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Loans and Related Allowance for Credit Losses

6 Months Ended

Jun. 30, 2022

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

See Note 1 Accounting Policies included in Item 8 of our 2021 Form 10-K 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 42 presents the composition and delinquency status of our loan portfolio at June 30, 2022 and December 31, 2021. 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 resulting from rising inflation levels, supply chain disruptions, higher rates, and secular changes fostered by 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 June 30, 2022 and December 31, 2021 based on the contractual terms of the loan, even where borrowers may not be making payments on their loans during the modification period.

Table 42: Analysis of Loan Portfolio (a) (b)


	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)
June 30, 2022
Commercial
Commercial and industrial	$	170,817		$	99		$	128		$	138		$	365			$	649					$	171,831
Commercial real estate	34,252			28			11						39				161						34,452
Equipment lease financing	6,224			7			4						11				5						6,240
Total commercial	211,293			134			143			138			415				815						212,523
Consumer
Residential real estate	42,067			298			95			202			595			(c)	457			$	598		43,717
Home equity	23,994			43			14						57				556			86			24,693
Automobile	15,016			102			24			6			132				175						15,323
Credit card	6,528			37			25			54			116				6						6,650
Education	2,207			44			23			58			125			(c)							2,332
Other consumer	5,454			38			21			12			71				37						5,562
Total consumer	95,266			562			202			332			1,096				1,231			684			98,277
Total	$	306,559		$	696		$	345		$	470		$	1,511			$	2,046		$	684		$	310,800
Percentage of total loans	98.63		%	0.22		%	0.11		%	0.15		%	0.49		%		0.66		%	0.22		%	100.00		%
December 31, 2021
Commercial
Commercial and industrial	$	151,698		$	235		$	72		$	132		$	439			$	796					$	152,933
Commercial real estate	33,580			46			24			1			71				364						34,015
Equipment lease financing	6,095			25			2						27				8						6,130
Total commercial	191,373			306			98			133			537				1,168						193,078
Consumer
Residential real estate	37,706			379			119			328			826			(c)	517			$	663		39,712
Home equity	23,305			53			18						71				596			89			24,061
Automobile	16,252			146			40			14			200				183						16,635
Credit card	6,475			49			33			62			144				7						6,626
Education	2,400			43			25			65			133			(c)							2,533
Other consumer	5,644			35			22			17			74				9						5,727
Total consumer	91,782			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 loans	98.19		%	0.35		%	0.12		%	0.21		%	0.69		%		0.86		%	0.26		%	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 $0.8 billion and $0.7 billion at June 30, 2022 and December 31, 2021, respectively. 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 $0.3 billion and $0.1 billion at June 30, 2022. Comparable amounts at December 31, 2021 were $0.4 billion and $0.1 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 at both June 30, 2022 and December 31, 2021.

(f)Collateral dependent loans totaled $1.2 billion and $1.7 billion at June 30, 2022 and December 31, 2021, respectively.

At June 30, 2022, we pledged $24.9 billion of commercial and other loans to the Federal Reserve Bank and $85.9 billion of residential real estate and other loans to the FHLB as collateral for the ability to borrow, if necessary. The comparable amounts at December 31, 2021 were $25.7 billion and $66.2 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 included in Item 8 of our 2021 Form 10-K for additional information on our nonperforming loan and lease policies.

The following table presents our nonperforming assets as of June 30, 2022 and December 31, 2021, respectively:

Table 43: Nonperforming Assets


Dollars in millions	June 30 2022			December 31 2021
Nonperforming loans
Commercial	$	815		$	1,168
Consumer (a)	1,231			1,312
Total nonperforming loans (b)	2,046			2,480
OREO and foreclosed assets	29			26
Total nonperforming assets	$	2,075		$	2,506
Nonperforming loans to total loans	0.66		%	0.86		%
Nonperforming assets to total loans, OREO and foreclosed assets	0.67		%	0.87		%
Nonperforming assets to total assets	0.38		%	0.45		%

(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 June 30, 2022 and primarily include loans with a fair value of collateral that exceeds the amortized cost basis. The comparable amount at December 31, 2021 was $1.0 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 included in Item 8 of our 2021 Form 10-K and the Troubled Debt Restructurings section of this Note 4 for additional information on TDRs.

Total nonperforming loans in Table 43 include TDRs of $0.7 billion and $1.0 billion at June 30, 2022 and December 31, 2021, respectively. TDRs that are performing, including consumer credit card TDR loans, are excluded from nonperforming loans and totaled $0.7 billion and $0.6 billion at June 30, 2022 and December 31, 2021, respectively.

