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Loans And Allowance For Credit Losses
3 Months Ended
Mar. 31, 2022
Receivables [Abstract]  
Financing Receivables Loans and Allowance for Credit Losses
Major classifications within the Company’s held for investment loan portfolio at March 31, 2022 and December 31, 2021 are as follows:

(In thousands)
March 31, 2022December 31, 2021
Commercial:
Business$5,508,508 $5,303,535 
Real estate – construction and land1,144,411 1,118,266 
Real estate – business3,109,668 3,058,837 
Personal Banking:
Real estate – personal2,820,076 2,805,401 
Consumer2,053,160 2,032,225 
Revolving home equity264,401 275,945 
Consumer credit card544,579 575,410 
Overdrafts14,211 6,740 
Total loans$15,459,014 $15,176,359 

Accrued interest receivable totaled $32.1 million and $25.9 million at March 31, 2022 and December 31, 2021, respectively, and was included within other assets on the consolidated balance sheets. For the three months ended March 31, 2022, the Company wrote-off accrued interest by reversing interest income of $29 thousand and $899 thousand in the Commercial and Personal Banking portfolios, respectively. Similarly, for the three months ended March 31, 2021, the Company wrote-off accrued interest of $125 thousand and $2.0 million in the Commercial and Personal Banking portfolios, respectively.

At March 31, 2022, loans of $3.2 billion were pledged at the Federal Home Loan Bank as collateral for borrowings and letters of credit obtained to secure public deposits. Additional loans of $1.3 billion were pledged at the Federal Reserve Bank as collateral for discount window borrowings.
Allowance for credit losses
The allowance for credit losses is measured using an average historical loss model which incorporates relevant information about past events (including historical credit loss experience on loans with similar risk characteristics), current conditions, and reasonable and supportable forecasts that affect the collectability of the remaining cash flows over the contractual term of the loans. The allowance for credit losses is measured on a collective (pool) basis. Loans are aggregated into pools based on similar risk characteristics including borrower type, collateral type and expected credit loss patterns. Loans that do not share similar risk characteristics, primarily large loans on non-accrual status, are evaluated on an individual basis.

For loans evaluated for credit losses on a collective basis, average historical loss rates are calculated for each pool using the Company’s historical net charge-offs (combined charge-offs and recoveries by observable historical reporting period) and outstanding loan balances during a lookback period. Lookback periods can be different based on the individual pool and represent management’s credit expectations for the pool of loans over the remaining contractual life. In certain loan pools, if the Company’s own historical loss rate is not reflective of the loss expectations, the historical loss rate is augmented by industry and peer data. The calculated average net charge-off rate is then adjusted for current conditions and reasonable and supportable forecasts. These adjustments increase or decrease the average historical loss rate to reflect expectations of future losses given a single path economic forecast of key macroeconomic variables including GDP, disposable income, various interest rates, unemployment rate, consumer price index (CPI) inflation rate, housing price index (HPI), commercial real estate price index (CREPI) and market volatility. The adjustments are based on results from various regression models projecting the impact of the macroeconomic variables to loss rates. The forecast is used for a reasonable and supportable period before reverting back to historical averages using a straight-line method. The forecast adjusted loss rate is applied to the amortized cost of loans over the remaining contractual lives, adjusted for expected prepayments. The contractual term excludes expected extensions (except for contractual extensions at the option of the customer), renewals and modifications unless there is a reasonable expectation that a troubled debt restructuring will be executed. Credit cards and certain similar consumer lines of credit do not have stated maturities and therefore, for these loan classes, remaining contractual lives are determined by estimating future cash flows expected to be received from customers until payments have been fully allocated to outstanding balances. Additionally, the allowance for credit losses considers other qualitative factors not included in historical loss rates or macroeconomic forecast such as changes in portfolio composition, underwriting practices, or significant unique events or conditions.
Key model assumptions in the Company’s allowance for credit loss model include the economic forecast, the reasonable and supportable period, forecasted macro-economic variables, prepayment assumptions and qualitative factors applied for portfolio composition changes, underwriting practices, or significant unique events or conditions. The assumptions utilized in estimating the Company’s allowance for credit losses at March 31, 2022 and December 31, 2021 are discussed below.

