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Allowance for Credit Losses
12 Months Ended
Dec. 31, 2022
Credit Loss [Abstract]  
Allowance for Credit Losses Allowance for credit losses
The Firm’s allowance for credit losses represents management's estimate of expected credit losses over the remaining expected life of the Firm's financial assets measured at amortized cost and certain off-balance sheet lending-related commitments. The allowance for credit losses comprises:
the allowance for loan losses, which covers the Firm’s retained loan portfolios (scored and risk-rated) and is presented separately on the Consolidated balance sheets,
the allowance for lending-related commitments, which is presented on the Consolidated balance sheets in accounts payable and other liabilities, and
the allowance for credit losses on investment securities, which is reflected in investment securities on the Consolidated balance sheets.
The income statement effect of all changes in the allowance for credit losses is recognized in the provision for credit losses.
Determining the appropriateness of the allowance for credit losses is complex and requires significant judgment by management about the effect of matters that are inherently uncertain. At least quarterly, the allowance for credit losses is reviewed by the CRO, the CFO and the Controller of the Firm. Subsequent evaluations of credit exposures, considering the macroeconomic conditions, forecasts and other factors then prevailing, may result in significant changes in the allowance for credit losses in future periods.
The Firm’s policies used to determine its allowance for loan losses and its allowance for lending-related commitments are described in the following paragraphs. Refer to Note 10 for a description of the policies used to determine the allowance for credit losses on investment securities.
Methodology for allowances for loan losses and lending-related commitments
The allowance for loan losses and allowance for lending-related commitments represents expected credit losses over the remaining expected life of retained loans and lending-related commitments that are not unconditionally cancellable. The Firm does not record an allowance for future draws on unconditionally cancellable lending-related commitments (e.g., credit cards). Expected losses related to accrued interest on credit card loans are considered in the Firm’s allowance for loan losses. However, the Firm does not record an allowance on other accrued interest receivables, due to its policy to write these receivables off no later than 90 days past due by reversing interest income.
The expected life of each instrument is determined by considering its contractual term, expected prepayments, cancellation features, and certain extension and call options. The expected life of funded credit card loans is generally estimated by considering expected future payments on the credit card account, and determining how much of those amounts should be allocated to repayments of the funded loan balance (as of the balance sheet date)
versus other account activity. This allocation is made using an approach that incorporates the payment application requirements of the Credit Card Accountability Responsibility and Disclosure Act of 2009, generally paying down the highest interest rate balances first.
The estimate of expected credit losses includes expected recoveries of amounts previously charged off or expected to be charged off, even if such recoveries result in a negative allowance.
Collective and Individual Assessments
When calculating the allowance for loan losses and the allowance for lending-related commitments, the Firm assesses whether exposures share similar risk characteristics. If similar risk characteristics exist, the Firm estimates expected credit losses collectively, considering the risk associated with a particular pool and the probability that the exposures within the pool will deteriorate or default. The assessment of risk characteristics is subject to significant management judgment. Emphasizing one characteristic over another or considering additional characteristics could affect the allowance.
Relevant risk characteristics for the consumer portfolio include product type, delinquency status, current FICO scores, geographic distribution, and, for collateralized loans, current LTV ratios.
Relevant risk characteristics for the wholesale portfolio include risk rating, delinquency status, tenor, level and type of collateral, LOB, geography, industry, credit enhancement, product type, facility purpose, and payment terms.
The majority of the Firm’s credit exposures share risk characteristics with other similar exposures, and as a result are collectively assessed for impairment (“portfolio-based component”). The portfolio-based component covers consumer loans, performing risk-rated loans and certain lending-related commitments.
If an exposure does not share risk characteristics with other exposures, the Firm generally estimates expected credit losses on an individual basis, considering expected repayment and conditions impacting that individual exposure (“asset-specific component”). The asset-specific component covers modified PCD loans, loans modified or reasonably expected to be modified in a TDR, collateral-dependent loans, as well as, risk-rated loans that have been placed on nonaccrual status.
