145
Long-term borrowings	1,374,732		2,354,448
Other liabilities	1,264,776		1,432,256
Total liabilities	42,113,190		40,924,312
Equity
Preferred stock, $0.01 par value, 2,000,000 shares authorized; 7,000 shares issued	169,302		169,302
Common stock, $1.00 par value, 220,000,000 shares authorized
Issued - 152,565,504 shares at December 31, 2020 and 152,965,571 shares at December 31, 2019	152,566		152,966
Additional paid-in capital	3,457,802		3,462,080
Retained earnings	1,735,201		1,896,427
Accumulated other comprehensive income	182,673		54,277
Other	(26,731)		(28,037)
Total TCF Financial Corporation shareholders' equity	5,670,813		5,707,015
Non-controlling interest	18,484		20,226
Total equity	5,689,297		5,727,241
Total liabilities and equity	$	47,802,487	$	46,651,553

See accompanying notes to consolidated financial statements.

79

Table of Contents

TCF FINANCIAL CORPORATION AND SUBSIDIARIES

Consolidated Statements of Income

	Year Ended December 31,
(Dollars in thousands, except per share data)	2020		2019		2018
Interest income
Interest and fees on loans and leases	$	1,575,186	$	1,430,628	$	1,082,135
Interest on investment securities:
Taxable	144,462		106,027		41,406
Tax-exempt	16,168		11,651		17,138
Interest on loans held-for-sale	11,394		18,599		6,686
Interest on other earning assets	18,452		20,356		11,964
Total interest income	1,765,662		1,587,261		1,159,329
Interest expense
Interest on deposits	166,986		226,157		107,690
Interest on borrowings	60,275		72,072		43,144
Total interest expense	227,261		298,229		150,834
Net interest income	1,538,401		1,289,032		1,008,495
Provision for credit losses	257,151		65,282		46,768
Net interest income after provision for credit losses	1,281,250		1,223,750		961,727
Noninterest income
Leasing revenue	142,723		163,718		172,603
Fees and service charges on deposit accounts	112,681		127,860		113,242
Card and ATM revenue	88,699		87,221		78,406
Net gains on sales of loans and leases	86,776		26,308		33,695
Wealth management revenue	25,701		10,413		—
Servicing fee revenue	10,603		20,776		27,334
Net gains on investment securities	2,338		7,425		348
Other	46,542		21,811		28,769
Total noninterest income	516,063		465,532		454,397
Noninterest expense
Compensation and employee benefits	702,702		576,922		502,196
Occupancy and equipment	209,690		189,560		165,839
Lease financing equipment depreciation	73,204		76,426		73,829
Net foreclosed real estate and repossessed assets	5,136		13,523		17,050
Merger-related expenses	203,888		171,968		—
Other	332,751		303,716		255,486
Total noninterest expense	1,527,371		1,332,115		1,014,400
Income before income tax expense	269,942		357,167		401,724
Income tax expense	39,901		50,241		86,096
Income after income tax expense	230,041		306,926		315,628
Income attributable to non-controlling interest	7,282		11,458		11,270
Net income attributable to TCF Financial Corporation	222,759		295,468		304,358
Preferred stock dividends	9,975		9,975		11,588
Impact of preferred stock redemption	—		—		3,481
Net income available to common shareholders	$	212,784	$	285,493	$	289,289
Earnings per common share
Basic	$	1.40	$	2.56	$	3.44
Diluted	1.40		2.55		3.43
Weighted-average common shares outstanding
Basic	151,812,393		111,604,094		84,133,983
Diluted	151,887,559		111,818,365		84,324,686

See accompanying notes to consolidated financial statements.

80

Table of Contents

TCF FINANCIAL CORPORATION AND SUBSIDIARIES

Consolidated Statements of Comprehensive Income

	Year Ended December 31,
(In thousands)	2020		2019		2018
Net income attributable to TCF Financial Corporation	$	222,759	$	295,468	$	304,358
Other comprehensive income (loss), net of tax:
Net unrealized gains (losses) on available-for-sale investment securities and interest-only strips	126,390		84,120		(11,669)
Net unrealized gains (losses) on net investment hedges	(4,195)		(5,186)		10,450
Foreign currency translation adjustment	5,894		8,514		(13,368)
Recognized postretirement prior service cost	307		(33)		(34)
Total other comprehensive income (loss), net of tax	128,396		87,415		(14,621)
Comprehensive income	$	351,155	$	382,883	$	289,737

 See accompanying notes to consolidated financial statements.

81

Table of Contents

TCF FINANCIAL CORPORATION AND SUBSIDIARIES

Consolidated Statements of Equity

	TCF Financial Corporation
	Number of Shares Issued		Preferred Stock		Common Stock		Additional Paid-in Capital		Retained Earnings		Accumulated Other Comprehensive Income (Loss)		Other		Total		Non- controlling Interest		Total Equity
(Dollars in thousands)	Preferred	Common
Balance, December 31, 2017	4,007,000	87,473,708	$	265,821	$	87,474	$	791,465	$1,577,311		$	(18,517)	$	(40,797)	$	2,662,757	$	17,827	$	2,680,584
Change in accounting principle	—	—	—				—		(116)		—		—		(116)		—		(116)
Balance, January 1, 2018	4,007,000	87,473,708	265,821		87,474		791,465		1,577,195		(18,517)		(40,797)		2,662,641		17,827		2,680,468
Net income	—	—	—		—		—		304,358		—		—		304,358		11,270		315,628
Other comprehensive income (loss), net of tax	—	—	—		—		—		—		(14,621)		—		(14,621)		—		(14,621)
Net investment by (distribution to) non-controlling interest	—	—	—		—		—		—		—		—		—		(10,638)		(10,638)
Redemption of Series B Preferred Stock	(4,000,000)	—	(96,519)		—		—		(3,481)		—		—		(100,000)		—		(100,000)
Repurchases of 4,668,723 shares of common stock	—	—	—		—		—		—		—		(212,929)		(212,929)		—		(212,929)
Dividends on 6.45% Series B Preferred Stock	—	—	—		—		—		(1,613)		—		—		(1,613)		—		(1,613)
Dividends on 5.70% Series C Preferred Stock	—	—	—		—		—		(9,975)		—		—		(9,975)		—		(9,975)
Dividends on common stock of $1.18 per common share	—	—	—		—		—		(99,490)		—		—		(99,490)		—		(99,490)
Common stock warrants exercised	—	553,279	—		553		(553)		—		—		—		—		—		—
Common shares purchased by TCF employee benefit plans	—	17,594	—		18		697		—		—		—		715		—		715
Stock compensation plans, net of tax	—	153,879	—		153		8,184		—		—		378		8,715		—		8,715
Change in shares held in trust for deferred compensation plans, at cost	—	—	—		—		(1,166)		—		—		1,166		—		—		—
Balance, December 31, 2018	7,000	88,198,460	$	169,302	$	88,198	$	798,627	$1,766,994		$	(33,138)	$	(252,182)	$	2,537,801	$	18,459	$	2,556,260
Balance, December 31, 2018	7,000	88,198,460	$	169,302	$	88,198	$	798,627	$	1,766,994	$	(33,138)	$	(252,182)	$	2,537,801	$	18,459	$	2,556,260
Net income	—	—	—		—		—		295,468		—		—		295,468		11,458		306,926
Other comprehensive income (loss), net of tax	—	—	—		—		—		—		87,415		—		87,415		—		87,415
Reverse merger with Chemical Financial Corporation	—	65,539,678	—		65,540		2,687,153		—		—		265,863		3,018,556		—		3,018,556
Net investment by (distribution to) non-controlling interest	—	—	—		—		—		—		—		—		—		(9,691)		(9,691)
Repurchases of 2,111,725 shares of common stock	—	(657,817)	—		(658)		(26,846)		—		—		(58,805)		(86,309)		—		(86,309)
Dividends on 5.70% Series C Preferred Stock	—	—	—		—		—		(9,975)		—		—		(9,975)		—		(9,975)
Dividends on common stock of $1.29 per common share	—	—	—		—		—		(156,060)		—		—		(156,060)		—		(156,060)
Stock compensation plans, net of tax	—	(114,750)	—		(114)		4,474		—		—		15,759		20,119		—		20,119
Change in shares held in trust for deferred compensation plans, at cost	—	—	—		—		(1,328)		—		—		1,328		—		—		—
Balance, December 31, 2019	7,000	152,965,571	$	169,302	$	152,966	$	3,462,080	$	1,896,427	$	54,277	$	(28,037)	$	5,707,015	$	20,226	$	5,727,241

See accompanying notes to consolidated financial statements.

82

Table of Contents

TCF FINANCIAL CORPORATION AND SUBSIDIARIES

Consolidated Statements of Equity, Continued

	TCF Financial Corporation
	Number of Shares Issued		Preferred Stock		Common Stock		Additional Paid-in Capital		Retained Earnings	Accumulated Other Comprehensive Income (Loss)		Other		Total		Non- controlling Interest		Total Equity
(Dollars in thousands)	Preferred	Common
Balance, December 31, 2019	7,000	152,965,571	$	169,302	$	152,966	$	3,462,080	$1,896,427	$	54,277	$	(28,037)	$	5,707,015	$	20,226	$	5,727,241
Cumulative effect adjustment related to adoption of Accounting Standards Update 2016-13(1)	—	—	—		—		—		(159,323)	—		—		(159,323)		74		(159,249)
Balance, January 1, 2020	7,000	152,965,571	169,302		152,966		3,462,080		1,737,104	54,277		(28,037)		5,547,692		20,300		5,567,992
Net income	—	—	—		—		—		222,759	—		—		222,759		7,282		230,041
Other comprehensive income (loss), net of tax	—	—	—		—		—		—	128,396		—		128,396		—		128,396
Net investment by (distribution to) non-controlling interest	—	—	—		—		—		—	—		—		—		(9,098)		(9,098)
Repurchases of 873,376 shares of common stock	—	(873,376)	—		(873)		(32,225)		—	—		—		(33,098)		—		(33,098)
Dividends on 5.70% Series C Preferred Stock	—	—	—		—		—		(9,975)	—		—		(9,975)		—		(9,975)
Dividends on common stock of $1.40 per common share	—	—	—		—		—		(214,687)	—		—		(214,687)		—		(214,687)
Stock compensation plans, net of tax	—	473,309	—		473		29,253		—	—		—		29,726		—		29,726
Change in shares held in trust for deferred compensation plans, at cost	—	—	—		—		(1,306)		—	—		1,306		—		—		—
Balance, December 31, 2020	7,000	152,565,504	$	169,302	$	152,566	$	3,457,802	$1,735,201	$	182,673	$	(26,731)	$	5,670,813	$	18,484	$	5,689,297

(1) See "Note 2. Summary of Significant Accounting Policies" for further information

See accompanying notes to consolidated financial statements.

83

Table of Contents

TCF FINANCIAL CORPORATION AND SUBSIDIARIES

Consolidated Statements of Cash Flows

	Year Ended December 31,
(In thousands)	2020		2019		2018
Cash flows from operating activities
Net income	$	230,041	$	306,926	$	315,628
Adjustments to reconcile net income to net cash provided by (used in) operating activities:
Provision for credit losses	257,151		65,282		46,768
Share-based compensation expense	35,438		28,351		17,824
Depreciation and amortization	437,585		308,638		204,778
Provision (benefit) for deferred income taxes	(74,841)		30,410		58,986
Net gains on sales of assets	(90,299)		(66,298)		(39,881)
Proceeds from sales of loans and leases held-for-sale	2,001,489		966,352		372,354
Originations of loans and leases held-for-sale, net of repayments	(2,011,048)		(835,047)		(375,622)
Impairment of loan servicing rights	17,605		3,882		—
Net change in other assets	(484,298)		(263,351)		(35,154)
Net change in other liabilities	(119,586)		162,533		39,898
Other, net	(78,131)		(65,921)		(41,949)
Net cash provided by (used in) operating activities	121,106		641,757		563,630
Cash flows from investing activities
Proceeds from sales of investment securities available-for-sale	50,797		1,986,386		254,146
Proceeds from maturities of and principal collected on investment securities available-for-sale	2,404,269		735,861		169,622
Purchases of investment securities available-for-sale	(3,587,494)		(2,806,598)		(1,230,430)
Proceeds from maturities of and principal collected on investment securities held-to-maturity	37,389		17,632		15,407
Purchases of investment securities held-to-maturity	(80,533)		(6,844)		(2,188)
Redemption of Federal Home Loan Bank stock	428,016		256,021		269,002
Purchases of Federal Home Loan Bank stock	(306,000)		(370,000)		(278,000)
Proceeds from sales of loans and leases	554,532		1,985,093		903,606
Loan and lease originations and purchases, net of principal collected	(639,089)		(2,037,489)		(957,672)
Proceeds from sales of other assets	70,936		113,771		88,942
Purchases of premises and equipment and lease equipment	(188,378)		(154,540)		(155,664)
Net cash acquired (paid) in business combinations	—		975,014		—
Other, net	17,626		(27,431)		20,935
Net cash provided by (used in) investing activities	(1,237,929)		666,876		(902,294)
Cash flows from financing activities
Net change in deposits	4,457,400		(901,522)		549,157
Net change in short-term borrowings	(2,051,721)		45,584		160
Proceeds from long-term borrowings	7,870,577		5,957,492		9,380,950
Payments on long-term borrowings	(8,855,775)		(5,499,669)		(9,182,536)
Payments on liabilities related to acquisition and portfolio purchase	—		(1,000)		(2,000)
Redemption of Series B preferred stock	—		—		(100,000)
Repurchases of common stock	(33,098)		(86,309)		(212,929)
Common shares sold to TCF employee benefit plans	—		—		715
Dividends paid on preferred stock	(9,975)		(9,975)		(11,588)
Dividends paid on common stock	(214,687)		(156,060)		(99,490)
Exercise of stock options	(23)		29		(997)
Payments related to tax-withholding upon conversion of share-based awards	(4,553)		(6,198)		(6,865)
Net investment by (distribution to) non-controlling interest	(9,098)		(9,691)		(10,638)
Net cash provided by (used in) financing activities	1,149,047		(667,319)		303,939
Net change in cash and due from banks	32,224		641,314		(34,725)
Cash and cash equivalents at beginning of period	1,228,371		587,057		621,782
Cash and cash equivalents at end of period	$	1,260,595	$	1,228,371	$	587,057
Supplemental disclosures of cash flow information
Cash paid (received) for:
Interest on deposits and borrowings	$	230,110	$	269,474	$	139,026
Income taxes, net	128,691		12,177		(26,308)
Noncash activities:
Transfer of loans and leases to other assets	45,394		88,716		105,247
Transfer of loans and leases from held-for-investment to held-for-sale, net	448,721		2,184,134		848,941

See accompanying notes to consolidated financial statements.

84

Table of Contents

TCF FINANCIAL CORPORATION AND SUBSIDIARIES

Notes to Consolidated Financial Statements

Note 1. Basis of Presentation

On August 1, 2019 (the "TCF/Chemical Merger Date"), TCF Financial Corporation, a Delaware corporation ("Legacy TCF"), merged with and into Chemical Financial Corporation, a Michigan corporation ("Chemical"), with Chemical continuing as the surviving legal corporation (the "TCF/Chemical Merger"). Immediately following the TCF/Chemical Merger, Chemical’s wholly owned bank subsidiary, Chemical Bank, a Michigan state-chartered bank, merged with and into Legacy TCF’s wholly owned bank subsidiary, TCF National Bank, a national banking association, with TCF National Bank ("TCF Bank") surviving the TCF/Chemical Merger. Upon completion of the TCF/Chemical Merger, Chemical was renamed TCF Financial Corporation. TCF Financial Corporation (together with its direct and indirect subsidiaries, "we," "us," "our," "TCF" or the "Corporation"), is a financial holding company, headquartered in Detroit, Michigan. TCF Bank has its main office in Sioux Falls, South Dakota. References herein to "TCF Financial" refer to TCF Financial Corporation on an unconsolidated basis.

The TCF/Chemical Merger was accounted for as a reverse merger using the acquisition method of accounting, therefore, Legacy TCF was deemed the acquirer for financial reporting purposes, even though Chemical was the legal acquirer. Accordingly, Legacy TCF's historical financial statements are the historical financial statements of the combined company for all periods before the TCF/Chemical Merger Date. TCF's results of operations for 2019 include the results of operations of Chemical on and after August 1, 2019. Results for periods before August 1, 2019 reflect only those of Legacy TCF and do not include the results of operations of Chemical. The number of shares issued and outstanding, earnings per share, additional paid-in-capital, dividends paid and all references to share quantities of TCF have been retrospectively adjusted to reflect the equivalent number of shares issued to holders of Legacy TCF common stock in the TCF/Chemical Merger. See "Note 3. Business Combinations" for further information. In addition, the assets and liabilities of Chemical as of the TCF/Chemical Merger Date have been recorded at their estimated fair value and added to those of Legacy TCF.

TCF Bank operates bank branches primarily located in Michigan, Illinois and Minnesota with additional locations in Colorado, Ohio, South Dakota and Wisconsin (TCF's "primary banking markets"). Through its direct subsidiaries, TCF Bank provides a full range of consumer-facing and commercial services, including consumer and commercial banking, trust and wealth management, and specialty leasing and lending products and services to consumers, small businesses and commercial customers.

The accompanying consolidated financial statements have been prepared in conformity with U.S. generally accepted accounting principles ("GAAP"). The preparation of financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities, disclosure of contingent assets and liabilities at the date of the financial statements and the reported amount of revenues and expenses during the reporting period. These estimates are based on information available to management at the time the estimates are made. Actual results could differ from those estimates. All significant intercompany accounts and transactions have been eliminated in consolidation. Certain reclassifications have been made to prior period financial statements to conform to the current period presentation.

Note 2. Summary of Significant Accounting Policies

Business Combinations Pursuant to the guidance of ASC Topic 805 ("ASC 805"), the Corporation recognized assets acquired, including identified intangible assets, and the liabilities assumed in mergers and acquisitions at their fair values as of the acquisition date, with the acquisition and merger-related transaction and restructuring costs expensed in the period incurred.

85

Table of Contents

ASC 805 affords a measurement period beyond the acquisition date that allows the opportunity to finalize the acquisition accounting in the event that new information is identified that existed as of the acquisition date but was not known or available at that time. This measurement period ends on the earlier of one year after the acquisition or the date information about the facts and circumstances that existed at the acquisition are available. The Corporation recorded the estimate of fair value based on initial valuations available at the TCF/Chemical Merger Date and these estimates were considered preliminary as of September 30, 2019, and subject to adjustment for up to one year after the TCF/Chemical Merger Date. While the Corporation believes that the information available on the TCF/Chemical Merger Date provided a reasonable basis for estimating fair value, following the TCF/Chemical Merger, the Corporation obtained additional information and evidence and then finalized all valuations and recorded final adjustments during the first quarter of 2020. 

In determining the estimated fair value of assets acquired as part of the TCF/Chemical Merger, including the estimated fair value of acquired loans and leases and a core deposit intangible, management relied on a framework of internal controls in place to evaluate the relevance and reliability of key inputs and assumptions used in the fair value and to ensure the mathematical accuracy used to determine an appropriate fair value. Acquired loans and leases were valued using a discounted cash flow methodology with adjustments to contractual cash flows for probability of default, loss given default, discount rates and prepayments rates. Management based the assumptions used on historical data or available market information. The fair value of the core deposit intangible was estimated under the income approach based on discounted net cash flows. This estimate was determined by projecting net cash flow benefits derived from estimating costs to carry deposits compared to alternative funding costs, and includes key assumptions related to deposit interest rates, customer attrition rates, costs of alternative funding, discount rate, and net maintenance costs.

These assumptions were based on both internal data and available market information. Management reviewed the relevance and reliability of key valuation inputs used to support key assumptions. In cases where management utilized a third-party to assist with the valuation, management assessed the qualifications of the third-party and reviewed all outputs provided by the third-party for reasonableness. See "Note 3. Business Combinations" for further information.

Fair Value Measurements Fair value for assets and liabilities measured at fair value on a recurring or nonrecurring basis refers to the price that would be received to sell an asset or paid to transfer a liability (an exit price) in an orderly transaction between market participants in the market in which the reporting entity transacts such sales or transfers based on the assumptions market participants would use when pricing an asset or liability. Assumptions are developed based on prioritizing information within a fair value hierarchy that gives the highest priority to quoted prices in active markets and the lowest priority to unobservable data, such as the reporting entity's own data.

The Corporation may choose to elect the fair value measurement option on eligible financial instruments. Unrealized gains and losses on items for which the fair value measurement option has been elected are reported in earnings at each subsequent reporting date. At December 31, 2020 and 2019, the Corporation had elected the fair value option on certain loans, primarily residential mortgage loans, it originates for the purpose of selling in secondary markets. The Corporation has not elected the fair value option for any other financial assets or liabilities as of December 31, 2020.

Allowance for Credit Losses The Corporation's reserve methodology used to determine the appropriate level of the allowance for credit losses ("ACL") is a critical accounting estimate. Effective January 1, 2020, the Corporation adopted ASU No. 2016-13, Financial Instruments - Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments and related ASUs on a modified retrospective basis. The ACL is maintained at a level believed to be appropriate to provide for the current credit losses expected to be incurred in the loan and lease portfolios over the remaining expected life of each financial asset at the balance sheet date, including known or anticipated problem loans and leases, as well as for loans and leases which are not currently known to require specific allowances. The Corporation individually evaluates loans and leases that do not share similar risk characteristics with other financial assets for impairment, generally this means troubled debt restructuring ("TDR") loans, previously removed TDR loans and any other loans and leases that no longer exhibit similar risk characteristics of one of the pools of financial assets used for collective evaluation. All other loans and leases are evaluated collectively for impairment. The ACL includes the allowance for loan and lease losses ("ALLL") and a reserve for unfunded lending commitments ("RULC"). The ALLL and RULC are valuation accounts presented separately on the Consolidated Statements of Financial Condition. The ALLL is deducted from or added to loans' amortized cost basis to present the net amount expected to be collected. The RULC for letters of credit, financial guarantees and binding unfunded loan commitments is recorded in other liabilities.

86

Table of Contents

Individually evaluated loans and leases are a key component of the ALLL. Individually evaluated consumer loans are generally measured at the present value of the expected future cash flows discounted at the loan's initial effective interest rate, unless the loans are collateral dependent, in which case loan impairment is based on the fair value of the collateral less estimated selling costs. Individually evaluated commercial loans and leases are generally measured at the present value of the expected future cash flows discounted at the initial effective interest rate of the loan or lease, unless the loan or lease is collateral dependent, in which case impairment is based on the fair value of collateral less estimated selling costs; however, if payment or satisfaction of the loan or lease is dependent on the operation, rather than the sale of the collateral, the impairment does not include estimated selling costs.

The impairment for all other consumer and commercial loans and leases is evaluated collectively by various characteristics. The collective evaluation of expected losses in these portfolios is based on their probability of default multiplied by the loss given default and the exposure at default (representing the estimated outstanding principal balance of the loans and leases upon default) on an undiscounted basis, as well as adjustments for forward-looking information, including industry and macroeconomic conditions. Management's current methodology for the quantitative component of the collective evaluation of expected losses utilizes a single economic forecast scenario over a twenty-four month reasonable and supportable forecast period with a twelve month straight line reversion to historical loss rates. Factors utilized in the determination of the amount of the allowance include historical loss experience and measurement date credit risk characteristics such as product type, lien position, delinquency, collateral value, credit bureau scores, credit risk ratings and financial statement ratios. These quantitative factors, as well as qualitative factors such as adjustments for economic conditions and asset-specific risk characteristics to the extent they do not exist in the historical loss information, are reviewed quarterly. Adjustments are based on qualitative factors not reflected in the quantitative component and impact the measurement of expected credit losses.

Loans and leases are charged off to the extent they are deemed to be uncollectible. Net charge-offs are included in historical data utilized for calculating the ACL. Loans that are not collateral dependent are charged off when deemed uncollectible based on specific facts and circumstances. Residential mortgage and home equity loans are charged off to the estimated fair value of the underlying collateral, less estimated selling costs, no later than 150 days past due. Additional review of the fair value, less estimated costs to sell, compared with the recorded value occurs upon foreclosure and additional charge-offs are recorded if necessary. Consumer installment loans will generally be charged off in full no later than 120 days past due, unless repossession is reasonably assured and in process, in which case the loan would be charged off to the fair value of the collateral, less estimated selling costs. Consumer loans in bankruptcy status may be charged down to the fair value of the collateral, less estimated selling costs, when the loan is 60 days past due, or within 60 days after receipt of bankruptcy notification, whichever is shorter. Deposit account overdrafts are reported in other loans. Net losses on uncollectible overdrafts are reported as net charge-offs in the ALLL within 60 days from the date of overdraft. Commercial loans and leases that are considered collateral dependent are charged off to the estimated fair value, less estimated selling costs when it becomes probable, based on current information and events, that all principal and interest amounts will not be collectible in accordance with their contractual terms.

The RULC leverages the same loss estimate methodology utilized to measure the ALLL. The Corporation estimates expected credit losses over the period in which it is exposed to credit risk via a contractual obligation to extend credit, unless that obligation is unconditionally cancellable by the Corporation. The RULC estimate considers both the likelihood that funding will occur and expected credit losses on funded balances at the time of default.

The amount of the ACL significantly depends on management's estimates of key factors and assumptions affecting valuation, appraisals of collateral, evaluations of performance and status, the amounts and timing of future cash flows expected to be received, forecasts of future economic conditions and reversion periods. Such estimates, appraisals, evaluations, cash flows and forecasts may be subject to frequent adjustments due to changing financial and economic prospects of borrowers, lessees, properties or economic conditions. These estimates are reviewed quarterly and adjustments, if necessary, are recorded in the provision for credit losses in the periods in which they become known.

Accrued interest receivable is included in other assets on the Consolidated Statements of Financial Condition, and an ACL is not recorded for these balances. Generally, when a loan or lease is placed on nonaccrual status, typically when the collection of interest or principal is 90 days or more past due, uncollected interest accrued in prior years is charged off against the ACL and interest accrued in the current year is reversed against interest income.

87

Table of Contents

Management maintains a framework of controls over the estimation process for the ACL, including review of collective reserve methodologies for compliance with GAAP. Management has a quarterly process to review the appropriateness of historical observation periods and loss assumptions, risk ratings assigned to commercial loans and leases, and discount rate assumptions used to estimate the fair value of consumer real estate. Management reviews its qualitative framework and the effect on the collective reserve compared with relevant credit risk factors and consistency with credit trends. Management also maintains controls over the information systems, models and spreadsheets used in the quantitative components of the reserve estimate. This includes the quality and accuracy of historical data used to derive loss rates, the probability of default, loss given default, exposure at default, the inputs to industry and macroeconomic conditions and the reversion periods utilized. The results of this process are summarized and presented to management quarterly for their approval of the recorded allowance.

Prior to the adoption of ASU No. 2016-13, the allowance for credit losses was calculated in accordance with ASC Topic 310, "Receivables" and ASC Topic 450, "Contingencies". The allowance for credit losses were maintained at a level believed to be appropriate to provide for probable loan and lease losses incurred in the portfolio as of the balance sheet date, including known or anticipated problem loans and leases, as well as for loans and leases not known to require specific allowances. The collective evaluation of incurred losses was based on historical loss rates multiplied by the respective loss emergence periods.

See "Note 8.  Allowance for Credit Losses and Credit Quality" and the following details within "Recently Adopted Accounting Policies" for further information.

Federal Home Loan Bank and Federal Reserve Bank Stocks The Corporation is required to hold nonmarketable equity securities, comprised of Federal Home Loan Bank ("FHLB") and Federal Reserve Bank ("FRB") stock, as a condition of membership. These securities are accounted for at cost, less any impairment. Impairment is assessed based on the ultimate recoverability of the investment. These securities do not have a readily determinable fair value as their ownership is restricted and there is no market for these securities. These securities can only be redeemed or sold at their par value and only to the respective issuing government supported institution or to another member institution. FHLB and FRB stock can only be redeemed upon giving notice to each issuing entity and may be subject to restrictions on the amount of stock that can be redeemed at any one time. The nonmarketable equity securities are periodically evaluated for impairment. Management considers these nonmarketable equity securities to be long-term investments. The Corporation recognizes dividend income from its FHLB stock holdings in the period that dividends are declared. See "Note 5. Federal Home Loan Bank and Federal Reserve Bank Stocks" for further information on nonmarketable equity securities.

Investment Securities Held-to-Maturity Investment securities held-to-maturity are carried at cost and adjusted for amortization of premiums or accretion of discounts using a level yield method; however, transfers of investment securities available-for-sale to investment securities held-to-maturity are made at fair value at the date of transfer. The unrealized holding gain or loss at the date of each transfer is retained in accumulated other comprehensive income (loss) and in the carrying value of the held-to-maturity investment security. Such amounts are then amortized over the remaining life of the transferred investment security as an adjustment of the yield on those securities. The Corporation evaluates investment securities held-to-maturity for credit losses on a quarterly basis, and records any such losses as a component of provision for credit losses in the Consolidated Statements of Income and a corresponding ACL. At December 31, 2020 there was no ACL recorded. See "Note 6. Investment Securities" for further information on investment securities held-to-maturity.

Investment Securities Available-for-Sale Investment securities available-for-sale are carried at fair value with the unrealized gains or losses net of related deferred income taxes reported within accumulated other comprehensive income (loss). The cost of investment securities sold is determined on a specific identification basis and gains or losses on sales of investment securities available-for-sale are recognized on trade dates. Discounts and premiums on investment securities available-for-sale are amortized using a level yield method over the expected life of the security, or to the earliest call date for premiums on investment securities with call features. The Corporation evaluates investment securities available-for-sale for credit losses on a quarterly basis, and records any such losses as a component of provision for credit losses in the Consolidated Statements of Income and a corresponding ACL. At December 31, 2020 there was no ACL recorded. See "Note 6. Investment Securities" for further information on investment securities available-for-sale.

88

Table of Contents

Loans and Leases Held-for-Sale Loans and leases designated as held-for-sale are generally carried at the lower of cost or fair value. Any amount by which cost exceeds fair value is initially recorded as a valuation allowance and subsequently recorded in net gains (losses) on sales of loans and leases when sold. Fair value calculations include the servicing value of loans as well as any accrued interest. From time to time, management identifies and designates, primarily consumer loans held in the loan portfolios, for sale. These loans are transferred to loans and leases held-for-sale at the lower of cost or fair value at the time of transfer net of any associated allowance for loan and lease losses.

Certain residential mortgage loans held-for-sale are recorded at fair value under the elected fair value option as prescribed by ASC Topic 820, Fair Value Measurements and Disclosures ("ASC 820"). The Corporation generally sells conforming long-term fixed interest rate mortgage loans it originates in the secondary market. Gains on the sales of these loans are determined using the specific identification method. The Corporation sells residential mortgage loans in the secondary market on servicing retained and servicing released bases. The fair value election allows for a more effective offset of the changes in fair value of residential mortgage loans held-for-sale and the derivative instruments used to economically hedge them without having to apply complex hedge accounting provisions. Residential mortgage loans held-for-sale are carried at fair value, with changes in fair value recorded through earnings.

Loans and Leases Held-for-Investment Loans and leases designated as held-for-investment are reported at historical cost including net direct fees and costs associated with originating and acquiring loans and leases. The net direct fees and costs for sales-type leases are offset against revenues recorded at the commencement of sales-type leases. Discounts and premiums on acquired loans, net direct fees and costs, unearned discounts and finance charges, and unearned lease income are amortized to interest income using methods that approximate a level yield over the estimated remaining lives of the loans and leases. Net direct fees and costs on all lines of credit are amortized on a straight line basis to fees and service charges over the contractual life of the line of credit and adjusted for payoffs. See "Note 7. Loans and Leases" for further information on loans and leases.

