Loans and Related Allowance for Credit Losses

12 Months Ended

Dec. 31, 2024

Receivables [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, but not limited to, trends in delinquency rates, nonperforming status, analyses 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 address operating environment changes such as inflation levels, industry specific risks, interest rate levels, the level of consumer savings and deposit balances, and structural and secular changes such as those arising from the pandemic. We offer loan modifications and collection programs to assist our customers, enhance support and mitigate losses.

Table 48 presents the composition and delinquency status of our loan portfolio at December 31, 2024 and December 31, 2023. Loan delinquencies include government insured or guaranteed loans and loans accounted for under the fair value option.

Table 48: 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, 2024
Commercial
Commercial and industrial	$	174,988		$	159		$	43		$	72		$	274			$	528					$	175,790
Commercial real estate	32,657			25			18						43				919						33,619
Equipment lease financing	6,687			41			12						53				15						6,755
Total commercial	214,332			225			73			72			370				1,462						216,164
Consumer
Residential real estate	45,134			234			106			188			528			(c)	278			$	475		46,415
Home equity	25,351			71			26						97				482			61			25,991
Automobile	15,155			83			22			9			114				86						15,355
Credit card	6,696			49			38			81			168				15						6,879
Education	1,557			25			15			39			79			(c)							1,636
Other consumer	3,998			10			8			8			26				3						4,027
Total consumer	97,891			472			215			325			1,012				864			536			100,303
Total	$	312,223		$	697		$	288		$	397		$	1,382			$	2,326		$	536		$	316,467
Percentage of total loans	98.66		%	0.22		%	0.09		%	0.13		%	0.44		%		0.73		%	0.17		%	100.00		%
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			(c)	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			(c)							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		%

(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 $1.3 billion and $1.5 billion at December 31, 2024 and 2023, 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 both December 31, 2024 and 2023, 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, they 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 $1.0 billion at both December 31, 2024 and 2023, respectively.

(f)Collateral dependent loans totaled $1.6 billion and $1.4 billion at December 31, 2024 and 2023, 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, term lengths that may expose the borrower to payment terms above 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 borrowers may not be able to make interest and principal payments when due as a result of the interest-only feature. We do not believe that these product features create a concentration of credit risk.

At December 31, 2024, we pledged unpaid principal balances in the amounts of $43.4 billion of commercial and other loans to the Federal Reserve Bank and $89.0 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, 2023 were $51.3 billion and $89.5 billion, respectively.

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 generally 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, 2024 and 2023:

Table 49: Nonperforming Assets

Dollars in millions	December 31, 2024			December 31, 2023
Nonperforming loans
Commercial	$	1,462		$	1,307
Consumer (a)	864			873
Total nonperforming loans (b)	2,326			2,180
OREO and foreclosed assets	31			36
Total nonperforming assets	$	2,357		$	2,216
Nonperforming loans to total loans	0.73		%	0.68		%
Nonperforming assets to total loans, OREO and foreclosed assets	0.74		%	0.69		%
Nonperforming assets to total assets	0.42		%	0.39		%

(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 $0.6 billion and $0.5 billion at December 31, 2024 and 2023, respectively. This primarily includes loans with a fair value of collateral that exceeds the amortized cost basis.

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 PD and LGD, 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 50: Commercial Credit Quality Indicators (a)

	Term Loans by Origination Year
December 31, 2024 In millions	2024			2023		2022		2021		2020		Prior		Revolving Loans		Revolving Loans Converted to Term		Total
Commercial and industrial
Pass Rated	$	22,145		$	13,815	$	17,043	$	5,275	$	4,594	$	11,270	$	91,389	$	522	$	166,053
Criticized	761			878		1,856		601		144		580		4,868		49		9,737
Total commercial and industrial loans	22,906			14,693		18,899		5,876		4,738		11,850		96,257		571		175,790
Gross charge-offs (b)	22		(c)	32		51		25		5		7		133		53		328
Commercial real estate
Pass Rated	2,331			5,575		6,875		2,232		1,220		9,685		423				28,341
Criticized	141			335		1,974		485		465		1,853		25				5,278
Total commercial real estate loans	2,472			5,910		8,849		2,717		1,685		11,538		448				33,619
Gross charge-offs (b)	28			5				2		1		322						358
Equipment lease financing
Pass Rated	1,814			1,264		1,112		478		478		1,305						6,451
Criticized	51			79		88		35		21		30						304
Total equipment lease financing loans	1,865			1,343		1,200		513		499		1,335						6,755
Gross charge-offs (b)	1			6		12		5		4		6						34
Total commercial loans	$	27,243		$	21,946	$	28,948	$	9,106	$	6,922	$	24,723	$	96,705	$	571	$	216,164
Total commercial gross charge-offs	$	51		$	43	$	63	$	32	$	10	$	335	$	133	$	53	$	720

	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

(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, 2024 and 2023.

