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Loans and Related Allowance for Credit Losses

12 Months Ended

Dec. 31, 2020

LOANS AND RELATED ALLOWANCE FOR CREDIT LOSSES

Loan Portfolio

Our loan portfolio consists of two portfolio segments – Commercial and Consumer. Each of these segments comprises multiple loan classes. Classes are characterized by similarities in risk attributes and the manner in which we monitor and assess credit risk.


Commercial						Consumer

• Commercial and industrial						• Home equity
• Commercial real estate						• Residential real estate
• Equipment lease financing						• Automobile
						• Credit card
						• Education
						• Other consumer

See Note 1 Accounting Policies for additional information on our loan related policies.

Credit Quality

We closely monitor economic conditions and loan performance trends to manage and evaluate our exposure to credit risk within the loan portfolio based on our defined loan classes. In doing so, we use several credit quality indicators, including trends in delinquency rates, nonperforming status, analysis of PD and LGD ratings, updated credit scores, and originated and updated LTV ratios.

The measurement of delinquency status is based on the contractual terms of each loan. Loans that are 30 days or more past due in terms of payment are considered delinquent. With the adoption of the CECL standard, accruing loans past due as of December 31, 2020 include PCD loans, while amounts as of December 31, 2019 excluded purchased impaired loans. See Note 1 Accounting Policies for additional information related to the adoption of this standard, including the discontinuation of purchased impaired loan accounting.

The following table presents the composition and delinquency status of our loan portfolio at December 31, 2020 and 2019. Pursuant to the interagency guidance issued in April 2020 and in connection with the credit reporting rules from the CARES Act, the December 31, 2020 delinquency status of loans modified due to COVID-19 related hardships aligns with the rules set forth for banks to report delinquency status to the credit agencies. These rules require that COVID-19 related loan modifications be reported as follows:

•if current at the time of modification, the loan remains current throughout the modification period,

•if delinquent at the time of modification and the borrower was not made current as part of the modification, the loan maintains its reported delinquent status during the modification period, or

•if delinquent at the time of modification and the borrower was made current as part of the modification or became current during the modification period, the loan is reported as current.

As a result, certain loans modified due to COVID-19 related hardships are not being reported as past due as of December 31, 2020 based on the contractual terms of the loan, even where borrowers may not be making payments on their loans during the modification period. Loan modifications due to COVID-19 related hardships that permanently reduce either the contractual interest rate or the principal balance of a loan do not qualify for TDR relief under the CARES Act or the interagency guidance.

Table 47: Analysis of Loan Portfolio


	Accruing
Dollars in millions	Current or Less Than 30 Days Past Due			30-59 Days Past Due			60-89 Days Past Due			90 Days Or More Past Due			Total Past Due (c)				Nonperforming Loans			Fair Value Option Nonaccrual Loans (d)			Total Loans (e)(f)
December 31, 2020 (a) (b)
Commercial
Commercial and industrial	$	131,245		$	106		$	26		$	30		$	162			$	666					$	132,073
Commercial real estate	28,485			6			1						7				224						28,716
Equipment lease financing	6,345			31			5						36				33						6,414
Total commercial	166,075			143			32			30			205				923						167,203
Consumer
Home equity	23,318			50			21						71				645			$	54		24,088
Residential real estate	20,945			181			78			319			578			(c)	528			509			22,560
Automobile	13,863			134			34			12			180				175						14,218
Credit card	6,074			43			30			60			133				8						6,215
Education	2,785			55			29			77			161			(c)							2,946
Other consumer	4,656			14			10			11			35				7						4,698
Total consumer	71,641			477			202			479			1,158				1,363			563			74,725
Total	$	237,716		$	620		$	234		$	509		$	1,363			$	2,286		$	563		$	241,928
Percentage of total loans	98.27		%	0.26		%	0.10		%	0.21		%	0.56		%		0.94		%	0.23		%	100.00		%

(a)Amounts in table represent loans held for investment and do not include any associated valuation allowance.

(b)The accrued interest associated with our loan portfolio at December 31, 2020 totaled $0.7 billion and is included in Other assets on the Consolidated Balance Sheet.

