Loans and Related Allowance for Credit Losses

12 Months Ended

Dec. 31, 2023

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.

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, such as inflation levels, industry specific risks, interest rate levels, the level of consumer savings and deposit balances, and structural and secular changes fostered by the pandemic. To mitigate losses and enhance customer support, we offer loan modifications and collection programs to assist our customers.

Table 40 presents the composition and delinquency status of our loan portfolio at December 31, 2023 and December 31, 2022. Loan delinquencies include government insured or guaranteed loans and loans accounted for under the fair value option.

Table 40: Analysis of Loan Portfolio (a) (b) (c)

	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 (d)				Nonperforming Loans			Fair Value Option Nonaccrual Loans (e)			Total Loans (f) (g)
December 31, 2023
Commercial
Commercial and industrial	$	176,796		$	104		$	45		$	76		$	225			$	559					$	177,580
Commercial real estate	34,685			7						9			16				735						35,436
Equipment lease financing	6,480			41			8						49				13						6,542
Total commercial	217,961			152			53			85			290				1,307						219,558
Consumer
Residential real estate	46,159			282			101			192			575			(d)	294			$	516		47,544
Home equity	25,533			63			27						90				458			69			26,150
Automobile	14,638			91			20			7			118				104						14,860
Credit card	6,991			54			39			86			179				10						7,180
Education	1,850			27			19			49			95			(d)							1,945
Other consumer	4,227			16			11			10			37				7						4,271
Total consumer	99,398			533			217			344			1,094				873			585			101,950
Total	$	317,359		$	685		$	270		$	429		$	1,384			$	2,180		$	585		$	321,508
Percentage of total loans	98.71		%	0.21		%	0.08		%	0.13		%	0.43		%		0.68		%	0.18		%	100.00		%
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			(d)	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			(d)							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		%

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

(b)The CARES Act credit reporting rules expired in the third quarter of 2023 and, as such, delinquency status at December 31, 2023 is being reported for all loans based on the contractual terms of the loan. Amounts as of December 31, 2022 continue to be presented in accordance with the credit reporting rules under the CARES Act, which required certain loans modified due to pandemic related hardships to not be reported as past due based on the contractual terms of the loan, even when borrowers may not have made payments on their loans during the modification period.

(c)The accrued interest associated with our loan portfolio totaled $1.5 billion and $1.2 billion at December 31, 2023 and 2022, respectively. These amounts are included in Other assets on the Consolidated Balance Sheet.

(d)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 both December 31, 2023 and 2022, respectively.

(e)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, they have been excluded from the nonperforming loan population.

(f)Includes unearned income, unamortized deferred fees and costs on originated loans and premiums or discounts on purchased loans totaling $1.0 billion and $0.9 billion at December 31, 2023 and 2022, respectively.

(g)Collateral dependent loans totaled $1.4 billion and $1.3 billion at December 31, 2023 and 2022, 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, 2023, we pledged $51.3 billion of commercial and other loans to the Federal Reserve Bank and $89.5 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, 2022 were $28.1 billion and $90.4 billion, respectively. Amounts pledged reflect the unpaid principal balances.

Nonperforming Assets

Nonperforming assets include nonperforming loans and leases, OREO and foreclosed assets. Nonperforming loans are those loans accounted for at amortized cost whose credit quality has deteriorated to the extent that full collection of contractual principal and interest is not probable. Interest income is not recognized on these loans. Loans accounted for under the fair value option are reported as performing loans; however, when nonaccrual criteria is met, interest income is not recognized on these loans. Additionally, certain government insured or guaranteed loans for which we expect to collect substantially all principal and interest are not reported as nonperforming loans and continue to accrue interest. 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, 2023 and 2022:

Table 41: Nonperforming Assets

Dollars in millions	December 31, 2023			December 31, 2022
Nonperforming loans (a)
Commercial	$	1,307		$	858
Consumer (b)	873			1,127
Total nonperforming loans (c)	2,180			1,985
OREO and foreclosed assets	36			34
Total nonperforming assets	$	2,216		$	2,019
Nonperforming loans to total loans	0.68		%	0.61		%
Nonperforming assets to total loans, OREO and foreclosed assets	0.69		%	0.62		%
Nonperforming assets to total assets	0.39		%	0.36		%

(a)In connection with the adoption of ASU 2022-02, nonperforming loans as of December 31, 2023 include certain loans where terms were modified as a result of a borrower’s financial difficulty. Prior period amounts included nonperforming TDRs, for which accounting guidance was eliminated effective January 1, 2023. See Note 1 Accounting Policies and the Loan Modifications to Borrowers Experiencing Financial Difficulty section of this Note 3 for more information on our adoption of this ASU.

(b)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.

(c)Nonperforming loans for which there is no related ALLL totaled $0.5 billion at December 31, 2023 and primarily include loans with a fair value of collateral that exceeds the amortized cost basis. The comparable amount at December 31, 2022 was $0.7 billion.

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 our commercial loan classes:

Table 42: Commercial Credit Quality Indicators (a)

	Term Loans by Origination Year
December 31, 2023 In millions	2023			2022		2021		2020		2019		Prior		Revolving Loans		Revolving Loans Converted to Term		Total
Commercial and industrial
Pass Rated	$	23,019		$	26,657	$	7,562	$	5,783	$	4,110	$	11,982	$	88,467	$	573	$	168,153
Criticized	838			1,781		739		331		281		698		4,708		51		9,427
Total commercial and industrial loans	23,857			28,438		8,301		6,114		4,391		12,680		93,175		624		177,580
Gross charge-offs (b)	25		(c)	32		33		8		3		26		105		12		244
Commercial real estate
Pass Rated	4,182			8,571		2,986		2,190		4,887		7,411		383				30,610
Criticized	155			1,300		455		490		622		1,753		51				4,826
Total commercial real estate loans	4,337			9,871		3,441		2,680		5,509		9,164		434				35,436
Gross charge-offs (b)								12		31		137						180
Equipment lease financing
Pass Rated	1,522			1,424		689		690		452		1,378						6,155
Criticized	90			81		81		51		35		49						387
Total equipment lease financing loans	1,612			1,505		770		741		487		1,427						6,542
Gross charge-offs (b)	4			4		4		4		1		1						18
Total commercial loans	$	29,806		$	39,814	$	12,512	$	9,535	$	10,387	$	23,271	$	93,609	$	624	$	219,558
Total commercial gross charge-offs	$	29		$	36	$	37	$	24	$	35	$	164	$	105	$	12	$	442

	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

(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, 2023 and 2022.

(b)Gross charge-offs are presented on a year-to-date basis, as of the reporting date.

(c)Includes charge-offs of deposit overdrafts.

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 40 for additional information.

Nonperforming Loans: We monitor trending of nonperforming loans for residential real estate and home equity loans. See Table 40 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 our residential real estate and home equity loan classes:

Table 43: Credit Quality Indicators for Residential Real Estate and Home Equity Loan Classes

	Term Loans by Origination Year
December 31, 2023 In millions	2023		2022		2021		2020		2019		Prior		Revolving Loans		Revolving Loans Converted to Term		Total
Residential real estate
Current estimated LTV ratios
Greater than 100%	$	15	$	139	$	79	$	31	$	10	$	28					$	302
Greater than or equal to 80% to 100%	1,665		1,928		955		221		69		92						4,930
Less than 80%	3,585		7,977		14,421		6,514		2,154		6,935						41,586
No LTV available	56				13						4						73
Government insured or guaranteed loans	14		20		16		66		37		500						653
Total residential real estate loans	$	5,335	$	10,064	$	15,484	$	6,832	$	2,270	$	7,559					$	47,544
Updated FICO scores
Greater than or equal to 780	$	3,206	$	7,797	$	12,197	$	5,035	$	1,492	$	4,004					$	33,731
720 to 779	1,482		1,659		2,389		1,107		432		1,388						8,457
660 to 719	400		508		657		334		171		721						2,791
Less than 660	93		71		133		122		82		680						1,181
No FICO score available	140		9		92		168		56		266						731
Government insured or guaranteed loans	14		20		16		66		37		500						653
Total residential real estate loans	$	5,335	$	10,064	$	15,484	$	6,832	$	2,270	$	7,559					$	47,544
Gross charge-offs (a)			$	2	$	1	$	1			$	4					$	8
Home equity
Current estimated LTV ratios
Greater than 100%					$	1	$	12	$	6	$	14	$	306	$	309	$	648
Greater than or equal to 80% to 100%					4		40		17		22		1,116		1,743		2,942
Less than 80%					157		1,866		845		2,556		6,843		10,293		22,560
Total home equity loans					$	162	$	1,918	$	868	$	2,592	$	8,265	$	12,345	$	26,150
Updated FICO scores
Greater than or equal to 780					$	102	$	1,254	$	489	$	1,605	$	4,604	$	6,083	$	14,137
720 to 779					38		423		216		488		2,222		3,225		6,612
660 to 719					17		174		110		271		1,207		1,894		3,673
Less than 660					5		65		52		220		223		1,089		1,654
No FICO score available							2		1		8		9		54		74
Total home equity loans					$	162	$	1,918	$	868	$	2,592	$	8,265	$	12,345	$	26,150
Gross charge-offs (a)											$	4	$	7	$	10	$	21

(Continued from previous page)	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

(a)Gross charge-offs are presented on a year-to-date basis, as of the reporting date.

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 our automobile, credit card, education and other consumer loan classes:

Table 44: Credit Quality Indicators for Automobile, Credit Card, Education and Other Consumer Loan Classes

	Term Loans by Origination Year
December 31, 2023 In millions	2023			2022		2021		2020		2019		Prior		Revolving Loans		Revolving Loans Converted to Term		Total
Automobile
Updated FICO scores
Greater than or equal to 780	$	2,722		$	1,650	$	1,483	$	535	$	368	$	88					$	6,846
720 to 779	1,797			1,104		778		301		250		80						4,310
660 to 719	1,014			604		408		186		186		70						2,468
Less than 660	264			272		243		152		200		105						1,236
Total automobile loans	$	5,797		$	3,630	$	2,912	$	1,174	$	1,004	$	343					$	14,860
Gross charge-offs (a)	$	8		$	24	$	22	$	17	$	30	$	20					$	121
Credit card
Updated FICO scores
Greater than or equal to 780														$	2,017	$	1	$	2,018
720 to 779														1,976		4		1,980
660 to 719														1,979		13		1,992
Less than 660														1,036		48		1,084
No FICO score available or required (b)														103		3		106
Total credit card loans														$	7,111	$	69	$	7,180
Gross charge-offs (a)														$	290	$	29	$	319
Education
Updated FICO scores
Greater than or equal to 780	$	35		$	88	$	45	$	40	$	51	$	331					$	590
720 to 779	32			47		24		19		24		131						277
660 to 719	20			17		8		6		8		54						113
Less than 660	4			3		2		1		2		21						33
No FICO score available or required (b)	15			5		4		2				1						27
Total loans using FICO credit metric	106			160		83		68		85		538						1,040
Other internal credit metrics												905						905
Total education loans	$	106		$	160	$	83	$	68	$	85	$	1,443					$	1,945
Gross charge-offs (a)						$	1	$	1	$	2	$	13					$	17
Other consumer
Updated FICO scores
Greater than or equal to 780	$	241		$	127	$	47	$	21	$	14	$	11	$	39	$	1	$	501
720 to 779	286			157		54		26		17		11		80		1		632
660 to 719	147			140		57		27		21		11		87		2		492
Less than 660	19			52		31		17		14		8		43		1		185
Total loans using FICO credit metric	693			476		189		91		66		41		249		5		1,810
Other internal credit metrics	19			97		33		48		71		34		2,149		10		2,461
Total other consumer loans	$	712		$	573	$	222	$	139	$	137	$	75	$	2,398	$	15	$	4,271
Gross charge-offs (a)	$	75	(c)	$	23	$	18	$	14	$	14	$	8	$	11	$	1	$	164

(Continued from previous page)	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 (b)													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 (b)	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

(a)Gross charge-offs are presented on a year-to-date basis, as of the reporting date.

(b)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.

(c)Includes charge-offs of deposit overdrafts.

