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Loans Held for Investment (LHFI) and Allowance for Loan Losses, excluding Covered Loans
9 Months Ended
Sep. 30, 2011
Loans and Allowance for Loan Losses [Abstract] 
Loans and Allowance for Loan Losses
Note 4 –Loans Held for Investment (LHFI) and Allowance for Loan Losses, excluding Covered Loans

For the periods presented, LHFI, excluding covered loans, consisted of the following ($ in thousands):

   
September 30, 2011
  
December 31, 2010
 
Loans secured by real estate:
      
Construction, land development and other land loans
 $481,821  $583,316 
Secured by 1-4 family residential properties
  1,717,366   1,732,056 
Secured by nonfarm, nonresidential properties
  1,437,573   1,498,108 
Other
  207,984   231,963 
Commercial and industrial loans
  1,083,753   1,068,369 
Consumer loans
  268,002   402,165 
Other loans
  587,213   544,265 
LHFI, excluding covered loans
  5,783,712   6,060,242 
Less allowance for loan losses
  89,463   93,510 
Net LHFI, excluding covered loans
 $5,694,249  $5,966,732 

The following table details LHFI, excluding covered loans, individually and collectively evaluated for impairment at September 30, 2011 and December 31, 2010 ($ in thousands):

   
September 30, 2011
 
   
LHFI Evaluated for Impairment
 
   
Individually
  
Collectively
  
Total
 
           
Loans secured by real estate:
         
Construction, land development and other land loans
 $29,594  $452,227  $481,821 
Secured by 1-4 family residential properties
  23,558   1,693,808   1,717,366 
Secured by nonfarm, nonresidential properties
  25,303   1,412,270   1,437,573 
Other
  4,821   203,163   207,984 
Commercial and industrial loans
  14,204   1,069,549   1,083,753 
Consumer loans
  907   267,095   268,002 
Other loans
  1,191   586,022   587,213 
Total
 $99,578  $5,684,134  $5,783,712 

   
December 31, 2010
 
   
LHFI Evaluated for Impairment
 
   
Individually
  
Collectively
  
Total
 
           
Loans secured by real estate:
         
Construction, land development and other land loans
 $57,831  $525,485  $583,316 
Secured by 1-4 family residential properties
  30,313   1,701,743   1,732,056 
Secured by nonfarm, nonresidential properties
  29,013   1,469,095   1,498,108 
Other
  6,154   225,809   231,963 
Commercial and industrial loans
  16,107   1,052,262   1,068,369 
Consumer loans
  2,112   400,053   402,165 
Other loans
  1,393   542,872   544,265 
Total
 $142,923  $5,917,319  $6,060,242 

Loan Concentrations

Trustmark does not have any loan concentrations other than those reflected in the preceding table, which exceed 10% of total LHFI.  At September 30, 2011, Trustmark's geographic loan distribution was concentrated primarily in its Florida, Mississippi, Tennessee and Texas markets.  A substantial portion of construction, land development and other land loans are secured by real estate in markets in which Trustmark is located.  Accordingly, the ultimate collectability of a substantial portion of these loans and the recovery of a substantial portion of the carrying amount of other real estate owned, are susceptible to changes in market conditions in these areas.

Nonaccrual/Impaired LHFI, Excluding Covered Loans

At September 30, 2011 and December 31, 2010, the carrying amounts of nonaccrual LHFI, excluding covered loans, which are considered for impairment analysis, were $99.6 million and $142.9 million, respectively.  For collateral dependent loans, when a loan is deemed impaired, the full difference between the carrying amount of the loan and the most likely estimate of the asset's fair value less cost to sell, is charged-off.  All of Trustmark's specifically evaluated impaired LHFI are collateral dependent loans.  At September 30, 2011 and December 31, 2010, specifically evaluated impaired LHFI totaled $66.2 million and $97.6 million, respectively.  In addition, these specifically evaluated impaired LHFI had a related allowance of $6.3 million and $8.3 million at the end of the respective periods.  Specific charge-offs related to impaired LHFI totaled $18.4 million and $26.9 million while the provisions charged to net income for these loans totaled $6.2 million and $9.6 million for the first nine months of 2011 and 2010, respectively.