Portfolio-based component
The portfolio-based component begins with a quantitative calculation that considers the likelihood of the borrower changing delinquency status or moving from one risk rating to another. The quantitative calculation covers expected credit losses over an instrument’s expected life and is estimated by applying credit loss factors to the Firm’s estimated exposure at default. The credit loss factors incorporate the probability of borrower default as well as loss severity in the event of default. They are derived using
a weighted average of five internally developed macroeconomic scenarios over an eight-quarter forecast period, followed by a single year straight-line interpolation to revert to long run historical information for periods beyond the eight-quarter forecast period. The five macroeconomic scenarios consist of a central, relative adverse, extreme adverse, relative upside and extreme upside scenario, and are updated by the Firm’s central forecasting team. The scenarios take into consideration the Firm’s macroeconomic outlook, internal perspectives from subject matter experts across the Firm, and market consensus and involve a governed process that incorporates feedback from senior management across LOBs, Corporate Finance and Risk Management.
The quantitative calculation is adjusted to take into consideration model imprecision, emerging risk assessments, trends and other subjective factors that are not yet reflected in the calculation. These adjustments are accomplished in part by analyzing the historical loss experience, including during stressed periods, for each major product or model. Management applies judgment in making this adjustment, including taking into account uncertainties associated with the economic and political conditions, quality of underwriting standards, borrower behavior, credit concentrations or deterioration within an industry, product or portfolio, as well as other relevant internal and external factors affecting the credit quality of the portfolio. In certain instances, the interrelationships between these factors create further uncertainties.
The application of different inputs into the quantitative calculation, and the assumptions used by management to adjust the quantitative calculation, are subject to significant management judgment, and emphasizing one input or assumption over another, or considering other inputs or assumptions, could affect the estimate of the allowance for loan losses and the allowance for lending-related commitments.
Asset-specific component
To determine the asset-specific component of the allowance, collateral-dependent loans (including those loans for which foreclosure is probable) and larger, nonaccrual risk-rated loans in the wholesale portfolio segment are generally evaluated individually, while smaller loans (both scored and risk-rated) are aggregated for evaluation using factors relevant for the respective class of assets.
The Firm generally measures the asset-specific allowance as the difference between the amortized cost of the loan and the present value of the cash flows expected to be collected, discounted at the loan’s original effective interest rate. Subsequent changes in impairment are generally recognized as an adjustment to the allowance for loan losses. For collateral-dependent loans, the fair value of collateral less estimated costs to sell is used to determine the charge-off amount for declines in value (to reduce the amortized cost of the loan to the fair value of collateral) or the amount of negative allowance that should be
recognized (for recoveries of prior charge-offs associated with improvements in the fair value of collateral).
The asset-specific component of the allowance for loans that have been or are expected to be modified in TDRs incorporates the effect of the modification on the loan’s expected cash flows (including forgone interest, principal forgiveness, as well as other concessions), and also the potential for redefault. For residential real estate loans modified in or expected to be modified in TDRs, the Firm develops product-specific probability of default estimates, which are applied at a loan level to compute expected losses. In developing these probabilities of default, the Firm considers the relationship between the credit quality characteristics of the underlying loans and certain assumptions about housing prices and unemployment, based upon industry-wide data. The Firm also considers its own historical loss experience to-date based on actual redefaulted modified loans. For credit card loans modified in or expected to be modified in TDRs, expected losses incorporate projected delinquencies and charge-offs based on the Firm’s historical experience by type of modification program. For wholesale loans modified or expected to be modified in TDRs, expected losses incorporate management’s expectation of the borrower’s ability to repay under the modified terms.
Estimating the timing and amounts of future cash flows is highly judgmental as these cash flow projections rely upon estimates such as loss severities, asset valuations, default rates (including redefault rates on modified loans), the amounts and timing of interest or principal payments (including any expected prepayments) or other factors that are reflective of current and expected market conditions. These estimates are, in turn, dependent on factors such as the duration of current overall economic conditions, industry, portfolio, or borrower-specific factors, the expected outcome of insolvency proceedings as well as, in certain circumstances, other economic factors. All of these estimates and assumptions require significant management judgment and certain assumptions are highly subjective.
Allowance for credit losses and related information
The table below summarizes information about the allowances for credit losses, and includes a breakdown of loans and lending-related commitments by impairment methodology. Refer to Note 10 for further information on the allowance for credit losses on investment securities.