Loan Modifications to Borrowers Experiencing Financial Difficulty

On January 1, 2023, we adopted ASU 2022-02, which eliminates the accounting guidance for TDRs and enhances the disclosure requirements for certain loan modifications when a borrower is experiencing financial difficulty (FDMs). FDMs result from our loss mitigation activities and include principal forgiveness, interest rate reductions, term extensions, payment delays or combinations thereof. See Note 1 Accounting Policies for additional information on FDMs.

The following table presents the amortized cost basis, as of December 31, 2023, of FDMs granted during the twelve months ended December 31, 2023:

Table 45: Loan Modifications Granted to Borrowers Experiencing Financial Difficulty (a) (b)

Year ended December 31, 2023 Dollars in millions	Interest Rate Reduction		Term Extension		Payment Delay		Repayment Plan		Interest Rate Reduction and Payment Delay		Interest Rate Reduction and Term Extension		Payment Delay and Term Extension		Other (c)		Total		% of Loan Class
Commercial
Commercial and industrial	$	13	$	683	$	65			$	14	$	18	$	156	$	150	$	1,099	0.62	%
Commercial real estate	47		816										17		87		967		2.73	%
Total commercial	60		1,499		65				14		18		173		237		2,066		0.94	%
Consumer
Residential real estate	2		1		95						5				6		109		0.23	%
Home equity			1		10						8				12		31		0.12	%
Credit card							$	58									58		0.81	%
Education			5														5		0.26	%
Other consumer							1										1		0.02	%
Total consumer	2		7		105		59				13				18		204		0.20	%
Total	$	62	$	1,506	$	170	$	59	$	14	$	31	$	173	$	255	$	2,270	0.71	%

(a)At December 31, 2023, there were $0.4 billion of unfunded lending related commitments associated with FDMs.

(b)Excludes the amortized cost basis of modified loans that were paid off, charged off or otherwise liquidated as of period end.

(c)Includes loans where we have received notification that a borrower has filed for Chapter 7 bankruptcy relief, but specific instructions as to the terms of the relief have not been formally ruled upon by the court. Amounts also include trial modifications.

Table 46 presents the financial effect of FDMs granted during the twelve months ended December 31, 2023:

Table 46: Financial Effect of FDMs (a)

Year ended December 31, 2023 Dollars in millions	Weighted-Average Interest Rate Reduction		Weighted-Average Term Extension (in Months)	Weighted-Average Payment Delay (in Months)
Commercial
Commercial and industrial	2.70	%	12	3
Commercial real estate	4.54	%	14	5
Consumer
Residential real estate	1.34	%	80	9
Home equity	1.17	%	56	4
Education			20

(a)Excludes the financial effects of modifications for loans that were paid off, charged off or otherwise liquidated as of period end.

Repayment plans are excluded from Table 46. The terms of these programs, which are offered for certain credit card and unsecured line of credit products, are as follows:

•Short-term programs are granted for periods of 6 and 12 months. These programs are structurally similar such that the interest rate is reduced to a standard rate of 4.99% and the minimum payment percentage is adjusted to 1.90% of the outstanding balance. At the end of the 6 or 12 months, the borrower is returned to the original contractual interest rate and minimum payment amount specified in the original lending agreement.

•Fully-amortized repayment plans are also granted, the most common of which being a 60 month program. In this program, we convert the borrower’s drawn and unpaid balances into a fully-amortized repayment plan consisting of an interest rate of 4.99% and an adjusted minimum payment percentage of 1.90% of the outstanding balance. This fully-amortized program is designed in a manner that allows the drawn and unpaid amounts to be recaptured at the end of the 60 months.

After we modify a loan, we continue to track its performance under its most recent modified terms. The following table presents the performance, as of December 31, 2023, of FDMs granted during the twelve months ended December 31, 2023:

Table 47: Delinquency Status of FDMs (a)

Year ended December 31, 2023 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		Nonperforming Loans		Total
Commercial
Commercial and industrial	$	828	$	14					$	257	$	1,099
Commercial real estate	863								104		967
Total commercial	1,691		14						361		2,066
Consumer
Residential real estate	15		1						93		109
Home equity	4								27		31
Credit card	41		5		$	4	$	7	1		58
Education	5										5
Other consumer									1		1
Total consumer	65		6		4		7		122		204
Total	$	1,756	$	20	$	4	$	7	$	483	$	2,270

(a)Represents amortized cost basis.