Loans and Leases Acquired in a Business Combination The Corporation records loans and leases acquired in a business combination at fair value at the acquisition date and the fair value discount or premium is recognized as an adjustment to yield over the remaining life of each loan or lease. An ALLL is also recorded following the Corporation's ACL accounting policy. Purchased and acquired loans and leases are evaluated at the acquisition date and classified as either (i) loans and leases purchased without evidence of deteriorated credit quality since origination, or (ii) loans and leases purchased that as of the date of acquisition have experienced a more-than-insignificant deterioration in credit quality since origination, referred to as purchased financial assets with credit deterioration ("PCD") assets. In determining whether an acquired asset should be classified as PCD, the Corporation must make numerous assumptions, interpretations and judgments using internal and third-party credit quality information to determine whether or not the asset has experienced more-than-insignificant credit deterioration since origination. This is a point in time assessment and is inherently subjective due to the nature of the available information and judgment involved. Evidence of credit quality deterioration as of the acquisition date may include statistics such as past due and nonaccrual status, recent borrower credit scores and loan-to-value percentages. The ALLL estimated for PCD loans and leases as of the acquisition date is recorded as a gross-up of the loan or lease balance and the ALLL. Any remaining discount or premium after the gross-up is then recognized as an adjustment to yield over the remaining life of each PCD loan or lease. After the acquisition date, the accounting for acquired loans a leases, including PCD and non-PCD loans and leases, follows the same accounting guidance as loans and leases originated by the Corporation.

See "Note 8. Allowance for Credit Losses and Credit Quality" for further information on loans and leases.

Nonaccrual Loans and Leases Loans and leases are generally placed on nonaccrual status when the collection of interest or principal is 90 days or more past due, unless, in the case of commercial loans and leases, they are well secured and in the process of collection. Delinquent consumer home equity junior lien loans are placed on nonaccrual status when there is evidence that the related third-party first lien mortgage may be 90 days or more past due, or foreclosure, charge-off or collection action has been initiated. TDR loans are placed on nonaccrual status prior to the past due thresholds outlined above if repayment under the modified terms is not likely after performing a well-documented credit analysis. In addition, under the CARES Act, loans and leases that have been granted a deferral of greater than 180 days are generally placed on nonaccrual status.

89

Table of Contents

Loans and leases on nonaccrual status are generally reported as nonaccrual loans until there is sustained repayment performance for six consecutive months, with the exception of loans not reaffirmed upon discharge under Chapter 7 bankruptcy, which remain on nonaccrual status until a well-documented credit analysis indicates full repayment of the remaining pre-discharged contractual principal and interest is likely. Income on these loans and leases is recognized on a cash basis when there is sustained repayment performance for nine or 12 consecutive months based on the credit evaluation and the loan is not more than 60 days delinquent.

Generally, when a loan or lease is placed on nonaccrual status, uncollected interest accrued in prior years is charged off against the allowance for loan and lease losses and interest accrued in the current year is reversed against interest income. For nonaccrual leases that have been discounted with third-party financial institutions on a non-recourse basis, the related liability is also placed on nonaccrual status. Interest payments received on loans and leases in nonaccrual status are generally applied to principal unless the remaining principal balance has been determined to be fully collectible, in which case interest income is recognized on a cash basis. See "Note 8. Allowance for Credit Losses and Credit Quality" for further information on nonaccrual loans and leases.

Leases The Corporation enters into lease contracts as both a lessor and a lessee. A contract, or part of a contract, is considered a lease if it conveys the right to obtain substantially all of the economic benefits from, and the right to direct and use, an identified asset for a period of time in exchange for consideration. The determination of lease classification requires various judgments and estimates by management which may include the fair value of the equipment at lease inception, useful life of the equipment under lease, estimate of the lease residual value and collectability of minimum lease payments. Management has policies and procedures in place for the determination of lease classification and review of the related judgments and estimates for all leases.

As a lessor, the Corporation provides various types of lease financing that are classified for accounting purposes as direct financing, sales-type or operating leases. Leases that transfer substantially all of the benefits and risks of ownership to the lessee are classified as direct financing or sales-type leases and are recorded in loans and leases. Direct financing and sales-type leases are carried at the combined present value of future minimum lease payments and lease residual values.

Interest income on net investment in direct financing and sales-type leases is recognized using methods that approximate a level yield over the fixed, non-cancelable term of the lease, including pro rata rent payments received for the interim period until the lease contract commences and the fixed, non-cancelable lease term begins. Sales-type leases generate selling profit (loss), which is recognized on the commencement date by recording lease revenue net of lease cost. Lease revenue consists of the present value of the future minimum lease payments and lease cost consists of the leased equipment's net book value, less the present value of its residual.

Some lease financing contracts include a residual value component, which represents the estimated fair value of the leased equipment at the expiration of the initial term of the transaction. The estimation of residual values involves judgment regarding product and technology changes, customer behavior, shifts in supply and demand and other economic assumptions. The Corporation reviews residual assumptions when assessing potential impairment of the net investment in direct financing and sales-type leases each quarter. Decreases in the expected residual value are reflected through an increase in the provision for credit losses, which results in an increase to the allowance for loan and lease losses.

The Corporation may sell minimum lease payment receivables, primarily as a credit risk reduction tool, to third-party financial institutions at fixed rates, on a non-recourse basis, with its underlying equipment as collateral. For those transactions that qualify for sale accounting, the related lease cash flow stream and the non-recourse financing are derecognized. For those transactions that do not qualify for sale accounting, the underlying lease remains on the Consolidated Statements of Financial Condition and non-recourse debt is recorded in the amount of the proceeds received. The Corporation retains servicing of these leases and bills, collects and remits funds to the third-party financial institution. Upon default by the lessee, the third-party financial institutions may take control of the underlying collateral which the Corporation would otherwise retain as residual value.

90

Table of Contents

Leases that do not transfer substantially all benefits and risks of ownership to the lessee are classified as operating leases. Such leased equipment and related initial direct costs are included in other assets and depreciated to their estimated salvage value on a straight-line basis over the term of the lease. Lease financing equipment depreciation is recorded in noninterest expense on the Consolidated Statements of Income. Operating lease payments received are recognized as lease income on the Consolidated Statements of Income when due and recorded as a component of leasing revenue in noninterest income. An allowance for lease losses is not provided on operating leases. See "Note 7. Loans and Leases" for further information on leases.

As a lessee, the Corporation enters into contracts to lease real estate, information technology equipment and various other types of equipment. Leases that transfer substantially all of the benefits and risks of ownership to the Corporation are classified as finance leases, while all others are classified as operating leases. At lease commencement, a lease liability and right-of-use asset are calculated and recognized for both types of leases. The lease liability is equal to the present value of future minimum lease payments. The right-of-use asset is equal to the lease liability, plus any initial direct costs and prepaid lease payments, less any lease incentives received. Operating lease right-of-use assets are recorded in other assets and finance lease right-of-use assets are recorded in premises and equipment, net. The Corporation uses the appropriate term FHLB rate to determine the discount rate for the present value calculation of future minimum payments when an implicit rate is not known for a given lease. The lease term used in the calculation includes any options to extend that the Corporation is reasonably certain to exercise.

Subsequent to lease commencement, lease liabilities recorded for finance leases are measured using the effective interest rate method and the related right-of-use assets are amortized on a straight-line basis over the lease term. Interest expense and amortization expense are recorded separately in the Consolidated Statements of Income in interest expense on borrowings and occupancy and equipment noninterest expense, respectively. For operating leases, total lease cost is comprised of lease expense, short-term lease cost, variable lease cost and sublease income. Lease expense includes future minimum lease payments, which are recognized on a straight-line basis over the lease term, as well as common area maintenance charges, real estate taxes, insurance and other expenses, where applicable, which are expensed as incurred. Total lease cost for operating leases is recorded in occupancy and equipment in noninterest expense. See "Note 12. Operating Lease Right-of-Use Assets and Liabilities" for further information.

Premises and Equipment Premises and equipment, including right-of-use assets for finance leases and leasehold improvements, are carried at cost and are depreciated or amortized on a straight-line basis over the estimated useful lives of owned assets (up to 39 years for buildings, and ranging from three to 15 years for all other depreciable owned assets), over the lease term for right-of-use assets and over the lesser of the estimated useful life of the related asset or the lease term for leasehold improvements. Maintenance and repairs are charged to expense as incurred. Rent expense for leased land with facilities is recognized in occupancy and equipment expense. Rent expense for leases with free rent periods or scheduled rent increases is recognized on a straight-line basis over the lease term. See "Note 9. Premises and Equipment, Net" for further information on premises and equipment.

Goodwill and Other Intangible Assets All assets and liabilities acquired in purchase acquisitions, including other intangibles, are initially recorded at fair value. Goodwill is recorded when the purchase price of an acquisition is greater than the fair value of net assets, including identifiable intangible assets. Goodwill is not amortized, but assessed for impairment annually at the reporting unit level. The Corporation has historically performed its annual assessment as of December 31st. As a result of the TCF/Chemical Merger, the Corporation has elected to perform its annual test in the fourth quarter utilizing September 30th financial data. The change in assessment date is not material to the financial statements and allows management more time to perform the analysis of the significant goodwill generated as a result of the TCF/Chemical Merger. Interim impairment analysis may be required if events occur or circumstances change that would more-likely-than-not reduce a reporting unit's fair value below its carrying amount. Other intangible assets are amortized on a straight-line basis or accelerated method over their estimated useful lives and are subject to impairment if events or circumstances indicate a possible inability to realize their carrying amounts.

91

Table of Contents

When testing for goodwill impairment, the Corporation has the option to perform a qualitative assessment of goodwill. The Corporation may also elect to perform a quantitative test without first performing a qualitative analysis. If the qualitative assessment is performed and the Corporation concludes it is more-likely-than-not that a reporting unit's fair value is less than its carrying amount, a quantitative analysis is performed. The quantitative valuation methodology includes discounted cash flow and market analyses in determining the fair value of reporting units. If the fair value is less than the carrying amount, additional analysis is required to measure the amount of impairment. Impairment losses, if any, are recorded as a charge to other noninterest expense and an adjustment to the carrying value of goodwill.

Loan Servicing Rights Loan servicing rights ("LSRs") are recognized as assets or liabilities as a result of selling residential mortgage and commercial real estate loans in the secondary market while retaining the right to service these loans and receive servicing income over the life of the loan, and from acquisitions of other banks that had LSRs. An LSR is recorded at estimated fair value when initially recognized. Fair value is determined by the present value of expected cash flows received in excess of a market servicing rate. If the amount earned to service assets is equal to the market rate, no value is recorded. Subsequently, LSRs are accounted for at the lower of amortized cost or fair value and amortized in proportion to and over the period of net servicing income. Unexpected prepayments of mortgage loans result in increased amortization of LSRs, as the remaining book value of the LSRs is expensed at the time of prepayment. LSRs are assessed quarterly for impairment. See "Note 11. Loan Servicing Rights" for further information.

Other Real Estate Owned and Repossessed and Returned Assets Other real estate owned and repossessed and returned assets is comprised of assets acquired through foreclosure, repossession or returned to the Corporation. These assets are initially recorded at the lower of the loan or lease carrying amount or fair value of the collateral less estimated selling costs at the time of transfer to real estate owned or repossessed and returned assets. The fair value of other real estate owned is based on independent appraisals, real estate brokers' price opinions or automated valuation methods, less estimated selling costs. The fair value of repossessed and returned assets is based on available pricing guides, auction results or price opinions, less estimated selling costs. Any carrying amount in excess of the fair value less estimated selling costs is charged off to the allowance for loan and lease losses upon transfer. Subsequently, if the fair value of an asset, less the estimated costs to sell, declines to less than the carrying amount of the asset, the shortfall is recognized in the period in which it becomes known and is included in foreclosed real estate and repossessed assets, net expense. Operating expenses of properties and recoveries on sales of other real estate owned are also recorded in noninterest expense within net foreclosed real estate and repossessed assets. Operating revenue from foreclosed property is included in other noninterest income. See "Note 8. Allowance for Credit Losses and Credit Quality" for further information on other real estate owned and repossessed and returned assets.

Investments in Qualified Affordable Housing Projects and Historic Projects The Corporation has investments in affordable housing limited liability entities that either operate qualified affordable housing projects or invest in other limited liability entities formed to operate affordable housing projects, which generally accounts for under the proportional amortization method. However, depending on circumstances, the effective yield, equity or cost methods may be utilized. The Corporation also has investments in historic projects, which are accounted for under the equity method. The amount of the investments, along with any unfunded equity contributions that are unconditional and legally binding, are recorded in other assets on the Consolidated Statements of Financial Condition. A liability for the unfunded equity contributions is recorded in accrued expenses and other liabilities on the Consolidated Statements of Financial Condition. The tax credits and amortization of the investments are recorded as a component of income tax expense (benefit). Investments in affordable housing limited liability entities are considered VIEs because the Corporation, as a limited partner, lacks the power to direct the activities that most significantly impact the entities' economic performance. The Corporation has concluded it is not the primary beneficiary of the investments in affordable housing limited liability entities and therefore, they are not consolidated. The maximum exposure to loss on the VIE investments is limited to the carrying amount of the investments and the potential recapture of any recognized tax credits. The Corporation believes the likelihood of the tax credits being recaptured is remote, as a loss would require the managing entity to fail to meet certain government compliance requirements. Further, certain of the Corporation's investments in affordable housing limited liability entities include guaranteed minimum returns which are backed by an investment grade credit-rated company, which reduces the risk of loss. See "Note 13. Investments in Qualified Affordable Housing Projects and Historic Projects" for further information on investments in affordable housing limited liability entities.

92

Table of Contents

Derivative Instruments All derivative instruments are recognized at fair value within other assets and other liabilities. The Corporation's derivative instruments may be subject to master netting arrangements and collateral arrangements and qualify for offset in the Consolidated Statements of Financial Condition. A master netting arrangement with a counterparty creates a right of offset for amounts due to and from that same counterparty that is enforceable in the event of a default or bankruptcy. The Corporation's policy is to recognize amounts subject to master netting arrangements and collateral arrangements on a net basis in the Consolidated Statements of Financial Condition. The value of derivative instruments will vary over their contractual terms as the related underlying rates fluctuate. The accounting for changes in the fair value of a derivative instrument depends on whether or not the contract has been designated and qualifies as a hedge. To qualify as a hedge, a contract must be highly effective at reducing the risk associated with the exposure being hedged. In addition, for a contract to be designated as a hedge, the risk management objective and strategy must be documented at inception. Hedge documentation must also identify the hedging instrument, the asset or liability and type of risk to be hedged and how the effectiveness of the contract is assessed prospectively and retrospectively. To assess effectiveness, the Corporation uses statistical methods such as regression analysis. A contract that has been, and is expected to continue to be effective at offsetting changes in fair values or the net investment, must be assessed and documented at least quarterly. If it is determined that a contract is not highly effective at hedging the designated exposure, hedge accounting is discontinued.

Upon origination of a derivative instrument, the contract is designated either as a hedge of the exposure to changes in the fair value of an asset or liability due to changes in market risk ("fair value hedge"), a hedge of the volatility of an investment in foreign operations driven by changes in foreign currency exchange rates ("net investment hedge") or is not designated as a hedge.

Fair Value Hedges TCF Bank entered into an interest rate swap agreement related to its contemporaneously issued subordinated debt, which settles through a central clearing house. The swap was designated as a fair value hedge and effectively converts the fixed interest rate to a floating rate based on the three-month London InterBank Offered Rate ("LIBOR") plus a fixed number of basis points on the $150.0 million notional amount through February 27, 2025, the maturity date of the subordinated debt.

The interest rate swap substantially offsets the change in fair value of the hedged underlying subordinated debt that is attributable to the changes in market risk. The gains and losses related to changes in the fair value of the interest rate swap, as well as the offsetting changes in fair value of the hedged debt, are recorded in interest on borrowings.

Net Investment Hedges  Forward foreign exchange contracts, which generally settle within 35 days, are used to manage the foreign exchange risk associated with the Corporation's net investment in TCF Commercial Finance Canada, Inc. ("TCFCFC"), a wholly-owned indirect Canadian subsidiary of TCF Bank. Changes in net investment hedges recorded within other comprehensive income (loss) are subsequently reclassified to other noninterest expense during the period in which the foreign investment is substantially liquidated or when other elements of the currency translation adjustment are reclassified to income.

Derivatives Not Designated as Hedges  The Corporation executes interest rate contracts with commercial banking customers to facilitate their respective risk management strategies. Those interest rate contracts are simultaneously hedged with offsetting interest rate contracts that the Corporation executes with a third party and generally settles through a central clearing house, minimizing the Corporation's net risk exposure. As the interest rate contracts do not meet hedge accounting requirements, changes in the fair value of both the customer contracts and the offsetting contracts are recorded in other noninterest income. These contracts have original fixed maturity dates ranging from 2 to 15 years.

Portions of loans to commercial banking customers with associated interest rate contracts may be sold or purchased by TCF Bank. In such circumstances, the Corporation often executes risk participation agreements ("RPAs") directly with the party that owns the remaining portion of the loan. These agreements require the party that has not originated the interest rate contract with the borrower to assume a portion of the risk that the borrower will default on the interest rate contract obligation. As the RPAs do not meet hedge accounting requirements, changes in the fair value of these contracts are recorded in other noninterest income. These contracts have original fixed maturity dates matching the associated interest rate contracts.

Certain of the Corporation's forward foreign exchange contracts are not designated as hedges and are generally settled within 35 days. Changes in the fair value of these forward foreign exchange contracts are recorded in other noninterest expense.

93

Table of Contents

The Corporation enters into interest rate lock commitments in conjunction with the sale of certain consumer real estate loans. These interest rate lock commitments are agreements to extend credit under certain specified terms and conditions at fixed rates with original lock expirations generally within 10 months. They are not designated as hedges and accordingly, changes in the valuation of these commitments are recorded in net gains on sales of loans and leases.

Mandatory forward loan sale commitments are accounted for as derivatives and recorded at fair value, with changes in fair value recorded through earnings. The Corporation recognizes revenue associated with the expected future cash flows of servicing loans for loans held-for-sale at the time a forward loan sale commitment is made to originate a held-for-sale loan.

The Corporation has written and purchased option derivatives consisting of instruments to facilitate an equity-linked time deposit product (the "Power Equity CD"). The Power Equity CD is a time deposit that provides the purchaser a guaranteed return of principal at maturity plus a potential equity return (a written option), while the Corporation receives a known stream of funds based on the equity return (a purchased option). The written and purchased options are mirror derivative instruments which are carried at fair value on the Consolidated Statements of Financial Condition.

During the second quarter of 2012, the Corporation sold its Visa® Class B stock. In conjunction with the sale, the Corporation and the purchaser entered into a derivative transaction whereby the Corporation may receive or be required to make cash payments whenever the conversion ratio of the Visa Class B stock into Visa Class A stock is adjusted. The fair value of this derivative has been determined using estimated future cash flows using probability weighted scenarios for multiple estimates of Visa's aggregate exposure to covered litigation matters, which include consideration of amounts funded by Visa into its escrow account for the covered litigation matters. Changes, if any, in the valuation of this swap agreement, which has no determinable maturity date, are recorded in other noninterest expense. See "Note 19. Derivative Instruments" for further information on derivative instruments.

Bank-Owned Life Insurance The Corporation has life insurance policies on certain key officers of TCF Bank. The bank-owned life insurance policies of the Corporation were obtained through its merger with Chemical Bank in August 2019. Bank-owned life insurance is recorded at the cash surrender value, net of surrender charges, and is included within other assets on the Consolidated Statements of Financial Condition and tax-exempt income from the periodic changes in the cash surrender values are recorded as other noninterest income on the Consolidated Statements of Income. The total cash surrender value of the bank-owned life insurance policies totaled $177.0 million at December 31, 2020 and $167.6 million at December 31, 2019. Bank-owned life insurance income was $7.8 million and $1.5 million for the years ended December 31, 2020 and December 31, 2019, respectively.

Short-term Borrowings Short-term borrowings are comprised of short-term FHLB advances with original scheduled maturities of one year or less, and collateralized customer deposits, which represent funds deposited by customers that are collateralized by investment securities owned by the Corporation, as these deposits are not covered by Federal Deposit Insurance Corporation ("FDIC") insurance and are reflected as a liability in the accompanying Consolidated Statements of Financial Condition. See "Note 15. Borrowings" for further information.

Long-term Borrowings Long-term borrowings are comprised of subordinated debentures, long-term FHLB advances, discounted lease rentals, and finance lease obligations. See "Note 15. Borrowings" for further information.

Advertising Costs Advertising costs are expensed as incurred. The Corporation has entered into long-term contracts for sponsorships or naming rights of certain events and buildings. Costs associated with these contracts are generally expensed ratable over the contract term.

Income Taxes The Corporation files consolidated and separate company U.S. federal income tax returns, combined and separate company state income tax returns and foreign income tax returns. Current and deferred tax assets and liabilities are measured based on the provisions of enacted tax law.

94

Table of Contents

Income taxes are accounted for using the asset and liability method. Under this method, current income tax expense represents the estimated liability for the current period and includes income tax expense related to uncertain tax positions. When income and expenses are recognized in different periods for tax purposes than for book purposes, deferred tax assets and liabilities are recognized for the future tax consequences attributable to the temporary differences between the financial statement carrying amounts of existing assets and liabilities and their respective tax bases. Differences in the tax and book carrying amounts of assets and liabilities can also be generated when the Corporation acquires other businesses or bank branches. Deferred tax assets and liabilities are measured using enacted tax rates expected to apply to taxable income in the years in which those temporary differences are expected to be recovered or settled. The effect on deferred tax assets and liabilities of a change in tax rates is recorded in income tax expense (benefit) in the period in which the enactment date occurs. If current period income tax rates change, the impact on the annual effective income tax rate is applied year to date in the period of enactment.

The determination of current and deferred income taxes is based on analyses of many factors, including interpretation of income tax laws, the evaluation of uncertain tax positions, temporary differences between the tax and financial reporting bases of assets and liabilities, estimates of amounts due or owed, the timing of reversals of temporary differences and current financial accounting standards. Additionally, there can be no assurance that estimates and interpretations used in determining income tax assets or liabilities will not be challenged by taxing authorities. Actual results could differ significantly from the estimates and tax law interpretations used in determining the current and deferred income tax assets and liabilities.

In the preparation of income tax returns, tax positions are taken based on interpretation of income tax laws for which the outcome is uncertain. At each balance sheet date, management reviews and evaluates the status of uncertain tax positions and makes estimates of amounts ultimately due or owed. The benefits of tax positions are recorded in income tax expense (benefit) net of the estimates of ultimate amounts due or owed, including any applicable interest and penalties. Changes in the estimated amounts due or owed may result from closing of the statute of limitations on tax returns, new legislation, clarification of existing legislation through government pronouncements, judicial action and through the examination process. The Corporation's policy is to record interest and penalties, if any, related to unrecognized tax benefits in income tax expense (benefit). See "Note 26. Income Taxes" for further information on income taxes.

Share-based Compensation The fair value of restricted stock awards, stock options and restricted stock units is determined on the date of grant and amortized to compensation and employee benefits expense, with a corresponding increase to additional paid-in capital, over the longer of the service period or performance period, but in no event beyond an employee's retirement date or date of employment termination. For performance-based restricted stock or stock units, the Corporation estimates the degree to which performance conditions will be met to determine the number of shares or units that will vest and the related expense. Compensation and employee benefits expense is adjusted in the period such estimates change. Non-forfeitable dividends, if any, paid on shares of restricted stock are recorded to retained earnings for shares that are expected to vest and to compensation and employee benefits expense for shares that are not expected to vest.

Income tax benefits (detriments) related to stock compensation, where the fair value on vesting or exercise of the award is greater than (less than) the grant date value less any proceeds on exercise, are recognized in income tax expense (benefit). See "Note 22. Share-based Compensation" for further information on stock-based compensation.

Earnings Per Common Share The Corporation's restricted stock awards that pay non-forfeitable common stock dividends meet the criteria of a participating security. Accordingly, earnings per share is calculated using the two-class method under which earnings are allocated to both common shares and participating securities.

All shares of restricted stock are deducted from weighted-average shares outstanding for the computation of basic earnings per common share. Shares of performance-based restricted stock and restricted stock units are included in the calculation of diluted earnings per common share using the treasury stock method at the beginning of the quarter in which the performance goals have been achieved. All other shares of restricted stock, which vest over specified time periods, stock options and warrants are included in the calculation of diluted earnings per common share using the treasury stock method. See "Note 24. Earnings Per Common Share" for further information on earnings per share.

95

Table of Contents

Accumulated Other Comprehensive Income (Loss) Comprehensive income of the Corporation includes net income and adjustments to shareholders' equity for changes in unrealized gains and losses on investment securities available-for-sale, interest only strips, and net investment hedges, as well as foreign currency translation adjustments and recognized postretirement prior service cost. All items included in comprehensive income are net of income taxes. The Corporation presents "Comprehensive income" as a component in the Consolidated Statements of Equity and the components of other comprehensive income (loss) separately in the Consolidated Statements of Comprehensive Income. See "Note 16. Accumulated Other Comprehensive Income (Loss)" for further information on accumulated other comprehensive income (loss).

Recently Adopted Accounting Pronouncements

Effective January 1, 2020, the Corporation adopted ASU No. 2020-03, Codification Improvements to Financial Instruments, which is comprised of amendments intended to clarify or improve the accounting guidance for various financial instruments, including fair value measurement and disclosure, disclosures for depository and lending institutions, and the interaction between Topic 326 - Financial Instruments - Credit losses and other Topics. Each of the clarifying amendments are either not relevant to the Corporation's consolidated financial statements or further confirmed the Corporation's existing interpretation of the accounting guidance. As such, the adoption of this guidance did not have a material impact on the consolidated financial statements.

Effective January 1, 2020, the Corporation adopted ASU No. 2019-08, Compensation-Stock Compensation (Topic 718) and Revenue from Contracts with Customers (Topic 606): Codification Improvements-Share-Based Consideration Payable to a Customer, which requires entities to measure and classify share-based payment awards granted to a customer by applying the guidance in Topic 718. The adoption of this guidance did not have a material impact on the consolidated financial statements.

Effective January 1, 2020, the Corporation adopted ASU No. 2018-18, Collaborative Arrangements (Topic 808): Clarifying the Interaction between Topic 808 and Topic 606, which makes targeted improvements to the accounting for collaborative arrangements in response to questions raised as a result of the issuance of ASU 2014-09, Revenue from Contracts with Customers (Topic 606). The adoption of this guidance did not have a material impact on the consolidated financial statements.

Effective January 1, 2020, the Corporation adopted ASU No. 2018-17, Consolidation (Topic 810): Targeted Improvements to Related Party Guidance for Variable Interest Entities. In addition to providing variable interest entities ("VIE") guidance to private companies, this ASU contains an amendment applicable to all entities which amends how a decision maker or service provider determines whether its fee is a variable interest in a VIE when a related party under common control also has an interest in the VIE. The adoption of this guidance did not have a material impact on the consolidated financial statements.

Effective January 1, 2020, the Corporation adopted ASU No. 2018-13, Fair Value Measurement (Topic 820): Disclosure Framework - Changes to the Disclosure Requirements for Fair Value Measurement, which eliminates, adds and modifies certain disclosure requirements for fair value measurements. While the adoption of this guidance required adjustments to our fair value disclosures, it did not have a material impact on the consolidated financial statements.

Effective January 1, 2020, the Corporation adopted ASU No. 2017-04, Intangibles - Goodwill and Other (Topic 350): Simplifying the Test for Goodwill Impairment. This ASU simplifies the accounting for goodwill impairment by removing Step 2 of the goodwill impairment test, which requires a hypothetical purchase price allocation. Under the new guidance, the Corporation will compare the fair value of a reporting unit with its carrying amount and recognize an impairment charge for any amount by which a reporting unit’s carrying amount exceeds its fair value, not to exceed the carrying amount of goodwill. All other goodwill impairment guidance largely remains unchanged. The adoption of this guidance did not have a material impact on the consolidated financial statements.

96

Table of Contents

Effective January 1, 2020, the Corporation adopted ASU No. 2016-13, Financial Instruments - Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments, which changes the impairment model for most financial assets (including off-balance sheet exposures), including trade and other receivables, debt securities held-to-maturity, loans, net investments in leases and purchased financial assets with credit deterioration. The ASU requires the use of a current expected credit loss ("CECL") methodology to determine the allowance for credit losses for loans and debt securities held-to-maturity. CECL requires loss estimates for the remaining estimated life of the asset to be measured using historical loss data as well as adjustments for current conditions and reasonable and supportable forecasts of future economic conditions. Effective January 1, 2020, the Corporation also adopted the following ASUs, which further amend the original CECL guidance in Topic 326: (i) ASU No. 2018-19, Codification Improvements to Topic 326, Financial Instruments - Credit Losses, which clarifies that receivables arising from operating leases are not within the scope of Subtopic 326-20 and should be accounted for in accordance with Topic 842; (ii) ASU No. 2019-04, Codification Improvements to Topic 326, Financial Instruments - Credit Losses, Topic 815, Derivatives and Hedging, and Topic 825, Financial Instruments, which clarifies and corrects certain unintended applications of the guidance contained in each of the amended Topics; (iii) ASU No. 2019-05, Financial Instruments - Credit Losses (Topic 326): Targeted Transition Relief, which provides an option to irrevocably elect to apply the fair value option in Subtopic 825-10 to certain instruments within the scope of Subtopic 326-20 upon adoption of Topic 326; (iv) ASU No. 2019-11, Codification Improvements to Topic 326, Financial Instruments-Credit Losses, which clarifies that expected recoveries of amounts previously written off or expected to be written off should be included in the estimate of allowance for credit losses for purchased financial assets with credit deterioration, provides certain transition relief for TDR accounting when the discounted cash flow method is used to estimate credit losses, allows entities to elect to disclose separately the total amount of accrued interest included in the amortized cost basis as a single balance to meet certain disclosure requirements, and clarifies that an entity should assess whether it reasonably expects the borrower will be able to continually replenish collateral securing financial assets when electing a practical expedient to measure the estimate of expected credit losses by comparing the amortized cost basis of the financial asset and the fair value of collateral securing the financial asset as of the reporting date. These ASUs were adopted on a modified retrospective basis.

97

Table of Contents

CECL represents a significant change in GAAP and has resulted in a significant change to industry practice, which the Corporation expects will continue to evolve over time. Our adoption resulted in an ALLL as of January 1, 2020 that is larger than the ALLL that would have been recorded under the legacy guidance on the same date by $206.0 million in total for all portfolios. Approximately 20% of the increase relates to originated loans and leases, with the largest impact on the consumer segment given the longer duration of the portfolios. A significant portion of the increase is a result of new requirements to record ALLL related to acquired loans and leases, regardless of any credit mark previously recorded with respect to them. Approximately 80% of the increase relates to acquired loans and leases, which were recorded at estimated fair value at their respective acquisition date, the majority of which relate to loans and leases acquired in the TCF/Chemical Merger. Under legacy GAAP, credit marks were included in the determination of the fair value adjustments reflected as a discount to the carrying value of the loans, and an ALLL was not recorded on acquired loans and leases until evidence of credit deterioration existed post acquisition. However, upon adoption of CECL an ALLL is recorded for all acquired loans and leases based on the lifetime loss concept. Further, for acquired loans and leases that do not meet the definition of PCD, the credit and interest marks which existed from acquisition accounting as of December 31, 2019 will continue to accrete over the life of loan. For acquired loans that met the definition of PCI under legacy GAAP and converted to PCD at CECL adoption, the ALLL recorded is recognized through a gross-up that increases the amortized cost basis of loans with a corresponding ALLL, and therefore results in little to no impact to the cumulative effect adjustment to retained earnings. Prior to the adoption of CECL, PCI loans were not classified as nonaccrual loans because they were recorded at their net realizable value based on the principal and interest expected to be collected on the loans. At January 1, 2020, $73.4 million of loans previously classified as PCI were reclassified to nonaccrual loans as a result of the adoption of CECL. The adoption of CECL also resulted in an increase in the liability for unfunded lending commitments of $14.7 million. For other assets within the scope of the standard such as available-for-sale investment securities, held-to-maturity investment securities, and trade and other receivables, the impact from the standard was inconsequential. The cumulative tax effected adjustment to record ALLL and to increase the unfunded lending commitment liability resulted in a reduction to retained earnings of $159.3 million. Post-adoption, as loans and leases are added to the portfolio, the Corporation expects higher levels of ACL determined by CECL assumptions, resulting in accelerated recognition of provision for credit losses, as compared to historical results. In response to the COVID-19 pandemic, the regulatory agencies published a final rule that provides the option to delay the cumulative effect of the day 1 impact of CECL adoption on regulatory capital, along with 25% of the change in the adjusted allowance for credit losses (as computed for regulatory capital purposes which excludes PCD loans), for 2 years, followed by a three-year phase-in period. Management elected the 5-year transition period consistent with the final rule issued by the regulatory agencies. Additional and modified disclosure requirements under CECL are included in "Note 6. Investment Securities" and "Note 8. Allowance for Credit Losses and Credit Quality."