Additional Credit Quality Indicators by Loan Class

Commercial Loan Classes

See Note 4 Loans and Related Allowance for Credit Losses included in Item 8 of our 2021 Form 10-K for additional information related to these loan classes, including discussion around the credit quality indicators that we use to monitor and manage the credit risk associated with each loan class.

The following table presents credit quality indicators for the commercial loan classes:

Table 44: Commercial Credit Quality Indicators (a)


	Term Loans by Origination Year
June 30, 2022 In millions	2022		2021		2020		2019		2018		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Commercial and industrial
Pass Rated	$	20,359	$	16,777	$	10,272	$	9,215	$	5,342	$	16,371	$	86,988	$	74	$	165,398
Criticized	315		398		325		649		460		863		3,397		26		6,433
Total commercial and industrial	20,674		17,175		10,597		9,864		5,802		17,234		90,385		100		171,831
Commercial real estate
Pass Rated	4,241		3,869		3,793		6,134		3,359		8,553		260				30,209
Criticized	240		158		260		748		883		1,905		49				4,243
Total commercial real estate	4,481		4,027		4,053		6,882		4,242		10,458		309				34,452
Equipment lease financing
Pass Rated	817		1,078		1,065		788		556		1,730						6,034
Criticized	15		51		56		43		25		16						206
Total equipment lease financing	832		1,129		1,121		831		581		1,746						6,240
Total commercial	$	25,987	$	22,331	$	15,771	$	17,577	$	10,625	$	29,438	$	90,694	$	100	$	212,523


	Term Loans by Origination Year
December 31, 2021 In millions	2021		2020		2019		2018		2017		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Commercial and industrial
Pass Rated	$	27,104	$	12,053	$	10,731	$	6,698	$	6,355	$	11,759	$	71,230	$	90	$	146,020
Criticized	283		368		815		649		496		824		3,448		30		6,913
Total commercial and industrial	27,387		12,421		11,546		7,347		6,851		12,583		74,678		120		152,933
Commercial real estate
Pass Rated	4,110		4,109		6,355		4,234		2,634		7,562		436				29,440
Criticized	294		298		999		820		566		1,552		46				4,575
Total commercial real estate	4,404		4,407		7,354		5,054		3,200		9,114		482				34,015
Equipment lease financing
Pass Rated	1,212		1,190		942		682		507		1,410						5,943
Criticized	37		54		41		29		19		7						187
Total equipment lease financing	1,249		1,244		983		711		526		1,417						6,130
Total commercial	$	33,040	$	18,072	$	19,883	$	13,112	$	10,577	$	23,114	$	75,160	$	120	$	193,078

(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 June 30, 2022 and December 31, 2021.

Consumer Loan Classes

associated with each loan class.

Residential Real Estate and Home Equity

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

Table 45: Credit Quality Indicators for Residential Real Estate and Home Equity Loan Classes


	Term Loans by Origination Year
June 30, 2022 In millions	2022		2021		2020		2019		2018		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Residential real estate
Current estimated LTV ratios
Greater than 100%			$	65	$	43	$	15	$	6	$	46					$	175
Greater than or equal to 80% to 100%	$	1,083	682		323		112		47		135						2,382
Less than 80%	5,893		16,007		7,312		2,471		877		7,896						40,456
No LTV available			48		1						9						58
Government insured or guaranteed loans	1		6		37		32		24		546						646
Total residential real estate	$	6,977	$	16,808	$	7,716	$	2,630	$	954	$	8,632					$	43,717
Updated FICO scores
Greater than or equal to 780	$	3,782	$	12,363	$	5,486	$	1,721	$	508	$	4,469					$	28,329
720 to 779	2,839		3,473		1,498		503		204		1,609						10,126
660 to 719	317		699		380		218		113		825						2,552
Less than 660	35		113		111		88		65		834						1,246
No FICO score available	3		154		204		68		40		349						818
Government insured or guaranteed loans	1		6		37		32		24		546						646
Total residential real estate	$	6,977	$	16,808	$	7,716	$	2,630	$	954	$	8,632					$	43,717
Home equity
Current estimated LTV ratios
Greater than 100%			$	1	$	15	$	10	$	2	$	19	$	246	$	87	$	380
Greater than or equal to 80% to 100%			5		65		38		6		43		795		945		1,897
Less than 80%			184		2,213		1,040		315		3,200		7,701		7,763		22,416
Total home equity			$	190	$	2,293	$	1,088	$	323	$	3,262	$	8,742	$	8,795	$	24,693
Updated FICO scores
Greater than or equal to 780			$	115	$	1,457	$	608	$	172	$	2,020	$	5,177	$	4,694	$	14,243
720 to 779			51		570		280		73		638		2,234		2,323		6,169
660 to 719			20		212		144		46		324		1,013		1,098		2,857
Less than 660			4		51		55		31		270		298		608		1,317
No FICO score available					3		1		1		10		20		72		107
Total home equity			$	190	$	2,293	$	1,088	$	323	$	3,262	$	8,742	$	8,795	$	24,693