(b)Gross charge-offs are presented on a year-to-date basis, as of the period end 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 delinquency/delinquency rate trends for residential real estate and home equity loans. See Table 48 for additional information.

Nonperforming Loans: We monitor nonperforming loan trends for residential real estate and home equity loans. See Table 48 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 51: Credit Quality Indicators for Residential Real Estate and Home Equity Loan Classes

	Term Loans by Origination Year
December 31, 2024 In millions	2024		2023		2022		2021		2020		Prior		Revolving Loans		Revolving Loans Converted to Term		Total
Residential real estate
Current estimated LTV ratios
Greater than 100%	$	10	$	55	$	85	$	52	$	23	$	32					$	257
Greater than or equal to 80% to 100%	591		485		954		601		171		111						2,913
Less than 80%	2,043		4,039		8,450		13,958		6,084		8,039						42,613
No LTV available							9				3						12
Government insured or guaranteed loans	1		16		23		17		66		497						620
Total residential real estate loans	$	2,645	$	4,595	$	9,512	$	14,637	$	6,344	$	8,682					$	46,415
Updated FICO scores
Greater than or equal to 780	$	1,730	$	3,264	$	7,584	$	11,723	$	4,683	$	4,858					$	33,842
720 to 779	789		805		1,406		2,035		1,004		1,567						7,606
660 to 719	115		270		401		620		324		784						2,514
Less than 660	9		108		90		156		116		696						1,175
No FICO score available	1		132		8		86		151		280						658
Government insured or guaranteed loans	1		16		23		17		66		497						620
Total residential real estate loans	$	2,645	$	4,595	$	9,512	$	14,637	$	6,344	$	8,682					$	46,415
Gross charge-offs (a)							$	1			$	2					$	3
Home equity (b)
Current estimated LTV ratios
Greater than 100%							$	1	$	12	$	17	$	368	$	372	$	770
Greater than or equal to 80% to 100%							5		31		30		1,098		1,619		2,783
Less than 80%							141		1,670		2,807		6,907		10,913		22,438
Total home equity loans							$	147	$	1,713	$	2,854	$	8,373	$	12,904	$	25,991
Updated FICO scores
Greater than or equal to 780							$	94	$	1,145	$	1,753	$	4,720	$	6,211	$	13,923
720 to 779							34		352		572		2,251		3,274		6,483
660 to 719							14		151		289		1,193		2,085		3,732
Less than 660							5		63		234		202		1,290		1,794
No FICO score available									2		6		7		44		59
Total home equity loans							$	147	$	1,713	$	2,854	$	8,373	$	12,904	$	25,991
Gross charge-offs (a)											$	1	$	16	$	19	$	36

(Continued from previous page)	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 (b)
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

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

(b)Beginning January 1, 2022, new originations consist of only revolving Home Equity Lines of Credit.

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

	Term Loans by Origination Year
December 31, 2024 In millions	2024			2023		2022		2021		2020		Prior		Revolving Loans		Revolving Loans Converted to Term		Total
Automobile
Updated FICO scores
Greater than or equal to 780	$	3,288		$	1,717	$	1,094	$	865	$	241	$	125					$	7,330
720 to 779	2,047			1,123		636		415		129		90						4,440
660 to 719	963			671		367		227		82		74						2,384
Less than 660	246			351		231		174		87		112						1,201
Total automobile loans	$	6,544		$	3,862	$	2,328	$	1,681	$	539	$	401					$	15,355
Gross charge-offs (a)	$	9		$	44	$	27	$	17	$	12	$	22					$	131
Credit card
Updated FICO scores
Greater than or equal to 780														$	2,090	$	2	$	2,092
720 to 779														1,859		5		1,864
660 to 719														1,815		16		1,831
Less than 660														936		57		993
No FICO score available or required (b)														97		2		99
Total credit card loans														$	6,797	$	82	$	6,879
Gross charge-offs (a)														$	316	$	39	$	355
Education
Updated FICO scores
Greater than or equal to 780	$	22		$	58	$	79	$	39	$	33	$	318					$	549
720 to 779	20			36		38		20		14		116						244
660 to 719	13			14		15		6		5		46						99
Less than 660	3			3		3		1		1		19						30
No FICO score available or required (b)	12			5		4		1				1						23
Total loans using FICO credit metric	70			116		139		67		53		500						945
Other internal credit metrics												691						691
Total education loans	$	70		$	116	$	139	$	67	$	53	$	1,191					$	1,636
Gross charge-offs (a)						$	1	$	1	$	1	$	16					$	19
Other consumer
Updated FICO scores
Greater than or equal to 780	$	245		$	129	$	64	$	20	$	5	$	6	$	37	$	1	$	507
720 to 779	292			141		70		21		6		6		72		1		609
660 to 719	203			97		72		22		8		6		79		1		488
Less than 660	20			33		34		15		6		5		40		1		154
Total loans using FICO credit metric	760			400		240		78		25		23		228		4		1,758
Other internal credit metrics	6			9		77		12		11		90		2,056		8		2,269
Total other consumer loans	$	766		$	409	$	317	$	90	$	36	$	113	$	2,284	$	12	$	4,027
Gross charge-offs (a)	$	76	(c)	$	27	$	26	$	13	$	8	$	9	$	11	$	1	$	171