CARES Act and Interagency Regulatory Guidance Regarding Troubled Debt Restructurings

On March 27, 2020, the Coronavirus Aid, Relief and Economic Security (“CARES”) Act was signed into law. Section 4013 of the CARES Act provides banks the option to temporarily suspend certain TDR accounting guidance for loans modified due to the effects of COVID-19. Additionally, on April 7, 2020, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency (collectively the "agencies") issued a statement, "Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working With Customers Affected by the Coronavirus (Revised)" ("Interagency Statement on Loan Modifications") to encourage banks to work prudently with borrowers and to describe the agencies' interpretation of how accounting guidance for troubled debt restructuring applies to certain COVID-19-related modifications.

The CARES Act includes a provision permitting the Corporation to opt out of applying TDR accounting guidance for certain loan modifications. Loan modifications made between March 1, 2020 and the earlier of December 31, 2020 or 60 days after the President of the United States declares a termination of the COVID-19 national emergency are eligible for this relief if the related loans were not more than 30 days past due as of December 31, 2019 and meet the other requirements. On December 27, 2020, these provisions were extended to the earlier of January 1, 2022 or 60 days after the President of the United States declares a termination of the COVID-19 national emergency. The Corporation will first assess if a loan modification meets the qualifications. If the loan modification does not meet the qualification under the CARES Act, the Corporation will then assess applicability of the Interagency Statement on Loan Modifications offering practical expedients for short term modifications. Under both guidance principals, subsequent modifications must be re-evaluated for the appropriate accounting treatment. The Corporation will apply its existing accounting policies for those loans that either do not qualify for the relief under either the CARES Act or the Interagency Statement on Loan Modifications, or for which the Corporation has decided not to apply the relief.

98

Table of Contents

The Corporation has granted short-term (up to 180 days) deferral of payment for certain borrowers. In these cases, the Corporation recognizes interest income as earned. The deferred interest will be repaid by the borrower in a future period, and will be evaluated by the Corporation for collectability. Certain borrowers that need additional relief beyond the initial 180 day deferral continue to be evaluated under the CARES Act, if applicable, but will generally be placed on nonaccrual with any remaining accrued interest balance reversed against interest income.

Recently Issued Accounting Pronouncements

In October 2020, the Financial Accounting Standards Board (the "FASB") issued ASU No. 2020-10, Codification Improvements, which is intended to clarify or correct the unintended application of the Codification of accounting guidance for a wide variety of topics. The adoption of this ASU will be required beginning with the Corporation's Quarterly Report on Form 10-Q for the quarter ending March 31, 2021. Early adoption is allowed. The adoption of this guidance will not have a material impact on the consolidated financial statements.

In October 2020, the FASB issued ASU No. 2020-08, Codification Improvements to Subtopic 310-20, Receivables - Nonrefundable Fees and Other Costs, which clarifies the intent of certain updates that were included in ASU No. 2017-08, Receivables - Nonrefundable Fees and Other Costs (Subtopic 310-20): Premium Amortization on Purchased Callable Debt Securities. The adoption of this ASU will be required beginning with the Corporation's Quarterly Report on Form 10-Q for the quarter ending March 31, 2021. Early adoption is allowed. The adoption of this guidance will not have a material impact on the consolidated financial statements.

In August 2020, the FASB issued ASU No. 2020-06, Debt-Debt with Conversion and Other Options (Subtopic 470-20) and Derivatives and Hedging-Contracts in Entity’s Own Equity (Subtopic 815-40): Accounting for Convertible Instruments and Contracts in an Entity’s Own Equity, which reduces the complexity of accounting for certain financial instruments with characteristics of both debt and equity. The adoption of this ASU will be required beginning with the Corporation's Quarterly Report on Form 10-Q for the quarter ending March 31, 2022. Early adoption is allowed, but no earlier than the quarter ending March 31, 2021. Management is currently evaluating the impact of this guidance on the consolidated financial statements.

In March 2020, the FASB issued ASU No. 2020-04, Reference Rate Reform (Topic 848): Facilitation of the Effects of Reference Rate Reform on Financial Reporting, which provides a number of optional expedients to general accounting guidance intended to ease the burden of the accounting impacts of reference rate reform related to contract modifications and hedge accounting elections. In January 2021, the FASB issued ASU No. 2021-01, Reference Rate Reform (Topic 848): Scope, which clarifies that the scope of Topic 848 includes derivative instruments that do not reference a rate that is expected to be discontinued but that use an interest rate for margining, discounting, or contract price alignment that is modified as a result of reference rate reform. Adoption of the expedients is allowed after March 12, 2020 and no later than December 31, 2022. Management is currently evaluating the impact of this guidance on the consolidated financial statements.

In January 2020, the FASB issued ASU No. 2020-01, Investments-Equity Securities (Topic 321), Investments-Equity Method and Joint Ventures (Topic 323), and Derivatives and Hedging (Topic 815)-Clarifying the Interactions between Topic 321, Topic 323, and Topic 815 (a consensus of the Emerging Issues Task Force), which clarifies the interactions between Topic 321, Topic 323 and Topic 815, including accounting for the transition into and out of the equity method and measuring certain purchased options and forward contracts to acquire investments. The adoption of this ASU will be required beginning with the Corporation's Quarterly Report on Form 10-Q for the quarter ending March 31, 2021. Early adoption is allowed. The adoption of this guidance will not have a material impact on the consolidated financial statements.

In December 2019, the FASB issued ASU No. 2019-12, Income Taxes (Topic 740): Simplifying the Accounting for Income Taxes, which is intended to simplify the accounting for income taxes by removing certain exceptions to the general rules found in Topic 740 - Income Taxes. The adoption of this ASU will be required beginning with the Corporation's Quarterly Report on Form 10-Q for the quarter ending March 31, 2021. Early adoption is allowed. The adoption of this guidance will not have a material impact on the consolidated financial statements.

99

Table of Contents

Note 3. Business Combinations

Proposed Merger with Huntington Bancshares Incorporated

On December 13, 2020, TCF and Huntington Bancshares Incorporated ("Huntington") jointly announced the signing of a definitive merger agreement (the "TCF/Huntington Merger Agreement"). Under the terms of the agreement, which was unanimously approved by the boards of directors of both companies, TCF will merge into Huntington, with Huntington continuing as the surviving entity, with dual headquarters for banking operations in Detroit, Michigan and Columbus, Ohio. Huntington is headquartered in Columbus, Ohio with reported assets of $123.0 billion as of December 31, 2020. Under the terms of the TCF/Huntington Merger Agreement, TCF shareholders will receive 3.0028 shares of Huntington common stock for each share of TCF common stock. Holders of TCF common stock will receive cash in lieu of fractional shares. Each outstanding share of 5.70% Series C Non-Cumulative Perpetual Preferred Stock of TCF will be converted into the right to receive one share of a newly created series of preferred stock of Huntington. Subject to receipt of regulatory approvals and satisfaction of other customary closing conditions, including approval of both TCF and Huntington shareholders, the transaction is anticipated to close in the second quarter of 2021.

TCF/Chemical Merger

As described in "Note 1. Basis of Presentation," on August 1, 2019, the Corporation completed the TCF/Chemical Merger with Legacy TCF.

The TCF/Chemical Merger was an all-stock transaction. Pursuant to the merger agreement, on the TCF/Chemical Merger Date, each holder of Legacy TCF common stock received 0.5081 shares (the "Exchange Ratio") of TCF's common stock for each share of Legacy TCF common stock held. Each outstanding share of common stock of Chemical remained outstanding and was unaffected by the TCF/Chemical Merger other than by the change of the Corporation’s name from Chemical Financial Corporation to TCF Financial Corporation. As of the effective time of the TCF/Chemical Merger on August 1, 2019, TCF Financial had approximately 153.5 million shares of common stock outstanding. On the TCF/Chemical Merger Date, the shares of Legacy TCF common stock, which previously traded under the ticker symbol "TCF" on the New York Stock Exchange (the "NYSE"), ceased trading on, and were delisted from, the NYSE. Following the TCF/Chemical Merger, TCF Financial common stock continues to trade on the Nasdaq Stock Market (“NASDAQ”), but its ticker symbol changed from "CHFC" to "TCF" effective August 1, 2019.

Pursuant to the merger agreement, each outstanding share of Legacy TCF 5.70% Series C Non-Cumulative Perpetual Preferred Stock, with a liquidation preference of $25,000 per share (the "Legacy TCF Preferred Stock") was converted into the right to receive one share of newly created 5.70% Series C Non-Cumulative Perpetual Preferred Stock of TCF, with a liquidation preference of $25,000 per share (the "New TCF Preferred Stock"), and each depository share representing 1/1000th of a share of Legacy TCF Preferred Stock was converted into one depositary share representing 1/1000th of a share of New TCF Preferred Stock. Immediately following the effective time of the TCF/Chemical Merger, as of August 1, 2019, TCF Financial had 7,000 shares of New TCF Preferred Stock outstanding and 7.0 million related depositary shares outstanding.

The TCF/Chemical Merger constituted a business combination and was accounted for as a reverse merger using the acquisition method of accounting, therefore, Legacy TCF was deemed the acquirer for financial reporting purposes even though Chemical was the legal acquirer. As a result, the historical financial statements of Legacy TCF became the historical financial statements of the combined company. In addition, the assets acquired, including the intangible assets identified, and assumed liabilities of Chemical as of the TCF/Chemical Merger Date, have been recorded at their estimated fair value and added to those of Legacy TCF. In many cases, the determination of fair value required management to make estimates about discount rates, expected future cash flows, market conditions and other future events that are highly subjective in nature and subject to change.

100

Table of Contents

As the legal acquirer, Chemical (now TCF Financial Corporation) issued approximately 81.9 million shares of TCF Financial common stock in connection with the TCF/Chemical Merger, which represented approximately 53% of the voting interests in TCF Financial upon completion of the TCF/Chemical Merger. Guidance in Accounting Standards Codification ("ASC") 805-40-30-2 explains that the purchase price in a reverse acquisition is determined based on “the number of equity interests the legal acquiree would have had to issue to give the owners of the legal acquirer the same percentage equity interest in the combined entity that results from the reverse acquisition.” The first step in calculating the purchase price in the TCF/Chemical Merger is to determine the ownership of the combined company following the TCF/Chemical Merger. The table below summarizes the ownership of the combined company ("TCF Financial") following the TCF/Chemical Merger, as well as the market capitalization of the combined company using shares of Chemical and Legacy TCF common stock outstanding at July 31, 2019 and Chemical’s closing price on July 31, 2019.

(Dollars in thousands)	TCF Financial Ownership and Market Value
	Number of Chemical Outstanding Shares	Percentage Ownership		Market Value at $42.04 Chemical Share Price
Legacy TCF shareholders	81,920,494	53.38	%	$	3,443,938
Chemical shareholders	71,558,755	46.62		3,008,330
Total	153,479,249	100.00		$	6,452,268

Next, the hypothetical number of shares Legacy TCF would have to issue to give Chemical owners the same percentage ownership in the combined company is calculated in the table below (based on shares of Legacy TCF common stock outstanding at July 31, 2019):

	Hypothetical Legacy TCF Ownership
	Number of Legacy TCF Outstanding Shares	Percentage Ownership
Legacy TCF shareholders	161,229,078	53.38	%
Chemical shareholders	140,835,967	46.62
Total	302,065,045	100.00

Finally, the purchase price is calculated based on the number of hypothetical shares of Legacy TCF common stock issued to Chemical shareholders multiplied by the share price as demonstrated in the table below.

(Dollars in thousands, except per share data)
Number of hypothetical Legacy TCF shares issued to Chemical shareholders	140,835,967
Legacy TCF market price per share as of July 31, 2019	$	21.38
Purchase price determination of hypothetical Legacy TCF shares issued to Chemical shareholders	3,011,073
Value of Chemical stock options hypothetically converted to options to acquire shares of Legacy TCF common stock	7,335
Cash in lieu of fractional shares	148
Purchase price consideration	$	3,018,556

101

Table of Contents

The following table provides the purchase price allocation as of the TCF/Chemical Merger Date and the assets acquired and liabilities assumed at their estimated fair value as of the TCF/Chemical Merger Date as recorded by the Corporation. The Corporation recorded the estimate of fair value based on initial valuations available at the TCF/Chemical Merger Date and these estimates were considered preliminary as of September 30, 2019, and subject to adjustment for up to one year after the TCF/Chemical Merger Date. While the Corporation believes that the information available on the TCF/Chemical Merger Date provided a reasonable basis for estimating fair value, following the TCF/Chemical Merger, the Corporation obtained additional information and evidence and then finalized all valuations and recorded final adjustments during the first quarter of 2020. These adjustments included: (i) changes in the estimated fair value of loans and leases acquired, (ii) changes in deferred tax assets related to fair value estimates and changes in the expected realization of items considered to be net operating loss carryforwards and (iii) changes in goodwill as a result of the net effect of any adjustments.

(In thousands)
Purchase price consideration:
Stock	$	3,018,556
Fair value of assets acquired(1):
Cash and cash equivalents	975,014
Federal Home Loan Bank and Federal Reserve Bank stocks	218,582
Investment securities	3,774,738
Loans held-for-sale	44,532
Loans and leases	15,713,399
Premises and equipment	140,219
Loan servicing rights	59,567
Other intangible assets	159,532
Net deferred tax asset(2)	65,685
Other assets	552,432
Total assets acquired	21,703,700
Fair value of liabilities assumed(1):
Deposits	16,418,215
Short-term borrowings	2,629,426
Long-term borrowings	442,323
Other liabilities	353,469
Total liabilities assumed	19,843,433
Fair value of net identifiable assets	1,860,267
Goodwill resulting from the TCF/Chemical Merger(1)	$	1,158,289

(1)All amounts were previously reported in the Corporation's Annual Report on Form 10-K for the year ended December 31, 2019, with the exception of the following adjustments to fair value based on additional information obtained in the first quarter of 2020: (i) loans and leases ($17.2 million decrease), (ii) net deferred tax asset ($4.0 million increase), and (iii) goodwill resulting from the TCF/Chemical Merger ($13.2 million increase).

(2)Net deferred tax asset includes acquisition-related fair value adjustments, loss and tax credit carry forwards, mortgage servicing rights and core deposit and customer intangibles.

The final loan valuation adjustments also impacted interest income in the first quarter of 2020. Additional accretion of $2.4 million would have been recorded as interest income in the year ended December 31, 2019, had the final loan valuation been recorded at the TCF/Chemical Merger Date.

As described in more detail in "Note 2. Summary of Significant Accounting Policies", all Chemical loans and leases were recorded at their estimated fair value as of the TCF/Chemical Merger Date with no carryover of the related allowance for loan and lease losses. The acquired loans and leases were segregated into two classifications at acquisition, purchased credit impaired (“PCI”) loans accounted for under the provisions of Accounting Standards Codification ("ASC") Topic 310-30, and purchased nonimpaired loans and leases, also referred to as purchased loans and leases. The excess of cash flows expected to be collected over the estimated fair value of PCI loans is referred to as the accretable yield and is accreted into interest income over the estimated remaining life of the loan using the effective yield method. The difference between the contractually required payments and the cash flows expected to be collected at acquisition, considering the impact of prepayment and estimates of future credit losses expected to be incurred, is referred to the nonaccretable difference.

102

Table of Contents

Information regarding acquired loans and leases included in loans and leases acquired at the TCF/Chemical Merger Date was as follows:

(In thousands)
PCI loans:
Contractually required payments receivable	$	413,176
Nonaccretable difference	(63,014)
Expected cash flows	350,162
Accretable yield	38,479
Fair value of PCI loans	$	311,683
Purchased nonimpaired loans and leases:
Unpaid principal balance	$	15,636,020
Fair value discount	(234,304)
Fair value at acquisition	15,401,716
Total fair value at acquisition	$	15,713,399

Supplemental disclosures of cash flow information related to investing and financing activities regarding the TCF/Chemical Merger are as follows for the year ended December 31, 2019:

(In thousands)
Business combination
Fair value of tangible assets acquired(1)	$	21,484,601
Goodwill, loan servicing rights and other identifiable intangible assets acquired(1)	1,377,388
Liabilities assumed	19,843,433
Common stock and stock options converted	3,018,556

(1)All amounts were previously reported in the Corporation's Annual Report on Form 10-K for the year ended December 31, 2019, with the exception of the following adjustments to fair value based on additional information obtained in the first quarter of 2020: (i) loans and leases ($17.2 million decrease), (ii) net deferred tax asset ($4.0 million increase), and (iii) goodwill resulting from the TCF/Chemical Merger ($13.2 million increase).

Other intangible assets consisted of core deposits and customer relationship intangibles with estimated fair values at the TCF/Chemical Merger Date of $138.2 million and $21.3 million, respectively. Core deposit intangibles are being amortized over a weighted-average life of ten years on an accelerated basis. Customer relationship intangibles are being amortized over a weighted-average life of 15.6 years based on expected economic benefits of the underlying intangible assets. The weighted-average life of amortizable intangibles acquired in the TCF/Chemical Merger was 11 years.

As a result of the TCF/Chemical Merger, the Corporation recorded $1.2 billion of goodwill. Of the $1.2 billion, $528.0 million was attributable to Consumer Banking and $630.3 million was attributable to Commercial Banking. The goodwill recorded is not deductible for income tax purposes.

103

Table of Contents

Pro Forma Combined Results of Operations (Unaudited) The following pro forma financial information presents the consolidated results of operations of Legacy TCF and Chemical as if the TCF/Chemical Merger had occurred as of January 1, 2018 with pro forma adjustments. The pro forma adjustments give effect to any change in interest income due to the accretion of the discount (amortization of premium) associated with the fair value adjustments to acquired loans and leases, any change in interest expense due to estimated premium amortization/discount accretion associated with the fair value adjustments to acquired time deposits and borrowings and other debt and the amortization of the core deposit intangible that would have resulted had the deposits been acquired as of January 1, 2018. Merger-related expenses incurred by TCF at the effective date of the TCF/Chemical Merger or subsequent to the TCF/Chemical Merger are not reflected in the pro forma amounts. The pro forma information does not necessarily reflect the results of operations that would have occurred had Legacy TCF merged with Chemical at the beginning of 2018. Anticipated cost savings that have not yet been realized are also not reflected in the pro forma amounts for the years ended December 31, 2019 and 2018.

	Year Ended December 31,
(In thousands, except per share data)	2019		2018
Net interest income and other noninterest income	$	2,225,244	$	2,228,154
Net income	587,335		590,594
Net income available to common shareholders	577,360		575,525
Earnings per share:
Basic	$	3.77	$	3.70
Diluted	3.75		3.67

Note 4.  Cash and Cash Equivalents

Cash and cash equivalents include cash and due from banks and interest-bearing deposits in other banks. Total cash and cash equivalents were $1.3 billion and $1.2 billion at December 31, 2020 and 2019, respectively.

As of March 26, 2020, TCF Bank was no longer required by Federal Reserve regulations to maintain reserves in cash on hand or at the Federal Reserve Bank.

The Corporation maintains cash balances that are restricted as to their use in accordance with certain obligations. Cash payments received on loans serviced for third parties are generally held in separate accounts until remitted. The Corporation may also retain cash balances for collateral on certain borrowings and derivatives. The Corporation maintained restricted cash totaling $95.1 million and $68.6 million at December 31, 2020 and 2019, respectively.

Note 5. Federal Home Loan Bank and Federal Reserve Bank Stocks

Federal Home Loan Bank ("FHLB") and Federal Reserve Bank ("FRB") stocks were as follows:

	At December 31,
(In thousands)	2020		2019
FHLB stock, at cost	$	196,457	$	318,473
FRB stock, at cost	123,979		123,967
Total investments	$	320,436	$	442,440

The investments in FHLB stock are required investments related to the Corporation's membership and borrowings from the FHLB of Des Moines, and additional commitments from the FHLB of Indianapolis and Cincinnati. The Corporation's investments in the FHLB of Des Moines, Indianapolis and Cincinnati could be adversely impacted by the financial operations of the Federal Home Loan Banks and actions of their regulator, the Federal Housing Finance Agency. The amount of FRB stock that TCF Bank is required to hold is based on TCF Bank's capital structure. The Corporation periodically evaluates investments for impairment. There was no impairment of these investments in 2020, 2019 and 2018.

104

Table of Contents

Note 6.  Investment Securities

The amortized cost and fair value of investment securities were as follows:

	Investment Securities Available-for-sale, At Fair Value
(In thousands)	Amortized Cost		Gross Unrealized Gains		Gross Unrealized Losses		Fair Value
At December 31, 2020
Debt securities:
Obligations of states and political subdivisions	$	827,191	$	44,077	$	1,087	$	870,181
Government and government-sponsored enterprises	196,560		153		813		195,900
Mortgage-backed securities:
Residential agency	6,151,511		157,955		1,388		6,308,078
Residential non-agency	156,865		2,819		2		159,682
Commercial agency	669,235		39,715		999		707,951
Commercial non-agency	39,358		3,072		—		42,430
Total mortgage-backed debt securities	7,016,969		203,561		2,389		7,218,141
Corporate debt and trust preferred securities	453		48		—		501
Total investment securities available-for-sale	$	8,041,173	$	247,839	$	4,289	$	8,284,723
At December 31, 2019
Debt securities:
Obligations of states and political subdivisions	$	852,096	$	12,446	$	687	$	863,855
Government and government-sponsored enterprises	235,045		18		678		234,385
Mortgage-backed securities:
Residential agency	4,492,427		68,797		6,103		4,555,121
Residential non-agency	374,046		1,166		616		374,596
Commercial agency	645,814		8,639		2,049		652,404
Commercial non-agency	39,398		17		205		39,210
Total mortgage-backed debt securities	5,551,685		78,619		8,973		5,621,331
Corporate debt and trust preferred securities	451		—		21		430
Total investment securities available-for-sale	$	6,639,277	$	91,083	$	10,359	$	6,720,001

	Investment Securities Held-to-Maturity
(In thousands)	Amortized Cost		Gross Unrealized Gains		Gross Unrealized Losses		Fair Value
At December 31, 2020
Residential agency mortgage-backed securities	$	180,946	$	9,267	$	72	$	190,141
Corporate debt and trust preferred securities	3,413		—		—		3,413
Total investment securities held-to-maturity(1)	$	184,359	$	9,267	$	72	$	193,554
At December 31, 2019
Residential agency mortgage-backed securities	$	135,769	$	5,576	$	177	$	141,168
Corporate debt and trust preferred securities	3,676		—		—		3,676
Total investment securities held-to-maturity	$	139,445	$	5,576	$	177	$	144,844

(1)The adoption of CECL was inconsequential to held-to-maturity investment securities. At December 31, 2020 there was no ACL for investment securities held-to-maturity.

105

Table of Contents

Accrued interest receivable for investment securities was $20.6 million and $21.6 million at December 31, 2020 and 2019, respectively, and is included in other assets on the Consolidated Statements of Financial Condition.

Gross unrealized losses and fair value of available-for-sale investment securities aggregated by investment category and the length of time the securities were in a continuous loss position were as follows: 

	At December 31, 2020
	Less than 12 months				12 months or more				Total
(In thousands)	Fair Value		Unrealized Losses		Fair Value		Unrealized Losses		Fair Value		Unrealized Losses
Investment securities available-for-sale
Debt securities:
Government and government sponsored enterprises	$	139,940	$	813	$	—	$	—	$	139,940	$	813
Obligations of states and political subdivisions	78,241		1,087		—		—		78,241		1,087
Mortgage-backed securities:
Residential agency	426,171		1,388		—		—		426,171		1,388
Residential non-agency	1,529		2		—		—		1,529		2
Commercial agency	96,667		999		—		—		96,667		999
Commercial non-agency	—		—		—		—		—		—
Total mortgage-backed debt securities	524,367		2,389		—		—		524,367		2,389
Total investment securities available-for-sale	$	742,548	$	4,289	$	—	$	—	$	742,548	$	4,289

	At December 31, 2019
	Less than 12 months				12 months or more				Total
(In thousands)	Fair Value		Unrealized Losses		Fair Value		Unrealized Losses		Fair Value		Unrealized Losses
Investment securities available-for-sale
Debt securities:
Government and government sponsored enterprises	$	226,177	$	678	$	—	$	—	$	226,177	$	678
Obligations of states and political subdivisions	60,639		687		—		—		60,639		687
Mortgage-backed securities:
Residential agency	667,511		3,586		200,534		2,517		868,045		6,103
Residential non-agency	140,403		616		—		—		140,403		616
Commercial agency	176,880		2,049		—		—		176,880		2,049
Commercial non-agency	25,560		205		—		—		25,560		205
Total mortgage-backed debt securities	1,010,354		6,456		200,534		2,517		1,210,888		8,973
Corporate debt and trust preferred securities	430		21		—		—		430		21
Total investment securities available-for-sale	$	1,297,600	$	7,842	$	200,534	$	2,517	$	1,498,134	$	10,359

The adoption of CECL was inconsequential to available-for-sale investment securities. At December 31, 2020 there was no ACL for investment securities available-for-sale. At December 31, 2020 there were 176 available-for-sale investment securities in an unrealized loss position. Management assessed each investment security with unrealized losses for credit impairment. Substantially all unrealized losses on investment securities available-for-sale were due to credit spreads and interest rates rather than credit impairment. As part of that assessment management evaluated and concluded that it is more-likely-than-not that the Corporation will not be required and does not intend to sell any of the investment securities prior to recovery of the amortized cost.

106

Table of Contents

The gross gains and losses on sales of investment securities were as follows: 

	Year Ended December 31,
(In thousands)	2020		2019		2018
Gross realized gains	$	2,310	$	10,877	$	1,148
Gross realized losses	—		3,491		1,021
Recoveries on previously impaired investment securities held-to-maturity	28		39		221
Net gains on investment securities	$	2,338	$	7,425	$	348

The amortized cost and fair value of investment securities by final contractual maturity were as follows. Securities with multiple maturity dates are classified in the period of final maturity. The final contractual maturities do not consider possible prepayments and therefore expected maturities may differ because borrowers may have the right to call or prepay obligations with or without call or prepayment penalties.

	At December 31,
	2020				2019
(In thousands)	Amortized Cost		Fair Value		Amortized Cost		Fair Value
Investment Securities Available-for-Sale
Due in one year or less	$	45,912	$	46,163	$	66,124	$	66,112
Due in 1-5 years	163,346		168,125		191,364		192,065
Due in 5-10 years	681,135		720,239		547,813		555,523
Due after 10 years	7,150,780		7,350,196		5,833,976		5,906,301
Total investment securities available-for-sale	$	8,041,173	$	8,284,723	$	6,639,277	$	6,720,001
Investment Securities Held-to-Maturity
Due in one year or less	$	400	$	400	$	—	$	—
Due in 1-5 years	2,150		2,150		3,550		3,550
Due in 5-10 years	46		51		58		64
Due after 10 years	181,763		190,953		135,837		141,230
Total investment securities held-to-maturity	$	184,359	$	193,554	$	139,445	$	144,844

At December 31, 2020 and 2019, investment securities with a carrying value of $1.0 billion and $627.0 million, respectively, were pledged as collateral to secure certain deposits and borrowings.

Note 7.  Loans and Leases

Loans and leases were as follows:

	At December 31,
(In thousands)	2020		2019
Commercial loan and lease portfolio:
Commercial and industrial(1)	$	11,422,383	$	11,439,602
Commercial real estate	9,702,587		9,136,870
Lease financing	2,817,231		2,699,869
Total commercial loan and lease portfolio	23,942,201		23,276,341
Consumer loan portfolio:
Residential mortgage	6,182,045		6,179,805
Home equity	3,108,736		3,498,907
Consumer installment	1,233,426		1,542,411
Total consumer loan portfolio	10,524,207		11,221,123
Total loans and leases(2)	$	34,466,408	$	34,497,464

(1)Includes $1.6 billion of PPP loans at December 31, 2020.

(2)Loans and leases are reported at historical cost including net direct fees and costs associated with originating and acquiring loans and leases, lease residuals, unearned income and unamortized purchase premiums and discounts. The aggregate amount of these loan and lease adjustments was $(118.6) million and $(201.5) million at December 31, 2020 and 2019, respectively.

Accrued interest receivable for loans and leases was $93.6 million and $106.5 million at December 31, 2020 and December 31, 2019, respectively, and is included in other assets on the Consolidated Statements of Financial Condition.

107

Table of Contents

Acquired Loans and Leases The Corporation acquires loans and leases through business combinations and purchases of loan and lease portfolios. These loans and leases are recorded at fair value at acquisition and the fair value discount or premium is recognized as an adjustment to yield over the remaining life of each loan or lease. The Corporation purchased jumbo residential mortgage loans at their fair value of $1.1 billion during the year ended December 31, 2020, none of which qualified as PCD loans.

See "Note 2. Summary of Significant Accounting Policies" for further acquired loans and leases policy information.

Leases The components of the net investment in direct financing and sales-type leases were as follows:

	At December 31,
(In thousands)	2020		2019
Carrying amount	$	2,893,070	$	2,794,212
Unguaranteed residual assets	170,930		152,030
Net direct fees and costs and unearned income	(246,769)		(246,373)
Total net investment in direct financing and sales-type leases	$	2,817,231	$	2,699,869

The carrying amount of the sales-type and direct financing leases subject to residual value guarantees was $344.3 million and $277.1 million at December 31, 2020 and December 31, 2019, respectively.

The components of total lease income were as follows:

	Year Ended December 31,
(In thousands)	2020		2019
Interest and fees on loans and leases (Interest income):
Interest income on net investment in direct financing and sales-type leases	$	133,272	$	131,547
Leasing revenue (Noninterest income):
Lease income from operating lease payments	95,530		100,975
Profit (loss) recorded on commencement date on sales-type	21,556		35,694
Gain (losses) on sales of leased equipment	25,637		27,049
Leasing revenue	142,723		163,718
Total lease income	$	275,995	$	295,265

Lease financing equipment depreciation on equipment leased to others was $73.2 million and the net book value of equipment leased to others and related initial direct costs under operating leases was $326.9 million at December 31, 2020. Lease financing equipment depreciation on equipment leased to others was $76.4 million and the net book value of equipment leased to others and related initial direct costs under operating leases was $289.7 million at December 31, 2019.

Undiscounted future minimum lease payments receivable for direct financing and sales-type leases, and a reconciliation to the carrying amount recorded at December 31, 2020 were as follows:

(In thousands)
2021	$	288,066
2022	408,137
2023	549,555
2024	589,430
2025	511,514
Thereafter	311,070
Equipment under leases not yet commenced	30,782
Total undiscounted future minimum lease payments receivable for direct financing and sales-type leases	2,688,554
Third-party residual value guarantees	204,516
Total carrying amount of direct financing and sales-type leases	$	2,893,070

108

Table of Contents

Undiscounted future minimum lease payments expected to be received for operating leases at December 31, 2020 were as follows:

(In thousands)
2021	$	75,689
2022	54,222
2023	33,560
2024	15,660
2025	5,042
Thereafter	1,957
Total undiscounted future minimum lease payments	$	186,130

Loan and Lease Sales The following table summarizes the net gains on sales of loans and leases. The Corporation retains servicing on a majority of loans sold. See "Note 11. Loan Servicing Rights" for further information.

	Year Ended December 31,
(In thousands)	2020		2019		2018
Sale proceeds, net	$	2,556,022	$	2,951,445	$	1,275,960
Recorded investment in loans and leases sold, including accrued interest	2,446,969		2,888,408		1,238,018
Changes in fair value of loans held-for-sale and related derivative instruments, capitalized servicing and other	(22,277)		(36,729)		(4,247)
Net gains on sales of loans and leases	$	86,776	$	26,308	$	33,695

During 2019, the Corporation completed the sale of the Legacy TCF auto finance portfolio of $1.1 billion, which had previously been included within loans held-for-sale, resulting in a $27.5 million loss for the year, included in net gains on sales of loans and leases.

The remaining interest-only strips on the balance sheet related to loan sales were as follows:

	At December 31,
(In thousands)	2020		2019
Interest-only strips	$	7,823	$	12,813

We recorded $224 thousand, $62 thousand and $661 thousand of impairment charges on interest-only strips in 2020, 2019 and 2018, respectively.

The Corporation's agreements to sell consumer loans typically contain certain representations, warranties and covenants regarding the loans sold or securitized. These representations, warranties and covenants generally relate to, among other things, the ownership of the loan, the validity, priority and perfection of the lien securing the loan, accuracy of information supplied to the buyer or investor, the loan's compliance with the criteria set forth in the agreement, the manner in which the loans will be serviced, payment delinquency and compliance with applicable laws and regulations. These agreements generally require the repurchase of loans or indemnification in the event we breach these representations, warranties or covenants and such breaches are not cured. In addition, some agreements contain a requirement to repurchase loans as a result of early payoffs by the borrower, early payment default of the borrower or the failure to obtain valid title. Losses related to repurchases pursuant to such representations, warranties and covenants were immaterial for 2020, 2019 and 2018.