Key AssumptionMarch 31, 2022December 31, 2021
Overall economic forecast
Improving health situation supports positive economic momentum in the short term
Projects significant monetary policy tightening to rein in inflation
Projects continued high inflation
Uncertainties related to supply chain issues
Continued recovery from the Global Coronavirus Recession (GCR)
Assumes improving health conditions
Assumes gradual easing of supply constraints
Continued uncertainty regarding the health crisis
Uncertainty regarding rising inflation
Reasonable and supportable period and related reversion period
One year for commercial and personal banking loans
Reversion to historical average loss rates within two quarters using straight-line method
One year for commercial and personal banking loans
Reversion to historical average loss rates within two quarters using straight-line method
Forecasted macro-economic variables
Unemployment rate ranging from 3.6% to 3.4% during the supportable forecast period
Real GDP growth ranging from 2.6% to 3.7%
Prime rate from 4.0% to 5.2%
Unemployment rate ranging from 4.1% to 3.7% during the supportable forecast period
Real GDP growth ranges from 5.0% to 3.4%
Prime rate of 3.25% through the second quarter of 2022, increasing to 3.5% by the end of 2022
Prepayment assumptions
Commercial loans
5% for most loan pools
Personal banking loans
Ranging from 28.3% to 16.5% for most loan pools
66.0% for consumer credit cards
Commercial loans
5% for most loan pools
Personal banking loans
Ranging from 28.0% to 16.5% for most loan pools
64.1% for consumer credit cards
Qualitative factors
Added qualitative factors related to:
Certain portfolios sensitive to pandemic economic uncertainties
Changes in the composition of the loan portfolios
Uncertainty related to unusually high rate of inflation, geopolitical environment, and supply chain issues
Loans downgraded to special mention, substandard, or non-accrual status
Added net reserves using qualitative processes related to:
Loans originated in our expansion markets, loans that are designated as shared national credits, and certain portfolios sensitive to pandemic economic uncertainties
Changes in the composition of the loan portfolios
Loans downgraded to special mention, substandard, or non-accrual status

The liability for unfunded lending commitments utilizes the same model as the allowance for credit losses on loans, however, the liability for unfunded lending commitments incorporates an assumption for the portion of unfunded commitments that are expected to be funded.

Sensitivity in the Allowance for Credit Loss model
The allowance for credit losses is an estimate that requires significant judgment including projections of the macro-economic environment. The forecasted macro-economic environment continuously changes which can cause fluctuations in estimated expected losses.

The current forecast projects a continued recovery of the COVID-19 related health situation, which is expected to create positive economic momentum. However, the higher inflation and Russia's invasion of Ukraine has created greater uncertainty in the forecast. The geopolitical environment, trends in health conditions, and ongoing supply constraints could significantly modify economic projections used in the estimation of the allowance for credit losses.
A summary of the activity in the allowance for credit losses on loans and the liability for unfunded lending commitments during the three months ended March 31, 2022 and 2021, respectively, follows:

For the Three Months Ended March 31, 2022
(In thousands)CommercialPersonal Banking

Total
ALLOWANCE FOR CREDIT LOSSES ON LOANS
Balance at beginning of period$97,776 $52,268 $150,044 
Provision for credit losses on loans(2,879)(7,807)(10,686)
Deductions:
   Loans charged off177 7,285 7,462 
   Less recoveries on loans107 2,707 2,814 
Net loan charge-offs (recoveries)70 4,578 4,648 
Balance March 31, 2022$94,827 $39,883 $134,710 
LIABILITY FOR UNFUNDED LENDING COMMITMENTS
Balance at beginning of period$23,271 $933 $24,204 
Provision for credit losses on unfunded lending commitments509 319 828 
Balance March 31, 2022$23,780 $1,252 $25,032 
ALLOWANCE FOR CREDIT LOSSES ON LOANS AND LIABILITY FOR UNFUNDED LENDING COMMITMENTS$118,607 $41,135 $159,742 