(Continued from previous page)	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

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

(b)Loans where FICO scores are not 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

Loan modifications to borrowers experiencing financial difficulty (FDMs) result from our loss mitigation activities and include principal forgiveness, interest rate reductions, term extensions, payment delays, repayment plans or combinations thereof. See Note 1 Accounting Policies for additional information on FDMs.

The following table presents the amortized cost basis, as of the period end date, of FDMs granted during the twelve months ended December 31, 2024:

Table 53: Loan Modifications Granted to Borrowers Experiencing Financial Difficulty (a) (b)

Year ended December 31, 2024 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	$	14	$	995	$	34			$	15	$	111	$	154	$	106	$	1,429	0.81	%
Commercial real estate			964		94								232				1,290		3.84	%
Equipment lease financing			2														2		0.03	%
Total commercial	14		1,961		128				15		111		386		106		2,721		1.26	%
Consumer
Residential real estate			1		84						6				7		98		0.21	%
Home equity					13		$	7							18		38		0.15	%
Credit card							62										62		0.90	%
Education			5														5		0.31	%
Other consumer							1										1		0.02	%
Total consumer			6		97		70				6				25		204		0.20	%
Total	$	14	$	1,967	$	225	$	70	$	15	$	117	$	386	$	131	$	2,925	0.92	%
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		67				5				18		204		0.20	%
Total	$	62	$	1,506	$	170	$	67	$	14	$	23	$	173	$	255	$	2,270	0.71	%

(a)The unfunded lending related commitments on FDMs granted were $0.9 billion and $0.4 billion during the year ended December 31, 2024 and 2023, respectively.

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

(c)Represents all other modifications, and includes trial modifications and 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.

Table 54 presents the weighted average financial effect of FDMs granted during the twelve months ended December 31, 2024 and 2023:

Table 54: Financial Effect of FDMs (a)

Year ended December 31, 2024 Dollars in millions	Amortized cost basis (b)	Weighted Average Financial Effect
Term Extension
Commercial and industrial	$1,260	Extended contractual term by 16 months.
Commercial real estate	$1,196	Extended contractual term by 17 months.
Equipment lease financing	$2	Extended contractual term by 43 months.
Residential real estate	$7	Extended contractual term by 94 months.
Education	$5	Extended contractual term by 13 months.
Interest Rate Reduction
Commercial and industrial	$140	Reduced contractual interest rate by 1.42%.
Residential real estate	$6	Reduced contractual interest rate by 2.00%.
Payment Delay
Commercial and industrial	$203	Provided 8 months of payment deferral.
Commercial real estate	$326	Provided 8 months of payment deferral.
Residential real estate	$84	Provided 9 months of payment deferral.
Home equity	$13	Provided 4 months of payment deferral.
Year ended December 31, 2023 Dollars in millions	Amortized cost basis (b)	Weighted Average Financial Effect
Term Extension
Commercial and industrial	$857	Extended contractual term by 12 months.
Commercial real estate	$833	Extended contractual term by 14 months.
Residential real estate	$6	Extended contractual term by 80 months.
Home equity	$1	Extended contractual term by 232 months.
Education	$5	Extended contractual term by 20 months.
Interest Rate Reduction
Commercial and industrial	$45	Reduced contractual interest rate by 2.70%.
Commercial real estate	$47	Reduced contractual interest rate by 4.54%.
Residential real estate	$7	Reduced contractual interest rate by 1.34%.
Payment Delay
Commercial and industrial	$235	Provided 3 months of payment deferral.
Commercial real estate	$17	Provided 5 months of payment deferral.
Residential real estate	$95	Provided 9 months of payment deferral.
Home equity	$10	Provided 4 months of payment deferral.

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

(b)The amortized cost basis presented in Table 54 includes combination modification categories in addition to the standalone modification categories presented in Table 53. Primarily due to this reason, the amortized cost basis presented in Table 54 may not agree to the amortized cost basis presented alongside the standalone modification categories in Table 53. Amortized cost basis is as of the period end date.

Repayment plans are excluded from Table 54. The terms of these programs, which are offered for certain consumer products, are as follows:

•Credit card and unsecured lines of credit

•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.