109

Table of Contents

Note 8.  Allowance for Credit Losses and Credit Quality

Effective January 1, 2020, the Corporation adopted ASU No. 2016-13, Financial Instruments - Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments and related ASUs on a modified retrospective basis. Financial information at December 31, 2020 reflects this adoption, and historical financial information disclosed is in accordance with ASC Topic 310 and ASC Topic 450.

Allowance for Credit Losses The rollforwards of the allowance for credit losses were as follows:

(In thousands)	Consumer Loan Portfolio		Commercial Loan and Lease Portfolio		Total Allowance for Loans and Leases		Reserve for Unfunded Lending Commitments(1)		Total Allowance for Credit Losses
Year ended December 31, 2020
Balance, beginning of period	$	28,572	$	84,480	$	113,052	$	3,528	$	116,580
Impact of CECL adoption	107,337		98,655		205,992		14,707		220,699
Adjusted balance, beginning of period	135,909		183,135		319,044		18,235		337,279
Charge-offs	(23,270)		(63,245)		(86,515)		—		(86,515)
Recoveries	15,527		25,905		41,432		—		41,432
Net (charge-offs) recoveries	(7,743)		(37,340)		(45,083)		—		(45,083)
Provision for credit losses(2)	8,773		243,300		252,073		5,078		257,151
Other	(45)		(121)		(166)		—		(166)
Balance, end of period	$	136,894	$	388,974	$	525,868	$	23,313	$	549,181
Year ended December 31, 2019
Balance, beginning of period	$	80,017	$	77,429	$	157,446	$	1,428	$	158,874
Charge-offs	(50,480)		(47,455)		(97,935)		—		$	(97,935)
Recoveries	23,653		6,731		30,384		—		30,384
Net (charge-offs) recoveries	(26,827)		(40,724)		(67,551)		—		(67,551)
Provision for credit losses(2)	17,492		47,790		65,282		233		65,515
Other(3)	(42,110)		(15)		(42,125)		—		(42,125)
Addition due to merger	—		—		—		1,867		1,867
Balance, end of period	$	28,572	$	84,480	$	113,052	$	3,528	$	116,580
Year ended December 31, 2018
Balance, beginning of period	$	98,085	$	72,956	$	171,041	$	1,479	$	172,520
Charge-offs	(64,520)		(20,208)		(84,728)		—		$	(84,728)
Recoveries	26,487		3,216		29,703		—		$	29,703
Net (charge-offs) recoveries	(38,033)		(16,992)		(55,025)		—		(55,025)
Provision for credit losses(2)	24,851		21,917		46,768		(51)		$	46,717
Other(3)	(4,886)		(452)		(5,338)		—		(5,338)
Balance, end of period	$	80,017	$	77,429	$	157,446	$	1,428	$	158,874

(1)RULC is recognized within other liabilities.

(2)As a result of the adoption of CECL, effective January 1, 2020, the provision for credit losses includes the provision for unfunded lending commitments that was previously included within other noninterest expense.

(3)Primarily includes the transfer of the allowance for credit losses to loans and leases held-for-sale.

Management considers our ACL of $549.2 million, or 1.59% of total loans and leases, appropriate to cover current credit losses expected to be incurred in the loan and lease portfolios over the remaining expected life of each financial asset at December 31, 2020, including loans and leases which are not currently known to require specific allowances. The increase in ACL and the ACL as a percentage of total loans and leases from December 31, 2019 was primarily due to the adoption of CECL at January 1, 2020, and the impact of COVID-19. During 2020 the COVID-19 pandemic had a negative impact on current and forecasted macroeconomic conditions and created uncertainty around the performance of certain sectors that have been more heavily impacted, including motor coach, shuttle bus, hotel, retail commercial real estate, franchise, retail trade and fitness. In the fourth quarter of 2020, we began to see improvement in current and forecasted macro-economic conditions, however, these improvements were offset by continued uncertainty around the performance of sectors more heavily impacted by COVID-19. PPP loans are individually guaranteed by the Small Business Administration and therefore the accounting under CECL does not require reserves to be recorded on such loans.

110

Table of Contents

The following tables provide additional disclosures previously required by ASC Topic 310 related to the Corporation's December 31, 2019 balances.

The allowance for loan and lease losses and loans and leases outstanding by type of allowance methodology was as follows:

	At December 31, 2019
(In thousands)	Consumer Loan Portfolio		Commercial Loan and Lease Portfolio		Total Loans and Leases
Allowance for loan and lease losses
Collectively evaluated for impairment	$	26,430	$	75,756	$	102,186
Individually evaluated for impairment	1,468		5,769		7,237
Loans acquired with deteriorated credit quality	674		2,955		3,629
Total	$	28,572	$	84,480	$	113,052
Loans and leases outstanding
Collectively evaluated for impairment	$	11,087,534	$	22,986,607	$	34,074,141
Individually evaluated for impairment	60,694		115,843		176,537
Loans acquired with deteriorated credit quality	72,895		173,891		246,786
Total	$	11,221,123	$	23,276,341	$	34,497,464

Information on impaired loans and leases at December 31, 2019 was as follows:

	At December 31, 2019
(In thousands)	Unpaid Contractual Balance		Loan and Lease Balance		Related Allowance Recorded
Impaired loans and leases with an allowance recorded:
Commercial loan and lease portfolio:
Commercial and industrial	$	20,069	$	20,090	$	2,844
Commercial real estate	4,225		3,962		333
Lease financing	10,956		10,956		2,592
Total commercial loan and lease portfolio	35,250		35,008		5,769
Consumer loan portfolio:
Residential mortgage	24,297		22,250		1,030
Home equity	9,418		8,791		438
Total consumer loan portfolio	33,715		31,041		1,468
Total impaired loans and leases with an allowance recorded	68,965		66,049		7,237
Impaired loans and leases without an allowance recorded:
Commercial loan and lease portfolio:
Commercial and industrial	55,889		39,098		—
Commercial real estate	69,143		41,737		—
Total commercial loan and lease portfolio	125,032		80,835		—
Consumer loan portfolio:
Residential mortgage	31,142		22,594		—
Home equity	24,709		6,179		—
Consumer installment	2,095		880		—
Total consumer loan portfolio	57,946		29,653		—
Total impaired loans and leases without an allowance recorded	182,978		110,488		—
Total impaired loans and leases	$	251,943	$	176,537	$	7,237

111

Table of Contents

Accruing and Nonaccrual Loans and Leases  The Corporation's key credit quality indicator is the receivable's payment performance status, defined as accruing or not accruing. Nonaccrual loans and leases are those which management believes have a higher risk of loss. Delinquent balances are determined based on the contractual terms of the loan or lease. Loans and leases that are over 90 days delinquent are a leading indicator for future charge-off trends and are generally placed on nonaccrual status. In addition, loans and leases that have requested payment deferral under the CARES Act of greater than 180 days are generally placed on nonaccrual status. The Corporation's accruing and nonaccrual loans and leases were as follows:

(In thousands)	Current		30-89 Days Delinquent and Accruing		90 Days or More Delinquent  and Accruing		Total Accruing		Nonaccrual(1)		Total
At December 31, 2020
Commercial loan and lease portfolio:
Commercial and industrial	$	11,119,453	$	42,033	$	1,458	$	11,162,944	$	259,439	$	11,422,383
Commercial real estate	9,453,743		94,383		22		9,548,148		154,439		9,702,587
Lease financing	2,695,356		27,118		3,935		2,726,409		90,822		2,817,231
Total commercial loan and lease portfolio	23,268,552		163,534		5,415		23,437,501		504,700		23,942,201
Consumer loan portfolio:
Residential mortgage	6,065,379		17,048		1,965		6,084,392		97,653		6,182,045
Home equity	3,008,450		30,840		63		3,039,353		69,383		3,108,736
Consumer installment	1,224,059		3,801		—		1,227,860		5,566		1,233,426
Total consumer loan portfolio	10,297,888		51,689		2,028		10,351,605		172,602		10,524,207
Total	$	33,566,440	$	215,223	$	7,443	$	33,789,106	$	677,302	$	34,466,408
At December 31, 2019
Commercial loan and lease portfolio:
Commercial and industrial	$	11,283,832	$	29,780	$	331	$	11,313,943	$	53,812	$	11,367,755
Commercial real estate	8,993,360		10,291		1,440		9,005,091		29,735		9,034,826
Lease financing	2,662,354		24,657		1,901		2,688,912		10,957		2,699,869
Total commercial loan and lease portfolio	22,939,546		64,728		3,672		23,007,946		94,504		23,102,450
Consumer loan portfolio:
Residential mortgage	6,056,817		17,245		559		$	6,074,621	38,577		$	6,113,198
Home equity	3,434,771		22,568		—		3,457,339		35,863		3,493,202
Consumer installment	1,536,714		4,292		108		1,541,114		714		1,541,828
Total consumer loan portfolio	11,028,302		44,105		667		11,073,074		75,154		11,148,228
Purchased credit impaired loans(1)	217,206		3,843		25,737		246,786		$	—	246,786
Total	$	34,185,054	$	112,676	$	30,076	$	34,327,806	$	169,658	$	34,497,464

(1)Prior to the adoption of CECL as of January 1, 2020, purchased credit impaired loans were not classified as nonaccrual loans because they were recorded at their net realizable value based on the principal and interest expected to be collected on the loans. At January 1, 2020, $73.4 million of previous purchased credit impaired loans were reclassified to nonaccrual loans as a result of the adoption of CECL.

The Corporation's nonaccrual loans and leases were as follows:

	At December 31,
	2020				2019
(In thousands)	Total nonaccrual		Nonaccrual with no ACL		Total nonaccrual
Commercial loan and lease portfolio:
Commercial and industrial	$	259,439	$	55,773	$	53,812
Commercial real estate	154,439		79,203		29,735
Lease financing	90,822		—		10,957
Total commercial loan and lease portfolio	504,700		134,976		94,504
Consumer loan portfolio:
Residential mortgage	97,653		49		38,577
Home equity	69,383		23		35,863
Consumer installment	5,566		3,531		714
Total consumer loan portfolio	172,602		3,603		75,154
Total	$	677,302	$	138,579	$	169,658

112

Table of Contents

Loans and leases that are 90 days or more delinquent and accruing by year of origination were as follows:

			Amortized Cost Basis
(In thousands)	Term Loans and Leases by Origination Year												Revolving Loans and Leases		Revolving Loans and Leases Converted to Term Loans and Leases
At December 31, 2020	2020		2019		2018		2017		2016		2015 and Prior						Total
Commercial loan and lease portfolio:
Commercial and industrial	$	874	$	50	$	94	$	13	$	—	$	52	$	375	$	—	$	1,458
Commercial real estate	—		—		—		—		—		22		—		—		22
Lease financing	1,286		975		680		463		392		139		—		—		3,935
Total commercial loan and lease portfolio	2,160		1,025		774		476		392		213		375		—		5,415
Consumer loan portfolio:
Residential mortgage	85		134		—		—		—		1,746		—		—		1,965
Home equity	—		—		—		—		—		27		36		—		63
Consumer installment	—		—		—		—		—		—		—		—		—
Total consumer loan portfolio	85		134		—		—		—		1,773		36		—		2,028
Total 90 days or more delinquent and accruing	$	2,245	$	1,159	$	774	$	476	$	392	$	1,986	$	411	$	—	$	7,443

Nonaccrual loans and leases by year of origination were as follows:

			Amortized Cost Basis
(In thousands)	Term Loans and Leases by Origination Year												Revolving Loans and Leases		Revolving Loans and Leases Converted to Term Loans and Leases
At December 31, 2020	2020		2019		2018		2017		2016		2015 and Prior						Total
Commercial loan and lease portfolio:
Commercial and industrial	$	26,109	$	61,595	$	60,686	$	29,360	$	17,669	$	23,644	$	40,364	$	12	$	259,439
Commercial real estate	5,194		4,835		14,452		53,934		21,667		54,357		—		—		154,439
Lease financing	3,190		27,412		26,348		15,184		8,601		8,145		—		1,942		90,822
Total commercial loan and lease portfolio	34,493		93,842		101,486		98,478		47,937		86,146		40,364		1,954		504,700
Consumer loan portfolio:
Residential mortgage	2,631		9,177		16,391		4,172		2,812		62,470		—		—		97,653
Home equity	889		1,449		530		379		223		5,149		59,826		938		69,383
Consumer installment	33		267		181		281		575		4,060		169		—		5,566
Total consumer loan portfolio	3,553		10,893		17,102		4,832		3,610		71,679		59,995		938		172,602
Total nonaccrual loans and leases	$	38,046	$	104,735	$	118,588	$	103,310	$	51,547	$	157,825	$	100,359	$	2,892	$	677,302

113

Table of Contents

The average balance of nonaccrual loans and leases and interest income recognized on nonaccrual loans and leases were as follows:

	Year Ended December 31,
	2020				2019				2018
(In thousands)	Average Loan and Lease Balance(1)		Interest Income Recognized(1)		Average Loan and Lease Balance		Interest Income Recognized		Average Loan and Lease Balance		Interest Income Recognized
Commercial loan and lease portfolio:
Commercial and industrial	$	156,626	$	10,288	$	39,937	$	1,844	$	18,510	$	324
Commercial real estate	92,087		11,562		17,127		2,435		5,652		—
Lease financing	50,889		244		9,474		152		9,120		76
Total commercial loan and lease portfolio	299,602		22,094		66,538		4,431		33,282		400
Consumer loan portfolio:
Residential mortgage	68,115		3,342		35,843		640		47,529		680
Home equity	52,623		6,034		30,759		406		7,974		—
Consumer installment	3,140		299		4,648		37		23,465		271
Total consumer loan portfolio	123,878		9,675		71,250		1,083		78,968		951
Total nonaccrual loans and leases	$	423,480	$	31,769	$	137,788	$	5,514	$	112,250	$	1,351

(1)At January 1, 2020, $73.4 million of previously purchased credit impaired loans were reclassified to nonaccrual loans as a result of the adoption of CECL. Beginning January 1, 2020, interest income, including the related purchase accounting accretion and amortization is included related to these loans.

In addition to the receivables payment performance status, credit quality is also analyzed using risk categories, which vary based on the size and type of credit risk exposure and additionally measure liquidity, debt capacity, coverage and payment behavior as shown in the borrower's financial statements. The risk categories also measure the quality of the borrower's management and the repayment support offered by any guarantors. Loan and lease credit classifications are derived from standard regulatory rating definitions, which include: pass, special mention, substandard, doubtful and loss. Substandard and doubtful loans and leases have well-defined weaknesses, but may never result in a loss.

114

Table of Contents

The amortized cost basis of loans and leases by credit risk classifications and year of origination was as follows:

	Amortized Cost Basis
(In thousands)	Term Loans and Leases by Origination Year												Revolving Loans and Leases(1)		Revolving Loans and Leases Converted to Term Loans and Leases(2)
At December 31, 2020	2020		2019		2018		2017		2016		2015 and Prior						Total
Commercial loan and lease portfolio:
Commercial and industrial
Pass	$	3,282,275	$	1,877,468	$	994,081	$	547,940	$	357,567	$	316,557	$	3,286,687	$	48,079	$	10,710,654
Special mention	13,377		66,485		46,174		34,959		4,661		6,733		94,338		858		267,585
Substandard	28,908		69,510		94,227		48,246		52,944		29,295		120,738		276		444,144
Total commercial and industrial	3,324,560		2,013,463		1,134,482		631,145		415,172		352,585		3,501,763		49,213		11,422,383
Commercial real estate
Pass	1,361,117		2,193,489		1,877,374		1,211,426		683,612		1,480,027		—		—		8,807,045
Special mention	17,745		78,236		53,087		197,935		79,540		104,473		—		—		531,016
Substandard	6,995		53,079		31,930		124,728		57,221		90,573		—		—		364,526
Total commercial real estate	1,385,857		2,324,804		1,962,391		1,534,089		820,373		1,675,073		—		—		9,702,587
Lease financing
Pass	1,013,374		715,327		393,644		226,818		109,992		30,620		23,806		167,726		2,681,307
Special mention	4,050		9,871		3,897		4,870		1,484		1,001		—		8,911		34,084
Substandard	6,440		29,040		27,579		16,150		9,360		8,635		7		4,629		101,840
Total lease financing	1,023,864		754,238		425,120		247,838		120,836		40,256		23,813		181,266		2,817,231
Total commercial	5,734,281		5,092,505		3,521,993		2,413,072		1,356,381		2,067,914		3,525,576		230,479		23,942,201
Consumer loan portfolio:
Residential mortgage
Pass	2,011,791		1,047,735		604,127		435,617		439,816		1,539,779		—		—		6,078,865
Special mention	—		—		—		—		—		112		—		—		112
Substandard	3,292		9,311		17,268		4,601		3,814		64,782		—		—		103,068
Total residential mortgage	2,015,083		1,057,046		621,395		440,218		443,630		1,604,673		—		—		6,182,045
Home equity
Pass	23,066		51,448		48,092		39,834		29,071		126,147		2,703,354		7,753		3,028,765
Substandard	940		1,469		579		515		424		8,354		66,590		1,100		79,971
Total home equity	24,006		52,917		48,671		40,349		29,495		134,501		2,769,944		8,853		3,108,736
Consumer installment
Pass	206,994		371,924		192,067		185,051		119,663		127,252		24,043		67		1,227,061
Substandard	247		1,179		680		887		909		2,086		377		—		6,365
Total consumer installment	207,241		373,103		192,747		185,938		120,572		129,338		24,420		67		1,233,426
Total consumer	2,246,330		1,483,066		862,813		666,505		593,697		1,868,512		2,794,364		8,920		10,524,207
Total loans and leases	$	7,980,611	$	6,575,571	$	4,384,806	$	3,079,577	$	1,950,078	$	3,936,426	$	6,319,940	$	239,399	$	34,466,408

(1)This balance includes $23.8 million of leased equipment that has been provided to lessees under certain master lease agreements. Under these agreements, the total amount of equipment included in each lease is provided over time, and additional amounts are required to be provided to the respective lessees in future accounting periods.

(2)This balance includes $230.5 million of leased equipment that has been provided to lessees under certain master lease agreements. Under these agreements, the total amount of equipment included in each lease was provided over time, and all equipment required by the lease has been provided to the respective lessees in current or previous accounting periods.

115

Table of Contents

The recorded investment of loans and leases by credit risk categories as of December 31, 2019 was as follows:

(In thousands)	Pass		Special Mention		Substandard		Total
At December 31, 2019
Commercial loan and lease portfolio:
Commercial and industrial	$	10,930,939	$	315,097	$	193,566	$	11,439,602
Commercial real estate	8,891,361		170,114		75,395		9,136,870
Lease financing	2,646,874		28,091		24,904		2,699,869
Total commercial loan and lease portfolio	22,469,174		513,302		293,865		23,276,341
Consumer loan portfolio:
Residential mortgage	6,135,096		565		44,144		6,179,805
Home equity	3,457,292		456		41,159		3,498,907
Consumer installment	1,541,524		—		887		1,542,411
Total consumer loan portfolio	11,133,912		1,021		86,190		11,221,123
Total loans and leases	$	33,603,086	$	514,323	$	380,055	$	34,497,464

Troubled Debt Restructurings In certain circumstances, the Corporation may consider modifying the terms of a loan for economic or legal reasons related to the customer's financial difficulties. If the Corporation grants a concession, the modified loan would generally be classified as a TDR. However, Section 4013 of the CARES Act and the Interagency Statement on Loan Modifications provide banks the option to temporarily suspend the application of TDR accounting guidance for loans modified due to the effects of COVID-19 when certain conditions are met. See "Note 2. Summary of Significant Accounting Policies" of the Notes to Consolidated Financial Statements for information regarding recent updated guidance on TDR accounting provided by the CARES Act and Interagency guidance. TDRs typically involve a deferral of the principal balance of the loan, a reduction of the stated interest rate of the loan or, in certain limited circumstances, a reduction of the principal balance of the loan or the loan's accrued interest.

The following table presents the recorded investment of loan modifications first classified as TDRs during the periods presented:

	Year Ended December 31,
	2020				2019				2018
(In thousands)	Pre-modification Investment		Post-modification Investment		Pre-modification Investment		Post-modification Investment		Pre-modification Investment		Post-modification Investment
Commercial loan and lease portfolio:
Commercial and industrial	$	4,136	$	3,956	$	5,347	$	5,347	$	7,253	$	7,253
Commercial real estate	41,902		41,902		35,997		35,997		5,228		5,228
Total commercial loan and lease portfolio	46,038		45,858		41,344		41,344		12,481		12,481
Consumer loan portfolio:
Residential mortgage	11,550		11,485		6,053		5,912		5,333		5,259
Home equity	5,269		5,210		4,144		4,089		2,182		2,181
Consumer installment	533		442		217		183		1,052		1,052
Total consumer loan portfolio	17,352		17,137		10,414		10,184		8,567		8,492
Total	$	63,390	$	62,995	$	51,758	$	51,528	$	21,048	$	20,973

The following table presents TDR loans:

	At December 31,
	2020						2019
(In thousands)	Accruing TDR Loans		Nonaccrual TDR Loans		Total TDR Loans		Accruing TDR Loans		Nonaccrual TDR Loans		Total TDR Loans
Commercial loan and lease portfolio	$	35,697	$	23,575	$	59,272	$	12,986	$	5,356	$	18,342
Consumer loan portfolio	16,658		22,804		39,462		12,403		14,875		27,278
Total	$	52,355	$	46,379	$	98,734	$	25,389	$	20,231	$	45,620

116

Table of Contents

Commitments to lend additional funds to borrowers whose terms have been modified in TDRs were $2.6 million at December 31, 2020 and $638 thousand at December 31, 2019.

Loan modifications to troubled borrowers are no longer disclosed as TDR loans in the calendar years after modification if the loans were modified to an interest rate equal to or greater than the yields of new loan originations with comparable risk at the time of restructuring and if the loan is performing based on the restructured terms; however, these loans are still considered impaired and follow the Corporation's impaired loan reserve policies.

The following table summarizes the TDR loans that defaulted during the periods presented that were modified during the respective reporting period or within one year of the beginning of the respective reporting period. The Corporation considers a loan to have defaulted when under the modified terms it becomes 90 or more days delinquent, has been transferred to nonaccrual status, has been charged down or has been transferred to other real estate owned or repossessed and returned assets.

	Year Ended December 31,
(In thousands)	2020		2019		2018
Defaulted TDR loan balances modified during the applicable period
Commercial loan and lease portfolio:
Commercial and industrial	$	827	$	956	$	4,697
Commercial real estate	1,593		—		—
Total commercial loan and lease portfolio	2,420		956		4,697
Consumer loan portfolio:
Residential mortgage	1,756		1,325		3,258
Home equity	1,372		401		558
Consumer installment	44		1,555		1,436
Total consumer loan portfolio	3,172		3,281		5,252
Defaulted TDR loan balances	$	5,592	$	4,237	$	9,949

Other Real Estate Owned and Repossessed and Returned Assets Other real estate owned, repossessed and returned assets and consumer real estate loans in process of foreclosure were as follows:

	At December 31,
(In thousands)	2020		2019
Other real estate owned	$	33,192	$	34,256
Repossessed and returned assets	8,932		8,045
Consumer real estate loans in process of foreclosure	14,790		17,758

Other real estate owned and repossessed and returned assets were written down $2.6 million, $7.7 million and $3.4 million in 2020, 2019 and 2018, respectively.

117

Table of Contents

Note 9. Premises and Equipment, Net

Premises and equipment, net were as follows:

	At December 31,
(In thousands)	2020		2019
Land	$	131,712	$	151,332
Office buildings	303,712		334,673
Leasehold improvements	56,687		59,141
Furniture, equipment and computer software	401,494		440,642
Premises and equipment leased under finance leases	3,185		3,180
Subtotal	896,790		988,968
Accumulated depreciation and amortization	(426,659)		(455,830)
Premises and equipment, net	$	470,131	$	533,138

Depreciation and amortization expense related to premises and equipment was $76.0 million, $75.3 million and $48.6 million for 2020, 2019 and 2018, respectively.

Note 10. Goodwill and Other Intangible Assets

Goodwill was as follows:

	At December 31,
(In thousands)	2020		2019
Goodwill related to consumer banking segment	$	771,555	$	764,389
Goodwill related to commercial banking segment	541,491		535,489
Goodwill, net	$	1,313,046	$	1,299,878

The Corporation recorded goodwill in the amount of $1.2 billion related to the TCF/Chemical Merger completed on August 1, 2019. Goodwill was allocated to the appropriate reporting unit based on the relative fair value of assets acquired and deposits held by the reporting unit. This methodology allocates goodwill in proportion to the assets held by each reporting unit as well as incorporating the value of the funding source provided by the in place deposits. The reporting units aggregate between the Consumer Banking and Commercial Banking segments. See "Note 3. Business Combinations" for further information. During each quarter of 2020 we evaluated whether it was more-likely-than-not that the fair value of any reporting unit was less than its carrying amount. During the fourth quarter we completed our annual impairment test, which did not indicate impairment for any reporting unit. There was no impairment of goodwill in 2020 and 2019.

The following table sets forth the carrying amount and accumulated amortization of intangible assets that are amortizable and arose from business combinations or other acquisitions.

(In thousands)	Core deposit intangibles		Program agreements		Non-compete agreements		Customer relationships		Total
At December 31, 2020
Gross carrying value	$	141,232	$	14,700	$	9,000	$	21,949	$	186,881
Accumulated amortization	(29,971)		(1,818)		(7,330)		(1,385)		(40,504)
Net carrying amount	$	111,261	$	12,882	$	1,670	$	20,564	$	146,377
At December 31, 2019
Gross carrying value	$	141,232	$	14,700	$	9,000	$	21,949	$	186,881
Accumulated amortization	(11,016)		(1,031)		(5,618)		(848)		(18,513)
Net carrying amount	$	130,216	$	13,669	$	3,382	$	21,101	$	168,368

There was no impairment of other intangible assets in 2020 and 2019.

Amortization expense for intangible assets was $22.0 million, $11.7 million and $3.4 million for 2020, 2019 and 2018, respectively.

118

Table of Contents

The estimated future amortization expense on intangible assets for the next five years is as follows:

(In thousands)	Total
2021	$	20,136
2022	18,180
2023	16,868
2024	16,161
2025	15,425

On August 1, 2019, the Corporation completed the TCF/Chemical Merger. As a result, the Corporation recorded $159.5 million in intangible assets consisting of core deposits and customer relationships intangibles. See "Note 3. Business Combinations" for further information.

Note 11. Loan Servicing Rights

Information regarding LSRs was as follows:

	At December 31,
(in thousands)	2020		2019		2018
Balance, beginning of period	$	56,313	$	23	$	25
Acquired in the TCF/Chemical Merger	—		59,567		—
New servicing assets created	17,209		4,969		7
Impairment (charge) recovery	(17,605)		(3,882)		—
Amortization	(17,614)		(4,364)		(9)
Balance, end of period	$	38,303	$	56,313	$	23
Valuation allowance, end of period	$	(21,488)	$	(3,882)	$	—
Loans serviced for others that have servicing rights capitalized, end of period	$	6,203,199	$	6,566,892	$	—

Total loan servicing, late fee and other ancillary fee income, included in servicing fee income, related to loans serviced for others that have servicing rights capitalized was $16.7 million and $7.0 million for December 31, 2020 and December 31, 2019, respectively.

Note 12. Operating Lease Right-of-Use Assets and Liabilities

Operating lease right-of-use assets, included in other assets, were $106.7 million and $118.7 million at December 31, 2020 and December 31, 2019, respectively. Operating lease liabilities, included in other liabilities, were $122.8 million and $138.4 million at December 31, 2020 and December 31, 2019, respectively. In connection with the TCF/Chemical Merger, during the year ended December 31, 2019, the Corporation recorded $39.8 million and $41.6 million of operating lease right-of-use assets and operating lease liabilities, respectively.

Undiscounted future minimum operating lease payments and a reconciliation to the amount recorded as operating lease liabilities at December 31, 2020 were as follows:

(In thousands)
2021	$	27,808
2022	22,725
2023	19,273
2024	17,879
2025	15,184
2026 and thereafter	31,555
Total undiscounted future minimum operating lease payments	134,424
Discount	(11,576)
Total operating lease liabilities	$	122,848

119

Table of Contents

As of December 31, 2020, the Corporation had approximately $231.6 million in additional leases for real property that have not yet commenced and are excluded from the operating lease liability table above. All of this amount was related to a lease agreement for the Corporation's new headquarters building in Detroit, Michigan signed on May 31, 2019 by Legacy Chemical, with an organization 50% owned by indirect related parties. The new headquarter lease has a term of 22.5 years commencing January 1, 2022 with renewal options.

The weighted-average discount rate and remaining lease term for operating leases was as follows:

	At December 31,
	2020		2019
Weighted-average discount rate	2.48	%	2.67	%
Weighted-average remaining lease term	7.6 years		6.8 years

The components of total lease cost for operating leases, included in occupancy and equipment noninterest expense, were as follows:

	Year Ended December 31,
(In thousands)	2020		2019
Lease expense	$	27,035	$	39,724
Short-term and variable lease cost	709		732
Sublease income	(1,491)		(1,716)
Total lease cost for operating leases	$	26,253	$	38,740

Supplemental cash flow information related to operating leases was as follows:

	Year Ended December 31,
(In thousands)	2020		2019
Operating lease right-of-use assets obtained in exchange for operating lease liabilities	$	20,746	$	131,305
Cash paid for amounts included in the measurement of lease liabilities - operating	34,725		33,231

Note 13. Investments in Qualified Affordable Housing Projects and Historic Projects

The Corporation invests in qualified affordable housing projects and historic projects for the purposes of community reinvestment and to obtain tax credits. Return on the Corporation's investment in these projects comes in the form of pass-through tax credits and tax losses. The carrying value of the investments is included in other assets. The Corporation primarily utilizes the proportional amortization method to account for investments in qualified affordable housing projects and the equity method to account for investments in other tax credit projects.

Under the proportional amortization method, the Corporation amortizes the initial cost of the investment in proportion to the tax credits and other tax benefits. The Corporation recognized amortization expense of investments in qualified affordable housing projects of $21.2 million, $13.3 million and $9.9 million for the years ended December 31, 2020, 2019 and 2018, respectively. Amortization expense was more than offset by tax credits and other tax benefits of $26.3 million, $16.6 million and $11.6 million for the years ended December 31, 2020, 2019 and 2018, respectively. The Corporation's remaining investment in qualified affordable housing projects accounted for under the proportional amortization method totaled $214.3 million at December 31, 2020 and $195.8 million at December 31, 2019.

Under the equity method, the Corporation's share of the earnings or losses is included in other noninterest expense. The Corporation's remaining investment in historic projects and Ohio historic preservation tax credits totaled $48.6 million at December 31, 2020 and $43.6 million at December 31, 2019. During the year ended December 31, 2020, $5.2 million of income tax benefit was recognized due to the federal historic tax credits, which was partially offset by amortization expense, inclusive of impairment, of $4.4 million. During the year ended December 31, 2019, $4.6 million of income tax benefit was recognized due to the federal historic tax credits, which was partially offset by amortization expense, inclusive of impairment, of $4.0 million. During the year ended December 31, 2020, the benefit provided by the Ohio historic preservation tax credits, inclusive of impairment, was $875 thousand, recognized as a reduction to other noninterest expense. There were no Ohio historic preservation tax credits outstanding during the year ended December 31, 2019.

120

Table of Contents

The Corporation's unfunded equity contributions relating to investments in qualified affordable housing projects and historic projects are included in other liabilities. The Corporation's remaining unfunded equity contributions totaled $107.4 million at December 31, 2020 and $131.3 million at December 31, 2019.

Management analyzes these investments for potential impairment when events or changes in circumstances indicate that it is more-likely-than-not that the carrying amount of the investment will not be realized. An impairment loss is measured as the amount by which the carrying amount of an investment exceeds its fair value.

Investments in qualified affordable housing projects and historic projects are considered VIEs because TCF, as a limited partner, lacks the power to direct the activities that most significantly impact the entities' economic performance. TCF has concluded it is not the primary beneficiary and therefore, they are not consolidated. The maximum exposure to loss on the VIE investments is limited to the carrying amount of the investments and the potential recapture of any recognized tax credits. TCF believes the likelihood of the tax credits being recaptured is remote, as a loss would only take place if the managing entity failed to meet certain government compliance requirements. Further, certain of TCF's investments in affordable housing limited liability entities include guaranteed minimum returns which are backed by an investment grade credit-rated company, which reduces the risk of loss.

Note 14.  Deposits

Deposits were as follows:

	At December 31,
	2020				2019
(Dollars in thousands)	Amount		Year-to-Date Weighted-average Rate		Amount		Year-to-Date Weighted-average Rate
Checking:
Noninterest-bearing	$	11,009,911	—	%	$	7,948,637	—	%
Interest-bearing	7,222,275		0.18		5,966,178		0.36
Total checking	18,232,186		0.07		13,914,815		0.15
Savings	9,523,073		0.31		8,521,093		0.72
Certificates of deposit	5,524,381		1.32		7,455,556		2.01
Money market	5,576,679		0.69		4,576,999		1.38
Total deposits	$	38,856,319	0.44	%	$	34,468,463	0.88	%

Excluded from total deposits are account overdrafts which have been classified as loans. At December 31, 2020 and 2019, overdrafts totaled $12.9 million and $19.0 million, respectively.

Scheduled maturities for certificates of deposits, including Certificate of Deposit Account Registry Service ("CDARS") deposits, IRA deposits and brokered deposits at December 31, 2020 were as follows:

(In thousands)
2021	$	5,012,121
2022	381,766
2023	62,257
2024	31,922
2025	26,905
Thereafter	9,410
Total	$	5,524,381

The aggregate amount of certificates of deposit with balances equal to or greater than the Federal Deposit Insurance Corporation insurance limit of $250,000 was $1.4 billion and $2.2 billion at December 31, 2020 and 2019, respectively.

121

Table of Contents

Note 15.  Borrowings

TCF Bank is a member of the FHLB, which provides short- and long-term funding collateralized by mortgage related assets to its members.

Collateralized deposits include TCF Bank's Repurchase Investment Sweep Agreement product collateralized by mortgage-backed securities, and funds deposited by customers that are collateralized by investment securities owned by TCF Bank, as these deposits are not covered by FDIC insurance.

Short-term borrowings (borrowings with an original maturity of less than one year) were as follows:

	At December 31,
	2020				2019
(Dollars in thousands)	Amount		Weighted-average Rate		Amount		Weighted-average Rate
FHLB advances	$	400,000	0.33	%	$	2,450,000	1.85	%
Collateralized deposits	217,363		0.11		219,145		0.64
Total short-term borrowings	$	617,363	0.25	%	$	2,669,145	1.75	%

On June 29, 2020, TCF Financial voluntarily prepaid the outstanding $80.0 million on its $150.0 million unsecured 364-day revolving credit facility with an unaffiliated bank and subsequently closed the credit facility.

Long-term borrowings were as follows:

		At December 31,
		2020		2019
(Dollars in thousands)	Stated Rate	Amount		Amount
FHLB advances due 2021 to 2025 (1)(2)	0.39% - 2.72%	$	709,848	$	1,822,058
Subordinated debt:
Subordinated debt obligation due 2022	6.25%	109,597		109,338
Subordinated debt obligation due 2025	4.60%	148,913		148,681
Subordinated debt obligation due 2029	4.13%	148,933		148,657
Subordinated debt obligation due 2030	5.50%	148,637		—
Subordinated debt securities due 2032-2035 (3)(4)	1.67% - 3.50%	19,090		19,021
Hedge related adjustment(5)		10,975		2,773
Total subordinated debt obligations		586,145		428,470
Discounted lease rentals due 2021 to 2025	2.03% - 6.07%	75,770		100,882
Finance lease obligation due 2038	3.73%	2,969		3,038
Total long-term borrowings		$	1,374,732	$	2,354,448

(1)Includes the current portion of FHLB advances of $150.0 million and $110.0 million at December 31, 2020 and 2019, respectively.

(2)The December 31, 2020 and 2019 balances include amounts payable of $0.7 billion and $1.8 billion, respectively, and purchase accounting premiums of $9.8 million and $12.1 million, respectively.

(3)The December 31, 2020 and 2019 balances include amounts payable of $20.6 million for both periods and purchase accounting discounts of $1.5 million and $1.6 million, respectively.

(4)Floating-rate based on three-month LIBOR plus 1.45% - 3.25%.

(5)Related to subordinated bank notes with a stated maturity of 2025.

FHLB advances are collateralized by residential mortgage and commercial real estate loans.

On May 6, 2020, TCF Bank issued $150.0 million of fixed-to-floating rate subordinated notes (the “2030 Notes”) at par. The fixed-to-floating rate subordinated notes, due May 6, 2030, bear an initial fixed interest rate of 5.50% per annum, payable semi-annually in arrears on May 6 and November 6, commencing on November 6, 2020. The 2030 Notes are redeemable at TCF Bank's option beginning on May 6, 2025. Commencing May 6, 2025, the interest rate will reset quarterly to an annual interest rate equal to the then-current three-month LIBOR rate plus 509 basis points, payable quarterly in arrears on February 6, May 6, August 6 and November 6. TCF Bank incurred issuance costs of $1.5 million that are amortized as interest expense over the full term of the 2030 Notes using the effective interest method.

122

Table of Contents

At December 31, 2020 and 2019, TCF Bank had pledged $12.5 billion and $10.5 billion, respectively, of loans secured by consumer and commercial real estate to provide borrowing capacity from the FHLB.

At December 31, 2020 and 2019, TCF Bank had pledged $3.2 billion and $903.1 million, respectively, of loans secured by assets to provide borrowing capacity from the Federal Reserve Bank discount window. No borrowings were sourced from this facility at December 31, 2020 and 2019.

The contractual maturities of long-term borrowings at December 31, 2020 were as follows:

(In thousands)
2021	$	157,618
2022	483,452
2023	25,739
2024	14,484
2025	373,810
Thereafter	319,629
Total long-term borrowings	$	1,374,732

123

Table of Contents

Note 16.  Accumulated Other Comprehensive Income (Loss)

The components of other comprehensive income (loss), reclassifications from accumulated other comprehensive income (loss) to various financial statement line items and the related tax effects were as follows:

(In thousands)	Before Tax		Tax Effect		Net of Tax
Year Ended December 31, 2020:
Net unrealized gains (losses) on available-for-sale investment securities and interest-only strips:
Net unrealized gains (losses) arising during the period	$	164,863	$	(39,674)	$	125,189
Reclassification of net (gains) losses from accumulated other comprehensive income (loss) to:
Total interest income	3,827		(885)		2,942
Net gains (losses) on investment securities	(2,309)		549		(1,760)
Other noninterest expense	29		(10)		19
Amounts reclassified from accumulated other comprehensive income (loss)	1,547		(346)		1,201
Net unrealized gains (losses) on available-for-sale investment securities and interest-only strips	166,410		(40,020)		126,390
Recognized postretirement prior service cost:
Net unrealized gains (losses) arising during the period	449		(107)		342
Reclassification of amortization of prior service cost to other noninterest expense	(46)		11		(35)
Net unrealized gains (losses) on recognized postretirement prior service cost	403		(96)		307
Net unrealized gains (losses) on net investment hedges	(5,452)		1,257		(4,195)
Foreign currency translation adjustment(1)	5,894		—		5,894
Total other comprehensive income (loss)	$	167,255	$	(38,859)	$	128,396
Year Ended December 31, 2019:
Net unrealized gains (losses) on available-for-sale investment securities and interest-only strips:
Net unrealized gains (losses) arising during the period	$	109,403	$	(25,707)	$	83,696
Reclassification of net (gains) losses from accumulated other comprehensive income (loss) to:
Total interest income	2,644		(716)		1,928
Net gains (losses) on investment securities	(1,517)		369		(1,148)
Other noninterest expense	(485)		129		(356)
Amounts reclassified from accumulated other comprehensive income (loss)	642		(218)		424
Net unrealized gains (losses) on available-for-sale investment securities and interest-only strips	110,045		(25,925)		84,120
Recognized postretirement prior service cost:
Reclassification of amortization of prior service cost to other noninterest expense	(46)		13		(33)
Net unrealized gains (losses) on net investment hedges	(7,001)		1,815		(5,186)
Foreign currency translation adjustment(1)	8,514		—		8,514
Total other comprehensive income (loss)	$	111,512	$	(24,097)	$	87,415
Year Ended December 31, 2018:
Net unrealized gains (losses) on available-for-sale investment securities and interest-only strips:
Unrealized gains (losses) arising during the period	$	(16,373)	$	4,002	$	(12,371)
Reclassification of net (gains) losses from accumulated other comprehensive income (loss) to:
Total interest income	1,066		(335)		731
Gains (losses) on debt securities, net	(127)		31		(96)
Other noninterest expense	90		(23)		67
Amounts reclassified from accumulated other comprehensive income (loss)	1,029		(327)		702
Net unrealized gains (losses) on available-for-sale investment securities and interest-only strips	(15,344)		3,675		(11,669)
Recognized postretirement prior service cost:
Reclassification of amortization of prior service cost to other noninterest expense	(46)		12		(34)
Net unrealized gains (losses) on net investment hedges	13,762		(3,312)		10,450
Foreign currency translation adjustment(1)	(13,368)		—		(13,368)
Total other comprehensive income (loss)	$	(14,996)	$	375	$	(14,621)

(1)Foreign investments are deemed to be permanent in nature and, therefore, TCF does not provide for taxes on foreign currency translation adjustments.

124

Table of Contents

Reclassifications of net (gains) losses from accumulated other comprehensive income (loss) for available-for-sale investment securities and interest-only strips were recorded in the Consolidated Statements of Income in interest income for those investment securities that were previously transferred to held-to-maturity, in net gains on investment securities for sales of available-for-sale investment securities and in other noninterest expense for interest-only strips. During 2014, the Corporation transferred $191.7 million of available-for-sale mortgage-backed investment securities to held-to-maturity. At December 31, 2020 and 2019, the unrealized holding loss on the transferred investment securities retained in accumulated other comprehensive income (loss) totaled $4.5 million and $8.4 million, respectively. These amounts are amortized over the remaining lives of the transferred investment securities. The tax effects of the reclassifications included in the table above were recorded in income tax expense (benefit) in the Consolidated Statements of Income.

The components of accumulated other comprehensive income (loss) were as follows:

(In thousands)	Net Unrealized Gains (Losses) on Available-for-Sale Investment Securities and Interest-only Strips		Net Unrealized Gains (Losses) on Net Investment Hedges		Foreign Currency Translation Adjustment		Recognized Postretirement Prior Service Cost		Total
At or For the Year Ended December 31, 2020:
Balance, beginning of period	$	56,098	$	9,800	$	(11,697)	$	76	$	54,277
Other comprehensive income (loss)	125,189		(4,195)		5,894		342		127,230
Amounts reclassified from accumulated other comprehensive income (loss)	1,201		—		—		(35)		1,166
Net other comprehensive income (loss)	126,390		(4,195)		5,894		307		128,396
Balance, end of period	$	182,488	$	5,605	$	(5,803)	$	383	$	182,673
At or For the Year Ended December 31, 2019:
Balance, beginning of period	$	(28,022)	$	14,986	$	(20,211)	$	109	$	(33,138)
Other comprehensive income (loss)	83,696		(5,186)		8,514		—		87,024
Amounts reclassified from accumulated other comprehensive income (loss)	424		—		—		(33)		391
Net other comprehensive income (loss)	84,120		(5,186)		8,514		(33)		87,415
Balance, end of period	$	56,098	$	9,800	$	(11,697)	$	76	$	54,277
At or For the Year Ended December 31, 2018:
Balance, beginning of period	$	(16,353)	$	4,536	$	(6,843)	$	143	$	(18,517)
Other comprehensive income (loss)	(12,371)		10,450		(13,368)		—		(15,289)
Amounts reclassified from accumulated other comprehensive income (loss)	702		—		—		(34)		668
Net other comprehensive income (loss)	(11,669)		10,450		(13,368)		(34)		(14,621)
Balance, end of period	$	(28,022)	$	14,986	$	(20,211)	$	109	$	(33,138)

Note 17. Equity

Preferred Stock Preferred stock was as follows:

	At December 31,
(In thousands)	2020		2019
Series C non-cumulative perpetual preferred stock	$	169,302	$	169,302

Series C Non-Cumulative Perpetual Preferred Stock, 5.70% with a par value $0.01 per share, has a liquidation preference of $25,000 per share (equivalent to $25 per depositary share) and each depository share represents 1/1000th of a share of TCF Preferred Stock. The Corporation had 7,000 shares of TCF Preferred Stock outstanding and 7,000,000 related depositary shares outstanding. Dividends are payable on the Series C Preferred Stock if, as and when declared by TCF's Board of Directors on a non-cumulative basis on March 1, June 1, September 1 and December 1 of each year. The Series C Preferred Stock may be redeemed at the Corporation's option in whole or in part on December 1, 2022 or on any dividend payment date thereafter.

125

Table of Contents

Restricted Retained Earnings Retained earnings at TCF Bank at December 31, 2020 included approximately $170.2 million for which no provision for federal income taxes has been made. This amount represents earnings legally appropriated to thrift bad debt reserves and deducted for federal income tax purposes in prior years and is generally not available for payment of cash dividends or other distributions to shareholders. Future payments or distributions of these appropriated earnings could create a tax liability for the Corporation based on the amount of the distributions and the tax rates in effect at that time.

Other Other equity consist of shares held in trust for deferred compensation plans was as follows:

	At December 31,
(In thousands)	2020	2019
Shares held in trust for deferred compensation plans, at cost	26,731	28,037

The cost of TCF common stock held in trust for the deferred compensation plans, including the Directors Deferred Compensation Plans, TCF Financial 2015 Omnibus Incentive Plan and the TCF 401K Supplemental Plan, is reported in a manner similar to treasury stock (that is, changes in fair value are not recognized) with a corresponding deferred compensation obligation reflected in additional paid-in capital. Upon resignation, death, disability or termination of a deferred compensation plan participant or based on other contractual requirements, the shares held in trust are distributed to the respective plan's participant or beneficiary, as applicable. See "Note 22. Share-based Compensation" and "Note 23. Retirement Plans" for further information on deferred compensation plans.

The Corporation repurchased $33.1 million and $27.5 million of its common stock in the years ended December 31, 2020 and 2019, respectively, pursuant to its share repurchase program in effect as of October 24, 2019. Repurchases of common stock prior to the TCF/Chemical Merger date were recorded as treasury stock. In connection with the TCF/Chemical Merger, all previously outstanding Legacy TCF treasury stock was eliminated. Subsequent to the TCF/Chemical Merger, repurchases of common stock are retired. The Corporation repurchased $58.8 million and $212.9 million of its common stock for 2019 and 2018, respectively, pursuant to the Legacy TCF share repurchase program. At December 31, 2020, the Corporation had the authority to repurchase an additional $89.4 million in aggregate value of shares pursuant to its share repurchase program. The Corporation had no treasury stock in 2020. The Corporation reissued 347,329 shares of treasury stock at a cost of $12.9 million in 2019, compared to 8,130 shares of treasury stock at a cost of $378 thousand in 2018.

Non-controlling Interest in Subsidiaries TCF has a joint venture with The Toro Company ("Toro") called Red Iron Acceptance, LLC ("Red Iron"). Red Iron provides U.S. distributors and dealers and select Canadian distributors of the Toro® and Exmark® branded products with sources of financing. TCF and Toro maintain a 55% and 45% ownership interest, respectively, in Red Iron. As TCF has a controlling financial interest in Red Iron, its financial results are consolidated in TCF's financial statements. Toro's interest is reported as a non-controlling interest within equity.

Note 18.  Regulatory Capital Requirements

TCF and TCF Bank are subject to minimum capital requirements administered by the federal banking regulators. Failure to meet minimum capital requirements can initiate certain mandatory, and possible additional discretionary, actions by the federal banking regulators that could have a material adverse effect on TCF. In general, TCF Bank may not declare or pay a dividend to TCF Financial in excess of 100% of its net retained earnings for the current year combined with its net retained earnings for the preceding two calendar years, which was $132.1 million at December 31, 2020, without prior approval of the Office of the Comptroller of the Currency (the "OCC"). The OCC also has the authority to prohibit the payment of dividends by a national bank when it determines such payments would constitute an unsafe and unsound banking practice. TCF Bank's ability to make capital distributions in the future may require regulatory approval and may be restricted by its federal banking regulators. TCF Bank's ability to make any such distributions will also depend on its earnings and ability to meet minimum regulatory capital requirements in effect during future periods. In the future, these capital adequacy standards may be higher than existing minimum regulatory capital requirements.

The Basel III capital standards allowed institutions not subject to the advanced approaches requirements to opt out of including components of accumulated other comprehensive income (loss) in common equity Tier 1 capital. TCF and TCF Bank made the one-time permanent election to not include accumulated other comprehensive income (loss) in regulatory capital.

126

Table of Contents

Effective January 1, 2020, the Corporation adopted CECL. In response to the COVID-19 pandemic, the regulatory agencies published a final rule that provides the option to delay the cumulative effect of the day 1 impact of CECL adoption on regulatory capital, along with 25% of the change in the adjusted allowance for credit losses (as computed for regulatory capital purposes which excludes PCD loans), for two years, followed by a three-year phase-in period. Management elected the 5-year transition period consistent with the final rule issued by the regulatory agencies resulting in a $211.2 million, or a cumulative 59 basis point, regulatory capital benefit as of December 31, 2020. The CECL transitional amount of $211.2 million includes $159.2 million related to the cumulative effect of adopting CECL and $52.0 million related to the estimated incremental effect of CECL since adoption.

Regulatory capital information for TCF and TCF Bank was as follows:

	TCF						TCF Bank
	At December 31,						At December 31,
(Dollars in thousands)	2020			2019			2020			2019			Well-capitalized Standard		Minimum Capital Requirement(1)
Regulatory Capital:
Common equity Tier 1 capital	$	4,103,007		$	4,050,826		$	4,093,974		$	4,039,191
Tier 1 capital	4,290,793			4,236,648			4,112,458			4,059,417
Total capital	5,026,611			4,681,630			4,831,026			4,524,051
Regulatory Capital Ratios:
Common equity Tier 1 capital ratio	11.45		%	10.99		%	11.45		%	10.97		%	6.50	%	4.50	%
Tier 1 risk-based capital ratio	11.98			11.49			11.50			11.03			8.00		6.00
Total risk-based capital ratio	14.03			12.70			13.51			12.29			10.00		8.00
Tier 1 leverage ratio	9.34			9.49			8.97			9.10			5.00		4.00

(1)Excludes capital conservation buffer of 2.5% at both December 31, 2020 and December 31, 2019.

Note 19.  Derivative Instruments

Derivative instruments, recognized at fair value within other assets or accrued expenses and other liabilities on the Consolidated Statements of Financial Condition, were as follows:

 

	At December 31, 2020
			Fair Value
(In thousands)	Notional Amount(1)		Derivative Assets		Derivative Liabilities
Derivatives designated as hedging instruments:
Interest rate contract	$	150,000	$	59	$	—
Forward foreign exchange contracts	207,515		—		1,521
Total derivatives designated as hedging instruments			59		1,521
Derivatives not designated as hedging instruments:
Interest rate contracts	6,140,464		248,208		14,681
Risk participation agreements	470,670		62		125
Forward foreign exchange contracts	90,647		11		865
Interest rate lock commitments	447,278		14,565		4
Forward loan sales commitments	535,244		37		3,411
Power Equity CDs	16,752		459		459
Swap agreement	12,652		—		66
Total derivatives not designated as hedging instruments			263,342		19,611
Total derivatives before netting			263,401		21,132
Netting(2)			(52)		(1,876)
Total derivatives, net			$	263,349	$	19,256

(1)Notional or contract amounts, which represent the extent of involvement in the derivatives market, are used to determine the contractual cash flows required in accordance with the terms of the agreement. These amounts are typically not exchanged, significantly exceed amounts subject to credit or market risk and are not reflected in the Consolidated Statements of Financial Condition.

(2)Includes netting of derivative asset and liability balances and related cash collateral, where counterparty netting agreements are in place.

127

Table of Contents

	At December 31, 2019
			Fair Value
(In thousands)	Notional Amount(1)		Derivative Assets		Derivative Liabilities
Derivatives designated as hedging instruments:
Interest rate contract	$	150,000	$	—	$	168
Forward foreign exchange contracts	177,593		—		3,251
Total derivatives designated as hedging instruments			—		3,419
Derivatives not designated as hedging instruments:
Interest rate contracts	5,095,969		102,893		5,872
Risk participation agreements	316,353		202		354
Forward foreign exchange contracts	262,656		—		3,268
Interest rate lock commitments	158,111		2,772		20
Forward loan sales commitments	174,013		41		289
Power Equity CDs	29,009		734		734
Swap agreement	12,652		—		356
Total derivatives not designated as hedging instruments			106,642		10,893
Total derivatives before netting			106,642		14,312
Netting(2)			(540)		(5,109)
Total derivatives, net			$	106,102	$	9,203

(1)Notional or contract amounts, which represent the extent of involvement in the derivatives market, are used to determine the contractual cash flows required in accordance with the terms of the agreement. These amounts are typically not exchanged, significantly exceed amounts subject to credit or market risk and are not reflected in the Consolidated Statements of Financial Condition.

(2)Includes netting of derivative asset and liability balances and related cash collateral, where counterparty netting agreements are in place.

128

Table of Contents

Derivative instruments may be subject to master netting arrangements and collateral arrangements and qualify for offset in the Consolidated Statements of Financial Condition. A master netting arrangement with a counterparty creates a right of offset for amounts due to and from that same counterparty that is enforceable in the event of a default or bankruptcy. Derivative instruments subject to master netting arrangements and collateral arrangements are recognized on a net basis in the Consolidated Statements of Financial Condition. The gross amounts recognized, gross amounts offset and net amount presented of derivative instruments were as follows:

	At December 31, 2020
(In thousands)	Gross Amounts Recognized		Gross Amounts  Offset(1)		Net Amount Presented
Derivative assets
Interest rate contracts	$	248,267	$	—	$	248,267
Risk participation agreements	62		—		62
Forward foreign exchange contracts	11		(11)		—
Interest rate lock commitments	14,565		(4)		14,561
Forward loan sales commitments	37		(37)		—
Power Equity CDs	459		—		459
Total derivative assets	$	263,401	$	(52)	$	263,349
Derivative liabilities
Interest rate contracts	$	14,681	$	—	$	14,681
Risk participation agreements	125		—		125
Forward foreign exchange contracts	2,386		(1,769)		617
Interest rate lock commitments	4		(4)		—
Forward loan sales commitments	3,411		(37)		3,374
Power Equity CDs	459		—		459
Swap agreement	66		(66)		—
Total derivative liabilities	$	21,132	$	(1,876)	$	19,256

	At December 31, 2019
(In thousands)	Gross Amounts Recognized		Gross Amounts Offset(1)		Net Amount Presented
Derivative assets
Interest rate contracts	$	102,893	$	(492)	$	102,401
Risk participation agreements	202		—		202
Interest rate lock commitments	2,772		(7)		2,765
Forward loan sales commitments	41		(41)		—
Power Equity CDs	734		—		734
Total derivative assets	$	106,642	$	(540)	$	106,102
Derivative liabilities
Interest rate contracts	$	6,040	$	(491)	$	5,549
Risk participation agreements	354		—		354
Forward foreign exchange contracts	6,519		(4,214)		2,305
Interest rate lock commitments	20		(7)		13
Forward loan sales commitments	289		(41)		248
Power Equity CDs	734		—		734
Swap agreement	356		(356)		—
Total derivative liabilities	$	14,312	$	(5,109)	$	9,203

(1)Includes the amounts with counterparties subject to enforceable master netting arrangements that have been offset in the Consolidated Statements of Financial Condition.

129

Table of Contents

Derivatives Designated as Hedging Instruments

Interest rate contract The carrying amount of the hedged subordinated debt, including the cumulative basis adjustment related to the application of fair value hedge accounting, is recorded in long-term borrowings on the Consolidated Statements of Financial Condition and was as follows:

	Carrying Amount of the Hedged Liability				Cumulative Amount of Fair Value Hedging Adjustments Included in the Carrying Amount of the Hedged Liability
	At December 31,				At December 31,
(In thousands)	2020		2019		2020		2019
Subordinated bank note - 2025	$	159,888	$	151,454	$	10,975	$	2,773

The following table summarizes the effect of fair value hedge accounting on the Consolidated Statements of Income for the years ended December 31, 2020, 2019 and 2018.

	Year Ended December 31,
(In thousands)	2020		2019		2018
Statement of income line where the gain (loss) on the fair value hedge was recorded:
Interest expense on borrowings	$	60,275	$	72,072	$	43,144
Gain (loss) on interest rate contract (fair value hedge)
Hedged item	(8,203)		(6,937)		2,163
Derivative designated as a hedging instrument	8,274		6,986		(2,275)
Net income (expense) recognized on fair value hedge in interest expense on borrowings	$	71	$	49	$	(112)

Forward Foreign Exchange Contracts The effect of net investment hedges on accumulated other comprehensive income was as follows:

	Year Ended December 31,
(In thousands)	2020		2019		2018
Forward foreign exchange contracts	$	(5,452)	$	(7,001)	$	13,762

Derivatives Not Designated as Hedging Instruments Certain other interest rate contracts, forward foreign exchange contracts, interest rate lock commitments and other contracts have not been designated as hedging instruments. The effect of these derivatives on the Consolidated Statements of Income was as follows:

		Year Ended December 31,
(In thousands)	Location of Gain (Loss)	2020		2019		2018
Interest rate contracts(1)	Other noninterest income	$	5,682	$	(18,240)	$	(440)
Risk participation agreements	Other noninterest expense	(387)		123		31
Forward foreign exchange contracts	Other noninterest expense	2,520		(10,209)		23,707
Interest rate lock commitments	Net gains on sales of loans and leases	12,582		(573)		806
Forward loan sales commitments	Net gains on sales of loans and leases	(3,126)		(172)		—
Swap agreement	Other noninterest income	(1)		(69)		(274)
Net gain (loss) recognized		$	17,270	$	(29,140)	$	23,830

(1)Included in the year ended December 31, 2019 is a loss of $17.3 million related to the termination of $1.1 billion of interest rate swaps.

The Corporation executes all of its forward foreign exchange contracts in the over-the-counter market with large financial institutions pursuant to International Swaps and Derivatives Association, Inc. agreements. These agreements include credit risk-related features that enhance the creditworthiness of these instruments, as compared with other obligations of the respective counterparty with whom the Corporation has transacted, by requiring that additional collateral be posted under certain circumstances. The amount of collateral required depends on the contract and is determined daily based on market and currency exchange rate conditions.

130

Table of Contents

At December 31, 2020 and 2019, credit risk-related contingent features existed on forward foreign exchange contracts with a notional value of $35.0 million and $23.1 million, respectively. In the event the Corporation is rated less than BB- by Standard and Poor's, the contracts could be terminated or the Corporation may be required to provide approximately $699 thousand and $462 thousand in additional collateral at December 31, 2020 and 2019 respectively. There were no forward foreign exchange contracts containing credit risk-related features in a liability position at both December 31, 2020 and December 31, 2019.

At December 31, 2020, the Corporation had posted $43.6 million and $2.4 million of cash collateral related to its interest rate contracts and forward foreign exchange contracts, respectively.

Note 20.  Fair Value Measurements

The Corporation uses fair value measurements to record fair value adjustments to certain assets and liabilities and to determine fair value disclosures. Fair values are based on the price that would be received upon the sale of an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. Investment securities available-for-sale, certain loans held-for-sale, interest-only strips, derivative instruments, forward loan sales commitments and assets and liabilities held in trust for deferred compensation plans are recorded at fair value on a recurring basis. From time to time we may be required to record at fair value other assets on a non-recurring basis, such as certain investment securities held-to-maturity, loans and leases, goodwill, loan servicing rights, other intangible assets, other real estate owned, repossessed and returned assets or the securitization receivable. These non-recurring fair value adjustments typically involve application of lower of cost or fair value accounting or write-downs of individual assets.

The Corporation groups its assets and liabilities measured at fair value in three levels, based on the markets in which the assets and liabilities are traded and the degree and reliability of estimates and assumptions used to determine fair value. The levels are as follows:

Level 1    Valuations that are based on prices obtained from independent pricing sources for the same instruments traded in active markets.

Level 2    Valuations that are based on prices obtained from independent pricing sources that are based on observable transactions of similar instruments, but not quoted markets.

Level 3    Valuations generated from Corporation model-based techniques that use at least one significant unobservable input. Such unobservable inputs reflect estimates of assumptions that market participants would use in pricing the asset or liability.

Assets and Liabilities Recorded at Fair Value on a Recurring Basis

Investment Securities Available-for-Sale: The fair value of investment securities available-for-sale, categorized as Level 2, is recorded using prices obtained from independent asset pricing services that are based on observable transactions, but not quoted markets. Management reviews the prices obtained from independent asset pricing services for unusual fluctuations and comparisons to current market trading activity.

Loans Held-for-Sale: The Corporation has elected the fair value option for certain residential mortgage loans held-for-sale. Accordingly, the fair values of these loans held-for-sale are based on valuation models that use the market price for similar loans sold in the secondary market. As these prices are derived from market observable inputs, the Corporation categorized as Level 2.

Interest-only Strips: The fair value of interest-only strips, categorized as Level 3, represents the present value of future cash flows expected to be received by the Corporation on certain assets. The Corporation uses available market data, along with its own empirical data and discounted cash flow models, to arrive at the fair value of its interest-only strips. The present value of the estimated expected future cash flows to be received is determined by using discount, loss and prepayment rates that the Corporation believes are commensurate with the risks associated with the cash flows and what a market participant would use. These assumptions are inherently subject to volatility and uncertainty and, as a result, the fair value of the interest-only strips may fluctuate significantly from period to period. Unobservable inputs used to value the interest-only strips include a discount rate of 14% (weighted average) and prepayment rates of 4% (weighted average).

131

Table of Contents

Derivative Instruments:

Interest Rate Contracts: The Corporation executes interest rate contracts as described in "Note 19. Derivative Instruments". The fair value of these interest rate contracts, categorized as Level 2, is determined using a cash flow model which may consider the forward curve, the discount curve, option volatilities and credit valuation adjustments related to counterparty and/or borrower nonperformance risk.

Risk Participation Agreements: The fair value of risk participation agreements, categorized as Level 2, is determined using a cash flow model which may consider the forward curve, the discount curve, option volatilities and credit valuation adjustments related to counterparty and/or borrower nonperformance risk.

Forward Foreign Exchange Contracts: The Corporation's forward foreign exchange contracts are recorded at fair value using a cash flow model that includes key inputs such as foreign exchange rates and an assessment of the risk of counterparty non-performance. The risk of counterparty non-performance is based on external assessments of credit risk. The fair value of these contracts, categorized as Level 2, is based on observable transactions, but not quoted markets.

Interest Rate Lock Commitments: The Corporation's interest rate lock commitments are derivative instruments that are recorded at fair value based on valuation models that use the market price for similar loans sold in the secondary market. The interest rate lock commitments are adjusted for expectations of exercise and funding. As the prices are derived from market observable inputs, the Corporation categorized as Level 2.

Power Equity CDs: Power Equity CDs are categorized as Level 2, and determined using quoted prices of underlying stocks, along with other terms and features of the derivative instruments.

Swap Agreement: The Corporation's swap agreement, categorized as Level 3, is related to the sale of Legacy TCF's Visa Class B stock. The fair value of the swap agreement is based on the Corporation's estimated exposure related to the Visa covered litigation through a probability analysis of the funding and estimated settlement amounts.

Forward Loan Sales Commitments: The Corporation enters into forward loan sales commitments to sell certain mortgage loans which are recorded at fair value based on valuation models. The Corporation’s expectation of the amount of its interest rate lock commitments that will ultimately close is a factor in determining the position. The valuation models utilize the fair value of related mortgage loans determined using observable market data and therefore categorized as Level 2.

Assets and Liabilities Held in Trust for Deferred Compensation Plans: Assets held in trust for deferred compensation plans include investments in publicly traded securities, excluding TCF Financial common stock reported in other equity and U.S. Treasury notes. The fair value of these assets, categorized as Level 1, is based on prices obtained from independent asset pricing services based on active markets. The fair value of the liabilities equals the fair value of the assets.