All nonaccrual LHFI over $500 thousand are individually assessed for impairment.  Impaired LHFI have been determined to be collateral dependent and assessed using a fair value approach.  Fair value estimates begin with appraised values based on the current market value/as is value of the property being appraised, normally from recently received and reviewed appraisals.  If a current appraisal, or one with an inspection date within the past 12 months, using the necessary assumptions is not in the file, a new appraisal is ordered.  Appraisals are obtained from State-certified Appraisers and are based on certain assumptions, which may include construction or development status and the highest and best use of the property.  The Appraisal Review Department has the authority to make adjustments to appraisals based on sales contracts, comparable sales and other pertinent information if an appraisal does not incorporate the effect of these assumptions.  Appraised values are adjusted down for costs associated with asset disposal.  Once the current appraisal is received and the estimated net realizable value determined, the value used in the impairment assessment is updated and adjustments are made to reflect further impairments.  At the time a LHFI is deemed to be impaired, the full difference between book value and the most likely estimate of the asset's net realizable value is charged off.  However, as subsequent events dictate and estimated net realizable values decline, required reserves are established.

At September 30, 2011 and December 31, 2010, nonaccrual LHFI, excluding covered loans, not specifically impaired and written down to fair value less cost to sell, totaled $33.4 million and $45.3 million, respectively.  In addition, these nonaccrual LHFI had allocated allowance for loan losses of $2.7 million and $3.5 million at the end of the respective periods. No material interest income was recognized in the income statement on impaired or nonaccrual loans for each of the periods ended September 30, 2011 and 2010.

At September 30, 2011 and December 31, 2010, LHFI, excluding covered loans, classified as troubled debt restructurings (TDRs) totaled $27.7 million and $19.2 million, respectively.  For TDRs, Trustmark had a related loan loss allowance of $1.9 million at both September 30, 2011 and December 31, 2010.  Specific charge-offs related to TDRs totaled $1.6 million for the nine months ended September 30, 2011 and 2010.  LHFI that are TDRs are charged down to the most likely fair value estimate less a cost to sell estimate for collateral dependent loans, which would approximate net realizable value.

The following table illustrates the impact of modifications classified as TDRs as a whole at September 30, 2011 as well as those TDRs modified within 2011 for which there was a payment default during the year ($ in thousands):

   
Nine Months Ended September 30, 2011
 
Troubled Debt Restructurings
 
Number of Contracts
  
Pre-Modification Outstanding Recorded Investment
  
Post-Modification Outstanding Recorded Investment
 
Construction, land development and other land loans
  14  $9,114  $8,447 
Secured by 1-4 family residential properties
  15   5,112   3,549 
Secured by nonfarm, nonresidential properties
  4   4,368   4,196 
Commercial and industrial
  2   11,998   11,531 
Total
  35  $30,592  $27,723 
              
              
   
Three Months Ended September 30, 2011
 
Troubled Debt Restructurings
 
Number of Contracts
  
Pre-Modification Outstanding Recorded Investment
  
Post-Modification Outstanding Recorded Investment
 
Construction, land development and other land loans
  1  $1,843  $1,843 
Secured by 1-4 family residential properties
  5   1,889   1,949 
Total
  6  $3,732  $3,792 
              
              
   
Nine Months Ended September 30, 2011
 
Troubled Debt Restructurings that Subsequently Defaulted
 
Number of Contracts
      
Recorded Investment
 
Construction, land development and other land loans
  2      $1,688 
Secured by 1-4 family residential properties
  2       1,485 
Total
  4      $3,173 

Trustmark's TDRs have resulted primarily from allowing the borrower to pay interest only for an extended period of time rather than from forgiveness.  Accordingly, as shown above, these TDRs have a similar recorded investment for both the pre-modification and post-modification disclosure.  Trustmark has utilized loans 90 days or more past due to define payment default in determining TDRs that have subsequently defaulted.

At September 30, 2011 and December 31, 2010, the following table details LHFI, excluding covered loans, classified as TDRs by loan type ($ in thousands):

   
September 30, 2011
 
   
Accruing
  
Nonaccrual
  
Total
 
Construction, land development and other land loans
 $244  $8,203  $8,447 
Secured by 1-4 family residential properties
  795   2,754   3,549 
Secured by nonfarm, nonresidential properties
  -   4,196   4,196 
Commercial and industrial
  -   11,531   11,531 
Total Troubled Debt Restructurings by Type
 $1,039  $26,684  $27,723 
              
              
   
December 31, 2010
 
   
Accruing
  
Nonaccrual
  
Total
 
Construction, land development and other land loans
 $-  $3,181  $3,181 
Secured by 1-4 family residential properties
  318   1,488   1,806 
Secured by nonfarm, nonresidential properties
  -   2,232   2,232 
Commercial and industrial
  -   11,997   11,997 
Total Troubled Debt Restructurings by Type
 $318  $18,898  $19,216 
              

At September 30, 2011 and December 31, 2010, the carrying amount of impaired loans, excluding covered loans, consisted of the following ($ in thousands):

   
September 30, 2011
 
      
Total LHFI
             
   
Unpaid
  
with No Related
  
Total LHFI
  
Total
     
Average
 
   
Principal
  
Allowance
  
with an Allowance
  
Carrying
  
Related
  
Recorded
 
   
Balance
  
Recorded
  
Recorded
  
Amount
  
Allowance
  
Investment
 
                    
Loans secured by real estate:
                  
Construction, land development and other land loans
 $47,736  $9,284  $20,310  $29,594  $4,165  $43,712 
Secured by 1-4 family residential properties
  32,273   3,624   19,934   23,558   540   26,935 
Secured by nonfarm, nonresidential properties
  29,547   13,841   11,462   25,303   1,510   27,158 
Other
  5,625   486   4,335   4,821   1,008   5,488 
Commercial and industrial loans
  15,966   8,833   5,371   14,204   1,454   15,155 
Consumer loans
  1,184   -   907   907   10   1,510 
Other loans
  2,725   17   1,174   1,191   275   1,292 
Total
 $135,056  $36,085  $63,493  $99,578  $8,962  $121,250 

   
December 31, 2010
 
      
Total LHFI
             
   
Unpaid
  
with No Related
  
Total LHFI
  
Total
     
Average
 
   
Principal
  
Allowance
  
with an Allowance
  
Carrying
  
Related
  
Recorded
 
   
Balance
  
Recorded
  
Recorded
  
Amount
  
Allowance
  
Investment
 
                    
Loans secured by real estate:
                  
Construction, land development and other land loans
 $81,945  $33,201  $24,630  $57,831  $6,782  $69,817 
Secured by 1-4 family residential properties
  41,475   3,082   27,231   30,313   1,745   30,888 
Secured by nonfarm, nonresidential properties
  35,679   18,582   10,431   29,013   1,580   23,535 
Other
  7,009   5,042   1,112   6,154   95   4,126 
Commercial and industrial loans
  17,413   9,172   6,935   16,107   1,514   11,369 
Consumer loans
  2,420   -   2,112   2,112   23   1,544 
Other loans
  2,868   1,107   286   1,393   58   765 
Total
 $188,809  $70,186  $72,737  $142,923  $11,797  $142,044 

Credit Quality Indicators

Trustmark's loan portfolio credit quality indicators focus on six key quality ratios that are compared against bank tolerances.  The loan indicators are total classified outstanding, total criticized outstanding, nonperforming loans, nonperforming assets, delinquencies and net loan losses.  Due to the homogenous nature of consumer loans, Trustmark does not assign a formal internal risk rating to each credit and therefore the criticized and classified measures are unique to commercial loans.
 
In addition to monitoring portfolio credit quality indictors, Trustmark also measures how effectively the lending process is being managed and risks are being identified.  As part of an ongoing monitoring process, Trustmark grades the commercial portfolio as it relates to financial statement exceptions, total policy exceptions, collateral exceptions and violations of law as shown below:

 
·
Financial Statement Exceptions – focuses on the officers' ongoing efforts to obtain, evaluate and/or document sufficient information to determine the quality and status of the credits.  This area includes the quality and condition of the files in terms of content, completeness and organization.  Included is an evaluation of the systems/procedures used to insure compliance with policy such as financial statements, review memos and loan agreement covenants.
 
·
Underwriting/Policy – evaluates whether credits are adequately analyzed, appropriately structured and properly approved within requirements of bank loan policy.  A properly approved credit is approved by adequate authority in a timely manner with all conditions of approval fulfilled. Total policy exceptions measure the level of exceptions to loan policy within a loan portfolio.
 
·
Collateral Documentation – focuses on the adequacy of documentation to support the obligation, perfect Trustmark's collateral position and protect collateral value.  There are two parts to this measure:
 
ü
Collateral exceptions where certain collateral documentation is either not present, is not considered current or has expired.
 
ü
90 days and over collateral exceptions are where certain collateral documentation is either not present, is not considered current or has expired and the exception has been identified in excess of 90 days.
 
