Accounting Policies (Tables)

12 Months Ended

Dec. 31, 2024

Schedule Of Policy For Classifying Nonperforming Assets

The matrix that follows summarizes our policies for classifying certain loans as nonperforming loans and/or discontinuing the accrual of loan interest income.


Commercial
Loans classified as nonperforming and accounted for as nonaccrual			• