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Loans and Related Allowance for Credit Losses
 12 Months Ended
Dec. 31, 2021
Asset Quality [Abstract]  
Loans and Related Allowance for Credit Losses 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.
CommercialConsumer
• Commercial and industrial
• Residential real estate
• Commercial real estate
• Home equity
• 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. Loan delinquencies include government insured or guaranteed loans, loans accounted for under the fair value option and PCD loans.

Table 50 presents the composition and delinquency status of our loan portfolio at December 31, 2021 and 2020. We manage credit risk based on the risk profile of the borrower, repayment sources, underlying collateral and other support given current events, economic conditions and expectations. We refine our practices to meet the changing environment and the continuing effects of the COVID-19 pandemic. To mitigate losses and enhance customer support, we have customer assistance, loan modification and collection programs that align with the CARES Act and subsequent interagency guidance.

As a result, under the CARES Act credit reporting rules, certain loans modified due to COVID-19 related hardships are not being reported as past due as of December 31, 2021 and 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 50: Analysis of Loan Portfolio (a) (b)

 Accruing    
Dollars in millionsCurrent 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, 2021 
Commercial 
Commercial and industrial$151,698 $235 $72 $132 $439   $796 $152,933 
Commercial real estate33,580 46 24 1 71   364 34,015 
Equipment lease financing6,095 25 2 27   8 6,130 
Total commercial191,373 306 98 133 537   1,168 193,078 
Consumer 
Residential real estate37,706 379 119 328 826 (c)517 $663 39,712 
Home equity23,305 53 18 71 596 89 24,061 
Automobile16,252 146 40 14 200   183 16,635 
Credit card6,475 49 33 62 144   7 6,626 
Education2,400 43 25 65 133 (c)2,533 
Other consumer5,644 35 22 17 74  9 5,727 
Total consumer91,782 705 257 486 1,448   1,312 752 95,294 
Total$283,155 $1,011 $355 $619 $1,985   $2,480 $752 $288,372 
Percentage of total loans98.19 %0.35 %0.12 %0.21 %0.69 %0.86 %0.26 %100.00 %
December 31, 2020
Commercial
Commercial and industrial$131,245 $106 $26 $30 $162 $666 $132,073 
Commercial real estate28,485 6 1 7 224 28,716 
Equipment lease financing6,345 31 5 36 33 6,414 
Total commercial166,075 143 32 30 205 923 167,203 
Consumer
Residential real estate20,945 181 78 319 578 (c)528 $509 22,560 
Home equity23,318 50 21 71 645 54 24,088 
Automobile13,863 134 34 12 180 175 14,218 
Credit card6,074 43 30 60 133 8 6,215 
Education2,785 55 29 77 161 (c)2,946 
Other consumer4,656 14 10 11 35 7 4,698 
Total consumer71,641 477 202 479 1,158 1,363 563 74,725 
Total$237,716 $620 $234 $509 $1,363 $2,286 $563 $241,928 
Percentage of total loans98.27 %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 ALLL.
(b)The accrued interest associated with our loan portfolio totaled $0.7 billion at both December 31, 2021 and 2020. These amounts are 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 $0.1 billion at December 31, 2021. Comparable amounts at December 31, 2020 were $0.4 billion and $0.2 billion.
(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)Includes unearned income, unamortized deferred fees and costs on originated loans and premiums or discounts on purchased loans totaling $0.7 billion and $1.3 billion at December 31, 2021 and 2020, respectively.
(f)Collateral dependent loans totaled $1.7 billion and $1.5 billion at December 31, 2021 and 2020, respectively.
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, 2021, we pledged $25.7 billion of commercial and other loans to the Federal Reserve Bank and $66.2 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, 2020 were $30.1 billion and $69.0 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 and include nonperforming TDRs and PCD loans. 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. See Note 1 Accounting Policies for additional information on our nonperforming loan and lease policies.
The following table presents our nonperforming assets as of December 31, 2021 and 2020, respectively.

Table 51: Nonperforming Assets
Dollars in millionsDecember 31
2021		December 31
2020
Nonperforming loans
Commercial$1,168 $923 
Consumer (a)1,312 1,363 
Total nonperforming loans (b) 2,480 2,286 
OREO and foreclosed assets26 51 
Total nonperforming assets$2,506 $2,337 
Nonperforming loans to total loans0.86 %0.94 %
Nonperforming assets to total loans, OREO and foreclosed assets0.87 %0.97 %
Nonperforming assets to total assets0.45 %0.50 %
(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 $1.0 billion at December 31, 2021 and primarily include loans with a fair value of collateral that exceeds the amortized cost basis. The comparable amount at December 31, 2020 was $0.8 billion.

Nonperforming loans 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 Troubled Debt Restructurings section of this Note 4 for additional information on TDRs.

Total nonperforming loans in Table 51 include TDRs of $1.0 billion and $0.9 billion at December 31, 2021 and 2020, respectively. TDRs that are performing, including consumer credit card TDR loans, totaled $0.6 billion and $0.7 billion at December 31, 2021 and 2020 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 reviews, 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.
The following table presents credit quality indicators for the commercial loan classes:

Table 52: Commercial Credit Quality Indicators (a)

Term Loans by Origination Year
December 31, 2021
In millions
20212020201920182017PriorRevolving LoansRevolving Loans Converted to TermTotal
Loans
Commercial and industrial
Pass Rated$27,104 $12,053 $10,731 $6,698 $6,355 $11,759 $71,230 $90 $146,020 
Criticized283 368 815 649 496 824 3,448 30 6,913 
Total commercial and industrial27,38712,42111,5467,3476,85112,58374,678120152,933
Commercial real estate
Pass Rated4,110 4,109 6,355 4,234 2,634 7,562 436 29,440 
Criticized294 298 999 820 566 1,552 46 4,575 
Total commercial real estate4,4044,4077,3545,0543,2009,11448234,015
Equipment lease financing
Pass Rated1,212 1,190 942 682 507 1,410 5,943 
Criticized37 54 41 29 19 7 187 
Total equipment lease financing1,2491,244 9837115261,4176,130
Total commercial$33,040 $18,072 $19,883 $13,112 $10,577 $23,114 $75,160 $120 $193,078 

 Term Loans by Origination Year  
December 31, 2020
In millions
20202019201820172016PriorRevolving LoansRevolving Loans Converted to TermTotal
Loans
Commercial and industrial
Pass Rated$31,680 $13,340 $8,209 $5,956 $4,242 $7,141 $54,775 $53 $125,396 
Criticized339702 578 334 224 351 4,130 19 6,677 
Total commercial and industrial32,019 14,042 8,787 6,290 4,466 7,492 58,905 72 132,073 
Commercial real estate
Pass Rated3,709 6,268 3,426 2,841 2,341 6,792 218 25,595 
Criticized319 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 Rated1,429 1,202 942 738 405 1,350 6,066 
Criticized78 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 
(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, 2021 and 2020.

Residential Real Estate and Home Equity
We use several credit quality indicators, including delinquency information, nonperforming loan information, updated credit scores and originated and updated LTV ratios, to monitor and manage credit risk within the residential real estate and home equity loan classes. A summary of credit quality indicators follows:
Delinquency/Delinquency Rates: We monitor trending of delinquency/delinquency rates for residential real estate and home equity loans. See Table 50 for additional information.
Nonperforming Loans: We monitor trending of nonperforming loans for residential real estate and home equity loans. See Table 50 for additional information.
Credit Scores: We use a national third-party provider to update FICO credit scores for residential real estate and home equity 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 residential real estate and home equity loan classes:
Table 53: Credit Quality Indicators for Residential Real Estate and Home Equity Loan Classes
Term Loans by Origination Year
December 31, 2021
In millions
20212020201920182017PriorRevolving LoansRevolving Loans Converted to TermTotal Loans
Residential real estate
Current estimated LTV ratios
Greater than 100%$10 $52 $21 $12 $13 $77 $185 
Greater than or equal to 80% to 100%1,460 560 221 86 66 190 2,583 
Less than 80%15,213 7,822 2,834 1,004 1,570 7,385 35,828 
No LTV available275 6 1 1 22 305 
Government insured or guaranteed loans
3 33 37 30 39 669 811 
Total residential real estate
$16,961 $8,473 $3,114 $1,133 $1,688 $8,343 $39,712 
Updated FICO scores
Greater than or equal to 780$11,110 $5,898 $1,996 $596 $1,029 $4,052 $24,681 
720 to 7794,921 1,735 643 247 345 1,619 9,510 
660 to 719717 463 255 136 133 796 2,500 
Less than 66083 103 96 75 94 848 1,299 
No FICO score available
127 241 87 49 48 359 911 
Government insured or guaranteed loans
3 33 37 30 39 669 811 
Total residential real estate$16,961 $8,473 $3,114 $1,133 $1,688 $8,343 $39,712 
Home equity
Current estimated LTV ratios
Greater than 100%$1 $16 $14 $3 $2 $25 $329 $90 $480 
Greater than or equal to 80% to 100% 7 85 62 13 11 66 990 674 1,908 
Less than 80%204 2,487 1,189 370 549 3,200 7,868 5,806 21,673 
Total home equity$212 $2,588 $1,265 $386 $562 $3,291 $9,187 $6,570 $24,061 
Updated FICO scores
Greater than or equal to 780$124 $1,619 $692 $201 $364 $2,035 $5,490 $3,320 $13,845 
720 to 77961 666 348 96 116 642 2,283 1,679 5,891 
660 to 71923 248 167 56 53 327 1,071 872 2,817 
Less than 6604 5357 32 28 277 325 615 1,391 
No FICO score available
21 1 1 10 18 84 117 
Total home equity
$212 $2,588 $1,265 $386 $562 $3,291 $9,187 $6,570 $24,061 
Term Loans by Origination Year
December 31, 2020
In millions
20202019201820172016PriorRevolving LoansRevolving Loans Converted to TermTotal Loans
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 loans7 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 7792,268 820 220 340 335 818 4,801 
660 to 719252 161 76 98 92 475 1,154 
Less than 66040 48 33 31 41 485 678 
No FICO score available4 2 2 3 6 129 146 
Government insured or guaranteed loans7 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
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 7791,028 558 153 181 145 777 2,137 941 5,920 
660 to 719334 273 86 84 66 402 985 625 2,855 
Less than 66052 7439 39 33 345 277 620 1,479 
No FICO score available
1 11 1 1 9 13 80 107 
Total home equity
$3,434 $2,000 $590 $830 $694 $4,000 $8,794 $3,746 $24,088 
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 54: Credit Quality Indicators for Automobile, Credit Card, Education and Other Consumer Loan Classes

Term Loans by Origination Year
December 31, 2021
In millions
20212020201920182017PriorRevolving LoansRevolving Loans Converted to TermTotal Loans
Updated FICO Scores
Automobile
FICO score greater than or equal to 780$3,247 $1,496 $1,380 $533 $226 $79 $6,961 
720 to 7792,119 983 1,030 499 195 62 4,888 
660 to 719969 609 772 413 155 44 2,962 
Less than 660277 315 583 429 162 58 1,824 
Total automobile$6,612 $3,403 $3,765 $1,874 $738 $243 $16,635 
Credit card
FICO score greater than or equal to 780$1,815 $2 $1,817 
720 to 7791,836 9 1,845 
660 to 7191,856 19 1,875 
Less than 660943 29 972 
No FICO score available or required (a)114 3 117 
Total credit card$6,564 $62 $6,626 
Education
FICO score greater than or equal to 780$37 $60 $77 $62 $48 $392 $676 
720 to 77920 29 37 30 21 160 297 
660 to 7197 9 11 11 7 73 118 
Less than 6601 1 2 2 2 25 33 
No FICO score available or required (a)11 10 7 2 1 31 
Total loans using FICO credit metric76 109 134 107 78 651 1,155 
Other internal credit metrics 1,378 1,378 
Total education$76 $109 $134 $107 $78 $2,029 $2,533 
Other consumer
FICO score greater than or equal to 780$199 $131 $123 $47 $12 $32 $95 $1 $640 
720 to 779250 172 167 68 15 19 125 816 
660 to 719190 145 165 82 16 11 122 731 
Less than 66050 62 85 54 10 6 50 1 318 
Total loans using FICO credit metric689 510 540 251 53 68 392 2 2,505 
Other internal credit metrics 87 31 35 23 22 48 2,955 21 3,222 
Total other consumer$776 $541 $575 $274 $75 $116 $3,347 $23 $5,727 
Term Loans by Origination Year
December 31, 2020
In millions
20202019201820172016PriorRevolving LoansRevolving Loans Converted to TermTotal 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 7791,098 1,581 789 381 167 44 4,060 
660 to 719617 1,222 684 288 109 31 2,951 
Less than 660192 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 7791,724 11 1,735 
660 to 7191,765 26 1,791 
Less than 660902 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 77924 46 38 28 20 190 346 
660 to 71915 15 14 9 6 90 149 
Less than 6603 2 3 2 2 37 49 
No FICO score available or required (a)16 10 6 3 1 36 
Education loans using FICO credit metric92 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 779197 247 82 22 5 22 123 698 
660 to 719127 210 81 17 3 14 117 1 570 
Less than 66028 86 41 9 2 8 53 1 228 
Other consumer loans using FICO credit metric514 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 
(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.