·
Compliance with Law – focuses on underwriting, documentation, approval and reporting in compliance with banking laws and regulations.  Primary emphasis is directed to Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA) and Regulation O requirements.

Commercial Credits

Trustmark has established a Loan Grading System that consists of ten individual Credit Risk Grades (Risk Ratings) that encompass a range from loans where the expectation of loss is negligible to loans where loss has been established. The model is based on the risk of default for an individual credit and establishes certain criteria to delineate the level of risk across the ten unique Credit Risk Grades.  Credit risk grade definitions are as follows:

 
·
Risk Rate (RR) 1 through RR 6 – Grades one through six represent groups of loans that are not subject to adverse criticism as defined in regulatory guidance.  Loans in these groups exhibit characteristics that represent low to moderate risk measured by using a variety of credit risk criteria such as cash flow coverage, debt service coverage, balance sheet leverage, liquidity, management experience, industry position, prevailing economic conditions, support from secondary sources of repayment and other credit factors that may be relevant to a specific loan.  In general, these loans are supported by properly margined collateral and guarantees of principal parties.
 
·
Other Assets Especially Mentioned (OAEM) - (RR 7) – a loan that has a potential weakness that if not corrected will lead to a more severe rating.  This rating is for credits that are currently protected but potentially weak because of an adverse feature or condition that if not corrected will lead to a further downgrade.
 
·
Substandard (RR 8) – a loan that has at least one identified weakness that is well defined.  This rating is for credits where the primary sources of repayment are not viable at this time or where either the capital or collateral is not adequate to support the loan and the secondary means of repayment do not provide a sufficient level of support to offset the identified weakness but are sufficient to prevent a loss at this time.  While these credits do not demonstrate any level of loss at this time, further deterioration would lead to a further downgrade.
 
·
Doubtful (RR 9) – a loan with an identified weakness that does not have a valid secondary source of repayment.  Generally these credits have an impaired primary source of repayment and secondary sources are not sufficient to prevent a loss in the credit.
 
·
Loss (RR 10) – a loan or a portion of a loan that is deemed to be uncollectible.

By definition, credit risk grades OAEM (RR 7), substandard (RR 8), doubtful (RR 9) and loss (RR 10) are criticized loans while substandard (RR 8), doubtful (RR 9) and loss (RR 10) are classified loans.  These definitions are standardized by all bank regulatory agencies and are generally equally applied to each individual lending institution. The remaining credit risk grades are considered pass credits and are solely defined by Trustmark.

The credit risk grades represent the probability of default (PD) for an individual credit and as such is not a direct indication of loss given default (LGD).  The LGD aspect of the subject risk ratings is neither uniform across the nine primary commercial loan groups or constant between the geographic areas.  To account for the variance in the LGD aspects of the risk rate system, the loss expectations for each risk rating is integrated into the allowance for loan loss methodology where the calculated LGD is allotted for each individual risk rating with respect to the individual loan group and unique geographic area.  The LGD aspect of the reserve methodology is calculated each quarter as a component of the overall reserve factor for each risk grade by loan group and geographic area.

To enhance this process, loans of a certain size that are rated in one of the criticized categories are routinely reviewed to establish an expectation of loss, if any, and if such examination indicates that the level of reserve is not adequate to cover the expectation of loss, a special reserve or impairment is generally applied.

Each loan officer assesses the appropriateness of the internal risk rating assigned to their credits on an ongoing basis.  Trustmark's Asset Review area conducts independent credit quality reviews of the majority of the bank's commercial loan portfolio concentrations both on the underlying credit quality of each individual loan portfolio as well as the adherence to bank loan policy and the loan administration process. In general, Asset Review conducts reviews of each lending area within a six to eighteen month window depending on the overall credit quality results of the individual area.

The distribution of the losses is accomplished by means of a loss distribution model that assigns a loss factor to each risk rating (1 to 9) in each commercial loan pool. A factor is not applied to risk rate 10 (Loss) as loans classified as Losses are not carried on the bank's books over quarter ends as they are charged off within the period that the loss is determined.
 
The expected loss distribution is spread across the various risk ratings by the perceived level of risk for loss. The nine grade scale above ranges from a negligible risk of loss to an identified loss across its breadth. The loss distribution factors are graduated through the scale on a basis proportional to the degree of risk that appears manifest in each individual rating and assumes that migration through the loan grading system will occur.