(c)Past due loan amounts include government insured or guaranteed Residential real estate loans and Education loans totaling $0.4 billion and $0.2 billion, respectively, at December 31, 2020.

(d)Consumer loans accounted for under the fair value option for which we do not expect to collect substantially all principal and interest are subject to nonaccrual accounting and classification upon meeting any of our nonaccrual policies. Given that these loans are not accounted for at amortized cost, these loans have been excluded from the nonperforming loan population.

(e)Net of unearned income, unamortized deferred fees and costs on originated loans, and premiums or discounts on purchased loans totaling $1.3 billion at December 31, 2020.

(f)Collateral dependent loans totaled $1.5 billion at December 31, 2020. The majority of these loans are within the Home equity and Residential real estate loan classes and are secured by consumer real estate.


	Accruing
Dollars in millions	Current or Less Than 30 Days Past Due			30-59 Days Past Due			60-89 Days Past Due			90 Days Or More Past Due			Total Past Due (h)				Nonperforming Loans			Fair Value Option Nonaccrual Loans (i)			Purchased Impaired Loans			Total Loans (j)
December 31, 2019 (g)
Commercial
Commercial and industrial	$	124,695		$	102		$	30		$	85		$	217			$	425								$	125,337
Commercial real estate	28,061			4			1						5				44									28,110
Equipment lease financing	7,069			49			5						54				32									7,155
Total commercial	159,825			155			36			85			276				501									160,602
Consumer
Home equity	23,791			58			24						82				669						$	543		25,085
Residential real estate	19,640			140			69			315			524			(h)	315			$	166		1,176			21,821
Automobile	16,376			178			47			18			243				135									16,754
Credit card	7,133			60			37			67			164				11									7,308
Education	3,156			55			34			91			180			(h)										3,336
Other consumer	4,898			15			11			9			35				4									4,937
Total consumer	74,994			506			222			500			1,228				1,134			166			1,719			79,241
Total	$	234,819		$	661		$	258		$	585		$	1,504			$	1,635		$	166		$	1,719		$	239,843
Percentage of total loans	97.90		%	0.28		%	0.11		%	0.24		%	0.63		%		0.68		%	0.07		%	0.72		%	100.00		%

(g) Amounts in table represent recorded investment and exclude loans held for sale. Recorded investment does not include any associated valuation allowance.

(h) Past due loan amounts exclude purchased impaired loans, even if contractually past due (or if we do not expect to receive payment in full based on the original contractual terms), as we accreted interest income over the expected life of the loans. Past due loan amounts include government insured or guaranteed Residential real estate loans totaling $0.4 billion and Education loans totaling $0.2 billion at December 31, 2019.

(i) Consumer loans accounted for under the fair value option for which we do not expect to collect substantially all principal and interest are subject to nonaccrual accounting and classification upon meeting any of our nonaccrual policies. Given that these loans are not accounted for at amortized cost, these loans have been excluded from the nonperforming loan population.

(j) Net of unearned income, unamortized deferred fees and costs on originated loans, and premiums or discounts on purchased loans totaling $1.1 billion at December 31, 2019.

In the normal course of business, we originate or purchase loan products with contractual characteristics that, when concentrated, may

increase our exposure as a holder of those loan products. Possible product features that may create a concentration of credit risk would

include a high original or updated LTV ratio, terms that may expose the borrower to future increases in repayments

above increases in market interest rates, and interest-only loans, among others.

We originate interest-only loans to commercial borrowers. Such credit arrangements are usually designed to match borrower cash flow

expectations (e.g., working capital lines, revolvers). These products are standard in the financial services industry and product features are considered during the underwriting process to mitigate the increased risk that the interest-only feature may result in borrowers not

being able to make interest and principal payments when due. We do not believe that these product features create a concentration of

credit risk.

At December 31, 2020, we pledged $30.1 billion of commercial loans to the Federal Reserve Bank and $69.0 billion of residential real estate and other loans to the Federal Home Loan Bank as collateral for the ability to borrow, if necessary. The comparable amounts at December 31, 2019 were $16.9 billion and $68.0 billion, respectively. Amounts pledged reflect the unpaid principal balances.

Nonperforming Assets

Nonperforming assets include nonperforming loans and leases, OREO and foreclosed assets. Nonperforming loans are those loans accounted for at amortized cost whose credit quality has deteriorated to the extent that full collection of contractual principal and interest is not probable. Interest income is not recognized on these loans. Loans accounted for under the fair value option are reported as performing loans, however, when nonaccrual criteria is met interest income is not recognized on these loans. Additionally, certain government insured or guaranteed loans for which we expect to collect substantially all principal and interest are not reported as nonperforming loans and continue to accrue interest.

With the adoption of the CECL standard, nonperforming loans as of December 31, 2020 include PCD loans. Amounts as of December 31, 2019 excluded purchased impaired loans as we were accreting interest income over the expected life of the loans. See Note 1 Accounting Policies for additional information related to the adoption of this standard and our nonperforming loan and lease policies.

The following table presents our nonperforming assets as of December 31, 2020 and 2019, respectively.

Table 48: Nonperforming Assets


Dollars in millions	December 31 2020			December 31 2019
Nonperforming loans
Commercial	$	923		$	501
Consumer (a)	1,363			1,134
Total nonperforming loans (b)	2,286			1,635
OREO and foreclosed assets	51			117
Total nonperforming assets	$	2,337		$	1,752
Nonperforming loans to total loans	0.94		%	0.68		%
Nonperforming assets to total loans, OREO and foreclosed assets	0.97		%	0.73		%
Nonperforming assets to total assets	0.50		%	0.43		%

(a)Excludes most unsecured consumer loans and lines of credit, which are charged off after 120 to 180 days past due and are not placed on nonperforming status.

(b)Nonperforming loans for which there is no related ALLL totaled $0.8 billion at December 31, 2020, and is primarily comprised of loans with a valuation that exceeds the amortized cost basis.

Nonperforming loans also include certain loans whose terms have been restructured in a manner that grants a concession to a borrower experiencing financial difficulties. In accordance with applicable accounting guidance, these loans are considered TDRs. See Note 1 Accounting Policies and the TDR section of this Note 4 for additional information on TDRs.

Total nonperforming loans in Table 48 include TDRs of $0.9 billion at both December 31, 2020 and 2019, respectively. TDRs that are performing, including consumer credit card TDR loans, totaled $0.7 billion and $0.8 billion at December 31, 2020 and 2019 and are excluded from nonperforming loans.

Additional Credit Quality Indicators by Loan Class

Commercial and Industrial

For commercial and industrial loans, we monitor the performance of the borrower in a disciplined and regular manner based upon the level of credit risk inherent in the loan. To evaluate the level of credit risk, we assign an internal risk rating reflecting the borrower’s PD and LGD. This two-dimensional credit risk rating methodology provides granularity in the risk monitoring process. These ratings

are reviewed and updated, generally at least once per year. For small balance homogeneous pools of commercial and industrial loans and leases, we apply scoring techniques to assist in determining the PD. The combination of the PD and LGD ratings assigned to commercial and industrial loans, capturing both the combination of expectations of default and loss severity in the event of default, reflects credit quality characteristics as of the reporting date and are used as inputs into our loss forecasting process.

Based upon the amount of the lending arrangement and our risk rating assessment, we follow a formal schedule of written periodic reviews. Quarterly, we conduct formal reviews of a market’s or business unit’s loan portfolio, focusing on those loans which we perceive to be of higher risk, based upon PDs and LGDs, or loans for which credit quality is weakening. If circumstances warrant, it is our practice to review any customer obligation and its level of credit risk more frequently. We attempt to proactively manage our loans by using various procedures that are customized to the risk of a given loan, including ongoing outreach, contact, and assessment of obligor financial conditions, collateral inspection and appraisal.

Commercial Real Estate

We manage credit risk associated with our commercial real estate projects and commercial mortgages similar to commercial and industrial loans by evaluating PD and LGD. Risks associated with commercial real estate projects and commercial mortgage activities tend to be correlated to the loan structure and collateral location, project progress and business environment. As a result, these attributes are also monitored and utilized in assessing credit risk.

As with the commercial and industrial loan class, a formal schedule of periodic reviews is also performed to assess market/geographic risk and business unit/industry risk. Often as a result of these overviews, more in-depth reviews and increased scrutiny are placed on areas of higher risk, such as adverse changes in risk ratings, deteriorating operating trends, and/or areas that concern management. These reviews are designed to assess risk and facilitate actions to mitigate such risks.

Equipment Lease Financing

We manage credit risk associated with our equipment lease financing loan class similar to commercial and industrial loans by analyzing PD and LGD.

Based upon the dollar amount of the lease and the level of credit risk, we follow a formal schedule of periodic reviews. Generally, this occurs quarterly, although we have established practices to review such credit risk more frequently if circumstances warrant. Our review process entails analysis of the following factors: equipment value/residual value, exposure levels, jurisdiction risk, industry risk, guarantor requirements, and regulatory compliance as applicable.

Table 49: Commercial Credit Quality Indicators (a)


	Term Loans by Origination Year
December 31, 2020 - In millions	2020		2019		2018		2017		2016		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Commercial and industrial
Pass Rated	$	31,680	$	13,340	$	8,209	$	5,956	$	4,242	$	7,141	$	54,775	$	53	$	125,396
Criticized	339		702		578		334		224		351		4,130		19		6,677
Total commercial and industrial	32,019		14,042		8,787		6,290		4,466		7,492		58,905		72		132,073
Commercial real estate
Pass Rated	3,709		6,268		3,426		2,841		2,341		6,792		218				25,595
Criticized	319		548		148		423		400		1,159		124				3,121
Total commercial real estate	4,028		6,816		3,574		3,264		2,741		7,951		342				28,716
Equipment lease financing
Pass Rated	1,429		1,202		942		738		405		1,350						6,066
Criticized	78		92		86		39		22		31						348
Total equipment lease financing	1,507		1,294		1,028		777		427		1,381						6,414
Total commercial	$	37,554	$	22,152	$	13,389	$	10,331	$	7,634	$	16,824	$	59,247	$	72	$	167,203


December 31, 2019 - In millions	Pass Rated		Criticized		Total Loans
Commercial and industrial	$	119,761	$	5,576	$	125,337
Commercial real estate	27,424		686		28,110
Equipment lease financing	6,891		264		7,155
Total commercial	$	154,076	$	6,526	$	160,602

(a)Loans in our commercial portfolio are classified as Pass Rated or Criticized based on the regulatory definitions, which are driven by the PD and LGD ratings that we assign. The Criticized classification includes loans that were rated special mention, substandard or doubtful as of December 31, 2020 and 2019.

Home Equity and Residential Real Estate

We use several credit quality indicators, including delinquency information, nonperforming loan information, updated credit scores, originated and updated LTV ratios, to monitor and manage credit risk within the home equity and residential real estate loan classes. A summary of credit quality indicators follows:

Delinquency/Delinquency Rates: We monitor trending of delinquency/delinquency rates for home equity and residential real estate loans. See Table 47 for additional information.

Nonperforming Loans: We monitor trending of nonperforming loans for home equity and residential real estate loans. See Table 47 for additional information.

Credit Scores: We use a national third-party provider to update FICO credit scores for home equity and residential real estate loans at least quarterly. The updated scores are incorporated into a series of credit management reports, which are utilized to monitor the risk in the loan classes.

LTV (inclusive of CLTV for first and subordinate lien positions): At least quarterly, we update the property values of real estate collateral and calculate an updated LTV ratio. For open-end credit lines secured by real estate in regions experiencing significant declines in property values, more frequent valuations may occur. We examine LTV migration and stratify LTV into categories to monitor the risk in the loan classes.

We use a combination of original LTV and updated LTV for internal risk management and reporting purposes (e.g., line management, loss mitigation strategies). In addition to the fact that estimated property values by their nature are estimates, given certain data limitations, it is important to note that updated LTVs may be based upon management’s assumptions (i.e., if an updated LTV is not provided by the third-party service provider, HPI changes will be incorporated in arriving at management’s estimate of updated LTV).

Updated LTV is estimated using modeled property values. The related estimates and inputs are based upon an approach that uses a combination of third-party automated valuation models, broker price opinions, HPI indices, property location, internal and external balance information, origination data and management assumptions. We generally utilize origination lien balances provided by a third-party, where applicable, which do not include an amortization assumption when calculating updated LTV. Accordingly, the results of

the calculations do not represent actual appraised loan level collateral or updated LTV based upon lien balances held by others, and as such, are necessarily imprecise and subject to change as we refine our methodology.

The following table presents credit quality indicators for the home equity and residential real estate loan classes:

Table 50: Home Equity and Residential Real Estate Credit Quality Indicators


	Term Loans by Origination Year
December 31, 2020 - In millions	2020		2019		2018		2017		2016		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Home equity
Current estimated LTV ratios																	.
Greater than 100%	$	8	$	44	$	18	$	15	$	9	$	88	$	580	$	279	$	1,041
Greater than or equal to 80% to 100%	517		320		59		42		25		158		1,781		591		3,493
Less than 80%	2,909		1,636		513		773		660		3,754		6,433		2,876		19,554
Total home equity	$	3,434	$	2,000	$	590	$	830	$	694	$	4,000	$	8,794	$	3,746	$	24,088
Updated FICO scores
Greater than or equal to 780	$	2,019	$	1,094	$	311	$	525	$	449	$	2,467	$	5,382	$	1,480	$	13,727
720 to 779	1,028		558		153		181		145		777		2,137		941		5,920
660 to 719	334		273		86		84		66		402		985		625		2,855
Less than 660	52		74		39		39		33		345		277		620		1,479
No FICO score available	1		1		1		1		1		9		13		80		107
Total home equity	$	3,434	$	2,000	$	590	$	830	$	694	$	4,000	$	8,794	$	3,746	$	24,088
Residential real estate
Current estimated LTV ratios
Greater than 100%	$	3	$	52	$	26	$	42	$	41	$	160					$	324
Greater than or equal to 80% to 100%	495		422		127		156		124		307						1,631
Less than 80%	7,491		3,656		992		1,706		1,847		3,991						19,683
Government insured or guaranteed loans	7		28		27		38		57		765						922
Total residential real estate	$	7,996	$	4,158	$	1,172	$	1,942	$	2,069	$	5,223					$	22,560
Updated FICO scores
Greater than or equal to 780	$	5,425	$	3,099	$	814	$	1,432	$	1,538	$	2,551					$	14,859
720 to 779	2,268		820		220		340		335		818						4,801
660 to 719	252		161		76		98		92		475						1,154
Less than 660	40		48		33		31		41		485						678
No FICO score available	4		2		2		3		6		129						146
Government insured or guaranteed loans	7		28		27		38		57		765						922
Total residential real estate	$	7,996	$	4,158	$	1,172	$	1,942	$	2,069	$	5,223					$	22,560


	Home equity		Residential real estate
December 31, 2019 - In millions
Current estimated LTV ratios
Greater than or equal to 100%	$	1,243	$	333
Greater than or equal to 90% to less than 100%	1,047		340
Less than 90%	22,068		19,305
No LTV ratio available	184		83
Government insured or guaranteed loans			584
Purchased impaired loans	543		1,176
Total loans	$	25,085	$	21,821
Updated FICO Scores
Greater than 660	$	22,245	$	19,341
Less than or equal to 660	2,019		569
No FICO score available	278		151
Government insured or guaranteed loans			584
Purchased impaired loans	543		1,176
Total loans	$	25,085	$	21,821

Automobile, Credit Card, Education and Other Consumer

We monitor a variety of credit quality information in the management of these consumer loan classes. For all loan types, we generally use a combination of internal loan parameters as well as an updated FICO score. We use FICO scores as a primary credit quality indicator for automobile and credit card loans, as well as non-government guaranteed or non-insured education loans and other secured and unsecured lines and loans. Internal credit metrics, such as delinquency status, are heavily relied upon as credit quality indicators for government guaranteed or insured education loans and consumer loans to high net worth individuals, as internal credit metrics are more relevant than FICO scores for these types of loans.