For the Three Months Ended March 31, 2021
(In thousands)CommercialPersonal Banking

Total
ALLOWANCE FOR CREDIT LOSSES ON LOANS
Balance at beginning of period$121,549 $99,285 $220,834 
Provision for credit losses on loans(1,909)(8,446)(10,355)
Deductions:
   Loans charged off232 12,709 12,941 
   Less recoveries on loans215 2,774 2,989 
Net loan charge-offs17 9,935 9,952 
Balance March 31, 2021$119,623 $80,904 $200,527 
LIABILITY FOR UNFUNDED LENDING COMMITMENTS
Balance at beginning of period$37,259 $1,048 $38,307 
Provision for credit losses on unfunded lending commitments4,254 (131)4,123 
Balance March 31, 2021$41,513 $917 $42,430 
ALLOWANCE FOR CREDIT LOSSES ON LOANS AND LIABILITY FOR UNFUNDED LENDING COMMITMENTS$161,136 $81,821 $242,957 
Delinquent and non-accrual loans
The Company considers loans past due on the day following the contractual repayment date, if the contractual repayment was not received by the Company as of the end of the business day. The following table provides aging information on the Company’s past due and accruing loans, in addition to the balances of loans on non-accrual status, at March 31, 2022 and December 31, 2021.




(In thousands)
Current or Less Than 30 Days Past Due

30 – 89
Days Past Due
90 Days Past Due and Still AccruingNon-accrual



Total
March 31, 2022
Commercial:
Business$5,494,664 $6,747 $341 $6,756 $5,508,508 
Real estate – construction and land1,144,411    1,144,411 
Real estate – business3,105,452 4,026  190 3,109,668 
Personal Banking:
Real estate – personal 2,811,330 5,076 2,281 1,389 2,820,076 
Consumer2,031,680 18,890 2,590  2,053,160 
Revolving home equity262,799 748 854  264,401 
Consumer credit card535,482 4,493 4,604  544,579 
Overdrafts13,891 320   14,211 
Total $15,399,709 $40,300 $10,670 $8,335 $15,459,014 
December 31, 2021
Commercial:
Business$5,292,125 $3,621 $477 $7,312 $5,303,535 
Real estate – construction and land1,117,434 832 — — 1,118,266 
Real estate – business3,058,566 57 — 214 3,058,837 
Personal Banking:
Real estate – personal 2,796,662 4,125 2,983 1,631 2,805,401 
Consumer2,005,556 24,458 2,211 — 2,032,225 
Revolving home equity274,372 772 801 — 275,945 
Consumer credit card565,335 4,821 5,254 — 575,410 
Overdrafts6,425 315 — — 6,740 
Total $15,116,475 $39,001 $11,726 $9,157 $15,176,359 

At March 31, 2022, the Company had $4.9 million in non-accrual business loans that had no allowance for credit loss. At December 31, 2021, the Company had $5.3 million in non-accrual business loans that had no allowance for credit loss. The Company did not record any interest income on non-accrual loans during the three months ended March 31, 2022 and 2021, respectively.