132

Table of Contents

The balances of assets and liabilities measured at fair value on a recurring basis were as follows:

	December 31, 2020
(In thousands)	Level 1		Level 2		Level 3		Total
Assets
Investment securities available-for-sale	$	—	$	8,284,219	$	504	$	8,284,723
Loans held-for-sale	—		221,784		—		221,784
Interest-only strips	—		—		7,823		7,823
Derivative assets:(1)
Interest rate contracts	—		248,267		—		248,267
Risk participation agreements	—		62		—		62
Forward foreign exchange contracts	—		11		—		11
Interest rate lock commitments	—		14,565		—		14,565
Forward loan sales commitments	—		37		—		37
Power Equity CDs	—		459		—		459
Total derivative assets	—		263,401		—		263,401
Assets held in trust for deferred compensation plans	48,659		—		—		48,659
Total assets at fair value	$	48,659	$	8,769,404	$	8,327	$	8,826,390
Liabilities
Derivative liabilities:(1)
Interest rate contracts	$	—	$	14,681	$	—	$	14,681
Risk participation agreements	—		125		—		125
Forward foreign exchange contracts	—		2,386		—		2,386
Interest rate lock commitments	—		4		—		4
Forward loan sales commitments	—		3,411		—		3,411
Power Equity CDs	—		459		—		459
Swap agreement	—		—		66		66
Total derivative liabilities	—		21,066		66		21,132
Liabilities held in trust for deferred compensation plans	48,659		—		—		48,659
Total liabilities at fair value	$	48,659	$	21,066	$	66	$	69,791

(1)As permitted under GAAP, the Corporation has elected to net derivative assets and derivative liabilities when a legally enforceable master netting agreement exists as well as the related cash collateral received and paid. For purposes of this table, the derivative assets and derivative liabilities are presented gross of this netting adjustment.

133

Table of Contents

	December 31, 2019
(In thousands)	Level 1		Level 2		Level 3		Total
Assets
Investment securities available-for-sale	$	—	$	6,719,568	$	433	$	6,720,001
Loans held-for-sale	—		91,202		—		91,202
Interest-only strips	—		—		12,813		12,813
Derivative assets:(1)
Interest rate contracts	—		102,893		—		102,893
Risk participation agreements	—		202		—		202
Interest rate lock commitments	—		2,772		—		2,772
Forward loan sales commitments	—		41		—		41
Power Equity CDs	—		734		—		734
Total derivative assets	—		106,642		—		106,642
Forward loan sales commitments, non-derivative	—		46		—		46
Assets held in trust for deferred compensation plans	43,743		—		—		43,743
Total assets at fair value	$	43,743	$	6,917,458	$	13,246	$	6,974,447
Liabilities
Derivative liabilities:(1)
Interest rate contracts	$	—	$	6,040	$	—	$	6,040
Risk participation agreements	—		354		—		354
Forward foreign exchange contracts	—		6,519		—		6,519
Interest rate lock commitments	—		20		—		20
Forward loan sales commitments	—		289		—		289
Power Equity CDs	—		734		—		734
Swap agreement	—		—		356		356
Total derivative liabilities	—		13,956		356		14,312
Liabilities held in trust for deferred compensation plans	43,743		—		—		43,743
Total liabilities at fair value	$	43,743	$	13,956	$	356	$	58,055

(1)As permitted under GAAP, the Corporation has elected to net derivative assets and derivative liabilities when a legally enforceable master netting agreement exists as well as the related cash collateral received and paid. For purposes of this table, the derivative assets and derivative liabilities are presented gross of this netting adjustment.

Management assesses the appropriate classification of financial assets and liabilities within the fair value hierarchy by monitoring the level of available observable market information. Changes in markets or economic conditions, as well as changes to the valuation models, may require the transfer of financial instruments from one fair value level to another. Such transfers, if any, are recorded at the fair values as of the beginning of the quarter in which the transfers occurred.

134

Table of Contents

The changes in Level 3 assets and liabilities measured at fair value on a recurring basis were as follows:

(In thousands)	Investment securities available-for-sale		Loans held-for-sale		Interest-only strips		Interest rate lock commitments		Swap agreement		Forward loan sales commitments
Asset (liability) balance, December 31, 2017	$	6	$	3,356	$	21,386	$	223	$	(615)	$	63
Total net gains (losses) included in:
Net income	—		454		2,616		401		(274)		(89)
Other comprehensive income (loss)	—		—		1,195		—		—		—
Sales	—		(332,288)		—		—		—		—
Originations	—		346,560		4,797		—		—		—
Principal paydowns / settlements	(2)		(12)		(13,159)		—		306		—
Asset (liability) balance, December 31, 2018	$	4	$	18,070	$	16,835	$	624	$	(583)	$	(26)
Unrealized gains (losses) included in other comprehensive income for assets held at the end of the period	—		—		1,195		—		—		—
Asset (liability) balance, beginning of period	$	4	$	18,070	$	16,835	$	624	$	(583)	$	(26)
Total net gains (losses) included in:
Net income	1		534		2,568		778		(68)		(119)
Other comprehensive income (loss)	(21)		—		(262)		—		—		—
Acquired	450		—		—		—		—		—
Sales	—		(164,693)		—		—		—		—
Originations	—		175,304		2,789		—		—		—
Principal paydowns / settlements	(1)		(4)		(9,117)		—		295		—
Transfers out of Level 3 (1)	—		(29,211)		—		(1,402)		—		145
Asset (liability) balance, December 31, 2019	$	433	$	—	$	12,813	$	—	$	(356)	$	—
Unrealized gains (losses) included in other comprehensive income for assets held at the end of the period	$	(21)	$	—	$	(262)	$	—	$	—	$	—
Asset (liability) balance, beginning of period	$	433	$	—	$	12,813	$	—	$	(356)	$	—
Total net gains (losses) included in:
Net income	3		—		1,009		—		(1)		—
Other comprehensive income (loss)	68		—		(242)		—		—		—
Acquired	—		—		—		—		—		—
Sales	—		—		—		—		—		—
Originations	—		—		—		—		—		—
Principal paydowns / settlements	—		—		(5,757)		—		291		—
Transfers out of Level 3 (1)	—		—		—		—		—		—
Asset (liability) balance, December 31, 2020	$	504	$	—	$	7,823	$	—	$	(66)	$	—
Unrealized gains (losses) included in other comprehensive income for assets held at the end of the period	$	68	$	—	$	(242)	$	—	$	—	$	—

(1)Certain assets (liabilities) previously classified as Level 3 were transferred to Level 2 because current period prices are derived from Level 2 observable market data.

Assets and Liabilities Recorded at Fair Value on a Non-recurring Basis

The following is a discussion of the valuation methodologies used to record assets and liabilities at fair value on a non-recurring basis.

Loans and Leases: Loans and leases for which repayment is expected to be provided solely by the value of the underlying collateral, categorized as Level 3 and recorded at fair value on a non-recurring basis, are valued based on the fair value of that collateral less estimated selling costs. The fair value of the collateral is determined based on internal estimates and/or assessments provided by third-party appraisers and the valuation relies on a discount rate of 10.0%.

Loan servicing rights: The fair value of loan servicing rights, categorized as Level 3, is based on a third party valuation model utilizing a discounted cash flow analysis using interest rates and prepayment speed assumptions currently quoted for comparable instruments and a discount rate determined by management. The valuation relies on discount rates ranging from 10% to 15% and prepayment speeds ranging from 8% to 40%. Loan servicing rights are recorded at the lower of cost or fair value.

135

Table of Contents

Other Real Estate Owned: The fair value of other real estate owned, categorized as Level 3, is based on independent appraisals, real estate brokers' price opinions or automated valuation methods, less estimated selling costs. Certain properties require assumptions that are not observable in an active market in the determination of fair value and include discount rates of 10.0%. Assets acquired through foreclosure are initially recorded at the lower of the loan or lease carrying amount or fair value less estimated selling costs at the time of transfer to other real estate owned.

Repossessed and Returned Assets: The fair value of repossessed and returned assets, categorized as Level 2 or Level 3 depending on the underlying asset type, is based on available pricing guides, auction results or price opinions, less estimated selling costs. Assets acquired through repossession or returned to TCF are initially recorded at the lower of carrying amount or fair value less estimated selling costs at the time of transfer to repossessed and returned assets.

The balances of assets measured at fair value on a non-recurring basis were as follows. There were no liabilities measured at fair value on a non-recurring basis at December 31, 2020 and December 31, 2019.

(In thousands)	Level 1		Level 2		Level 3		Total
At December 31, 2020
Loans and leases	$	—	$	—	$	592,133	$	592,133
Loan servicing rights	—		—		38,303		38,303
Other real estate owned	—		—		14,575		14,575
Repossessed and returned assets	—		7,332		—		7,332
Total non-recurring fair value measurements	$	—	$	7,332	$	645,011	$	652,343
At December 31, 2019
Loans and leases	$	—	$	—	$	141,199	$	141,199
Loan servicing rights	—		—		56,298		56,298
Other real estate owned	—		—		17,577		17,577
Repossessed and returned assets	—		6,968		—		6,968
Total non-recurring fair value measurements	$	—	$	6,968	$	215,074	$	222,042

Fair Value Option

The Corporation has elected the fair value option for certain residential mortgage loans held-for-sale. This election facilitates the offsetting of changes in fair value of the loans held-for-sale and the derivative financial instruments used to economically hedge them. The difference between the aggregate fair value and aggregate unpaid principal balance of these loans held-for-sale was as follows:

	At December 31,
(In thousands)	2020		2019
Fair value carrying amount	$	221,784	$	91,202
Aggregate unpaid principal amount	210,311		88,192
Fair value carrying amount less aggregate unpaid principal	$	11,473	$	3,010

Differences between the fair value carrying amount and the aggregate unpaid principal balance include changes in fair value recorded at and subsequent to funding and gains and losses on the related loan commitment prior to funding. No loans recorded under the fair value option were delinquent or on nonaccrual status at December 31, 2020 and December 31, 2019. The net gain from initial measurement of the loans held-for-sale, any subsequent changes in fair value while the loans are outstanding and any actual adjustment to the gains realized upon sales of the loans totaled $100.8 million, $27.9 million and $10.0 million for the years ended December 31, 2020, 2019 and 2018, respectively, and are included in net gains on sales of loans and leases. These amounts exclude the impacts from the interest rate lock commitments and forward loan sales commitments which are also included in net gains on sales of loans and leases.

136

Table of Contents

Disclosures about Fair Value of Financial Instruments

Management discloses the estimated fair value of financial instruments, including assets and liabilities on and off the Consolidated Statements of Financial Condition, for which it is practicable to estimate fair value. These fair value estimates were made at December 31, 2020 and December 31, 2019 based on relevant market information and information about the financial instruments. Fair value estimates are intended to represent the price at which an asset could be sold or a liability could be settled. However, given there is no active market or observable market transactions for many of TCF's financial instruments, the estimates of fair value are subjective in nature, involve uncertainties and include matters of significant judgment. Changes in assumptions could significantly affect the estimated values.

The carrying amounts and estimated fair values of the financial instruments, excluding short-term financial assets and liabilities as their carrying amounts approximate fair value and excluding financial instruments recorded at fair value on a recurring basis, were as follows. This information represents only a portion of the Consolidated Statements of Financial Condition not recorded in their entirety on a recurring basis and not the estimated value of the Corporation as a whole. Nonfinancial instruments such as the intangible value of the Corporation's branches and core deposits, leasing operations, goodwill, premises and equipment and the future revenues from the Corporation's customers are not reflected in this disclosure. Therefore, this information is of limited use in assessing the value of the Corporation.

	At December 31, 2020
	Carrying		Estimated Fair Value
(In thousands)	Amount		Level 1		Level 2		Level 3		Total
Financial instrument assets
FHLB and FRB stocks	$	320,436	$	—	$	320,436	$	—	$	320,436
Investment securities held-to-maturity	184,359		—		190,141		3,413		193,554
Loans and leases held-for-sale	244		—		—		248		248
Net loans(1)	31,164,287		—		—		31,434,749		31,434,749
Securitization receivable(2)	19,949		—		—		19,916		19,916
Deferred fees on commitments to extend credit	20,002		—		20,002		—		20,002
Total financial instrument assets	$	31,709,277	$	—	$	530,579	$	31,458,326	$	31,988,905
Financial instrument liabilities
Certificates of deposits	$	5,524,381	$	—	$	5,534,751	$	—	$	5,534,751
Long-term borrowings	1,374,732		—		1,416,355		—		1,416,355
Total financial instrument liabilities	$	6,899,113	$	—	$	6,951,106	$	—	$	6,951,106

	At December 31, 2019
	Carrying		Estimated Fair Value
(In thousands)	Amount		Level 1		Level 2		Level 3		Total
Financial instrument assets
FHLB and FRB stocks	$	442,440	$	—	$	442,440	$	—	$	442,440
Investment securities held-to-maturity	139,445		—		141,168		3,676		144,844
Loans held-for-sale	108,584		—		110,252		2,273		112,525
Net loans(1)	31,699,285		—		—		31,804,513		31,804,513
Securitization receivable(2)	19,689		—		—		19,466		19,466
Deferred fees on commitments to extend credit(2)	19,300		—		19,300		—		19,300
Total financial instrument assets	$	32,428,743	$	—	$	713,160	$	31,829,928	$	32,543,088
Financial instrument liabilities
Certificates of deposits	$	7,455,556	$	—	$	7,460,577	$	—	$	7,460,577
Long-term borrowings	2,354,448		—		2,368,469		—		2,368,469
Deferred fees on standby letters of credit(3)	56		—		56		—		56
Total financial instrument liabilities	$	9,810,060	$	—	$	9,829,102	$	—	$	9,829,102

(1)Expected credit losses are included in the carrying amount and estimated fair values.

(2)Carrying amounts is included in other assets.

(3)Carrying amounts are included in other liabilities.

137

Table of Contents

Note 21.  Revenue from Contracts with Customers

The Corporation earns a variety of revenue, including interest and fees, from customers, as well as revenues from noncustomers. The majority of the Corporation's sources of revenue are included in interest income and noninterest income and are outside of the scope of ASC Topic 606, Revenue from Contracts with Customers ("ASC 606"). Other sources of revenue fall within the scope of ASC 606 and are included in noninterest income.

The Corporation recognizes revenue when the performance obligations related to the transfer of goods or services under the terms of a contract are satisfied. Some obligations are satisfied at a point in time, while others are satisfied over a period of time. Revenue is recognized as the amount of consideration expected to be received in exchange for transferring goods or services to a customer and is segregated based on the nature of product and services offered as part of contractual arrangements. Revenue streams within the scope of ASC 606 are discussed below.

•Fees and Service Charges on Deposit Accounts Fees and service charges on deposit accounts includes fees and other charges the Corporation receives to provide various services, including but not limited to, service charges on deposit accounts and other fees including account analysis fees, monthly service fees, overdraft services, transferring funds, and accepting and executing stop-payment orders. The Corporation's performance obligation for account analysis fees and monthly service fees are generally satisfied and, therefore, revenue is recognized over the period in which the service is provided. Deposit account related fees are largely transactional based, and therefore, the performance obligation is satisfied and the related revenue is recognized at the point in time when the transaction occurs.

•Wealth Management Revenue Wealth management revenue includes fee income generated from personal and institutional customers. The Corporation also provides investment management services. Revenue is recognized over the period of time the services are rendered. Wealth management revenue also includes commissions that are earned for placing a brokerage transaction for execution. Revenue is recognized once the transaction is completed and the Corporation is entitled to receive consideration.

•Card and ATM Revenue Card and ATM revenue includes ATM surcharges and debit card related revenue. ATM surcharges and certain debit card fees are transactional based and, therefore, the performance obligation is satisfied and the related revenue is recognized at the point in time when the transaction occurs. Other debit card fees satisfied over a period of time are recognized over the period in which the service is provided.

•Other Noninterest Income Other noninterest income includes wire transfer fees, safe deposit box income and check orders. The consideration includes both fixed (e.g., safe deposit box fees) and transaction (i.e., wire-transfer fee and check orders) fees. Fixed fees are recognized over the period of time the service is provided, while transaction fees are recognized when a specific service is rendered to the customer.

138

Table of Contents

The following tables present total noninterest income segregated between contracts with customers within the scope of ASC 606 and those within the scope of other GAAP topics.

	Year Ended December 31, 2020
	Within the scope of ASC 606						Out of scope of ASC 606		Total
(In thousands)	Consumer Banking		Commercial Banking		Enterprise Services
Noninterest income
Fees and service charges on deposit accounts	$	101,897	$	10,165	$	—	$	619	$	112,681
Wealth management revenue	5,839		—		—		19,862		25,701
Card and ATM revenue	80,195		95		—		8,409		88,699
Other noninterest income	3,332		7,044		849		277,757		288,982
Total	$	191,263	$	17,304	$	849	$	306,647	$	516,063

	Year Ended December 31, 2019
	Within the scope of ASC 606						Out of scope of ASC 606		Total
(In thousands)	Consumer Banking		Commercial Banking		Enterprise Services
Noninterest income
Fees and service charges on deposit accounts	$	121,080	$	6,682	$	—	$	98	$	127,860
Wealth management revenue	2,204		—		—		8,209		$	10,413
Card and ATM revenue	81,472		6		—		5,743		87,221
Other noninterest income	190		9,384		558		229,906		240,038
Total	$	204,946	$	16,072	$	558	$	243,956	$	465,532

	Year Ended December 31, 2018
	Within the scope of ASC 606						Out of scope of ASC 606		Total
(In thousands)	Consumer Banking		Commercial Banking		Enterprise Services
Noninterest income
Fees and service charges on deposit accounts	$	108,883	$	4,224	$	—	$	135	$	113,242
Card and ATM revenue	78,119		4		—		283		78,406
Other noninterest income	1,363		11,492		1,007		248,887		262,749
Total	$	188,365	$	15,720	$	1,007	$	249,305	$	454,397

Contract Balances A contract asset balance occurs when an entity performs a service for a customer before the customer pays consideration (resulting in a contract receivable) or before payment is due (resulting in a contract asset). A contract liability balance is an entity's obligation to transfer a service to a customer for which the entity has already received payment (or payment is due) from the customer. The Corporation's noninterest income streams are largely based on transactional activity, or standard month-end revenue accruals such as asset management fees based on month-end market values. Consideration is most often received immediately or shortly after the Corporation satisfies its performance obligation and revenue is recognized. The Corporation does not typically enter into long-term revenue contracts with customers, and therefore, does not experience significant contract balances.

Note 22.  Share-based Compensation

The Corporation maintains share-based compensation plans under which it periodically grants share-based awards for a fixed number of shares to directors and certain officers of the Corporation.

Before the TCF/Chemical Merger, Chemical and Legacy TCF granted share-based awards under their respective share-based compensation plans, including the Chemical Stock Incentive Plan of 2019 (the "Stock Incentive Plan of 2019") and the TCF Financial 2015 Omnibus Incentive Plan (the "Legacy TCF Omnibus Incentive Plan"). At December 31, 2020, there were 1,002,931 shares reserved for issuance under the Stock Incentive Plan of 2019 and there were 1,358,516 shares reserved for issuance under the Legacy TCF Omnibus Incentive Plan.

139

Table of Contents

The fair value of share-based awards is recognized as compensation expense over the requisite service or performance period. Compensation expense for share-based awards, including merger-related share-based compensation expense was $46.0 million, $26.3 million and $16.5 million for the years ended December 31, 2020, 2019 and 2018, respectively. The excess tax realized from share-based compensation transactions during the years ended December 31, 2020, 2019 and 2018 was an expense of $2.6 million, a benefit of $2.3 million and a benefit of $2.6 million, respectively.

Restricted Stock Units

The Corporation can grant performance-based restricted stock units ("PRSUs") and time-based restricted stock units ("TRSUs") (collectively referred to as "RSUs") under the Stock Incentive Plan of 2019 and the Legacy TCF Omnibus Incentive Plan; provided that, RSUs granted under the Legacy TCF Omnibus Incentive Plan may only be granted to new employees hired after the TCF/Chemical Merger or employees who previously were employees of Legacy TCF. At December 31, 2020, there were 309,432 PRSUs outstanding dependent on achieving certain performance target levels and the grantee completing the requisite service period. The TRSUs vest upon satisfaction of a service condition. Upon achievement of the satisfaction of a service condition and/or performance target level, as applicable, the TRSUs are converted into shares of TCF Financial's common stock on a one-to-one basis and the PRSUs are converted into shares of TCF Financial's common stock in accordance with the achievement of the performance target (ranging from 0% to 150% of the granted PRSUs). Compensation expense related to RSUs is recognized over the expected requisite performance or service period, as applicable.

A summary of the activity for RSUs for the years ended December 31, 2020, 2019 and 2018 is presented below:

	Number of Units	Weighted-average Grant Date Fair Value Per Unit
Outstanding at December 31, 2017	360,988	$	15.17
Outstanding at December 31, 2017 as adjusted for conversion	183,419	29.86
Granted	60,181	43.78
Forfeited/canceled	(10,411)	28.59
Vested	(26,609)	28.81
Outstanding at December 31, 2018	406,575	17.33
Outstanding at December 31, 2018 as adjusted for conversion	206,580	34.11
Granted	638,138	41.99
Acquired in the TCF/Chemical Merger(1)	879,779	47.36
Forfeited/canceled	(26,347)	43.43
Vested	(186,330)	38.11
Outstanding at December 31, 2019	1,511,820	44.49
Granted	1,542,671	24.67
Forfeited/canceled	(83,818)	32.06
Vested	(955,159)	41.51
Outstanding at December 31, 2020	2,015,514	31.25

(1)Inclusive of certain Legacy TCF PRSUs which were converted at their maximum payout into 55,022 TRSUs with a weighted-average grant date fair value per unit of $42.06.

Unrecognized compensation expense related to RSUs totaled $43.1 million at December 31, 2020 and is expected to be recognized over the remaining weighted-average period of 2.5 years.

140

Table of Contents

Restricted Stock Awards

The Corporation's restricted stock award transactions were as follows:

	Number of Awards	Weighted-Average Grant Date Fair Value Per Award
Outstanding at December 31, 2017	2,639,663	$	13.65
Outstanding at December 31, 2017 as adjusted for conversion	1,341,136	26.86
Granted	387,909	42.61
Forfeited/canceled	(119,366)	29.77
Vested	(446,447)	24.09
Outstanding at December 31, 2018	2,289,446	$	16.70
Outstanding at December 31, 2018 as adjusted for conversion	1,163,232	32.87
Granted	269,915	40.82
Forfeited/canceled	(136,489)	34.18
Vested	(408,353)	34.37
Outstanding at December 31, 2019	888,305	40.67
Granted	54,040	25.91
Forfeited/canceled	(12,927)	39.96
Vested	(424,256)	41.08
Outstanding at December 31, 2020	505,162	$	38.57

At December 31, 2020, there were no shares of performance-based restricted stock awards outstanding. Unrecognized stock compensation expense for restricted stock awards was $8.7 million at December 31, 2020 with a weighted-average remaining amortization period of 1.8 years.

The following table provides information regarding total expense for restricted stock awards:

	Year Ended December 31,
(In thousands)	2020		2019		2018
Restricted stock expense related to employees(1)	$	26,906	$	15,218	$	16,549
Restricted stock expense related to directors(2)	918		950		—
Total restricted stock expense	$	27,824	$	16,168	$	16,549

(1)Included in "Compensation and employee benefits" in the Consolidated Statements of Income.

(2)Included in "Other noninterest expense" in the Consolidated Statements of Income.

141

Table of Contents

Stock Options

A summary of activity for the Corporation's stock options is presented below:

	Non-Vested Stock Options Outstanding			Stock Options Outstanding
	Number of Options	Weighted-average Exercise Price		Number of Options	Weighted-average Exercise Price
Outstanding at December 31, 2017	—	$	—	366,000	$	15.75
Outstanding at December 31, 2017 as adjusted for conversion	—	—		185,964	31.00
Exercised	—	—		(185,964)	31.00
Outstanding at December 31, 2018	—	—		—	—
Acquired in the TCF/Chemical Merger(1)	127,906	39.38		520,379	29.48
Exercised	—	—		(25,602)	30.10
Forfeited/canceled	(5,953)	32.81		—	—
Expired	—	—		(756)	32.81
Vested	(1,144)	46.95		1,144	46.95
Outstanding at December 31, 2019	120,809	39.63		495,165	29.48
Exercised	—	—		(101,913)	21.07
Forfeited/canceled	(3,659)	38.18		—	—
Expired	—	—		(53,044)	39.08
Vested	(61,428)	38.26		61,428	38.26
Outstanding at December 31, 2020	55,722	$	41.23	401,636	$	31.69
Exercisable/vested at December 31, 2020				401,636	$	31.69

(1)Options acquired in the TCF/Chemical Merger expire ten years from the date of grant and vest ratably over a five-year period.

The weighted-average remaining contractual term was 4.0 years for all stock options outstanding and 3.8 years for all exercisable stock options at December 31, 2020. The intrinsic value of all outstanding in-the-money stock options and exercisable in-the-money stock options was $2.9 million and $2.8 million, respectively, at December 31, 2020. The aggregate intrinsic values of outstanding and exercisable options at December 31, 2020 were calculated based on the closing market price of TCF Financial's common stock on December 31, 2020 of $37.02 per share less the exercise price. Options with intrinsic values less than zero, or "out-of-the-money" options, are not included in the aggregate intrinsic value reported.

During the year ended December 31, 2020, $2.1 million cash was received from option exercises.

At December 31, 2020, unrecognized compensation expense related to stock options totaled $189 thousand and is expected to be recognized over a remaining weighted average period of 1.1 years.

Note 23.  Retirement Plans

The Corporation's retirement plans include qualified defined benefit pension plans, nonqualified postretirement benefit plans, 401(k) savings plans and nonqualified supplemental retirement plans. The TCF 401K Plan (the "TCF 401K") is a qualified postretirement benefit plan that provides the option to invest in TCF common stock. The TCF 401K Supplemental Plan (the "TCF SERP") and the TCF Financial Corporation Deferred Compensation Plan (the "TCF Deferred Compensation Plan") are both nonqualified supplemental retirement plans. The TCF Cash Balance Pension Plan (the "Legacy TCF Pension Plan") and the Chemical Financial Corporation Employees' Pension Plan ("Chemical Pension Plan") are both qualified benefit pension plans (collectively, the "Pension Plans"), which previously provided for postretirement pension benefits for eligible participants. The TCF Postretirement Plan (the "TCF Postretirement Plan") and the Chemical Financial Corporation Nonqualified Postretirement Benefit Plan (the "Chemical Postretirement Benefit Plan" and together with the TCF Postretirement Plan, the "Postretirement Plans") are both nonqualified postretirement benefit plans.

142

Table of Contents

Qualified Defined Benefit Pension Plans

The Board of Directors of Legacy TCF approved the termination of the Legacy TCF Pension Plan effective November 1, 2019. The weighted-average interest crediting rate was 3.00% for 2019. All participants have had their benefits paid in full. During 2020, distributions were made to all participants electing a lump sum payment. Due to the TCF Pension Plan’s funding level, assets were liquidated and additional funding was made for the annuity purchase in 2020. The weighted-average interest crediting rate was 2.05% at liquidation. The Corporation does not consolidate the assets and liabilities associated with the Legacy TCF Pension Plan.

The Board of Directors terminated the Chemical Pension Plan effective August 31, 2019. The discount rate was adjusted to 3.48% based on the remeasurement of the Chemical Pension Plan required due to the TCF/Chemical Merger and the termination. At the time of the TCF/Chemical Merger, as a result of the termination, the Corporation recognized a prepaid asset representing the funded status of the Chemical Pension Plan, net of estimated settlement costs, and the balance previously recorded in accumulated other comprehensive income was eliminated. The purchase accounting adjustment, as a result of the TCF/Chemical Merger, was reported in goodwill. The Chemical Pension Plan was fully funded as of December 31, 2020. During 2020, distributions were made to all participants electing a lump-sum payment. Plan assets remaining following the lump sum distribution and annuity purchase completed in 2020 will be liquidated and/or transferred to a qualified retirement plan over the next several months.

Nonqualified Postretirement Benefit Plans

The Legacy TCF Postretirement Plan provides health care benefits to eligible retired employees who retired prior to December 31, 2009. Effective January 1, 2000, the Legacy TCF modified the TCF Postretirement Plan for employees not yet eligible for benefits under the Postretirement Plan by eliminating the company subsidy. The provisions for full-time and retired employees then eligible for these benefits were not changed. The TCF Postretirement Plan is not funded.

The Chemical Postretirement Benefit Plan provides medical and dental benefits, upon retirement, to a limited number of active and retired employees. The majority of the retirees are required to make contributions toward the cost of their benefits based on their years of credited service and age at retirement. Covered employees include those who were at least age 50 as of January 1, 2012, that retire at age 60 or older, have at least 25 years of service with Chemical and are participants in the active employee group health insurance plan. Eligible employees may also cover their spouse until age 65 as long as the spouse is not offered health insurance coverage through his or her employer. Employees and their spouses eligible to participate in the Chemical Postretirement Benefit Plan are required to make contributions toward the cost of their benefits upon retirement, with the contribution levels designed to cover the projected overall cost of these benefits over the long-term. Retiree contributions are generally adjusted annually. The accounting for these postretirement benefits anticipates changes in future cost-sharing features such as retiree contributions, deductibles, copayments and coinsurance. The benefits can be amended, modified or terminated by the Corporation at any time.

401(k) Savings Plans

Effective December 31, 2019, the Chemical Financial Corporation 401K Savings Plan merged with and into the TCF 401K. All participant balances remaining were transferred into the TCF 401K on December 31, 2019. The TCF 401K, a qualified postretirement benefit and employee stock ownership plan, allows participants to make contributions of up to 50% of their covered compensation on a tax-deferred and/or after-tax basis, subject to the annual covered compensation limitation imposed by the Internal Revenue Service ("IRS"). TCF matches the contributions of all participants at the rate of $1 per dollar for employees with 180 days or more of service up to a maximum company contribution of 5 percent of the employee's covered compensation per pay period subject to the annual covered compensation limitation imposed by the IRS. Employee contributions and matching contributions vest immediately.

143

Table of Contents

Employees have the opportunity to diversify and invest their account balance, including matching contributions, in various mutual funds or TCF common stock. At December 31, 2020, the fair value of the assets in the TCF 401K totaled $593.5 million and included $146.8 million invested in TCF common stock. Dividends on TCF common shares held in the 401K reduce retained earnings and the shares are considered outstanding for computing earnings per share. The Corporation's matching contributions are expensed when earned. The Corporation's contributions to the TCF 401K were $20.8 million for 2020, compared to $16.4 million and $12.3 million for 2019 and 2018, respectively.

Nonqualified Supplemental Retirement Plans

The Legacy TCF Supplemental Plan, a nonqualified plan, allows certain employees to contribute up to 50% of their salary and bonus. The Corporation's matching contributions to this plan totaled $0.5 million, $1.2 million and $1.3 million for 2020, 2019 and 2018, respectively. The Corporation made no other contributions to this plan, other than payment of administrative expenses. The amounts deferred under this plan are invested in TCF common stock or mutual funds. At December 31, 2020 and 2019, the fair value of the assets in the plan totaled $69.5 million and $69.7 million, respectively, and included $21.5 million and $27.6 million, respectively, invested in TCF common stock. The plan's assets invested in TCF common stock are held in trust and included in Other equity. See "Note 17. Equity" for further information on Other equity.

Benefit Obligations and Plan Expenses

The measurement of the benefit obligation, prepaid pension asset, pension liability and annual pension expense involves actuarial valuation methods and the use of actuarial and economic assumptions. Due to the long-term nature of the Pension Plans' obligation, actual results may differ significantly from the actuarial-based estimates. Differences between estimates and actual experience are recorded in the year they arise. The Corporation closely monitors all assumptions and updates them annually. The Corporation does not consolidate the assets and liabilities associated with the Pension Plans. The information set forth in the following tables is based on current actuarial reports.