We generally consider FDMs to have subsequently defaulted when they become 60 days past due after the most recent date the loan was modified. The following table presents loans that were both (i) classified as FDMs, and (ii) subsequently defaulted during the period.

Table 48: Subsequently Defaulted FDMs (a)

Year ended December 31, 2023 Dollars in millions	Interest Rate Reduction		Term Extension		Payment Delay		All Other Modifications (b)		Total
Commercial
Commercial and industrial			$	38	$	166	$	7	$	211
Commercial real estate	$	46	15						61
Total commercial	46		53		166		7		272
Consumer
Residential real estate	1				28		2		31
Home equity					2		10		12
Credit card							16		16
Total consumer	1				30		28		59
Total	$	47	$	53	$	196	$	35	$	331

(a)Represents amortized cost basis.

(b)Includes the following modification categories: principal forgiveness, repayment plans, combinations of interest rate reduction/payment delay and interest rate reduction/ term extension and other.

Troubled Debt Restructuring Disclosures Prior to the Adoption of ASU 2022-02

Table 49 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 years ended December 31, 2022 and 2021. Additionally, the table provides information about the types of TDR concessions. See Note 1 Accounting Policies for additional discussion of TDRs.

Table 49: 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

(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 was determined to be a TDR, we continued to track its performance under its most recent restructured terms. We considered a TDR to have subsequently defaulted when it became 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 and 2021.

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 50: Rollforward of Allowance for Credit Losses

At or for the year ended December 31	2023						2022						2021
In millions	Commercial		Consumer		Total		Commercial		Consumer		Total		Commercial		Consumer		Total
Allowance for loan and lease losses
Beginning balance	$	3,114	$	1,627	$	4,741	$	3,185	$	1,683	$	4,868	$	3,337	$	2,024	$	5,361
Adoption of ASU 2022-02 (a)			(35)		(35)
Beginning balance, adjusted	3,114		1,592		4,706		3,185		1,683		4,868		3,337		2,024		5,361
Acquisition PCD reserves													774		282		1,056
Charge-offs	(442)		(650)		(1,092)		(307)		(678)		(985)		(434)		(667)		(1,101)
Recoveries	137		245		382		114		308		422		106		338		444
Net (charge-offs)	(305)		(405)		(710)		(193)		(370)		(563)		(328)		(329)		(657)
Provision for (recapture of) credit losses	447		345		792		126		313		439		(594)		(293)		(887)
Other	3				3		(4)		1		(3)		(4)		(1)		(5)
Ending balance	$	3,259	$	1,532	$	4,791	$	3,114	$	1,627	$	4,741	$	3,185	$	1,683	$	4,868
Allowance for unfunded lending related commitments (b)
Beginning balance	$	613	$	81	$	694	$	564	$	98	$	662	$	485	$	99	$	584
Acquisition PCD reserves													43		3		46
Provision for (recapture of) credit losses	(68)		37		(31)		49		(17)		32		36		(4)		32
Ending balance	$	545	$	118	$	663	$	613	$	81	$	694	$	564	$	98	$	662
Allowance for credit losses at December 31 (c)	$	3,804	$	1,650	$	5,454	$	3,727	$	1,708	$	5,435	$	3,749	$	1,781	$	5,530

(a)    Represents the impact of adopting ASU 2022-02 on January 1, 2023. As a result of adoption, we eliminated the accounting guidance for TDRs, including the use of a discounted cash flow approach to measure the allowance for TDRs.

(b)    See Note 10 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 $120 million, $176 million and $171 million at December 31, 2023, 2022 and 2021 respectively.

The ACL related to loans totaled $5.5 billion at December 31, 2023, and was relatively stable in comparison to reserves at December 31, 2022. The slight increase in reserves was primarily driven by portfolio activity, including changes in credit quality related to the commercial real estate portfolio, partially offset by an updated economic outlook.