Along with the monitoring of delinquency trends and losses for each class, FICO credit score updates are obtained at least quarterly along with a variety of credit bureau attributes. Loans with high FICO scores tend to have a lower likelihood of loss. Conversely, loans with low FICO scores tend to have a higher likelihood of loss.

The following table presents credit quality indicators for the automobile, credit card, education and other consumer loan classes:

Table 51: Credit Quality Indicators for Automobile, Credit Card, Education and Other Consumer Loan Classes


	Term Loans by Origination Year
December 31, 2020 - In millions	2020		2019		2018		2017		2016		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Updated FICO Scores
Automobile
FICO score greater than or equal to 780	$	1,807	$	1,915	$	807	$	452	$	246	$	58					$	5,285
720 to 779	1,098		1,581		789		381		167		44						4,060
660 to 719	617		1,222		684		288		109		31						2,951
Less than 660	192		776		598		240		87		29						1,922
Total automobile	$	3,714	$	5,494	$	2,878	$	1,361	$	609	$	162					$	14,218
Credit card
FICO score greater than or equal to 780													$	1,635	$	3	$	1,638
720 to 779													1,724		11		1,735
660 to 719													1,765		26		1,791
Less than 660													902		51		953
No FICO score available or required (a)													94		4		98
Total credit card													$	6,120	$	95	$	6,215
Education
FICO score greater than or equal to 780	$	34	$	90	$	74	$	59	$	50	$	428					$	735
720 to 779	24		46		38		28		20		190						346
660 to 719	15		15		14		9		6		90						149
Less than 660	3		2		3		2		2		37						49
No FICO score available or required (a)	16		10		6		3				1						36
Total loans using FICO credit metric	92		163		135		101		78		746						1,315
Other internal credit metrics											1,631						1,631
Total education	$	92	$	163	$	135	$	101	$	78	$	2,377					$	2,946
Other consumer
FICO score greater than or equal to 780	$	162	$	187	$	63	$	21	$	5	$	42	$	86	$	1	$	567
720 to 779	197		247		82		22		5		22		123				698
660 to 719	127		210		81		17		3		14		117		1		570
Less than 660	28		86		41		9		2		8		53		1		228
Total loans using FICO credit metric	514		730		267		69		15		86		379		3		2,063
Other internal credit metrics	67		33		37		26		60		75		2,334		3		2,635
Total other consumer	$	581	$	763	$	304	$	95	$	75	$	161	$	2,713	$	6	$	4,698


December 31, 2019 - In millions	Automobile		Credit Card		Education		Other consumer
FICO score greater than 719	$	9,232	$3,867		$	1,139	$1,421
650 to 719	4,577		2,326		197		843
620 to 649	1,001		419		25		132
Less than 620	1,603		544		27		143
No FICO score available or required (a)	341		152		15		27
Total loans using FICO credit metric	16,754		7,308		1,403		2,566
Consumer loans using other internal credit metrics					1,933		2,371
Total loans	$	16,754	$	7,308	$	3,336	$	4,937
Weighted-average updated FICO score (b)	726		724		773		727

(a)Loans with no FICO score available or required generally refers to new accounts issued to borrowers with limited credit history, accounts for which we cannot obtain an updated FICO score (e.g., recent profile changes), cards issued with a business name and/or cards secured by collateral. Management proactively assesses the risk and size of this loan category and, when necessary, takes actions to mitigate the credit risk.

(b)Weighted-average updated FICO score excludes accounts with no FICO score available or required.

Troubled Debt Restructurings

A TDR is a loan whose terms have been restructured in a manner that grants a concession to a borrower experiencing financial difficulty. Loans that have been restructured for COVID-19 related hardships and meet certain criteria under the CARES Act are not categorized as TDRs. See Note 1 Accounting Policies for additional information related to TDRs.

Table 52 quantifies the number of loans that were classified as TDRs as well as the change in the loans’ balance as a result of becoming a TDR during 2020, 2019 and 2018. Additionally, the table provides information about the types of TDR concessions. The Principal Forgiveness TDR category includes principal forgiveness and accrued interest forgiveness. The Rate Reduction TDR category includes reduced interest rate and interest deferral. The Other TDR category primarily includes consumer borrowers that have been discharged from personal liability through Chapter 7 bankruptcy and have not formally reaffirmed their loan obligations to us, as well as postponement/reduction of scheduled amortization and contractual extensions for both consumer and commercial borrowers.

In some cases, there have been multiple concessions granted on one loan. This is most common within the commercial loan portfolio. When there have been multiple concessions granted in the commercial loan portfolio, the principal forgiveness concession was prioritized for purposes of determining the inclusion in Table 52. Second in priority would be rate reduction. In the event that multiple concessions are granted on a consumer loan, concessions resulting from discharge from personal liability through Chapter 7 bankruptcy without formal affirmation of the loan obligations to us would be prioritized and included in the Other type of concession in Table 52. After that, consumer loan concessions would follow the previously discussed priority of concessions for the commercial loan portfolio.

Table 52: Financial Impact and TDRs by Concession Type


	Number of Loans	Pre-TDR Amortized Cost Basis (b)		Post-TDR Amortized Cost Basis (c)
During the year ended December 31, 2020 (a) Dollars in millions				Principal Forgiveness		Rate Reduction		Other		Total
Commercial	73	$	513	$	39	$	56	$	346	$	441
Consumer	12,270	178				88		73		161
Total TDRs	12,343	$	691	$	39	$	144	$	419	$	602

(a)Impact of partial charge-offs at TDR date are included in this table.

(b)Represents the amortized cost basis of the loans as of the quarter end prior to TDR designation.

(c)Represents the amortized cost basis of the TDRs as of the end of the quarter in which the TDR occurs.


			Pre-TDR Recorded Investment (e)		Post-TDR Recorded Investment (f)
During the year ended December 31, 2019 (d) Dollars in millions	Number of Loans				Principal Forgiveness		Rate Reduction		Other		Total
Commercial		75	$	278			$	11	$	241	$	252
Consumer		14,548	172				97		64		161
Total TDRs		14,623	$	450			$	108	$	305	$	413
During the year ended December 31, 2018 (d) Dollars in millions
Commercial		85	$	272	$	2	$	67	$	179	$	248
Consumer		12,096	163		1		86		63		150
Total TDRs		12,181	$	435	$	3	$	153	$	242	$	398

(d) Impact of partial charge-offs at TDR date are included in this table.

(e) Represents the recorded investment of the loans as of the quarter end prior to TDR designation, and excludes immaterial amounts of accrued interest receivable.

(f) Represents the recorded investment of the TDRs as of the end of the quarter in which the TDR occurs, and excludes immaterial amounts of accrued interest receivable.

After a loan is determined to be a TDR, we continue to track its performance under its most recent restructured terms. We consider a TDR to have subsequently defaulted when it becomes 60 days past due after the most recent date the loan was restructured. Loans that were both (i) classified as TDRs, and (ii) subsequently defaulted during the period totaled $0.1 billion for each of the years ended December 31, 2020, 2019 and 2018, respectively.

Allowance for Credit Losses

We maintain the ACL related to loans at levels that we believe to be appropriate to absorb expected credit losses in the portfolios as of the balance sheet date. See Note 1 Accounting Policies for a discussion of the methodologies used to determine this allowance. A rollforward of the ACL related to loans follows:

Table 53: Rollforward of Allowance for Credit Losses (a)


At or for the year ended December 31	2020
In millions	Commercial		Consumer		Total
Allowance for loan and lease losses
Beginning balance	$	1,812	$	930	$	2,742
Adoption of ASU 2016-13 (b)	(304)		767		463
Beginning balance, adjusted	1,508		1,697		3,205
Charge-offs	(407)		(785)		(1,192)
Recoveries	94		266		360
Net (charge-offs)	(313)		(519)		(832)
Provision for credit losses	2,139		846		2,985
Other	3				3
Ending balance	$	3,337	$	2,024	$	5,361
Allowance for unfunded lending related commitments (c)
Beginning balance	$	316	$	2	$	318
Adoption of ASU 2016-13 (b)	53		126		179
Beginning balance, adjusted	369		128		497
Provision for (recapture of) credit losses	116		(29)		87
Ending balance	$	485	$	99	$	584
Allowance for credit losses at December 31	$	3,822	$	2,123	$	5,945

(a) Excludes allowances for investment securities and other financial assets, which together totaled $109 million at December 31, 2020.