(Continued from previous page)	Term Loans by Origination Year
December 31, 2021 In millions	2021		2020		2019		2018		2017		Prior		Revolving Loans		Revolving Loans Converted to Term		Total 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 available	275		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 779	4,921		1,735		643		247		345		1,619						9,510
660 to 719	717		463		255		136		133		796						2,500
Less than 660	83		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 779	61		666		348		96		116		642		2,283		1,679		5,891
660 to 719	23		248		167		56		53		327		1,071		872		2,817
Less than 660	4		53		57		32		28		277		325		615		1,391
No FICO score available			2		1		1		1		10		18		84		117
Total home equity	$	212	$	2,588	$	1,265	$	386	$	562	$	3,291	$	9,187	$	6,570	$	24,061

Automobile, Credit Card, Education and Other Consumer

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

Table 46: Credit Quality Indicators for Automobile, Credit Card, Education and Other Consumer Loan Classes


	Term Loans by Origination Year
June 30, 2022 In millions	2022		2021		2020		2019		2018		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Updated FICO Scores
Automobile
FICO score greater than or equal to 780	$	1,391	$	2,543	$	1,186	$	1,032	$	371	$	161					$	6,684
720 to 779	868		1,702		738		745		340		139						4,532
660 to 719	392		817		446		552		278		109						2,594
Less than 660	51		291		267		459		313		132						1,513

Total automobile	$	2,702	$	5,353	$	2,637	$	2,788	$	1,302	$	541					$	15,323
Credit card
FICO score greater than or equal to 780													$	1,864	$	2	$	1,866
720 to 779													1,912		8		1,920
660 to 719													1,807		16		1,823
Less than 660													897		33		930
No FICO score available or required (a)													108		3		111
Total credit card													$	6,588	$	62	$	6,650
Education
FICO score greater than or equal to 780	$	10	$	58	$	54	$	67	$	55	$	391					$	635
720 to 779	8		28		26		32		26		159						279
660 to 719	3		7		8		10		9		68						105
Less than 660	1		2		2		2		2		25						34
No FICO score available or required (a)	3		8		9		6		1		1						28
Education loans using FICO credit metric	25		103		99		117		93		644						1,081
Other internal credit metrics											1,251						1,251
Total education	$	25	$	103	$	99	$	117	$	93	$	1,895					$	2,332
Other consumer
FICO score greater than or equal to 780	$	116	$	144	$	86	$	76	$	28	$	28	$	58	$	2	$	538
720 to 779	151		179		107		102		38		21		99		3		700
660 to 719	124		138		98		106		49		15		99		2		631
Less than 660	6		51		49		57		33		9		44		1		250

Other consumer loans using FICO credit metric	397		512		340		341		148		73		300		8		2,119
Other internal credit metrics	60		46		35		58		15		44		3,158		27		3,443
Total other consumer	$	457	$	558	$	375	$	399	$	163	$	117	$	3,458	$	35	$	5,562


(Continued from previous page)	Term Loans by Origination Year
December 31, 2021 In millions	2021		2020		2019		2018		2017		Prior		Revolving Loans		Revolving Loans Converted to Term		Total 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 779	2,119		983		1,030		499		195		62						4,888
660 to 719	969		609		772		413		155		44						2,962
Less than 660	277		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 779													1,836		9		1,845
660 to 719													1,856		19		1,875
Less than 660													943		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 779	20		29		37		30		21		160						297
660 to 719	7		9		11		11		7		73						118
Less than 660	1		1		2		2		2		25						33
No FICO score available or required (a)	11		10		7		2				1						31
Education loans using FICO credit metric	76		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 779	250		172		167		68		15		19		125				816
660 to 719	190		145		165		82		16		11		122				731
Less than 660	50		62		85		54		10		6		50		1		318
Other consumer loans using FICO credit metric	689		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

(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

Table 47 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 the three and six months ended June 30, 2022 and June 30, 2021. Additionally, the table provides information about the types of TDR concessions. See Note 1 Accounting Policies and Note 4 Loans and Related Allowance for Credit Losses included in Item 8 of our 2021 Form 10-K for additional discussion of TDRs.