Credit quality indicators
The following table provides information about the credit quality of the Commercial loan portfolio. The Company utilizes an internal risk rating system comprised of a series of grades to categorize loans according to perceived risk associated with the expectation of debt repayment based on borrower specific information including, but not limited to, current financial information, historical payment experience, industry information, collateral levels and collateral types. The “pass” category consists of a range of loan grades that reflect increasing, though still acceptable, risk. A loan is assigned the risk rating at origination and then monitored throughout the contractual term for possible risk rating changes. Movement of risk through the various grade levels in the “pass” category is monitored for early identification of credit deterioration. The “special mention” rating is applied to loans where the borrower exhibits negative financial trends due to borrower specific or systemic conditions that, if left uncorrected, threaten its capacity to meet its debt obligations. The borrower is believed to have sufficient financial flexibility to react to and resolve its negative financial situation. It is a transitional grade that is closely monitored for improvement or deterioration. The “substandard” rating is applied to loans where the borrower exhibits well-defined weaknesses that jeopardize its continued performance and are of a severity that the distinct possibility of default exists. Loans are placed on “non-accrual” when management does not expect to collect payments consistent with acceptable and agreed upon terms of repayment.

All loans are analyzed for risk rating updates annually. For larger loans, rating assessments may be more frequent if relevant information is obtained earlier through debt covenant monitoring or overall relationship management. Smaller loans
are monitored as identified by the loan officer based on the risk profile of the individual borrower or if the loan becomes past due related to credit issues. Loans rated Special Mention, Substandard or Non-accrual are subject to quarterly review and monitoring processes. In addition to the regular monitoring performed by the lending personnel and credit committees, loans are subject to review by a credit review department which verifies the appropriateness of the risk ratings for the loans chosen as part of its risk-based review plan.

The risk category of loans in the Commercial portfolio as of March 31, 2022 and December 31, 2021 are as follows:

Term Loans Amortized Cost Basis by Origination Year
(In thousands)20222021202020192018PriorRevolving Loans Amortized Cost BasisTotal
March 31, 2022
Business
    Risk Rating:
       Pass$305,308 $1,246,520 $644,426 $533,462 $219,320 $368,615 $2,106,483 $5,424,134 
       Special mention2,622 976 83 1,315 11,452 8,138 2,806 27,392 
       Substandard2,437 1,230 1,110 7,172 4,530 10,503 23,244 50,226 
       Non-accrual302 86 — — 1,462 4,906 — 6,756 
   Total Business:$310,669 $1,248,812 $645,619 $541,949 $236,764 $392,162 $2,132,533 $5,508,508 
Real estate-construction
    Risk Rating:
       Pass$155,429 $591,643 $249,882 $53,869 $1,236 $2,800 $13,968 $1,068,827 
       Special mention— 19,474 — — 976 — — 20,450 
       Substandard— 15,486 11,600 — 14,891 13,157 — 55,134 
    Total Real estate-construction:$155,429 $626,603 $261,482 $53,869 $17,103 $15,957 $13,968 $1,144,411 
Real estate-business
    Risk Rating:
       Pass$232,411 $726,266 $687,933 $514,629 $206,324 $378,239 $83,578 $2,829,380 
       Special mention— 3,537 30,657 8,995 34,319 2,345 — 79,853 
       Substandard589 15,589 62,170 12,993 4,867 103,044 993 200,245 
       Non-accrual— — — — 173 17 — 190 
   Total Real estate-business:$233,000 $745,392 $780,760 $536,617 $245,683 $483,645 $84,571 $3,109,668 
Commercial loans
    Risk Rating:
       Pass$693,148 $2,564,429 $1,582,241 $1,101,960 $426,880 $749,654 $2,204,029 $9,322,341 
       Special mention2,622 23,987 30,740 10,310 46,747 10,483 2,806 127,695 
       Substandard3,026 32,305 74,880 20,165 24,288 126,704 24,237 305,605 
       Non-accrual302 86 — — 1,635 4,923 — 6,946 
   Total Commercial loans:$699,098 $2,620,807 $1,687,861 $1,132,435 $499,550 $891,764 $2,231,072 $9,762,587 
Term Loans Amortized Cost Basis by Origination Year
(In thousands)20212020201920182017PriorRevolving Loans Amortized Cost BasisTotal
December 31, 2021
Business
    Risk Rating:
       Pass$1,473,869 $704,157 $554,759 $248,739 $159,238 $270,454 $1,795,073 $5,206,289 
       Special mention1,785 126 17,576 12,050 1,490 3,232 16,545 52,804 
       Substandard836 1,191 8,855 4,936 10,775 10,536 37,130 
       Non-accrual430 — 1,549 — 5,332 — 7,312 
   Total Business:$1,476,920 $705,474 $581,191 $267,274 $160,729 $289,793 $1,822,154 $5,303,535 
Real estate-construction
    Risk Rating:
       Pass$598,734 $346,507 $66,985 $2,110 $2,655 $2,252 $13,230 $1,032,473 
       Special mention44,649 — — 985 — — — 45,634 
       Substandard485 11,620 — 14,896 13,158 — — 40,159 
    Total Real estate-construction:$643,868 $358,127 $66,985 $17,991 $15,813 $2,252 $13,230 $1,118,266 
Real estate- business
    Risk Rating:
       Pass$775,561 $712,173 $551,697 $230,138 $170,888 $254,489 $76,641 $2,771,587 
       Special mention4,011 30,322 10,500 37,576 2,068 2,103 86,581 
       Substandard17,079 62,939 12,930 2,326 58,934 45,265 982 200,455 
       Non-accrual— — — 189 — 25 — 214 
   Total Real-estate business:$796,651 $805,434 $575,127 $270,229 $231,890 $301,882 $77,624 $3,058,837 
Commercial loans
    Risk Rating:
       Pass$2,848,164 $1,762,837 $1,173,441 $480,987 $332,781 $527,195 $1,884,944 $9,010,349 
       Special mention50,445 30,448 28,076 50,611 3,558 5,335 16,546 185,019 
       Substandard18,400 75,750 21,785 22,158 72,093 56,040 11,518 277,744 
       Non-accrual430 — 1,738 — 5,357 — 7,526 
   Total Commercial loans:$2,917,439 $1,869,035 $1,223,303 $555,494 $408,432 $593,927 $1,913,008 $9,480,638 
The credit quality of Personal Banking loans is monitored primarily on the basis of aging/delinquency, and this information is provided as of March 31, 2022 and December 31, 2021 below:

Term Loans Amortized Cost Basis by Origination Year
(In thousands)20222021202020192018PriorRevolving Loans Amortized Cost BasisTotal
March 31, 2022
Real estate-personal
       Current to 90 days past due$144,994 $668,179 $853,063 $328,209 $150,144 $661,855 $9,962 $2,816,406 
       Over 90 days past due— 192 962 126 114 887 — 2,281 
       Non-accrual— — — 182 107 1,100 — 1,389 
   Total Real estate-personal:$144,994 $668,371 $854,025 $328,517 $150,365 $663,842 $9,962 $2,820,076 
Consumer
       Current to 90 days past due$208,522 $504,841 $310,052 $165,881 $66,175 $102,869 $692,230 $2,050,570 
       Over 90 days past due— 283 157 243 200 444 1,263 2,590 
    Total Consumer:$208,522 $505,124 $310,209 $166,124 $66,375 $103,313 $693,493 $2,053,160 
Revolving home equity
       Current to 90 days past due$— $— $— $— $— $— $263,547 $263,547 
       Over 90 days past due— — — — — — 854 854 
   Total Revolving home equity:$— $— $— $— $— $— $264,401 $264,401 
Consumer credit card
       Current to 90 days past due$— $— $— $— $— $— $539,975 $539,975 
       Over 90 days past due— — — — — — 4,604 4,604 
   Total Consumer credit card:$— $— $— $— $— $— $544,579 $544,579 
Overdrafts
       Current to 90 days past due$14,211 $— $— $— $— $— $— $14,211 
    Total Overdrafts:$14,211 $— $— $— $— $— $— $14,211 
Personal banking loans
       Current to 90 days past due$367,727 $1,173,020 $1,163,115 $494,090 $216,319 $764,724 $1,505,714 $5,684,709 
       Over 90 days past due— 475 1,119 369 314 1,331 6,721 10,329 
       Non-accrual— — — 182 107 1,100 — 1,389 
   Total Personal banking loans:$367,727 $1,173,495 $1,164,234 $494,641 $216,740 $767,155 $1,512,435 $5,696,427 
Term Loans Amortized Cost Basis by Origination Year
(In thousands)20212020201920182017PriorRevolving Loans Amortized Cost BasisTotal
December 31, 2021
Real estate-personal
       Current to 90 days past due$690,058 $888,631 $354,292 $157,485 $149,391 $551,460 $9,470 $2,800,787 
       Over 90 days past due133 1,150 298 124 97 1,181 — 2,983 
       Non-accrual115 — 251 109 — 1,156 — 1,631 
   Total Real estate-personal:$690,306 $889,781 $354,841 $157,718 $149,488 $553,797 $9,470 $2,805,401 
Consumer
       Current to 90 days past due$571,455 $348,774 $192,076 $79,887 $47,401 $78,088 $712,333 $2,030,014 
       Over 90 days past due283 335 257 250 74 351 661 2,211 
    Total Consumer:$571,738 $349,109 $192,333 $80,137 $47,475 $78,439 $712,994 $2,032,225 
Revolving home equity
       Current to 90 days past due$— $— $— $— $— $— $275,144 $275,144 
       Over 90 days past due— — — — — — 801 801 
   Total Revolving home equity:$— $— $— $— $— $— $275,945 $275,945 
Consumer credit card
       Current to 90 days past due$— $— $— $— $— $— $570,156 $570,156 
       Over 90 days past due— — — — — — 5,254 5,254 
   Total Consumer credit card:$— $— $— $— $— $— $575,410 $575,410 
Overdrafts
       Current to 90 days past due$6,740 $— $— $— $— $— $— $6,740 
    Total Overdrafts:$6,740 $— $— $— $— $— $— $6,740 
Personal banking loans
       Current to 90 days past due$1,268,253 $1,237,405 $546,368 $237,372 $196,792 $629,548 $1,567,103 $5,682,841 
       Over 90 days past due416 1,485 555 374 171 1,532 6,716 11,249 
       Non-accrual115 — 251 109 — 1,156 — 1,631 
   Total Personal banking loans:$1,268,784 $1,238,890 $547,174 $237,855 $196,963 $632,236 $1,573,819 $5,695,721 