144

Table of Contents

The following schedule sets forth the changes in the benefit obligation and plan assets of the Corporation's plans:

	Pension Plans				Postretirement Benefit Plans
	At or For the Year Ended December 31,
(In thousands)	2020		2019		2020		2019
Benefit obligation:
Benefit obligation, beginning of year	$	165,976	$	28,330	$	5,276	$	3,320
Benefit obligation acquired in TCF/Chemical Merger	—		136,587		—		2,271
Service cost	—		—		1		1
Interest cost	3,785		3,013		143		149
Net actuarial (gain) loss	782		3,831		295		(19)
Plan amendment(1)	—		—		(449)		—
Benefits paid	(170,543)		(5,785)		(460)		(446)
Benefit obligations, end of year	—		165,976		4,806		5,276
Fair value of plan assets:
Fair value of plan assets, beginning of year	169,484		32,844		—		—
Fair value of plan assets acquired in TCF/Chemical Merger	—		141,746		—		—
Actual gain on plan assets(2)	12,551		333		—		—
Benefits paid	(170,543)		(5,439)		(460)		(377)
Employer contributions	2,423		—		460		377
Fair value of plan assets, end of year	13,915		169,484		—		—
Funded status of plan, end of period	$	13,915	$	3,508	$	(4,806)	$	(5,276)
Accumulated benefit obligation	$	—	$	165,976	$	—	$	—
Amounts recognized in the Consolidated Statements of Financial Condition:
Prepaid (accrued) benefit cost, end of period	$	—	$	3,508	$	(4,806)	$	(5,276)
Prior service cost included in accumulated other comprehensive income (loss)	$	—	$	—	$	(504)	$	(101)

(1)The Legacy TCF Postretirement Plan was updated to move a fully insured medical program through Medicare Advantage and a prior service credit has been established.

(2)Includes $8.5 million net gain as a result of the Pension Plans mark to market adjustment and a net pension settlement gain, included in other noninterest expense in the Consolidated Statements of Income during 2020.

Weighted-average rate assumptions of the Corporation's plans follow:

	Legacy TCF Pension Plan						Chemical Pension Plan						Legacy TCF Postretirement Plan						Chemical Postretirement Plan
(In thousands)	2020		2019		2018		2020		2019		2018		2020		2019		2018		2020		2019		2018
Discount rate used in determining benefit obligation -December 31	N/A		2.17	%	3.95	%	N/A		2.54	%	—	%	1.57	%	2.70	%	3.85	%	2.14	%	3.14	%	—	%
Discount rate used in determining expense	2.17	%	3.95		3.30		2.54	%	3.48		—		2.70		3.85		3.15		3.14		3.11		—
Expected long-term return on Pension Plan Assets	0.50		1.75		1.50		2.54		3.48		—		N/A		N/A		N/A		N/A		N/A		N/A
Health care cost trend rate assumed for next year	—		—		—		—		—		—		5.34		5.45		5.6		6.75		—		—
Final health care cost trend rate	—		—		—		—		—		—		4.50		4.50		4.5		4.75		—		—
Year that final health care trend rate is reached	—		—		—		—		—		—		2038		2038		2038		2028		—		—

N/A Not Applicable.

145

Table of Contents

The net periodic benefit plan (income) cost included in other noninterest expense for the Corporation's plans was as follows for the years ended December 31:

	Pension Plans						Postretirement Plans
(In thousands)	2020		2019		2018		2020		2019		2018
Interest cost	$	3,785	$	3,013	$	983	$	143	$	149	$	110
Service cost	—		—		—		1		1		—
Return on plan assets	(12,551)		(333)		607		—		—		—
Recognized actuarial loss (gain)	782		3,831		(630)		295		(19)		(115)
Amortization of prior service cost	—		—		—		(46)		(46)		(46)
Net periodic benefit plan (income) cost	$	(7,984)	$	6,511	$	960	$	393	$	85	$	(51)

The Corporation is eligible to contribute up to $10.0 million to the Pension Plans until the 2020 federal income tax return extended due date under various IRS funding methods. The Corporation made a $2.4 million cash contribution to the Legacy TCF Pension Plan in 2020, compared to none in 2019 and 2018, respectively. The Corporation made no cash contributions to the Chemical Pension Plan in 2020 and 2019. As a result of the Pension Plan terminations, the Corporation will not make any further contributions.

The Corporation contributed $264 thousand, $377 thousand and $392 thousand to the TCF Postretirement Plan in 2020, 2019 and 2018, respectively and no contributions were made to the Chemical Postretirement Benefit Plan in 2020 and 2019. The Corporation expects to contribute $332 thousand to the Postretirement Plans in 2021. The Corporation currently has no plans to pre-fund the Postretirement Plans in 2021.

The Pension Plans have been fully terminated and no longer have estimated future benefit payments. The following schedule presents estimated future benefit payments for the next 10 years under the Corporation's Postretirement Plans for retirees already receiving benefits and future retirees, assuming they retire and begin receiving unreduced benefits as soon as they are eligible:

(In thousands)	Postretirement Plans
2021	$	591
2022	550
2023	510
2024	462
2025	428
2026 - 2029	1,574
Total	$	4,115

Pension Plan Assets

TCF's Pension Plan investment policy permits investments in cash, money market mutual funds, direct fixed income securities to include U.S. Treasury securities and U.S. Government-sponsored enterprises, and indirect fixed income investment securities made in fund form (mutual fund or institutional fund) where the fund invests in fixed income securities in investment grade corporate credits, non-investment grade floating-rate bank loans and non-investment grade bonds.

146

Table of Contents

Prior to the termination, the assets of the Chemical Pension Plan were historically invested by the Wealth Management department of Chemical Bank. Previously, the Chemical Pension Plan's primary investment objective was long-term growth coupled with income. In consideration of the Chemical Pension Plan's fiduciary responsibilities, emphasis was placed on quality investments with sufficient liquidity to meet benefit payments and plan expenses, as well as providing the flexibility to manage the investments to accommodate current economic and financial market conditions. Prior to the termination, to meet the Chemical Pension Plan's long-term objective within the constraints of prudent management, target ranges were set for the three primary asset classes: an equity securities range from 40.0% to 70.0%, a debt securities range from 20.0% to 60.0%, and a cash and cash equivalents and other range from 0.0% to 10.0%. Modest asset positions outside of these targeted ranges did occur due to the repositioning of assets within industries or other activity in the financial markets. Equity securities were primarily comprised of both individual securities and equity-based mutual funds, invested in either domestic or international markets. The stocks were diversified among the major economic sectors of the market and were selected based on balance sheet strength, expected earnings growth, the management team and position within their industries, among other characteristics. Debt securities were comprised of U.S. dollar denominated bonds issued by the U.S. Treasury, U.S. government sponsored agencies and investment grade bonds issued by corporations. The notes and bonds purchased were primarily rated "A" or better by the major bond rating companies from diverse industries.

Prior to the termination, the Pension Plans' assets were measured at fair value on a recurring basis and grouped in three levels, based on the markets in which the assets are traded and the degree and reliability of estimates and assumptions used to determine fair value. Mutual funds, U.S. Treasury Bills, equity securities and interest-bearing cash were categorized as Level 1. The fair value of Level 1 assets is based on quotes from independent asset pricing services based on active markets. Mortgage-backed securities and U.S. Treasury and government sponsored enterprises and notes were categorized as Level 2. The fair value of level 2 assets is based on prices obtained from independent pricing sources that were based on observable transactions of similar instruments, but not quoted markets. At December 31, 2020 and 2019, there were no assets categorized as Level 3. The fair value of the collective investment fund was based on the net asset value ("NAV") of units as a practical expedient, and therefore the asset was not classified in the fair value hierarchy.

The following schedule sets forth the fair value of the Pension Plans' assets and the level of valuation inputs used to value those assets at December 31, 2020 and 2019.

	At December 31, 2020
(In thousands)	Level 1		Level 2		Level 3		Total
Cash	$	12,515	$	—	$	—	$	12,515
Total investments at fair value	$	12,515	$	—	$	—	$	12,515
	At December 31, 2019
(In thousands)	Level 1		Level 2		Level 3		Total
Cash	$	3,579	$	—	$	—	$	3,579
Debt Securities:
U.S. Treasury and government sponsored agency bonds and notes	—		86,952		—		86,952
Mutual funds(1)	69,845		—		—		69,845
Corporate bonds	—		6,718		—		6,718
Mortgage-backed securities	—		2,346		—		2,346
Other	775		—		—		775
Total investments at fair value	$	74,199	$	96,016	$	—	$	170,215

(1)Comprised primarily of money market mutual funds, fixed-income bonds issued by the U.S. Treasury and government sponsored agencies and bonds of U.S. and foreign issuers from diverse industries.

At December 31, 2019, the Pension Plans did not hold any shares of the Corporation's common stock.

147

Table of Contents

Accumulated Other Comprehensive Loss

The following sets forth the changes in accumulated other comprehensive income (loss), before tax, related to the Corporation's Postretirement Plans:

	At or For the Year Ended December 31,
	Postretirement Plans
(In thousands)	2020		2019		2018
Accumulated other comprehensive income (loss) before tax, beginning of period	$	(101)	$	(147)	$	(193)
Amortization of prior service credit (recognized in net periodic benefit cost)	46		46		46
Plan amendment	(449)		—		—
Accumulated other comprehensive income (loss) before tax, end of period	$	(504)	$	(101)	$	(147)

The Pension Plans do not have any accumulated other comprehensive income (loss).

Note 24.  Earnings Per Common Share

The computations of basic and diluted earnings per common share were as follows:

	Year Ended December 31,
(Dollars in thousands, except per share data)	2020		2019		2018
Basic earnings per common share:
Net income attributable to TCF Financial Corporation	$	222,759	$	295,468	$	304,358
Preferred stock dividends	9,975		9,975		11,588
Impact of preferred stock redemption(1)	—		—		3,481
Net income available to common shareholders	212,784		285,493		289,289
Less: Earnings allocated to participating securities	—		20		42
Earnings allocated to common stock	$	212,784	$	285,473	$	289,247
Weighted-average common shares outstanding used in basic earnings per common share calculation	151,812,393		111,604,094		84,133,983
Basic earnings per common share	$	1.40	$	2.56	$	3.44
Diluted earnings per common share:
Earnings allocated to common stock	$	212,784	$	285,473	$	289,247
Weighted-average common shares outstanding used in basic earnings per common share calculation	151,812,393		111,604,094		84,133,983
Net dilutive effect of:
Non-participating restricted stock	23,901		140,832		—
Stock options	51,265		73,439		1,184
Warrants	—		—		189,519
Weighted-average common shares outstanding used in diluted earnings per common share calculation	151,887,559		111,818,365		84,324,686
Diluted earnings per common share	$	1.40	$	2.55	$	3.43
Anti-dilutive shares outstanding not included in the computation of diluted earnings per common share
Non-participating restricted stock	2,086,305		1,288,539		1,028,942
Stock options	244,004		97,980		—

(1)Amounts represent the deferred stock issuance costs originally recorded in preferred stock that were reclassified to retained earnings.

148

Table of Contents

Note 25. Other Noninterest Income and Expense

Other noninterest income and expense was as follows:

	Year Ended December 31,
(In thousands)	2020		2019		2018
Other Noninterest Income
Gain on branch sales(1)	$	14,717	$	—	$	—
Termination of interest rate swaps	—		(17,302)		—
Loan servicing rights impairment	(17,605)		(3,882)		—
Other	49,430		42,995		28,769
Total other noninterest income	$	46,542	$	21,811	$	28,769
Other Noninterest Expense
Outside processing	$	60,650	$	38,151	$	20,574
Loan and lease expense	29,386		22,557		13,649
Professional fees	26,077		26,863		21,529
Advertising and marketing	25,854		28,220		28,120
FDIC insurance	23,893		18,298		15,056
Card processing and issuance costs	24,363		21,235		17,461
CFPB and OCC settlement charge	—		—		32,000
Other	142,528		148,392		107,097
Total other noninterest expense	$	332,751	$	303,716	$	255,486

(1) Represents the completion of the sale of seven banking centers in conjunction with deposits associated with those banking centers.

Note 26. Income Taxes

Applicable income taxes in the Consolidated Statements of Income were as follows:

(In thousands)	Current		Deferred		Total
Year Ended December 31, 2020:
Federal	$	95,116	$	(70,261)	$	24,855
State	16,206		(4,579)		11,627
Foreign	3,420		(1)		3,419
Total	$	114,742	$	(74,841)	$	39,901
Year Ended December 31, 2019:
Federal	$	(8,471)	$	40,038	$	31,567
State	23,154		(9,564)		13,590
Foreign	5,148		(64)		5,084
Total	$	19,831	$	30,410	$	50,241
Year Ended December 31, 2018:
Federal	$	9,424	$	54,858	$	64,282
State	13,251		3,722		16,973
Foreign	4,435		406		4,841
Total	$	27,110	$	58,986	$	86,096

149

Table of Contents

Reconciliations to the Corporation's effective income tax rates from the statutory federal income tax rates were as follows:

	Year Ended December 31,
	2020		2019		2018
Federal income tax rate	21.00	%	21.00	%	21.00	%
Increase (decrease) resulting from:
CARES Act federal NOL carryback	(5.93)		—		—
Tax credit investments	(4.03)		(1.94)		(0.34)
Executive compensation limitation	3.54		0.67		0.36
State income tax, net of federal tax	3.40		3.01		3.34
Tax-exempt income	(3.04)		(1.74)		(1.64)
FDIC Insurance	1.80		0.96		0.25
Tax basis adjustment	(1.35)		(3.30)		—
State tax settlements, net of federal tax	(0.67)		(1.40)		—
TCF/Chemical Merger deferred tax reprice	—		(1.59)		—
Other, net	0.06		(1.60)		(1.54)
Effective income tax rate	14.78	%	14.07	%	21.43	%

The Corporation considers its undistributed foreign earnings to be reinvested indefinitely. This position is based on management's determination that cash held in the Corporation's foreign jurisdictions is not needed to fund its U.S. operations and that it either has reinvested or has intentions to reinvest these earnings. While management currently intends to indefinitely reinvest all of the Corporation's foreign earnings, should circumstances or tax laws change, the Corporation may need to record additional income tax expense in the period in which such determination or tax law change occurs.

Due to the shift to a worldwide territorial tax regime as part of tax reform enacted by the Tax Cuts and Jobs Act, future repatriations of foreign earnings are no longer subject to U.S. federal income tax. However, these foreign earnings may be subject to foreign withholding taxes should they be distributed in the form of dividends. As of December 31, 2020, the estimated withholding taxes that could be due on these earnings was $5.3 million.

The CARES Act was enacted in March 2020 in response to the COVID-19 pandemic. The CARES Act, among other things, permits NOLs from 2018, 2019 and 2020 to be carried back five years to generate refunds of previously paid income taxes. Additionally, it provides retroactive changes in depreciation rules for certain qualified improvement property. Guidance implementing the CARES Act’s provisions provided retroactive choices to opt into or out of the full expensing of equipment purchases in the year of acquisition. During the year ended December 31, 2020, the Corporation implemented these and other options provided by the CARES Act, which resulted in a forecasted full year 2020 federal tax NOL. Carrying back 2020 federal tax NOLs to pre-2018 years results in tax refunds and a permanent tax benefit associated with the difference between the 21% federal tax rate in 2020 and the 35% federal tax rate prior to 2018.

Reconciliations of the changes in unrecognized tax benefits were as follows:

	At or For the Year Ended December 31,
(In thousands)	2020		2019		2018
Balance, beginning of period	$	2,695	$	5,872	$	4,645
Increases for tax positions related to the current year	282		444		903
Increases for tax positions related to prior years	1,178		445		1,438
Decreases for tax positions related to prior years	(261)		(1,498)		(970)
Settlements with taxing authorities	(2,317)		(2,479)		—
Decreases related to lapses of applicable statutes of limitation	(78)		(89)		(144)
Balance, end of period	$	1,499	$	2,695	$	5,872

150

Table of Contents

The total amount of unrecognized tax benefits that, if recognized, would affect the effective tax rate was $1.2 million and $2.1 million at December 31, 2020 and 2019, respectively. The Corporation recognizes increases and decreases for interest and penalties related to unrecognized tax benefits, where applicable, in income tax expense (benefit). The Corporation recognized approximately $0.2 million of tax benefit, $0.4 million of tax benefit and $0.1 million of tax expense for 2020, 2019 and 2018, respectively, related to interest and penalties. Interest and penalties of approximately $0.1 million and $0.3 million were accrued at December 31, 2020 and 2019, respectively.

The Corporation's federal income tax returns are open and subject to examination for 2017 and later tax return years. The Corporation's various state income tax returns are generally open for 2016 and later tax return years based on individual state statutes of limitation. The Corporation's various foreign income tax returns are open and subject to examination for 2016 and later tax return years. Changes in the amount of unrecognized tax benefits within the next 12 months from normal expirations of statutes of limitation are not expected to be material.

The Corporation's deferred tax assets and deferred tax liabilities were as follows:

	At December 31,
(In thousands)	2020		2019
Deferred tax assets:
Allowance for loan and lease losses	$	121,614	$	25,178
Net operating losses and other carryforwards	74,240		70,820
Stock compensation and deferred compensation plans	45,588		42,980
Acquisition-related fair value adjustments	25,721		44,800
Nonaccrual interest	7,823		6,209
Other	8,290		5,516
Deferred tax assets	283,276		195,503
Valuation allowance	(10,828)		(12,840)
Total deferred tax assets, net of valuation allowance	272,448		182,663
Deferred tax liabilities:
Lease financing	296,184		339,691
Investment securities available-for-sale	56,839		16,760
Goodwill and other intangibles	32,494		35,031
Loan fees and discounts	24,572		10,098
Premises and equipment	16,213		30,122
Deferred Income	12,453		—
Prepaid expenses	10,507		9,508
Loan servicing rights	7,666		12,989
Other	4,926		7,862
Total deferred tax liabilities	461,854		462,061
Net deferred tax liabilities	$	189,406	$	279,398

The net operating losses and other carryforwards at December 31, 2020 consisted of federal net operating losses of $23.1 million that expire in 2028 through 2036, state net operating losses of $4.6 million that expire in 2023 through 2040, charitable contribution carryforwards of $1.3 million that expire in 2025, capital loss carryforwards of $0.2 million that expire in 2022, federal credit carryforwards of $29.4 million that expire in 2028 through 2040 and federal credit carryforwards of $4.9 million that do not expire. The valuation allowance against the Corporation’s deferred tax asset at December 31, 2020 consisted of state net operating losses of $10.7 million and other items of $0.1 million. The valuation allowance at December 31, 2020 and 2019 principally applies to net operating losses and capital loss carryforwards that, in the opinion of management, are more-likely-than-not to expire unutilized. However, to the extent that tax benefits related to these carryforwards are realized in the future, the reduction in the valuation allowance will reduce income tax expense.

151

Table of Contents

Note 27. Reportable Segments

The Corporation's reportable segments are Consumer Banking, Commercial Banking and Enterprise Services. Consumer Banking is comprised of all of the Corporation's consumer-facing businesses and includes retail banking, consumer lending, wealth management and small business banking. Commercial Banking, previously named Wholesale Banking, is comprised of commercial and industrial and commercial real estate banking and lease financing. Enterprise Services is comprised of (i) corporate treasury, which includes the Corporation's investment and borrowing portfolios and management of capital, debt and market risks, (ii) corporate functions, such as information technology, risk and credit management, bank operations, finance, investor relations, corporate development, internal audit, legal and human capital management that provide services to the operating segments, (iii) TCF Financial and (iv) eliminations.

The Corporation evaluates performance and allocates resources based on each reportable segment's net income or loss. The reportable segments follow GAAP as described in "Note 1. Basis of Presentation," except for the accounting for intercompany interest income and interest expense, which are eliminated in consolidation and presenting net interest income on a fully tax-equivalent basis. The Corporation generally accounts for inter-segment sales and transfers at cost.

Certain information for each of the reportable segments, including reconciliations of the Corporation's consolidated totals, was as follows:

(In thousands)	Consumer Banking		Commercial Banking		Enterprise Services		Consolidated
At or For the Year Ended December 31, 2020:
Net interest income	$	834,106	$	697,190	$	7,105	$	1,538,401
Provision for credit losses	16,945		240,206		—		257,151
Net interest income after provision for credit losses	817,161		456,984		7,105		1,281,250
Noninterest income	318,029		186,304		11,730		516,063
Noninterest expense	852,733		430,158		244,480		1,527,371
Income (loss) before income tax expense (benefit)	282,457		213,130		(225,645)		269,942
Income tax expense (benefit)	62,654		35,128		(57,881)		39,901
Income (loss) after income tax expense (benefit)	219,803		178,002		(167,764)		230,041
Income attributable to non-controlling interest	—		7,282		—		7,282
Preferred stock dividends	—		—		9,975		9,975
Net income (loss) available to common shareholders	$	219,803	$	170,720	$	(177,739)	$	212,784
Total assets	$	13,663,990	$	24,063,599	$	10,074,898	$	47,802,487
Revenues from external customers:
Interest income	$	558,729	$	1,027,896	$	179,037	$	1,765,662
Noninterest income	318,029		186,304		11,730		516,063
Total	$	876,758	$	1,214,200	$	190,767	$	2,281,725

152

Table of Contents

(In thousands)	Consumer Banking		Commercial Banking		Enterprise Services		Consolidated
At or For the Year Ended December 31, 2019:
Net interest income	$	676,552	$	536,154	$	76,326	$	1,289,032
Provision for credit losses	16,550		48,732		—		65,282
Net interest income after provision for credit losses	660,002		487,422		76,326		1,223,750
Noninterest income	273,915		198,898		(7,281)		465,532
Noninterest expense	753,904		383,390		194,821		1,332,115
Income (loss) before income tax expense (benefit)	180,013		302,930		(125,776)		357,167
Income tax expense (benefit)	38,353		50,581		(38,693)		50,241
Income (loss) after income tax expense (benefit)	141,660		252,349		(87,083)		306,926
Income attributable to non-controlling interest	—		11,458		—		11,458
Preferred stock dividends	—		—		9,975		9,975
Net income (loss) available to common shareholders	$	141,660	$	240,891	$	(97,058)	$	285,493
Total assets	$	14,224,545	$	20,395,308	$	12,031,700	$	46,651,553
Revenues from external customers:
Interest income	$	533,545	$	919,091	$	134,625	$	1,587,261
Noninterest income	273,915		198,898		(7,281)		465,532
Total	$	807,460	$	1,117,989	$	127,344	$	2,052,793

(In thousands)	Consumer Banking		Commercial Banking		Enterprise Services		Consolidated
At or For the Year Ended December 31, 2018:
Net interest income (expense)	$	569,220	$	383,031	$	56,244	$	1,008,495
Provision for credit losses	24,661		22,107		—		46,768
Net interest income after provision for credit losses	544,559		360,924		56,244		961,727
Noninterest income	262,797		190,442		1,158		454,397
Noninterest expense	669,967		308,727		35,706		1,014,400
Income (loss) before income tax expense (benefit)	137,389		242,639		21,696		401,724
Income tax expense (benefit)	31,645		52,675		1,776		86,096
Income (loss) after income tax expense (benefit)	105,744		189,964		19,920		315,628
Income attributable to non-controlling interest	—		11,270		—		11,270
Preferred stock dividends	—		—		11,588		11,588
Impact of preferred stock call	—		—		3,481		3,481
Net income (loss) available to common shareholders	$	105,744	$	178,694	$	4,851	$	289,289
Total assets	$	6,414,228	$	9,086,125	$	8,199,259	$	23,699,612
Revenues from external customers:
Interest income	$	456,904	$	636,108	$	66,317	$	1,159,329
Noninterest income	262,797		190,442		1,158		454,397
Total	$	719,701	$	826,550	$	67,475	$	1,613,726

 

Note 28.  Commitments, Contingent Liabilities and Guarantees

Financial Instruments with Off-Balance Sheet Risk In the normal course of business, the Corporation enters into financial instruments with off-balance sheet risk, primarily to meet the financing needs of its customers. These financial instruments, which are issued or held for purposes other than trading, involve elements of credit and interest-rate risk in excess of the amounts recognized in the Consolidated Statements of Financial Condition.

The Corporation's exposure to credit loss, in the event of nonperformance by the counterparty to the financial instrument is represented by the contractual amount of the commitments. The Corporation uses the same credit policies in making these commitments as it does for making direct loans. The Corporation evaluates each customer's creditworthiness on a case-by-case basis. The amount of collateral obtained is based on a credit evaluation of the customer.

153

Table of Contents

Financial instruments with off-balance sheet risk were as follows:

	At December 31,
(In thousands)	2020		2019
Commitments to extend credit:
Commercial	$	4,396,191	$	5,743,072
Consumer	2,126,327		2,305,096
Total commitments to extend credit	6,522,518		8,048,168
Standby letters of credit and guarantees on industrial revenue bonds	114,636		129,192
Total	$	6,637,154	$	8,177,360

Commitments to Extend Credit Commitments to extend credit are agreements to lend provided there is no violation of any condition in the contract. These commitments generally have fixed expiration dates or other termination clauses and may require payment of a fee. Since a certain amount of the commitments are expected to expire without being drawn upon, the total commitment amounts do not necessarily represent future cash requirements. Collateral to secure any funding of these commitments predominantly consists of residential and commercial real estate mortgages.

Standby Letters of Credit and Guarantees on Industrial Revenue Bonds Standby letters of credit and guarantees on industrial revenue bonds are conditional commitments issued by the Corporation guaranteeing the performance of a customer to a third-party. These conditional commitments expire in various years through 2039. The majority of these standby letters of credit are collateralized. Collateral held consists primarily of commercial real estate mortgages. Since the conditions under which the Corporation is required to fund these commitments may not materialize, the cash requirements are expected to be less than the total outstanding commitments.

Contingencies and Guarantees The Corporation has originated and sold certain loans, and additionally acquired the potential liability for those historical originated and sold loans by merged or acquired entities, for which the buyer has limited recourse to the Corporation in the event the loans do not perform as specified in the agreements. These loans had an outstanding balance of $7.0 million and $6.2 million at December 31, 2020 and 2019, respectively. The maximum potential amount of undiscounted future payments that the Corporation could be required to make in the event of nonperformance by the borrower totaled $7.0 million and $6.0 million at December 31, 2020 and 2019, respectively. In the event of nonperformance, the Corporation has rights to the underlying collateral securing the loans. At December 31, 2019, the Corporation had recorded a liability of $100 thousand, in connection with the recourse agreements, in other liabilities. There was no recorded liability at December 31, 2020.

In addition, the Corporation has certain Small Business Administration ("SBA") guaranteed loans in which the guaranteed portion had been sold to a third party investor. In the event these loans default and the SBA guaranty is no longer intact (i.e. an issue found to have occurred during the origination or the liquidation of the loans) the Corporation would be liable to make the loan whole to the third-party investor. The maximum potential amount of undiscounted future payments that the Corporation could be required to make in the event of default by the borrower was $13.2 million and $16.7 million at December 31, 2020 and 2019, respectively. In the event of default, the Corporation has rights to the underlying collateral securing the loans. At December 31, 2020 and 2019, the Corporation had recorded a liability of $829 thousand and $891 thousand, respectively, in other liabilities.

Representations, Warranties and Contractual Liabilities In connection with the Corporation's residential mortgage loan sales, and the historical sales of merged or acquired entities, the Corporation makes certain representations and warranties that the loans meet certain criteria, such as collateral type, underwriting standards and the manner in which the loans will be serviced. The Corporation may be required to repurchase individual loans and/or indemnify the purchaser against losses if the loan fails to meet established criteria. In addition, some agreements contain a requirement to repurchase loans as a result of early payoffs by the borrower, early payment default of the borrower or the failure to obtain valid title. At December 31, 2020 and 2019 the liability recorded in connection with these representations and warranties was $3.6 million and $5.7 million, respectively, included in other liabilities.

154

Table of Contents

Litigation Contingencies From time to time, the Corporation is a party to legal proceedings arising out of the Corporation's lending, leasing and deposit operations, including foreclosure proceedings and other collection actions as part of the Corporation's lending and leasing collections activities. The Corporation may also be subject to regulatory examinations and enforcement actions brought by federal regulators, including the SEC, the Federal Reserve, the OCC and the CFPB which may impose sanctions in the event of a regulatory violation. The COVID-19 pandemic has resulted in novel legal and regulatory risks, including risks in the area of workplace safety, risks related to emergency lending programs and the associated risk of fraud and regulatory activity. From time to time, borrowers and other customers, and employees and former employees have also brought actions against the Corporation, in some cases claiming substantial damages. The Corporation, like other financial services companies is subject to the risk of class action litigation. Litigation is often unpredictable and the actual results of litigation cannot be determined, and therefore the ultimate resolution of a matter and the possible range of loss associated with certain potential outcomes cannot be established. Based on the current understanding of the Corporation's pending legal proceedings, management does not believe that judgments or settlements arising from pending or threatened legal matters, individually or in the aggregate, would have a material adverse effect on the consolidated financial position, operating results or cash flows.

Note 29.  Parent Company Financial Information

TCF Financial's condensed statements of financial condition, income and cash flows were as follows:

Condensed Statements of Financial Condition

	At December 31,
(In thousands)	2020		2019
Assets:
Cash and due from banks	$	174,157	$	157,103
Premises and equipment, net	3,407		3,813
Deferred tax asset	8,888		8,536
Investment in TCF Bank	5,492,479		5,526,078
Accounts receivable from TCF Bank	23,202		25,887
Other assets	43,258		40,961
Total assets	$	5,745,391	$	5,762,378
Liabilities and Equity:
Long term borrowings	$	19,090	$	19,021
Accrued expenses and other liabilities	55,488		36,342
Total liabilities	74,578		55,363
Equity	5,670,813		5,707,015
Total liabilities and equity	$	5,745,391	$	5,762,378

155

Table of Contents

Condensed Statements of Income

	Year Ended December 31,
(In thousands)	2020		2019		2018
Interest income:	$	436	$	262	$	200
Interest expense	1,318		484		—
Net interest income	(882)		(222)		200
Noninterest income:
Dividends from TCF Bank	245,000		225,000		431,000
Management fees	53,318		14,001		20,532
Other	2,655		581		426
Total noninterest income	300,973		239,582		451,958
Noninterest expense:
Compensation and employee benefits	45,507		18,677		20,282
Occupancy and equipment	532		470		301
Merger-Related expenses	30,273		69,944		—
Other	4,309		5,040		5,682
Total noninterest expense	80,621		94,131		26,265
Income before income tax benefit and equity in undistributed earnings (loss) of TCF Bank	219,470		145,229		425,893
Income tax benefit	5,961		15,513		952
Income before equity in undistributed earnings (loss) of TCF Bank	225,431		160,742		426,845
Equity in undistributed earnings (loss) of TCF Bank	(2,672)		134,726		(122,487)
Net income	222,759		295,468		304,358
Preferred stock dividends	9,975		9,975		11,588
Impact of preferred stock redemption	—		—		3,481
Net income available to common shareholders	$	212,784	$	285,493	$	289,289

156

Table of Contents

Condensed Statements of Cash Flows

	Year Ended December 31,
(In thousands)	2020		2019		2018
Cash flows from operating activities:
Net income	$	222,759	$	295,468	$	304,358
Adjustments to reconcile net income to net cash provided by (used in) operating activities:
Equity in undistributed (earnings) loss of TCF Bank	2,672		(134,726)		122,487
Share-based compensation expense	35,439		28,351		17,824
Depreciation and amortization	(99)		(640)		4,986
Provision (benefit) for deferred income taxes	(352)		4,893		(583)
Net gains (losses) on sales of assets	—		6		(402)
Net change in other assets	(10,572)		(1,072)		753
Net change in other liabilities	30,900		(1,154)		(374)
Other, net	(1,332)		(21,719)		(7,958)
Net cash provided by operating activities	279,415		169,407		441,091
Cash flows from investing activities:
Purchases of premises and equipment and lease equipment	(23)		(95)		(3)
Proceeds from sales of premises and equipment	—		17		727
Net cash acquired in business combination	—		155,155		—
Net cash provided by (used in) investing activities	(23)		155,077		724
Cash flows from financing activities:
Redemption of Series B preferred stock	—		—		(100,000)
Repurchases of common stock	(33,098)		(86,309)		(212,929)
Common shares sold to TCF employee benefit plans	—		—		715
Dividends paid on preferred stock	(9,975)		(9,975)		(11,588)
Dividends paid on common stock	(214,687)		(156,060)		(99,490)
Payments related to tax-withholding upon conversion of share-based awards	(4,555)		(6,198)		(6,865)
Exercise of stock options	(23)		29		(997)
Net cash used in financing activities	(262,338)		(258,513)		(431,154)
Net change in cash and due from banks	17,054		65,971		10,661
Cash and due from banks at beginning of period	157,103		91,132		80,471
Cash and due from banks at end of period	$	174,157	$	157,103	$	91,132

TCF Financial's operations are conducted through its banking subsidiary, TCF Bank. As a result, TCF Financial's cash flows and ability to make dividend payments to its preferred and common shareholders depend on the earnings of TCF Bank. The ability of TCF Bank to pay dividends or make other payments to TCF Financial is limited by its obligation to maintain sufficient capital and by other regulatory restrictions on dividends. See "Note 18. Regulatory Capital Requirements" of Notes to Consolidated Financial Statements for further information.