Table 47: Financial Impact and TDRs by Concession Type (a)


			Pre-TDR Amortized Cost Basis (b)		Post-TDR Amortized Cost Basis (c)
During the three months ended June 30, 2022 Dollars in millions	Number of Loans				Principal Forgiveness		Rate Reduction		Other		Total
Commercial		15	$	35	$	9			$	22	$	31
Consumer		3,025	50				$	40	5		45
Total TDRs		3,040	$	85	$	9	$	40	$	27	$	76
During the six months ended June 30, 2022 Dollars in millions
Commercial		27	$	88	$	9			$	68	$	77
Consumer		5,920	86				$	66	12		78
Total TDRs		5,947	$	174	$	9	$	66	$	80	$	155

			Pre-TDR Amortized Cost Basis (b)		Post-TDR Amortized Cost Basis (c)
During the three months ended June 30, 2021 Dollars in millions	Number of Loans				Principal Forgiveness		Rate Reduction		Other		Total
Commercial		11	$	104					$	82	$	82
Consumer		1,386	23				$	12	9		21
Total TDRs		1,397	$	127			$	12	$	91	$	103
During the six months ended June 30, 2021 Dollars in millions
Commercial		30	$	197					$	176	$	176
Consumer		3,482	55				$	28	21		49
Total TDRs		3,512	$	252			$	28	$	197	$	225

(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.

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. The following table provides a summary of TDRs that subsequently defaulted during the periods presented and were classified as TDRs during the applicable 12-month period preceding June 30, 2022 and June 30, 2021.

Table 48: Subsequently Defaulted TDRs


In millions	2022		2021
Three months ended June 30	$	20	$	14
Six months ended June 30	$	27	$	26

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 included in Item 8 of our 2021 Form 10-K for a discussion of the methodologies used to determine this allowance. A rollforward of the ACL related to loans follows:

Table 49: Rollforward of Allowance for Credit Losses


	Three months ended June 30												Six months ended June 30
	2022						2021						2022						2021
In millions	Commercial		Consumer		Total		Commercial		Consumer		Total		Commercial		Consumer		Total		Commercial		Consumer		Total
Allowance for loan and lease losses
Beginning balance	$	3,003	$	1,555	$	4,558	$	3,083	$	1,631	$	4,714	$	3,185	$	1,683	$	4,868	$	3,337	$	2,024	$	5,361
Acquisition PCD reserves							828		287		1,115								828		287		1,115
Charge-offs	(37)		(158)		(195)		(274)		(154)		(428)		(89)		(357)		(446)		(343)		(328)		(671)
Recoveries	19		93		112		34		88		122		53		173		226		52		167		219
Net (charge-offs)	(18)		(65)		(83)		(240)		(66)		(306)		(36)		(184)		(220)		(291)		(161)		(452)
Provision for (recapture of) credit losses	(45)		35		(10)		140		66		206		(208)		26		(182)		(64)		(232)		(296)
Other	(3)				(3)		1				1		(4)				(4)		2				2
Ending balance	$	2,937	$	1,525	$	4,462	$	3,812	$	1,918	$	5,730	$	2,937	$	1,525	$	4,462	$	3,812	$	1,918	$	5,730
Allowance for unfunded lending related commitments (a)
Beginning balance	$	587	$	52	$	639	$	403	$	104	$	507	$	564	$	98	$	662	$	485	$	99	$	584
Acquisition PCD reserves							43		3		46								43		3		46
Provision for (recapture of) credit losses	43		(1)		42		87		5		92		66		(47)		19		5		10		15
Ending balance	$	630	$	51	$	681	$	533	$	112	$	645	$	630	$	51	$	681	$	533	$	112	$	645
Allowance for credit losses at June 30 (b)	$	3,567	$	1,576	$	5,143	$	4,345	$	2,030	$	6,375	$	3,567	$	1,576	$	5,143	$	4,345	$	2,030	$	6,375

(a) See Note 8 Commitments for additional information about the underlying commitments related to this allowance.

(b) Represents the ALLL plus allowance for unfunded lending related commitments and excludes allowances for investment securities and other financial assets, which together totaled $163 million and $138 million at June 30, 2022 and 2021, respectively.

The ACL related to loans at June 30, 2022 totaled $5.1 billion, a decrease of $0.4 billion since December 31, 2021. This decline was primarily driven by the impacts from portfolio changes and improved COVID-19 related economic conditions. The following summarizes the changes in these factors that influenced the ACL during the six months ended June 30, 2022:

•Portfolio changes that drove reserve declines at June 30, 2022 reflected improvements in credit quality, partially offset by the impact from loan growth in the commercial and industrial portfolio.

•The improved COVID-19 related economic conditions reduced reserves at June 30, 2022 for specific high-risk segments of our commercial and consumer portfolios impacted by the pandemic. This decline was partially offset by increased reserves to account for the elevated risks associated with inflation and supply chain disruptions.