Collateral-dependent loans
The Company's collateral-dependent loans are comprised of large loans on non-accrual status. The Company requires that collateral-dependent loans are either over-collateralized or carry collateral equal to the amortized cost of the loan. The following table presents the amortized cost basis of collateral-dependent loans as of March 31, 2022 and December 31, 2021.

(In thousands)Business AssetsOil & Gas AssetsTotal
March 31, 2022
Commercial:
  Business$1,498 $2,401 $3,899 
Total$1,498 $2,401 $3,899 
December 31, 2021
Commercial:
Business$1,604 $2,459 $4,063 
Total$1,604 $2,459 $4,063 

Other Personal Banking loan information
As noted above, the credit quality of Personal Banking loans is monitored primarily on the basis of aging/delinquency, and this information is provided in the table in the above section on "Credit quality indicators." In addition, FICO scores are obtained and updated on a quarterly basis for most of the loans in the Personal Banking portfolio. This is a published credit score designed to measure the risk of default by taking into account various factors from a borrower's financial history and is considered supplementary information utilized by the Company, as management does not consider this information in evaluating the allowance for credit losses on loans. The Bank normally obtains a FICO score at the loan's origination and renewal dates, and updates are obtained on a quarterly basis. Excluded from the table below are certain personal real estate loans for which FICO scores are not obtained because the loans generally pertain to commercial customer activities and are
often underwritten with other collateral considerations. These loans totaled $183.4 million at March 31, 2022 and $185.6 million at December 31, 2021. The table also excludes consumer loans related to the Company's patient healthcare loan program, which totaled $181.8 million at March 31, 2022 and $186.6 million at December 31, 2021. As the healthcare loans are guaranteed by the hospital, customer FICO scores are not obtained for these loans. The personal real estate loans and consumer loans excluded below totaled less than 7% of the Personal Banking portfolio. For the remainder of loans in the Personal Banking portfolio, the table below shows the percentage of balances outstanding at March 31, 2022 and December 31, 2021 by FICO score.