157

Table of Contents

Note 30. Selected Quarterly Financial Data (Unaudited)

	Quarter Ended
(In thousands, except per share data)	Dec. 31, 2020		Sep. 30, 2020		Jun. 30, 2020		Mar. 31, 2020		Dec. 31, 2019		Sep. 30, 2019		Jun. 30, 2019		Mar. 31, 2019
Net interest income	$	381,394	$	377,167	$	378,359	$	401,481	$	408,753	$	371,793	$	254,057	$	254,429
Provision for credit losses	11,818		69,664		78,726		96,943		14,403		27,188		13,569		10,122
Net interest income after provision for credit losses	369,576		307,503		299,633		304,538		394,350		344,605		240,488		244,307
Noninterest income	127,236		118,810		133,054		136,963		158,052		94,258		109,718		103,504
Noninterest expense	379,091		373,440		400,241		374,599		416,571		425,620		236,849		253,075
Income before income tax expense (benefit)	117,721		52,873		32,446		66,902		135,831		13,243		113,357		94,736
Income tax expense (benefit)	25,031		(4,429)		6,213		13,086		21,375		(11,735)		19,314		21,287
Income after income tax expense (benefit)	92,690		57,302		26,233		53,816		114,456		24,978		94,043		73,449
Income attributable to non-controlling interest	1,332		1,564		2,469		1,917		2,057		2,830		3,616		2,955
Net income attributable to TCF Financial Corporation	91,358		55,738		23,764		51,899		112,399		22,148		90,427		70,494
Preferred stock dividends	2,494		2,494		2,494		2,493		2,494		2,494		2,494		2,493
Net income available to common shareholders	$	88,864	$	53,244	$	21,270	$	49,406	$	109,905	$	19,654	$	87,933	$	68,001
Earnings per common share:
Basic	$	0.58	$	0.35	$	0.14	$	0.33	$	0.72	$	0.15	$	1.07	$	0.83
Diluted	0.58		0.35		0.14		0.32		0.72		0.15		1.07		0.83

158

Table of Contents

Item 9. Changes in and Disagreements With Accountants on Accounting and Financial Disclosure

None.

Item 9A. Controls and Procedures

Disclosure Controls and Procedures TCF Financial carried out an evaluation, under the supervision and with the participation of TCF Financial's management, including its Chief Executive Officer (Principal Executive Officer), Chief Financial Officer (Principal Financial Officer) and Chief Accounting Officer (Principal Accounting Officer), of the effectiveness of the design and operation of TCF Financial’s disclosure controls and procedures pursuant to Rules 13a-15 and 15d-15 of the Securities Exchange Act of 1934, as amended (the "Exchange Act"). Based on that evaluation, management concluded that TCF Financial’s disclosure controls and procedures were effective as of December 31, 2020.

Any system of disclosure controls and procedures, no matter how well conceived and operated, can provide only reasonable, not absolute, assurance that the objectives of the control system are met. The design of a control system inherently has limitations and the benefits of controls must be weighed against their costs. Additionally, controls can be circumvented by the individual acts of some persons, by collusion of two or more people or by management override of the controls. Therefore, no assessment of a cost-effective system of internal controls can provide absolute assurance that all control issues and instances of fraud, if any, will be detected.

Disclosure controls and procedures are designed to ensure that information required to be disclosed by TCF Financial in reports filed or submitted under the Exchange Act is recorded, processed, summarized and reported within the time periods specified in the Securities and Exchange Commission's rules and forms. Disclosure controls are also designed with the objective of ensuring that such information is accumulated and communicated to TCF Financial's management, including the Chief Executive Officer (Principal Executive Officer), Chief Financial Officer (Principal Financial Officer) and Chief Accounting Officer (Principal Accounting Officer), as appropriate, to allow for timely decisions regarding required disclosure. TCF Financial's disclosure controls also include internal controls that are designed to provide reasonable assurance that transactions are properly authorized, assets are safeguarded against unauthorized or improper use and that transactions are properly recorded and reported.

Changes in Internal Control Over Financial Reporting Management is responsible for establishing and maintaining adequate internal control over financial reporting for TCF. Internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles.

Internal control over financial reporting includes those policies and procedures that pertain to the maintenance of records that in reasonable detail accurately and fairly reflect the transactions and dispositions of the assets of TCF; provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles and that receipts and expenditures of TCF are only being made in accordance with authorizations of management and directors of TCF; and provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of TCF’s assets that could have a material effect on the financial statements.

There were no changes in internal control over financial reporting (as a defined rule in Rule 13a-15(f) of the Exchange Act) during the quarter ended December 31, 2020 that materially affected, or are reasonably likely to materially affect, TCF's internal control over financial reporting.

159

Table of Contents

Management's Report on Internal Control Over Financial Reporting

Management is responsible for establishing and maintaining adequate internal control over financial reporting for TCF Financial Corporation (the "Corporation"). Internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles.

Internal control over financial reporting includes those policies and procedures that pertain to the maintenance of records that in reasonable detail accurately and fairly reflect the transactions and dispositions of the assets of the Corporation; provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles and that receipts and expenditures of the Corporation are only being made in accordance with authorizations of management and directors of the Corporation; and provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the Corporation's assets that could have a material effect on the financial statements.

Management, with the participation of the Chief Executive Officer (Principal Executive Officer) and Chief Financial Officer (Principal Financial Officer), completed an assessment of TCF's internal control over financial reporting as of December 31, 2020. This assessment was based on criteria for evaluating internal control over financial reporting established in Internal Control - Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission in May 2013. Based on this assessment, management concluded that TCF's internal control over financial reporting was effective as of December 31, 2020.

KPMG LLP, the Corporation's independent registered public accounting firm that audited the consolidated financial statements included in this annual report, has issued an unqualified attestation report on the effectiveness of the Corporation's internal control over financial reporting as of December 31, 2020.

Any control system, no matter how well conceived and operated, can provide only reasonable, not absolute, assurance that the objectives of the control system are met. The design of a control system inherently has limitations and the benefits of controls must be weighed against their costs. Additionally, controls can be circumvented by the individual acts of some persons, by collusion of two or more people or by management override of the controls. Therefore, no assessment of a cost-effective system of internal controls can provide absolute assurance that all control issues and instances of fraud, if any, will be detected.

160

Table of Contents

Report of Independent Registered Public Accounting Firm

To the Shareholders and Board of Directors

TCF Financial Corporation:

Opinion on Internal Control Over Financial Reporting

We have audited TCF Financial Corporation and subsidiaries’ (the Corporation) internal control over financial reporting as of December 31, 2020, based on criteria established in Internal Control – Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission. In our opinion, the Corporation maintained, in all material respects, effective internal control over financial reporting as of December 31, 2020, based on criteria established in Internal Control – Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), the consolidated statements of financial condition of the Corporation as of December 31, 2020 and 2019, the related consolidated statements of income, comprehensive income, equity, and cash flows for each of the years in the three-year period ended December 31, 2020, and the related notes (collectively, the consolidated financial statements), and our report dated February 26, 2021 expressed an unqualified opinion on those consolidated financial statements.

Basis for Opinion

The Corporation’s management is responsible for maintaining effective internal control over financial reporting and for its assessment of the effectiveness of internal control over financial reporting, included in the accompanying Management's Report on Internal Control Over Financial Reporting. Our responsibility is to express an opinion on the Corporation’s internal control over financial reporting based on our audit. We are a public accounting firm registered with the PCAOB and are required to be independent with respect to the Corporation in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether effective internal control over financial reporting was maintained in all material respects. Our audit of internal control over financial reporting included obtaining an understanding of internal control over financial reporting, assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. Our audit also included performing such other procedures as we considered necessary in the circumstances. We believe that our audit provides a reasonable basis for our opinion.

Definition and Limitations of Internal Control Over Financial Reporting

A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the company’s assets that could have a material effect on the financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

/s/ KPMG LLP

Detroit, Michigan

February 26, 2021

161

Table of Contents

Item 9B. Other Information

None.

Part III

Item 10. Directors, Executive Officers and Corporate Governance

Information regarding our directors and executive officers will be set forth in the following sections of our definitive Proxy Statement for the 2021 Annual Meeting of Shareholders ("2021 Proxy"): Election of Directors; Background of Executive Officers Who Are Not Directors; and Delinquent Section 16(a) Reports, and is incorporated herein by reference, or will be included in an amendment to the Annual Report on Form 10-K/A to be filed with the SEC not later than 120 days after December 31, 2020 ("2021 10-K/A").

Information regarding procedures for nominations of directors is set forth in the following sections of our 2021 Proxy and is incorporated herein by reference, or will be included in our 2021 10-K/A: Corporate Governance - Director Nominations; and Additional Information.

Audit Committee and Financial Expert

Information regarding our Audit Committee, its members and financial experts will be set forth in the following sections of our 2021 Proxy and is incorporated herein by reference, or will be included in our 2021 10-K/A: Election of Directors - Background of the Nominees; Corporate Governance - Board Committees, Committee Memberships, and Meetings in 2020; and Corporate Governance - Audit Committee.

Our Board of Directors is required to determine whether it has at least one Audit Committee Financial Expert and that the expert is independent. An Audit Committee Financial Expert is a committee member who has an understanding of generally accepted accounting principles and financial statements and has the ability to assess the general application of these principles in connection with the accounting for estimates, accruals and reserves. Additionally, this individual should have experience preparing, auditing, analyzing or evaluating financial statements that present the breadth and level of complexity of accounting issues that are generally comparable to the breadth and complexity of issues that can reasonably be expected to be raised by our financial statements or experience actively supervising one or more persons engaged in such activities. The member should also have an understanding of internal control over financial reporting as well as an understanding of audit committee functions.

The Board has determined that all members of the Audit Committee, including Karen L. Grandstrand, Barbara J. Mahone, Roger J. Sit, Julie H. Sullivan, Jeffery L. Tate, and Franklin C. Wheatlake, are independent and that Directors Sit, Sullivan and Tate each meet the requirements of audit committee financial experts. Additional information regarding Ms. Grandstrand, Ms. Mahone, Mr. Sit, Dr. Sullivan, Mr. Tate and Mr. Wheatlake and the other directors will be set forth in the section Election of Directors - Background of the Nominees in our 2021 Proxy and is incorporated herein by reference, or will be included in our 2021 10-K/A.

Code of Ethics for Senior Financial Management

We have adopted a code of ethics applicable to the Principal Executive Officer ("PEO"), Principal Financial Officer ("PFO") and Principal Accounting Officer ("PAO") (the "Senior Financial Management Code of Ethics") as well as a code of ethics generally applicable to all of our employees (including the PEO, PFO and PAO) and directors (the "Code of Ethics"). The Code of Ethics and the Senior Financial Management Code of Ethics are both available for review on our website at www.tcfbank.com by clicking on "About TCF" and then "Corporate Governance" and then selecting either "Code of Ethics Policy" or "Code of Ethics for Senior Financial Management". Any changes to either code will be posted on the website and any waivers granted to or violations by the PEO, PFO, PAO or any director of TCF Financial will also be posted on our website. To date, there have been no waivers granted to or violations by the PEO, PFO, PAO or any director of our directors.

162

Table of Contents

Item 11. Executive Compensation

Information regarding compensation of our directors and executive officers will be set forth in the following sections of our 2021 Proxy and is incorporated herein by reference, or will be included in our 2021 10-K/A: Corporate Governance - Compensation and Pension Committee; Director Compensation; Compensation Discussion and Analysis; Compensation Committee Report; and Executive Compensation.

Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters

Information regarding ownership of our common stock by our directors, executive officers and certain other shareholders and shares authorized under equity compensation plans will be set forth in the following sections of TCF's 2021 Proxy and is incorporated herein by reference, or will be included in our 2021 10-K/A: Equity Compensation Plans Approved by Shareholders; and Ownership of TCF Stock.

Item 13. Certain Relationships and Related Transactions, and Director Independence

Information regarding director independence and certain relationships and transactions between TCF and certain related persons will be set forth in the section entitled Corporate Governance - Director Independence and Related Person Transactions of our 2021 Proxy and is incorporated herein by reference, or will be included in our 2021 10-K/A.

Item 14. Principal Accounting Fees and Services

Information regarding principal accounting fees and services and the Audit Committee's pre-approval policies and procedures relating to audit and non-audit services provided by our independent registered public accounting firm will be set forth in the section entitled Independent Registered Public Accountants in our 2021 Proxy and is incorporated herein by reference, or will be included in our 2021 10-K/A.

163

Table of Contents

Part IV

Item 15. Exhibits, Financial Statement Schedules

1. Financial Statements
The following consolidated financial statements of TCF Financial Corporation are filed as part of this report:
Description	Page
Report of Independent Registered Public Accounting Firm	76
Consolidated Statements of Financial Condition at December 31, 2020 and 2019	79
Consolidated Statements of Income for each of the years in the three-year period ended December 31, 2020	80
Consolidated Statements of Comprehensive Income for each of the years in the three-year period ended December 31, 2020	81
Consolidated Statements of Equity for each of the years in the three-year period ended December 31, 2020	82
Consolidated Statements of Cash Flows for each of the years in the three-year period ended December 31, 2020	84
Notes to Consolidated Financial Statements	85
2. Financial Statement Schedules
All financial statement schedules have been included in the Consolidated Financial Statements or the Notes thereto, or are either inapplicable or not required.

164

Table of Contents

3. Exhibits

Exhibit Number	Description
2(a)	Agreement and Plan of Merger, by and between TCF Financial Corporation and Huntington Bancshares Incorporated, dated as of December 13, 2020*. Previously filed as Exhibit 2.1 to the registrant’s Current Report on Form 8-K filed with the SEC on December 17, 2020. Here incorporated by reference.
3(a)	Restated Articles of Incorporation of TCF Financial Corporation Previously filed as Exhibit 3.1 to the registrant’s Quarterly Report on Form 10-Q for the quarter ended March 31, 2017, filed with the SEC on May 10, 2017. Here incorporated by reference.
3(b)	Amendment to the Restated Articles of Incorporation of TCF Financial Corporation, including the Certificate of Designations of 5.70% Series C Non-Cumulative Perpetual Preferred Stock. Previously filed as Exhibit 3.2 to the registrant’s Current Report on Form 8-K filed with the SEC on August 1, 2019. Here incorporated by reference.
3(c)	Amended and Restated Bylaws of TCF Financial Corporation, as of October 28, 2020. Previously filed as Exhibit 3.1 to the registrant's Current Report on Form 8-K filed with the SEC on October 26, 2020. Here incorporated by reference.
4(a)#	Description of Capital Stock.
4(b)	Long-Term Debt. The registrant has outstanding long-term debt which at the time of this Annual Report does not exceed 10% of the registrant's total consolidated assets. The registrant agrees to furnish copies of the agreements defining the rights of holders of such long-term debt to the SEC upon request.
10(a)*	Amended and Restated Chemical Financial Corporation Stock Incentive Plan of 2006. Previously filed as Exhibit 10.1 to the registrant's Quarterly Report on Form 10-Q for the quarter ended June 30, 2011, filed with the SEC on August 3, 2011. Here incorporated by reference.
10(b)*	Chemical Financial Corporation Stock Incentive Plan of 2012. Previously filed as Appendix A to the registrant's definitive proxy statement for the registrant's 2012 Annual Meeting of Shareholders, filed with the SEC on March 1, 2012. Here incorporated by reference.
10(c)*	Chemical Financial Corporation Stock Incentive Plan of 2015. Previously filed as Appendix C to the registrant's definitive proxy statement for the registrant's 2015 Annual Meeting of Shareholders, filed with the SEC on March 6, 2015. Here incorporated by reference.
10(d)*	Chemical Financial Corporation Stock Incentive Plan of 2017. Previously filed as Exhibit 10.1 to the registrant's Quarterly Report on Form 10-Q for the quarter ended March 31, 2017, filed with the SEC on May 10, 2017. Here incorporated by reference.
10(e)*	Chemical Financial Corporation Supplemental Retirement Income Plan. Previously filed as Exhibit 10.5 to the registrant's Registration Statement on Form S-4, filed with the SEC on February 19, 2010. Here incorporated by reference.
10(f)*	Chemical Financial Corporation Deferred Compensation Plan for Directors. Previously filed as Exhibit 10.2 to the registrant's Annual Report on Form 10-K for the year ended December 31, 2011, filed with the SEC on February 24, 2012. Here incorporated by reference.
10(g)*	TCF Financial Corporation Deferred Compensation Plan, as amended effective January 1, 2020. Previously filed as Exhibit 10(g) to the registrant's Annual Report on Form 10-K, filed with the SEC on March 2, 2020. Here incorporated by reference.
10(h)*	Chemical Financial Corporation Directors' Deferred Stock Plan. Previously filed as Exhibit 10.8 to the registrant's Annual Report on Form 10-K for the year ended December 31, 2013, filed with the SEC on February 26, 2014. Here incorporated by reference.
10(i)*	Chemical Financial Corporation Executive Annual Incentive Plan. Previously filed as Exhibit 10.9 of the registrant's Annual Report on Form 10-K filed with the SEC on February 28, 2018. Here incorporated by reference.
10(j)*	Form of Restricted Stock Unit Agreement pursuant to the Stock Incentive Plan of 2017 for Performance-Based Restricted Stock. Previously filed as Exhibit 10.29 of the registrant’s Annual Report on Form 10-K filed with the SEC on February 28, 2018. Here incorporated by reference.
10(k)*	Form of Restricted Stock Unit Agreement pursuant to the Stock Incentive Plan of 2017 for Time-Vested Restricted Stock. Previously filed as Exhibit 10.30 of the registrant’s Annual Report on Form 10-K filed with the SEC on February 28, 2018. Here incorporated by reference.
10(l)*	Form of Restricted Stock Unit Agreement pursuant to the Stock Incentive Plan of 2017 for Performance-Based Restricted Stock awarded to Executive Leadership. Previously filed as Exhibit 10.29 of the registrant’s Annual Report on Form 10-K filed with the SEC on February 28, 2019. Here incorporated by reference.
10(m)*	Form of Restricted Stock Unit Agreement pursuant to the Stock Incentive Plan of 2017 for Performance-Based Restricted Stock awarded to the Chairman and Chief Executive Officer. Previously filed as Exhibit 10.30 of the registrant’s Annual Report on Form 10-K filed with the SEC on February 28, 2019. Here incorporated by reference.
10(n)*	Form of Restricted Stock Unit Agreement pursuant to the Stock Incentive Plan of 2017 for Time-Vested Restricted Stock awarded to Executive Leadership. Previously filed as Exhibit 10.31 of the registrant’s Annual Report on Form 10-K filed with the SEC on February 28, 2019. Here incorporated by reference.
10(o)*	Form of Restricted Stock Unit Agreement pursuant to the Stock Incentive Plan of 2017 for Time-Vested Restricted Stock awarded to the Chairman and Chief Executive Officer. Previously filed as Exhibit 10.32 of the registrant’s Annual Report on Form 10-K filed with the SEC on February 28, 2019. Here incorporated by reference.
10(p)*	Stock Incentive Plan of 2019. Previously filed as Appendix A to the registrant's definitive proxy statement for the registrant's 2019 Annual Meeting of Shareholders, filed with the SEC on March 28, 2019. Here incorporated by reference.
10(q)*	Form of Restricted Stock Unit Agreement pursuant to the Stock Incentive Plan of 2019 for Time-Based Restricted Stock Units. Previously filed as Exhibit 10(d) of the registrant’s Quarterly Report on Form 10-Q filed with the SEC on May 8, 2020. Here incorporated by reference.
10(r)*	Form of Restricted Stock Unit Agreement pursuant to the Stock Incentive Plan of 2019 for Performance-Based Restricted Stock Units. Previously filed as Exhibit 10(e) of the registrant’s Quarterly Report on Form 10-Q filed with the SEC on May 8, 2020. Here incorporated by reference.
10(u)*	Form of Director’s Restricted Stock Agreement pursuant to the Stock Incentive Plan of 2019 for Deferred Restricted Stock. Previously filed as Exhibit 10(f) of the registrant’s Quarterly Report on Form 10-Q filed with the SEC on May 8, 2020. Here incorporated by reference.

165

Table of Contents

10(v)*	Form of Director’s Restricted Stock Agreement pursuant to the Stock Incentive Plan of 2019 for Non-Deferred Restricted Stock. Previously filed as Exhibit 10(g) of the registrant’s Quarterly Report on Form 10-Q filed with the SEC on May 8, 2020. Here incorporated by reference.
10(w)*	Form of Retention Time-Vesting Restricted Stock Unit Agreement. Previously filed as Exhibit 10.4 of the registrant’s Current Report on Form 8-K filed with the SEC on August 1, 2019. Here incorporated by reference.
10(x)*	Amended and Restated TCF Financial 2015 Omnibus Incentive Plan. Previously filed as Exhibit 10(a) to Legacy TCF’s Annual Report on Form 10-K filed with the SEC on February 26, 2019. Here incorporated by reference.
10(y)*	Form of Restricted Stock Award Agreement under the TCF Financial 2015 Omnibus Incentive Plan. Previously filed as Exhibit 10(aa) of the registrant’s Annual Report on Form 10-K filed with the SEC on March 2, 2020. Here incorporated by reference.
10(z)*	Form of Performance-Based Restricted Stock Award Agreement under the TCF Financial 2015 Omnibus Incentive Plan. Previously filed as Exhibit 10(bb) of the registrant’s Annual Report on Form 10-K filed with the SEC on March 2, 2020. Here incorporated by reference.
10(aa)*	Form of Restricted Stock Unit Agreement pursuant to the TCF Financial 2015 Omnibus Incentive Plan for Time-Based Restricted Stock Units. Previously filed as Exhibit 10(i) of the registrant’s Quarterly Report on Form 10-Q filed with the SEC on May 8, 2020. Here incorporated by reference.
10(bb)*	Form of Restricted Stock Unit Agreement pursuant to the TCF Financial 2015 Omnibus Incentive Plan for Performance-Based Restricted Stock Units. Previously filed as Exhibit 10(j) of the registrant’s Quarterly Report on Form 10-Q filed with the SEC on May 8, 2020. Here incorporated by reference.
10(cc)*	Form of TCF Financial Corporation Management Incentive Plan - Executive Award. Previously filed as Exhibit 10(a)-6 to Legacy TCF’s Annual Report on Form 10-K filed with the SEC on February 26, 2019. Here incorporated by reference.
10(dd)*	TCF Financial Incentive Stock Program, as amended and restated April 24, 2013. Previously filed as Exhibit 10(b) to Legacy TCF’s Annual Report on Form 10-K filed with the SEC on February 26, 2019. Here incorporated by reference.
10(ee)*	Form of Deferred Restricted Stock Award Agreement as executed by certain executives. Previously filed as Exhibit 10(b)-2 to Legacy TCF’s Annual Report on Form 10-K filed with the SEC on February 26, 2019. Here incorporated by reference.
10(ff)*	Form of Performance-Based Restricted Stock Award Agreement as executed by certain executives. Previously filed as Exhibit 10(b)-3 to Legacy TCF’s Annual Report on Form 10-K filed with the SEC on February 26, 2019. Here incorporated by reference.
10(gg)*	TCF Financial Corporation Supplemental Employee Retirement Plan - ESPP Plan as amended and restated through January 24, 2005. Previously filed as Exhibit 10(e) to Legacy TCF’s Annual Report on Form 10-K filed with the SEC on February 26, 2019. Here incorporated by reference.
10(hh)*	TCF 401K Plan, as amended and restated effective January 1, 2020. Previously filed as Exhibit 10(qq) to the registrant’s Annual Report on Form 10-K filed with the SEC on March 2, 2020. Here incorporated by reference.
10(ii)*	TCF 401K Supplemental Plan, as amended and restated effective January 1, 2020. Previously filed as Exhibit 10(qq) to the registrant’s Annual Report on Form 10-K filed with the SEC on March 2, 2020. Here incorporated by reference.
10(jj)*	Trust Agreement for TCF 401K Plan Supplemental Plan effective November 1, 2017, by and between TCF Financial Corporation and Reliance Trust Company. Previously filed as Exhibit 10(f) to Legacy TCF’s Annual Report on Form 10-K filed with the SEC on February 26, 2019. Here incorporated by reference.
10(kk)*	Form of Deferred Director’s Restricted Stock Agreement. Previously filed as Exhibit 10(k)-1 to Legacy TCF’s Annual Report on Form 10-K filed with the SEC on February 26, 2019. Here incorporated by reference.
10(ll)*	TCF Financial Corporation TCF Directors Deferred Compensation Plan as amended and restated through January 24, 2005. Previously filed as Exhibit 10(l) to Legacy TCF’s Annual Report on Form 10-K filed with the SEC on February 26, 2019. Here incorporated by reference.
10(mm)*	TCF Financial Corporation TCF Directors 2005 Deferred Compensation Plan, adopted effective as of January 6, 2005, as amended and restated through January 24, 2005; and as amended by Amendment of Directors 2005 Deferred Compensation Plan effective July 19, 2010.
10(nn)*	Trust Agreement for TCF Directors Deferred Compensation Plan; as amended by amendment adopted April 30, 2001; as amended by amendment adopted October 10, 2001; and as amended by amendments adopted May 3, 2002; and as amended by Third Amendment of TCF Directors Deferred Compensation Trust effective as of June 30, 2003.
10(oo)*	TCF Employees Omnibus Deferred Compensation Plan, as restated effective April 15, 2019. Previously filed as Exhibit 10(rr) to the registrant’s Annual Report on Form 10-K filed with the SEC on March 2, 2020. Here incorporated by reference.
10(pp)*	Rabbi Trust Agreement for TCF Employees Omnibus Deferred Compensation Plan, effective April 15, 2019. Previously filed as Exhibit 10(ss) to the registrant’s Annual Report on Form 10-K filed with the SEC on March 2, 2020. Here incorporated by reference.
10(qq)*	Amended and Restated Employment Agreement dated November 6, 2019, between TCF Financial Corporation and Craig R. Dahl. Previously filed as Exhibit 10.1 of the registrant’s Quarterly Report on Form 10-Q with the SEC on November 12, 2019. Here incorporated by reference.
10(rr)*	Separation and Release Agreement by and between Craig R. Dahl and TCF Financial Corporation, dated October 26, 2020. Previously filed as Exhibit 10.1 of the registrant’s Current Report on Form 8-K filed with the SEC on October 26, 2020. Here incorporated by reference.
10(ss)*	Amended and Restated Retention Agreement between David T. Provost and TCF Financial Corporation, dated March 10, 2020. Previously filed as Exhibit 10.1 of the registrant’s Current Report on Form 8-K filed with the SEC on March 16, 2020. Here incorporated by reference.
10(tt)*	Separation and Release between David T. Provost and TCF Financial Corporation, dated May 8, 2020. Previously filed as Exhibit 10(k) of the registrant’s Quarterly Report on Form 10-Q filed with the SEC on May 8, 2020. Here incorporated by reference.
10(uu)*	Executive Employment Agreement, by and between David T. Provost and TCF Financial Corporation, dated as of December 13, 2020. Previously filed as Exhibit 10.1 of the registrant’s Current Report on Form 8-K filed with the SEC on December 17, 2020. Here incorporated by reference.
10(vv)*	Executive Employment Agreement, by and between Gary Torgow and TCF Financial Corporation, dated as of December 13, 2020. Previously filed as Exhibit 10.2 of the registrant’s Current Report on Form 8-K filed with the SEC on December 17, 2020. Here incorporated by reference.
10(ww)*	Amended and Restated Executive Employment Agreement dated December 13, 2020, between TCF Financial Corporation and Thomas C. Shafer. Previously filed as Exhibit 10.3 to the registrant’s Current Report on Form 8-K filed with the SEC on December 17, 2020. Here incorporated by reference.

166

Table of Contents

10(xx)*	Employment Agreement between Dennis L. Klaeser, Chemical Financial Corporation and Chemical Bank, dated July 1, 2018. Previously filed as Exhibit 10.2 to the registrant's Current Report on Form 8-K filed with the SEC on July 3, 2018. Here incorporated by reference.
10(yy)*	Letter Agreement dated December 13, 2019 between Dennis L. Klaeser and TCF Financial Corporation. Previously filed as Exhibit 10.1 to the registrant’s Current Report on Form 8-K filed with the SEC on December 16, 2019. Here incorporated by reference.
10(zz)*	Consulting Agreement between Dennis L. Klaeser and TCF Financial Corporation, dated August 5, 2020. Previously filed as Exhibit 10(j) of the registrant's Quarterly Report on Form 10-Q filed with the SEC on August 7, 2020. Here incorporated by reference.
10(aaa)*	Amended and Restated Executive Employment Agreement dated December 13, 2020, by and among TCF Financial Corporation, TCF National Bank, and Brian Maass. Previously filed as Exhibit 10.4 to the registrant’s Current Report on Form 8-K filed with the SEC on December 17, 2020. Here incorporated by reference.
10(bbb)*	Lease, dated May 31, 2019, by and between GPC Adams LLC and Chemical Bank. Previously filed as Exhibit 10.1 to the registrant’s Current Report on Form 8-K filed with the SEC on June 6, 2019. Here incorporated by reference.
10(ccc)*#	Summary of Non-Employee Director Compensation
21#	Subsidiaries
23#	Consent of KPMG
31.1#	Certification of the Chief Executive Officer Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002
31.2#	Certification of the Chief Financial Officer Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002
32.1#	Certification of the Chief Executive Officer Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002
32.2#	Certification of the Chief Financial Officer Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002
101.INS	XBRL Instance Document - the instance document does not appear in the Interactive Data File because its XBRL tags are embedded within the Inline XBRL document.
101.SCH#	Inline XBRL Taxonomy Extension Schema Document
101.CAL#	Inline XBRL Taxonomy Extension Calculation Linkbase Document
101.DEF#	Inline XBRL Taxonomy Extension Definitions Linkbase Document
101.LAB#	Inline XBRL Taxonomy Extension Label Linkbase Document
101.PRE#	Inline XBRL Taxonomy Extension Presentation Linkbase Document
104	Cover Page Interactive Data File (formatted as Inline XBRL and embedded within Exhibit 101).

*These agreements are management contracts or compensation plans or arrangements required to be filed as Exhibits to this Form 10-K.

# Filed herein

167

Table of Contents

SIGNATURES

Pursuant to the requirements of Section 13 or Section 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

TCF FINANCIAL CORPORATION

/s/ David T. Provost

David T. Provost,

Chief Executive Officer

(Principal Executive Officer)

Dated: February 26, 2021

168

Table of Contents

Pursuant to the requirements of the Securities Exchange Act of 1934, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

Name	Title	Date
/s/ David T. Provost		February 26, 2021
David T. Provost	Chief Executive Officer (Principal Executive Officer)
/s/ Brian W. Maass		February 26, 2021
Brian W. Maass	Executive Vice President and Chief Financial Officer (Principal Financial Officer)
/s/ Kathleen S. Wendt		February 26, 2021
Kathleen S. Wendt	Executive Vice President and Chief Accounting Officer (Principal Accounting Officer)
/s/ Gary Torgow		February 26, 2021
Gary Torgow	Executive Chairman
/s/ Thomas C. Shafer		February 26, 2021
Thomas C. Shafer	Executive Vice Chairman
/s/ Peter Bell		February 26, 2021
Peter Bell	Director
/s/ Karen L. Grandstrand		February 26, 2021
Karen L. Grandstrand	Director
/s/ Richard H. King		February 26, 2021
Richard H. King	Director
/s/ Ronald A. Klein		February 26, 2021
Ronald A. Klein	Director
/s/ Barbara J. Mahone		February 26, 2021
Barbara J. Mahone	Director
/s/ Barbara L. McQuade		February 26, 2021
Barbara L. McQuade	Director
/s/ Vance K. Opperman		February 26, 2021
Vance K. Opperman	Lead Director
/s/ Roger J. Sit		February 26, 2021
Roger J. Sit	Director
/s/ Julie H. Sullivan		February 26, 2021
Julie H. Sullivan	Director
/s/ Jeffrey L. Tate		February 26, 2021
Jeffrey L. Tate	Director
/s/ Arthur A. Weiss		February 26, 2021
Arthur A. Weiss	Director
/s/ Franklin C. Wheatlake		February 26, 2021
Franklin C. Wheatlake	Director
/s/ Theresa M. H. Wise		February 26, 2021
Theresa M. H. Wise	Director

169