In addition to the ongoing internal risk rate monitoring described above, Trustmark conducts monthly credit quality reviews (CQR) as well as semi-annual analysis and stress testing on all residential real estate development credits and non-owner occupied commercial real estate (CRE) credits of $1.0 million or more as described below:

 
·
Trustmark's Credit Quality Review Committee meets monthly and performs the following functions: detailed review and evaluation of all loans of $100 thousand or more that are either delinquent thirty days or more or on nonaccrual, including determination of appropriate risk ratings, accrual status, and appropriate servicing officer; review of risk rate changes for relationships of $100 thousand or more; quarterly review of all nonaccruals less than $100 thousand to determine whether the credit should be charged off, returned to accrual, or remain in nonaccrual status; monthly/quarterly review of continuous action plans for all credits rated seven or worse for relationships of $100 thousand or more; monthly review of all commercial charge-offs of $25 thousand or more for the preceding month.

 
·
Residential real estate developments - a development project analysis is performed on all projects regardless of size.  Performance of the development is assessed through an evaluation of the number of lots remaining, the payout ratios, and the loan-to-value ratios.  Results are stress tested as to absorption and price of lots.  This information is reviewed by each senior credit officer for that market to determine the need for any risk rate or accrual status changes.
 
 
·
Non-owner occupied commercial real estate – a cash flow analysis is performed on all projects with an outstanding balance of $1.0 million or more.  In addition, credits are stress tested for vacancies and rate sensitivity.  Confirmation is obtained that guarantor's financial statements are current, taxes have been paid, and that there are no other issues that need to be addressed.  This information is reviewed by each senior credit officer for that market to determine the need for any risk rate or accrual status changes.

Consumer Credits

Loans that do not meet a minimum custom credit score are reviewed quarterly by Management.  The Retail Credit Review Committee reviews the volume and percentage of approvals that did not meet the minimum passing custom score by region, individual location, and officer.  To assure that Trustmark continues to originate quality loans, this process allows Management to make necessary changes such as changes to underwriting procedures, credit policies, or changes in loan authority to Trustmark personnel.

Trustmark monitors the levels and severity of past due consumer loans on a daily basis through its collection activities.  A detailed assessment of consumer loan delinquencies is performed monthly at both a product and market level by delivery channel, which incorporates the perceived level of risk at time of underwriting.  Trustmark also monitors its consumer loan delinquency trends by comparing them to quarterly industry averages.

The allowance calculation methodology delineates the consumer loan portfolio into homogeneous pools of loans that contain similar structure, repayment, collateral and risk profile, which include residential mortgage, direct consumer loans, auto finance, credit cards, and overdrafts.  For these pools, the historical loss experience is determined by calculating a 20-quarter rolling average and that loss factor is applied to each homogeneous pool to establish the quantitative aspect of the methodology.  Where the loss experience does not fully cover the anticipated loss for a pool, an estimate is also applied to each homogeneous pool to establish the qualitative aspect of the methodology.  The qualitative portion is the allocation of perceived risks across the loan portfolio to derive the potential losses that exist at the current point in time.  This methodology utilizes five separate factors where each factor is made up of unique components that when weighted and combined produce an estimated level of reserve for each of the loan pools.  The five factors include economic indicators, performance trends, management experience, lending policy measures, and credit concentrations.

The risk measure for each factor is converted to a scale ranging from 0 (No risk) to 100 (High Risk) to ensure that the combination of such factors is proportional. The determination of the risk measurement for each qualitative factor is done for each market, so that the risk measurements for the qualitative factors are market-specific. The resulting estimated reserve factor is then applied to each pool.

The resulting ratings from the individual factors are weighted and summed to establish the weighted average qualitative factor of a specific loan portfolio. This weighted average qualitative factor is then applied over the five loan pools.
 
The table below illustrates the carrying amount of loans, excluding covered loans, by credit quality indicator at September 30, 2011 and December 31, 2010 ($ in thousands):
 
   
September 30, 2011
 
      
Commercial Loans
 
      
Pass -
  
Special Mention -
  
Substandard -
  
Doubtful -
    
      
Categories 1-6
  
Category 7
  
Category 8
  
Category 9
  
Subtotal
 
Loans secured by real estate:
                  
