Loans and Related Allowance for Credit Losses

12 Months Ended

Dec. 31, 2022

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.

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 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 52 presents the composition and delinquency status of our loan portfolio at December 31, 2022 and 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 resulting from 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, 2022 and 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 52: 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)
December 31, 2022
Commercial
Commercial and industrial	$	181,223		$	169		$	27		$	137		$	333			$	663					$	182,219
Commercial real estate	36,104			19			4						23				189						36,316
Equipment lease financing	6,484			20			4						24				6						6,514
Total commercial	223,811			208			35			137			380				858						225,049
Consumer
Residential real estate	44,306			281			112			199			592			(c)	424			$	567		45,889
Home equity	25,305			53			20						73				526			79			25,983
Automobile	14,543			106			25			7			138				155						14,836
Credit card	6,906			50			35			70			155				8						7,069
Education	2,058			34			22			59			115			(c)							2,173
Other consumer	4,975			15			12			10			37				14						5,026
Total consumer	98,093			539			226			345			1,110				1,127			646			100,976
Total	$	321,904		$	747		$	261		$	482		$	1,490			$	1,985		$	646		$	326,025
Percentage of total loans	98.73		%	0.23		%	0.08		%	0.15		%	0.46		%		0.61		%	0.20		%	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 $1.2 billion and $0.7 billion at December 31, 2022 and 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 December 31, 2022. Comparable amounts at December 31, 2021 were $0.4 billion and $0.1 billion, respectively.

(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 policy criteria. 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 $0.9 billion and $0.7 billion at December 31, 2022 and 2021, respectively.

(f)Collateral dependent loans totaled $1.3 billion and $1.7 billion at December 31, 2022 and 2021, 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, 2022, we pledged $28.1 billion of commercial and other loans to the Federal Reserve Bank and $90.4 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 for additional information on our nonperforming loan and lease policies.

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

Table 53: Nonperforming Assets

Dollars in millions	December 31, 2022			December 31, 2021
Nonperforming loans
Commercial	$	858		$	1,168
Consumer (a)	1,127			1,312
Total nonperforming loans (b)	1,985			2,480
OREO and foreclosed assets	34			26
Total nonperforming assets	$	2,019		$	2,506
Nonperforming loans to total loans	0.61		%	0.86		%
Nonperforming assets to total loans, OREO and foreclosed assets	0.62		%	0.87		%
Nonperforming assets to total assets	0.36		%	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 $0.7 billion at December 31, 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 and the Troubled Debt Restructurings section of this Note 4 for additional information on TDRs.

Total nonperforming loans in Table 53 include TDRs of $0.7 billion and $1.0 billion at December 31, 2022 and 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 December 31, 2022 and 2021, respectively.

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 generally reviewed and updated 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 54: Commercial Credit Quality Indicators (a)

	Term Loans by Origination Year
December 31, 2022 In millions	2022		2021		2020		2019		2018		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Commercial and industrial
Pass Rated	$	41,685	$	12,493	$	8,134	$	6,261	$	4,209	$	13,165	$	89,384	$	69	$	175,400
Criticized	1,259		423		277		299		297		551		3,682		31		6,819
Total commercial and industrial	42,944		12,916		8,411		6,560		4,506		13,716		93,066		100		182,219
Commercial real estate
Pass Rated	8,835		4,153		3,266		5,511		3,005		7,454		450				32,674
Criticized	348		37		322		758		807		1,367		3				3,642
Total commercial real estate	9,183		4,190		3,588		6,269		3,812		8,821		453				36,316
Equipment lease financing
Pass Rated	1,797		962		942		670		410		1,495						6,276
Criticized	60		55		56		39		17		11						238
Total equipment lease financing	1,857		1,017		998		709		427		1,506						6,514
Total commercial	$	53,984	$	18,123	$	12,997	$	13,538	$	8,745	$	24,043	$	93,519	$	100	$	225,049

	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 December 31, 2022 and 2021.