   Personal Banking Loans
% of Loan Category
Real Estate - PersonalConsumerRevolving Home EquityConsumer Credit Card
March 31, 2022
FICO score:
Under 600.9 %1.9 %0.9 %3.4 %
600 - 6592.5 3.9 2.6 11.3 
660 - 7197.2 13.5 10.1 31.0 
720 - 77926.6 24.9 21.7 28.0 
780 and over62.8 55.8 64.7 26.3 
Total100.0 %100.0 %100.0 %100.0 %
December 31, 2021
FICO score:
Under 6001.0 %1.9 %0.9 %3.4 %
600 - 6592.4 3.9 2.6 11.3 
660 - 7197.4 13.8 9.4 29.9 
720 - 77925.2 25.3 20.4 28.2 
780 and over64.0 55.1 66.7 27.2 
Total100.0 %100.0 %100.0 %100.0 %

Troubled debt restructurings
Restructured loans are those extended to borrowers who are experiencing financial difficulty and who have been granted a concession. Restructured loans are placed on non-accrual status if the Company does not believe it probable that amounts due under the contractual terms will be collected. Commercial performing restructured loans are primarily comprised of certain business, construction and business real estate loans classified as substandard but renewed at rates judged to be non-market. These loans are performing in accordance with their modified terms, and because the Company believes it probable that all amounts due under the modified terms of the agreements will be collected, interest on these loans is being recognized on an accrual basis. Troubled debt restructurings also include certain credit card and other small consumer loans under various debt management and assistance programs. Modifications to these loans generally involve removing the available line of credit, placing loans on amortizing status, and lowering the contractual interest rate. Certain personal real estate, revolving home equity, and consumer loans were classified as consumer bankruptcy troubled debt restructurings because they were not reaffirmed by the borrower in bankruptcy proceedings. Interest on these loans is being recognized on an accrual basis, as the borrowers are continuing to make payments. Other consumer loans classified as troubled debt restructurings consist of various other workout arrangements with consumer customers.

(In thousands)March 31, 2022December 31, 2021
Accruing restructured loans:
Commercial
$108,789 $46,867 
Assistance programs
5,865 6,146 
Other consumer
4,681 4,787 
Non-accrual loans
6,457 7,087 
Total troubled debt restructurings
$125,792 $64,887 
Section 4013 of the CARES Act was signed into law on March 27, 2020, and included a provision that short-term modifications are not troubled debt restructurings, if made on a good-faith basis in response to COVID-19 to borrowers who were current prior to December 31, 2019. The Company elected such option under the CARES Act when determining if a customer’s modification is subject to troubled debt restructuring classification. The initial guidance issued under the CARES Act was due to expire on December 31, 2020. During January 2021, the Consolidated Appropriations Act, 2021 was enacted and extended through the end of 2021 the relief offered under the CARES Act related to the accounting and disclosure
requirements for troubled debt restructurings as a result of COVID-19. The Company elected to extend its application of this guidance through December 31, 2021. During the period covered by the CARES Act, if it was deemed that the loan modification was not short-term, not COVID-19 related or the customer does not meet the criteria under the guidance to be scoped out of troubled debt restructuring classification, the Company evaluated the loan modifications under its existing framework and accounted for the modification as a troubled debt restructuring.

The table below shows the balance of troubled debt restructurings by loan classification at March 31, 2022, in addition to the outstanding balances of these restructured loans which the Company considers to have been in default at any time during the past twelve months. For purposes of this disclosure, the Company considers "default" to mean 90 days or more past due as to interest or principal.