Construction, land development and other land loans
    $305,155  $28,014  $96,487  $69  $429,725 
Secured by 1-4 family residential properties
     118,644   147   16,795   -   135,586 
Secured by nonfarm, nonresidential properties
     1,291,830   13,123   131,656   51   1,436,660 
Other
     190,265   314   10,180   -   200,759 
Commercial and industrial loans
     999,567   24,922   55,456   1,405   1,081,350 
Consumer loans
     796   24   -   -   820 
Other loans
     572,818   5,994   2,469   553   581,834 
      $3,479,075  $72,538  $313,043  $2,078  $3,866,734 
                         
   
Consumer Loans
     
      
Past Due
  
Past Due Greater
          
Total LHFI, excluding
 
   
Current
  
30-89 Days
  
Than 90 days
  
Nonaccrual
  
Subtotal
  
covered loans
 
Loans secured by real estate:
                       
Construction, land development and other land loans
 $49,668  $490  $176  $1,762  $52,096  $481,821 
Secured by 1-4 family residential properties
  1,551,510   11,346   1,742   17,182   1,581,780   1,717,366 
Secured by nonfarm, nonresidential properties
  876   37   -   -   913   1,437,573 
Other
  7,189   6   -   30   7,225   207,984 
Commercial and industrial loans
  2,327   52   -   24   2,403   1,083,753 
Consumer loans
  258,724   6,973   579   906   267,182   268,002 
Other loans
  5,348   31   -   -   5,379   587,213 
   $1,875,642  $18,935  $2,497  $19,904  $1,916,978  $5,783,712 


   
December 31, 2010
 
      
Commercial Loans
 
      
Pass -
  
Special Mention -
  
Substandard -
  
Doubtful -
    
      
Categories 1-6
  
Category 7
  
Category 8
  
Category 9
  
Subtotal
 
Loans secured by real estate:
                  
Construction, land development and other land loans
  $347,287  $44,459  $134,503  $512  $526,761 
Secured by 1-4 family residential properties
     113,776   780   25,167   226   139,949 
Secured by nonfarm, nonresidential properties
     1,353,794   16,858   126,050   431   1,497,133 
Other
     216,022   180   7,418   -   223,620 
Commercial and industrial loans
     977,793   25,642   58,307   1,416   1,063,158 
Consumer loans
     524   -   -   -   524 
Other loans
     535,110   210   3,633   146   539,099 
      $3,544,306  $88,129  $355,078  $2,731  $3,990,244 
                         
                         
   
Consumer Loans
     
      
Past Due
  
Past Due Greater
          
Total LHFI, excluding
 
   
Current
  
30-89 Days
  
Than 90 days
  
Nonaccrual
  
Subtotal
  
covered loans
 
Loans secured by real estate:
                       
Construction, land development and other land loans
 $53,797  $223  $-  $2,535  $56,555  $583,316 
Secured by 1-4 family residential properties
  1,559,611   10,302   1,278   20,916   1,592,107   1,732,056 
Secured by nonfarm, nonresidential properties
  975   -   -   -   975   1,498,108 
Other
  8,282   26   -   35   8,343   231,963 
Commercial and industrial loans
  5,075   97   -   39   5,211   1,068,369 
Consumer loans
  383,529   13,741   2,260   2,111   401,641   402,165 
Other loans
  5,166   -   -   -   5,166   544,265 
   $2,016,435  $24,389  $3,538  $25,636  $2,069,998  $6,060,242 

Past Due LHFI, Excluding Covered Loans

LHFI past due 90 days or more totaled $36.1 million and $19.4 million at September 30, 2011 and December 31, 2010, respectively. Included in these amounts are $33.0 million and $15.8 million, respectively, of serviced loans eligible for repurchase, which are fully guaranteed by GNMA.  GNMA optional repurchase programs allow financial institutions to buy back individual delinquent mortgage loans that meet certain criteria from the securitized loan pool for which the institution provides servicing. At the servicer's option and without GNMA's prior authorization, the servicer may repurchase such a delinquent loan for an amount equal to 100 percent of the remaining principal balance of the loan. This buy-back option is considered a conditional option until the delinquency criteria are met, at which time the option becomes unconditional. When Trustmark is deemed to have regained effective control over these loans under the unconditional buy-back option, the loans can no longer be reported as sold and must be brought back onto the balance sheet as loans held for sale, regardless of whether Trustmark intends to exercise the buy-back option.  These loans are reported as held for sale with the offsetting liability being reported as short-term borrowings.  During December of 2010, Trustmark purchased approximately $53.9 million of GNMA serviced loans, which were subsequently sold to a third party.  Trustmark will retain the servicing for these loans, which are fully guaranteed by FHA/VA.  Trustmark did not exercise its buy-back option on any delinquent loans serviced for GNMA during the first nine months of 2011.