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 55 for additional information.

Nonperforming Loans: We monitor trending of nonperforming loans for residential real estate and home equity loans. See Table 55 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 55: Credit Quality Indicators for Residential Real Estate and Home Equity Loan Classes

	Term Loans by Origination Year
December 31, 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%	$	4	$	52	$	20	$	10	$	4	$	41					$	131
Greater than or equal to 80% to 100%	1,185		678		232		84		24		92						2,295
Less than 80%	9,396		15,844		7,074		2,346		822		7,220						42,702
No LTV available			61				3				4						68
Government insured or guaranteed loans	9		15		66		39		28		536						693
Total residential real estate	$	10,594	$	16,650	$	7,392	$	2,482	$	878	$	7,893					$	45,889
Updated FICO scores
Greater than or equal to 780	$	6,825	$	12,596	$	5,276	$	1,623	$	463	$	4,027					$	30,810
720 to 779	3,172		3,024		1,369		476		180		1,457						9,678
660 to 719	514		744		378		189		98		796						2,719
Less than 660	63		108		110		88		71		740						1,180
No FICO score available	11		163		193		67		38		337						809
Government insured or guaranteed loans	9		15		66		39		28		536						693
Total residential real estate	$	10,594	$	16,650	$	7,392	$	2,482	$	878	$	7,893					$	45,889
Home equity
Current estimated LTV ratios
Greater than 100%			$	4	$	14	$	9	$	2	$	15	$	268	$	137	$	449
Greater than or equal to 80% to 100%			4		51		27		4		31		854		1,149		2,120
Less than 80%			172		2,078		961		285		2,851		7,780		9,287		23,414
Total home equity			$	180	$	2,143	$	997	$	291	$	2,897	$	8,902	$	10,573	$	25,983
Updated FICO scores
Greater than or equal to 780			$	110	$	1,357	$	554	$	155	$	1,791	$	5,093	$	5,545	$	14,605
720 to 779			47		515		248		64		567		2,305		2,843		6,589
660 to 719			19		211		140		42		288		1,146		1,449		3,295
Less than 660			4		57		54		29		242		342		671		1,399
No FICO score available					3		1		1		9		16		65		95
Total home equity			$	180	$	2,143	$	997	$	291	$	2,897	$	8,902	$	10,573	$	25,983

(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

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

	Term Loans by Origination Year
December 31, 2022 In millions	2022		2021		2020		2019		2018		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Updated FICO Scores
Automobile
Greater than or equal to 780	$	2,390	$	2,162	$	922	$	760	$	241	$	75					$	6,550
720 to 779	1,702		1,312		561		538		222		69						4,404
660 to 719	854		660		341		401		187		56						2,499
Less than 660	193		290		230		368		228		74						1,383
Total automobile	$	5,139	$	4,424	$	2,054	$	2,067	$	878	$	274					$	14,836
Credit card
Greater than or equal to 780													$	1,954	$	2	$	1,956
720 to 779													1,994		6		2,000
660 to 719													1,957		13		1,970
Less than 660													1,001		35		1,036
No FICO score available or required (a)													104		3		107
Total credit card													$	7,010	$	59	$	7,069
Education
Greater than or equal to 780	$	42	$	53	$	48	$	61	$	51	$	357					$	612
720 to 779	39		27		24		30		24		143						287
660 to 719	21		8		8		9		8		59						113
Less than 660	4		1		1		2		2		24						34
No FICO score available or required (a)	20		8		7		3				1						39
Education loans using FICO credit metric	126		97		88		105		85		584						1,085
Other internal credit metrics											1,088						1,088
Total education	$	126	$	97	$	88	$	105	$	85	$	1,672					$	2,173
Other consumer
Greater than or equal to 780	$	224	$	97	$	53	$	46	$	14	$	18	$	47	$	2	$	501
720 to 779	302		122		68		62		20		15		89		2		680
660 to 719	229		110		68		66		28		8		95		2		606
Less than 660	32		48		37		40		20		6		44		2		229
Other consumer loans using FICO credit metric	787		377		226		214		82		47		275		8		2,016
Other internal credit metrics	125		43		40		34		7		29		2,720		12		3,010
Total other consumer	$	912	$	420	$	266	$	248	$	89	$	76	$	2,995	$	20	$	5,026