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 55 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 2021, 2020 and 2019. 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 55. 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 55. After that, consumer loan concessions would follow the previously discussed priority of concessions for the commercial loan portfolio.
Table 55: 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, 2021 (a)
Dollars in millions		Principal
Forgiveness		Rate
Reduction		OtherTotal
Commercial57 $536 $6 $510 $516 
Consumer6,109 108 $64 33 97 
Total TDRs6,166 $644 $6 $64 $543 $613 
During the year ended December 31, 2020 (a)
Dollars in millions
Commercial73 $513 $39 $56 $346 $441 
Consumer12,270 178 88 73 161 
Total TDRs12,343 $691 $39 $144 $419 $602 
(a)Impact of partial charge-offs at TDR date is 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		OtherTotal
Commercial 75 $278 $11 $241 $252 
Consumer14,548 172 97 64 161 
Total TDRs14,623 $450 $108 $305 $413 
(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, 2021, 2020 and 2019, 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 56: Rollforward of Allowance for Credit Losses
At or for the year ended December 3120212020
In millionsCommercialConsumerTotalCommercialConsumerTotal
Allowance for loan and lease losses
Beginning balance$3,337 $2,024 $5,361 $1,812 $930 $2,742 
Adoption of ASU 2016-13 (a)(304)767463 
Beginning balance, adjusted3,337 2,024 5,361 1,508 1,697 3,205 
Acquisition PCD reserves774 282 1,056 
Charge-offs(434)(667)(1,101)(407)(785)(1,192)
Recoveries106 338 444 94 266 360 
Net (charge-offs) (328)(329)(657)(313)(519)(832)
Provision for (recapture of) credit losses (594)(293)(887)2,139 846 2,985 
Other(4)(1)(5)33 
Ending balance$3,185 $1,683 $4,868 $3,337 $2,024 $5,361 
Allowance for unfunded lending related commitments (b)
Beginning balance$485 $99 $584 $316 $2 $318 
Adoption of ASU 2016-13 (a)53 126 179 
Beginning balance, adjusted485 99 584 369 128 497 
Acquisition PCD reserves43 3 46 
Provision for (recapture of) credit losses36 (4)32 116 (29)87 
Ending balance$564 $98 $662 $485 $99 $584 
Allowance for credit losses at December 31 (c)$3,749 $1,781 $5,530 $3,822 $2,123 $5,945 
(a)    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.
(b)    See Note 11 Commitments for additional information about the underlying commitments related to this allowance.
(c)    Represents the ALLL plus allowance for unfunded lending related commitments and excludes allowances for investment securities and other financial assets, which together totaled $171 million and $109 million at December 31, 2021 and 2020, respectively.

The ACL related to loans at December 31, 2021 totaled $5.5 billion, a decrease of $0.4 billion since December 31, 2020. This decrease was primarily driven by the impacts from portfolio changes and an improved economic environment, partially offset by the addition of reserves related to the BBVA acquisition. The following summarizes the changes in these factors that influenced the current ACL during the year ended December 31, 2021:

•Portfolio changes that drove reserve declines included improvements in credit quality along with changes in portfolio composition reflecting both shifts in the portfolio mix and declines in certain loan balances.
•The improved economic environment was reflected in both the forecasted economic scenarios utilized in the quantitative models and the qualitative factor reserves. The economic scenarios used at December 31, 2021 were primarily driven by improvements in the outlook for both consumer spending and the labor market. Reductions in qualitative factor reserves reflect the improved economic environment's impact on specific high risk industries.
•Reserves in the current period reflect expected credit losses within the acquired BBVA loan portfolio.

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.
A rollforward of the ALLL and associated loan data follows:

Table 57: Rollforward of Allowance for Loan and Lease Losses and Associated Loan Data
At or for the year ended December 312019
Dollars in millionsCommercialConsumerTotal
Allowance for loan and lease losses
January 1$1,663 $966 $2,629 
Charge-offs(216)(758)(974)
Recoveries78 254 332 
Net (charge-offs)(138)(504)(642)
Provision for credit losses320 453 773 
Net (increase) / decrease in allowance for unfunded loan commitments and letters of credit(34)1 (33)
Other1 14 15 
December 31$1,812 $930 $2,742 
TDRs individually evaluated for impairment$40 $93 $133 
Other loans individually evaluated for impairment58 58 
Loans collectively evaluated for impairment1,714 563 2,277 
Purchased impaired loans274 274 
December 31$1,812 $930 $2,742 
Loan portfolio
TDRs individually evaluated for impairment$361 $1,303 $1,664 
Other loans individually evaluated for impairment220 220 
Loans collectively evaluated for impairment160,021 75,477 235,498 
Fair value option loans (a)742 742 
Purchased impaired loans1,719 1,719 
December 31$160,602 $79,241 $239,843 
(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.