•Home equity loans and lines of credit

•Fixed payment plan programs establish a modified monthly payment that is informed by the borrower’s financial situation and the current market environment at the time of modification, among other factors. As such, we may change the borrower’s interest rate, modify the term of the loan, and/or defer payment to arrive at the modified monthly

payment. Each of the aforementioned terms may increase or decrease, and may vary from loan to loan, based on the individual loan and borrower characteristics.

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 period end date, of FDMs granted during the year ended December 31, 2024 and 2023:

Table 55: Delinquency Status of FDMs (a) (b)

Year ended December 31, 2024 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	$	1,191	$	9	$	4			$	225	$	1,429
Commercial real estate	864								426		1,290
Equipment lease financing	2										2
Total commercial	2,057		9		4				651		2,721
Consumer
Residential real estate	5		1						92		98
Home equity	4								34		38
Credit card	45		5		4		$	7	1		62
Education	5										5
Other consumer									1		1
Total consumer	59		6		4		7		128		204
Total	$	2,116	$	15	$	8	$	7	$	779	$	2,925
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.

(b)Loans in our Payment Delay category are reported as past due in accordance with their contractual terms. Once contractually modified, these loans are reported as past due in accordance with their restructured terms.

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 56: Subsequently Defaulted FDMs (a)

Year ended December 31, 2024 Dollars in millions	Interest Rate Reduction		Term Extension		Payment Delay		Repayment Plan		Payment Delay and Term Extension		All Other Modifications (b)		Total
Commercial
Commercial and industrial			$	87	$	17			$	3			$	107
Commercial real estate			46		33				37				116
Total commercial			133		50				40				223
Consumer
Residential real estate					43						$	8	51
Home equity					3		$	1			13		17
Credit card							32						32
Total consumer					46		33				21		100
Total			$	133	$	96	$	33	$	40	$	21	$	323
Year ended December 31, 2023 Dollars in millions	Interest Rate Reduction		Term Extension		Payment Delay		Repayment Plan				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		16				12		59
Total	$	47	$	53	$	196	$	16			$	19	$	331

(a)Represents amortized cost basis.

(b)As of December 31, 2024, the following modification categories are included: interest rate reduction, combination of interest rate reduction/payment delay, combination of interest rate reduction/term extension and other. As of December 31, 2023, the following modification categories are included: principal forgiveness, combinations of interest rate reduction/payment delay and interest rate reduction/term extension and other. There were no applicable values for the combination of payment delay/term extension.

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

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

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

(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 the year ended December 31, 2022.

Allowance for Credit Losses

We maintain the ACL related to loans at levels that we believe to be appropriate to absorb expected credit losses 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	2024						2023						2022
In millions	Commercial		Consumer		Total		Commercial		Consumer		Total		Commercial		Consumer		Total
Allowance for loan and lease losses
Beginning balance	$	3,259	$	1,532	$	4,791	$	3,114	$	1,627	$	4,741	$	3,185	$	1,683	$	4,868
Adoption of ASU 2022-02 (a)									(35)		(35)
Beginning balance, adjusted	3,259		1,532		4,791		3,114		1,592		4,706		3,185		1,683		4,868
Charge-offs	(720)		(715)		(1,435)		(442)		(650)		(1,092)		(307)		(678)		(985)
Recoveries	149		245		394		137		245		382		114		308		422
Net (charge-offs)	(571)		(470)		(1,041)		(305)		(405)		(710)		(193)		(370)		(563)
Provision for credit losses	464		277		741		447		345		792		126		313		439
Other	(4)		(1)		(5)		3				3		(4)		1		(3)
Ending balance	$	3,148	$	1,338	$	4,486	$	3,259	$	1,532	$	4,791	$	3,114	$	1,627	$	4,741
Allowance for unfunded lending related commitments (b)
Beginning balance	$	545	$	118	$	663	$	613	$	81	$	694	$	564	$	98	$	662
Provision for (recapture of) credit losses	36		20		56		(68)		37		(31)		49		(17)		32
Other	(1)		1
Ending balance	$	580	$	139	$	719	$	545	$	118	$	663	$	613	$	81	$	694
Allowance for credit losses at December 31 (c)	$	3,728	$	1,477	$	5,205	$	3,804	$	1,650	$	5,454	$	3,727	$	1,708	$	5,435

(a)    Represents the impact of adopting ASU 2022-02 Financial Instruments - Credit Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures 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 $114 million, $120 million and $176 million at December 31, 2024, 2023 and 2022 respectively.

The ACL related to loans totaled $5.2 billion at December 31, 2024 and $5.5 billion at December 31, 2023. The reserve change was driven by improved macroeconomic factors as well as portfolio activity.