(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
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
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
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
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

A TDR is a loan whose terms have been restructured in a manner that grants a concession to a borrower experiencing financial difficulty. See Note 1 Accounting Policies for additional information related to TDRs.

Table 57 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 2022, 2021 and 2020. 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 57. 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 57. After that, consumer loan concessions would follow the previously discussed priority of concessions for the commercial loan portfolio.

Table 57: Financial Impact and TDRs by Concession Type (a)

	Number of Loans	Pre-TDR Amortized Cost Basis (b)		Post-TDR Amortized Cost Basis (c)
During the year ended December 31, 2022 Dollars in millions				Principal Forgiveness		Rate Reduction		Other		Total
Commercial	57	$	363	$	9	$	58	$	202	$	269
Consumer	10,809	162				123		22		145
Total TDRs	10,866	$	525	$	9	$	181	$	224	$	414
During the year ended December 31, 2021 Dollars in millions
Commercial	57	$	536	$	6			$	510	$	516
Consumer	6,109	108				$	64	33		97
Total TDRs	6,166	$	644	$	6	$	64	$	543	$	613
During the year ended December 31, 2020 Dollars in millions
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.

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, 2022, 2021 and 2020, 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 58: Rollforward of Allowance for Credit Losses

At or for the year ended December 31	2022						2021						2020
In millions	Commercial		Consumer		Total		Commercial		Consumer		Total		Commercial		Consumer		Total
Allowance for loan and lease losses
Beginning balance	$	3,185	$	1,683	$	4,868	$	3,337	$	2,024	$	5,361	$	1,812	$	930	$	2,742
Adoption of ASU 2016-13 (a)													(304)		767		463
Beginning balance, adjusted	3,185		1,683		4,868		3,337		2,024		5,361		1,508		1,697		3,205
Acquisition PCD reserves							774		282		1,056
Charge-offs	(307)		(678)		(985)		(434)		(667)		(1,101)		(407)		(785)		(1,192)
Recoveries	114		308		422		106		338		444		94		266		360
Net (charge-offs)	(193)		(370)		(563)		(328)		(329)		(657)		(313)		(519)		(832)
Provision for (recapture of) credit losses	126		313		439		(594)		(293)		(887)		2,139		846		2,985
Other	(4)		1		(3)		(4)		(1)		(5)		3				3
Ending balance	$	3,114	$	1,627	$	4,741	$	3,185	$	1,683	$	4,868	$	3,337	$	2,024	$	5,361
Allowance for unfunded lending related commitments (b)
Beginning balance	$	564	$	98	$	662	$	485	$	99	$	584	$	316	$	2	$	318
Adoption of ASU 2016-13 (a)													53		126		179
Beginning balance, adjusted	564		98		662		485		99		584		369		128		497
Acquisition PCD reserves							43		3		46
Provision for (recapture of) credit losses	49		(17)		32		36		(4)		32		116		(29)		87
Ending balance	$	613	$	81	$	694	$	564	$	98	$	662	$	485	$	99	$	584
Allowance for credit losses at December 31 (c)	$	3,727	$	1,708	$	5,435	$	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 $176 million, $171 million and $109 million at December 31, 2022, 2021 and 2020 respectively.

The ACL related to loans at December 31, 2022 totaled $5.4 billion, a decrease of $0.1 billion since December 31, 2021. The decline in reserves was primarily driven by the reassessment of pandemic-related risks and improvements in credit quality, partially offset by our weakened economic outlook along with loan growth.