(b) Represents the impact of adopting ASU 2016-13, Financial Instruments - Credit Losses on January 1, 2020 and our transition from an incurred loss methodology for our reserves to an expected credit loss methodology.

The following presents an analysis of changes impacting the ACL related to loans for the year ended December 31, 2020:

Table 54: Analysis of Changes in the Allowance for Credit Losses (a)

In millions

(a) Excludes allowances for investment securities and other financial assets, which together totaled $109 million at December 31, 2020.

(b) Portfolio changes primarily represent the impact of increases/decreases in loan balances, age and mix due to new originations/purchases, as well as credit quality and net charge-off activity.

(c) Economic and qualitative factors primarily represent our evaluation and determination of an economic forecast applied to our loan portfolio, which is based on a three year forecast period and the use of four economic scenarios with associated probability weights, as well as updates to qualitative factor adjustments.

The $2.2 billion increase in the ACL since January 1, 2020 was driven by the following factors in the commercial and consumer portfolios:

•Commercial reserves increased $1.9 billion attributable to the significantly adverse economic impacts of the pandemic and its resulting effects on credit quality and loan growth.

•Consumer reserves increased $0.3 billion primarily reflecting the significantly adverse economic impacts of the pandemic.

Allowance for Loan and Lease Losses

Prior to January 1, 2020, we maintained our ALLL at levels we believed to be appropriate to absorb estimated probable credit losses incurred in the portfolios as of the balance sheet date. We used the two main portfolio segments - Commercial and Consumer, and developed and documented the ALLL under separate methodologies for each of these portfolio segments. See Note 1 Accounting Policies for a summary of the accounting policies for ALLL prior to the adoption of CECL.

A rollforward of the ALLL and associated loan data follows:

Table 55: Rollforward of Allowance for Loan and Lease Losses and Associated Loan Data


At or for the year ended December 31	2019						2018
Dollars in millions	Commercial		Consumer		Total		Commercial		Consumer		Total
Allowance for loan and lease losses
January 1	$	1,663	$	966	$	2,629	$	1,582	$	1,029	$	2,611
Charge-offs	(216)		(758)		(974)		(124)		(640)		(764)
Recoveries	78		254		332		99		245		344
Net (charge-offs)	(138)		(504)		(642)		(25)		(395)		(420)
Provision for credit losses	320		453		773		97		311		408
Net (increase) / decrease in allowance for unfunded loan commitments and letters of credit	(34)		1		(33)		11		1		12
Other	1		14		15		(2)		20		18
December 31	$	1,812	$	930	$	2,742	$	1,663	$	966	$	2,629
TDRs individually evaluated for impairment	$	40	$	93	$	133	$	25	$	136	$	161
Other loans individually evaluated for impairment	58				58		48				48
Loans collectively evaluated for impairment	1,714		563		2,277		1,590		555		2,145
Purchased impaired loans			274		274				275		275
December 31	$	1,812	$	930	$	2,742	$	1,663	$	966	$	2,629
Loan portfolio
TDRs individually evaluated for impairment	$	361	$	1,303	$	1,664	$	409	$	1,442	$	1,851
Other loans individually evaluated for impairment	220				220		232				232
Loans collectively evaluated for impairment	160,021		75,477		235,498		151,641		69,722		221,363
Fair value option loans (a)			742		742				782		782
Purchased impaired loans			1,719		1,719				2,017		2,017
December 31	$	160,602	$	79,241	$	239,843	$	152,282	$	73,963	$	226,245

(a)Loans accounted for under the fair value option were not evaluated for impairment as these loans are accounted for at fair value. Accordingly, there was no allowance recorded on those loans.