The following table provides an aging analysis of past due and nonaccrual LHFI, excluding covered loans, by class at September 30, 2011 and December 31, 2010 ($ in thousands):

   
September 30, 2011
 
   
Past Due
          
      
Greater than
        
Current
  
Total LHFI, excluding
 
   
30-89 Days
  
90 Days (1)
  
Total
  
Nonaccrual
  
Loans
  
covered loans
 
                    
Loans secured by real estate:
                  
Construction, land development and other land loans
 $4,653  $844  $5,497  $29,594  $446,730  $481,821 
Secured by 1-4 family residential properties
  12,798   1,743   14,541   23,558   1,679,267   1,717,366 
Secured by nonfarm, nonresidential properties
  19,863   -   19,863   25,303   1,392,407   1,437,573 
Other
  63   -   63   4,821   203,100   207,984 
Commercial and industrial loans
  8,781   -   8,781   14,204   1,060,768   1,083,753 
Consumer loans
  6,973   579   7,552   907   259,543   268,002 
Other loans
  785   -   785   1,191   585,237   587,213 
Total past due LHFI
 $53,916  $3,166  $57,082  $99,578  $5,627,052  $5,783,712 
                          
(1) - Past due greater than 90 days but still accruing interest.
 


   
December 31, 2010
 
   
Past Due
          
      
Greater than
        
Current
  
Total LHFI, excluding
 
   
30-89 Days
  
90 Days (1)
  
Total
  
Nonaccrual
  
Loans
  
covered loans
 
                    
Loans secured by real estate:
                  
Construction, land development and other land loans
 $1,651  $-  $1,651  $57,831  $523,834  $583,316 
Secured by 1-4 family residential properties
  11,654   1,278   12,932   30,313   1,688,811   1,732,056 
Secured by nonfarm, nonresidential properties
  9,149   31   9,180   29,013   1,459,915   1,498,108 
Other
  441   -   441   6,154   225,368   231,963 
Commercial and industrial loans
  4,178   39   4,217   16,107   1,048,045   1,068,369 
Consumer loans
  13,741   2,260   16,001   2,112   384,052   402,165 
Other loans
  67   -   67   1,393   542,805   544,265 
Total past due LHFI
 $40,881  $3,608  $44,489  $142,923  $5,872,830  $6,060,242 
                          
(1) - Past due greater than 90 days but still accruing interest.
 

Allowance for Loan Losses

During 2009, Trustmark refined its allowance for loan loss methodology for commercial loans based upon regulatory guidance from its primary regulator.  This refined methodology delineated the commercial purpose and commercial construction loan portfolios into 13 separate loan types (or pools), which had similar characteristics, such as, repayment, collateral and risk profiles.  During the first quarter of 2010, Trustmark refined the allowance for loan loss methodology for commercial loans by segregating the pools into Trustmark's four key market regions, Florida, Mississippi, Tennessee and Texas, to take into consideration the uniqueness of each market while continuing to utilize a 10-point risk rating system for each pool.  As a result, risk rate factors for commercial loan types increased to 360 while having an immaterial impact to the overall balance of the allowance for loan losses.  The nine separate pools are segmented below:
 
Commercial Purpose Loans
 
·
Real Estate – Owner Occupied
 
·
Real Estate – Non-Owner Occupied
 
·
Working Capital
 
·
Non-Working Capital
 
·
Land
 
·
Lots and Development
 
·
Political Subdivisions

Commercial Construction Loans
 
·
1 to 4 Family
 
·
Non-1 to 4 Family

The quantitative factors utilized in determining the required reserve are intended to reflect a twelve-quarter rolling average, one quarter in arrears, by loan type within each key market region, unless subsequent market factors suggests that a different method is called for. Prior to converting to a twelve-quarter rolling average at September 30, 2011, the quantitative factors reflected a three-year rolling average for its commercial loan book of business.  Because of the severe economic environment at the time, starting in 2009, Management determined to alter the methodology of calculating historical loss to use data from the single year for 2008 as the historical loss factor for 2009, and use the average historical loss for 2008 and 2009 for 2010.