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2022
Year ended December 31,
(in millions)
Consumer,
excluding
credit card
Credit cardWholesaleTotal
Allowance for loan losses
Beginning balance at January 1,$1,765 $10,250 $4,371 $16,386 
Cumulative effect of a change in accounting principle(a)
NANANANA
Gross charge-offs812 

3,192 322 4,326 
Gross recoveries collected(543)(789)(141)(1,473)
Net charge-offs269 

2,403 181 2,853 
Provision for loan losses543 3,353 2,293 6,189 
Other
1 

 3 4 
Ending balance at December 31,$2,040 $11,200 $6,486 $19,726 
Allowance for lending-related commitments
Beginning balance at January 1,
$113 $ $2,148 $2,261 
Cumulative effect of a change in accounting principle(a)
NANANANA
Provision for lending-related commitments
(37) 157 120 
Other
  1 1 
Ending balance at December 31,$76 $ $2,306 $2,382 
Total allowance for investment securitiesNANANA$96 
Total allowance for credit losses(b)
$2,116 $11,200 $8,792 $22,204 
Allowance for loan losses by impairment methodology
Asset-specific(c)
$(624)$223 $467 $66 
Portfolio-based2,664 10,977 6,019 19,660 
Total allowance for loan losses$2,040 $11,200 $6,486 $19,726 
Loans by impairment methodology
Asset-specific(c)
$11,978 $796 $2,189 $14,963 
Portfolio-based288,775 184,379 601,481 1,074,635 
Total retained loans$300,753 $185,175 $603,670 $1,089,598 
Collateral-dependent loans
Net charge-offs$(33)

$ $16 $(17)
Loans measured at fair value of collateral less cost to sell
3,585  464 4,049 
Allowance for lending-related commitments by impairment methodology
Asset-specific
$ $ $90 $90 
Portfolio-based76  2,216 2,292 
Total allowance for lending-related commitments(d)
$76 $ $2,306 $2,382 
Lending-related commitments by impairment methodology
Asset-specific
$ $ $455 $455 
Portfolio-based(e)
20,423  461,688 482,111 
Total lending-related commitments
$20,423 $ $462,143 $482,566 
(a)Represents the impact to allowance for credit losses upon the adoption of CECL on January 1, 2020. Refer to Note 1 for further information.
(b)At December 31, 2022 excludes an allowance for credit losses associated with certain accounts receivable in CIB of $21 million.
(c)Includes collateral dependent loans, including those considered TDRs and those for which foreclosure is deemed probable, modified PCD loans and non-collateral dependent loans that have been modified or are reasonably expected to be modified in a TDR. Also includes risk-rated loans that have been placed on nonaccrual status for the wholesale portfolio segment. The asset-specific credit card allowance for loans modified, or reasonably expected to be modified, in a TDR is calculated based on the loans’ original contractual interest rates and does not consider any incremental penalty rates.
(d)The allowance for lending-related commitments is reported in accounts payable and other liabilities on the Consolidated balance sheets.
(e)At December 31, 2022, 2021 and 2020, lending-related commitments excluded $13.1 billion, $15.7 billion and $19.5 billion, respectively, for the consumer, excluding credit card portfolio segment; $821.3 billion, $730.5 billion and $658.5 billion, respectively, for the credit card portfolio segment; and $9.8 billion, $32.1 billion and $25.3 billion, respectively, for the wholesale portfolio segment, which were not subject to the allowance for lending-
related commitments. Prior-period amount for wholesale lending-related commitments, including the amount not subject to allowance, has been revised to conform with the current presentation.