(In thousands)March 31, 2022Balance 90 days past due at any time during previous 12 months
Commercial:
Business$30,254 $— 
Real estate - construction and land10,101 — 
Real estate - business73,804 — 
Personal Banking:
Real estate - personal3,220 729 
Consumer20 — 
Revolving home equity2,637 282 
Consumer credit card5,756 518 
Total troubled debt restructurings$125,792 $1,529 

For those loans on non-accrual status also classified as restructured, the modification did not create any further financial effect on the Company as those loans were already recorded at net realizable value. For those performing commercial loans classified as restructured, there were no concessions involving forgiveness of principal or interest and, therefore, there was no financial impact to the Company as a result of modification to these loans. However, the effects of modifications to loans under various debt management and assistance programs were estimated to decrease interest income by approximately $649 thousand on an annual, pre-tax basis, compared to amounts contractually owed. Other modifications to consumer loans mainly involve extensions and other small modifications that did not include the forgiveness of principal or interest.

The allowance for credit losses related to troubled debt restructurings on non-accrual status is determined by individual evaluation, including collateral adequacy, using the same process as loans on non-accrual status which are not classified as troubled debt restructurings. Those performing loans classified as troubled debt restructurings are accruing loans which management expects to collect under contractual terms. Performing commercial loans having no other concessions granted other than being renewed at non-market interest rates are judged to have similar risk characteristics as non-troubled debt commercial loans and are collectively evaluated based on internal risk rating, loan type, delinquency, historical experience and current economic factors. Performing personal banking loans classified as troubled debt restructurings resulted from the borrower not reaffirming the debt during bankruptcy and have had no other concession granted, other than the Bank's future limitations on collecting payment deficiencies or in pursuing foreclosure actions. As such, they have similar risk characteristics as non-troubled debt personal banking loans and are evaluated collectively based on loan type, delinquency, historical experience and current economic factors.

If a troubled debt restructuring defaults and is already on non-accrual status, the allowance for credit losses continues to be based on individual evaluation, using discounted expected cash flows or the fair value of collateral. If an accruing troubled debt restructuring defaults, the loan's risk rating is downgraded to non-accrual status and the loan's related allowance for credit losses is determined based on individual evaluation, or if necessary, the loan is charged off and collection efforts begin.

The Company had commitments of $17.7 million at March 31, 2022 to lend additional funds to borrowers with restructured loans. Additionally, the Company had commitments at March 31, 2022 of $24.0 million related to letters of credit with an internal risk rating below substandard.

Loans held for sale
The Company designates certain long-term fixed rate personal real estate loans as held for sale, and the Company has elected the fair value option for these loans. The election of the fair value option aligns the accounting for these loans with the related economic hedges discussed in Note 11. The loans are primarily sold to Federal Home Loan Mortgage Corporation
(FHLMC) and Federal National Mortgage Association (FNMA). At March 31, 2022, the fair value of these loans was $3.9 million, and the unpaid principal balance was $3.9 million.

The Company also designates certain student loan originations as held for sale. The borrowers are credit-worthy students who are attending colleges and universities. The loans are intended to be sold in the secondary market, and the Company maintains contracts with Sallie Mae to sell the loans within 210 days after the last disbursement to the student. These loans are carried at lower of cost or fair value, which at March 31, 2022 totaled $5.0 million.

At March 31, 2022, none of the loans held for sale were on non-accrual status or 90 days past due and still accruing interest.
Foreclosed real estate/repossessed assets
The Company’s holdings of foreclosed real estate totaled $296 thousand and $115 thousand at March 31, 2022 and December 31, 2021, respectively. Personal property acquired in repossession, generally autos, totaled $1.3 million and $1.1 million at March 31, 2022 and December 31, 2021, respectively. Upon acquisition, these assets are recorded at fair value less estimated selling costs at the date of foreclosure, establishing a new cost basis. They are subsequently carried at the lower of this cost basis or fair value less estimated selling costs.