The qualitative factors utilize eight separate factors made up of unique characteristics that, when weighted and combined, produce an estimated level of reserve for each loan type.  The qualitative factors considered are the following:

 
·
National and regional economic trends and conditions
 
·
Impact of recent performance trends
 
·
Experience, ability and effectiveness of management
 
·
Adherence to Trustmark's loan policies, procedures and internal controls
 
·
Collateral, financial and underwriting exception trends
 
·
Credit concentrations
 
·
Acquisitions
 
·
Catastrophe

The measure for each qualitative factor is converted to a scale ranging from 0 (No risk) to 100 (High Risk), other than the last two factors, which are applied on a dollar-for-dollar basis, to ensure that the combination of such factors is proportional. The resulting ratings from the individual factors are weighted and summed to establish the weighted average qualitative factor of a specific loan portfolio within each key market region.  This weighted average qualitative factor is then distributed over the nine primary loan pools within each key market region based on the ranking by risk of each.

Changes in the allowance for loan losses were as follows ($ in thousands):

   
Nine Months Ended September 30,
 
   
2011
  
2010
 
Balance at January 1,
 $93,510  $103,662 
Loans charged-off
  (37,312)  (56,014)
Recoveries
  9,634   9,058 
Net charge-offs
  (27,678)  (46,956)
Provision for loan losses
  23,631   37,752 
Balance at September 30,
 $89,463  $94,458 

The following tables detail the balance in the allowance for loan losses by portfolio segment at September 30, 2011 and 2010, respectively ($ in thousands):

   
Allowance for Loan Losses
 
   
Balance
           
Balance
 
   
January 1,
        
Provision for
  
September 30,
 
   
2011
  
Charge-offs
  
Recoveries
  
Loan Losses
  
2011
 
Loans secured by real estate:
               
Construction, land development and other land loans
 $35,562  $(14,375) $-  $8,353  $29,540 
Secured by 1-4 family residential properties
  13,051   (7,461)  410   5,538   11,538 
Secured by nonfarm, nonresidential properties
  20,980   (3,124)  -   4,882   22,738 
Other
  1,582   (577)  -   1,969   2,974 
Commercial and industrial loans
  14,775   (3,811)  2,259   2,529   15,752 
Consumer loans
  5,400   (4,410)  4,475   (1,474)  3,991 
Other loans
  2,160   (3,554)  2,490   1,834   2,930 
Total
 $93,510  $(37,312) $9,634  $23,631  $89,463 
                      
                      
           
Allowance for Loan Losses
 
           
Disaggregated by Impairment Method
 
           
Individually
  
Collectively
  
Total
 
Loans secured by real estate:
                    
Construction, land development and other land loans
         $4,165  $25,375  $29,540 
Secured by 1-4 family residential properties
          540   10,998   11,538 
Secured by nonfarm, nonresidential properties
          1,510   21,228   22,738 
Other
          1,008   1,966   2,974 
Commercial and industrial loans
          1,454   14,298   15,752 
Consumer loans
          10   3,981   3,991 
Other loans
          275   2,655   2,930 
Total
         $8,962  $80,501  $89,463 

   
Allowance for Loan Losses
 
   
Balance
           
Balance
 
   
January 1,
        
Provision for
  
September 30,
 
   
2010
  
Charge-offs
  
Recoveries
  
Loan Losses
  
2010
 
Loans secured by real estate:
               
Construction, land development and other land loans
 $43,552  $(25,462) $-  $15,915  $34,005 
Secured by 1-4 family residential properties
  13,151   (8,569)  372   6,941   11,895 
Secured by nonfarm, nonresidential properties
  20,110   (5,183)  -   6,345   21,272 
Other
  1,631   (576)  -   480   1,535 
Commercial and industrial loans
  16,275   (2,515)  1,617   2,120   17,497 
Consumer loans
  7,246   (8,175)  4,698   2,137   5,906 
Other loans
  1,697   (5,534)  2,371   3,814   2,348 
Total
 $103,662  $(56,014) $9,058  $37,752  $94,458 
                      
                      
           
Allowance for Loan Losses
 
           
Disaggregated by Impairment Method
 
           
Individually
  
Collectively
  
Total
 
Loans secured by real estate:
                    
Construction, land development and other land loans
         $4,706  $29,299  $34,005 
Secured by 1-4 family residential properties
          755   11,140   11,895 
Secured by nonfarm, nonresidential properties
          1,398   19,874   21,272 
Other
          203   1,332   1,535 
Commercial and industrial loans
          4,528   12,969   17,497 
Consumer loans
          17   5,889   5,906 
Other loans
          38   2,310   2,348 
Total
         $11,645  $82,813  $94,458