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20212020
Consumer,
excluding
credit card
Credit cardWholesaleTotalConsumer,
excluding
credit card
Credit cardWholesaleTotal
$3,636 $17,800 $6,892 $28,328 $2,538 $5,683 $4,902 $13,123 
NANANANA297 5,517 (1,642)4,172 
630 3,651 283 4,564 805 5,077 954 6,836 
(619)(939)(141)(1,699)(631)(791)(155)(1,577)
11 2,712 142 2,865 174 4,286 799 5,259 
(1,858)(4,838)(2,375)(9,071)974 10,886 4,431 16,291 
(2)— (4)(6)— — 
$1,765 $10,250 $4,371 $16,386 $3,636 $17,800 $6,892 $28,328 
$187 $— $2,222 $2,409 $12 $— $1,179 $1,191 
NANANANA133 — (35)98 
(75)— (74)(149)42 — 1,079 1,121 
— — — — (1)(1)
$113 $— $2,148 $2,261 $187 $— $2,222 $2,409 
NANANA$42 NANANA$78 
$1,878 $10,250 $6,519 $18,689 $3,823 $17,800 $9,114 $30,815 
$(665)$313 $263 $(89)$(7)$633 $682 $1,308 
2,430 9,937 4,108 16,475 3,643 17,167 6,210 27,020 
$1,765 $10,250 $4,371 $16,386 $3,636 $17,800 $6,892 $28,328 
$13,919 $987 $2,255 $17,161 $16,648 $1,375 $3,606 $21,629 
281,637 153,309 558,099 993,045 285,479 142,057 511,341 938,877 
$295,556 $154,296 $560,354 $1,010,206 $302,127 $143,432 $514,947 $960,506 
$33 $— $38 $71 $133 $— $76 $209 
4,472 — 617 5,089 4,956 — 188 5,144 
$— $— $167 $167 $— $— $114 $114 
113 — 1,981 2,094 187 — 2,108 2,295 
$113 $— $2,148 $2,261 $187 $— $2,222 $2,409 
$— $— $764 $764 $— $— $577 $577 
29,588 — 453,571 

483,159 37,783 — 423,993 461,776 
$29,588 $— $454,335 $483,923 $37,783 $— $424,570 $462,353 
Discussion of changes in the allowance
The allowance for credit losses as of December 31, 2022 was $22.2 billion, reflecting a net addition of $3.5 billion from December 31, 2021, consisting of:
$2.3 billion in wholesale, driven by deterioration in the Firm’s macroeconomic outlook and loan growth, predominantly in CB and CIB, and
$1.2 billion in consumer, predominantly driven by Card Services, reflecting higher outstanding balances and deterioration in the Firm’s macroeconomic outlook, partially offset by a reduction in the allowance related to a decrease in uncertainty associated with borrower behavior as the effects of the pandemic gradually recede.
Deterioration in the Firm’s macroeconomic outlook included both updates to the central scenario in the fourth quarter of 2022, which now reflects a mild recession, as well as the impact of the increased weight placed on the adverse scenarios beginning in the first quarter of 2022 due to the effects associated with higher inflation, changes in monetary policy, and geopolitical risks, including the war in Ukraine.
The Firm's allowance for credit losses is estimated using a weighted average of five internally developed macroeconomic scenarios. The adverse scenarios incorporate more punitive macroeconomic factors than the central case assumptions provided in the table below, resulting in a weighted average U.S. unemployment rate peaking at 5.6% in the second quarter of 2024, and a 1.2% lower U.S. real GDP exiting the second quarter of 2024.
The Firm’s central case assumptions reflected U.S. unemployment rates and U.S. real GDP as follows:
Assumptions at December 31, 2022
2Q234Q232Q24
U.S. unemployment rate(a)
3.8 %4.3 %5.0 %
YoY growth in U.S. real GDP(b)
1.5 %0.4 % %
Assumptions at December 31, 2021
2Q224Q222Q23
U.S. unemployment rate(a)
4.2 %4.0 %3.9 %
YoY growth in U.S. real GDP(b)
3.1 %2.8 %2.1 %
(a)Reflects quarterly average of forecasted U.S. unemployment rate.
(b)The year over year growth in U.S. real GDP in the forecast horizon of the central scenario is calculated as the percentage change in U.S. real GDP levels from the prior year.
Subsequent changes to this forecast and related estimates
will be reflected in the provision for credit losses in future
periods.
Refer to Critical Accounting Estimates Used by the Firm on pages 149-152 for further information on the allowance for credit losses and related management judgments.
Refer to Consumer Credit Portfolio on pages 110-115, Wholesale Credit Portfolio on pages 116-126 for additional information on the consumer and wholesale credit portfolios.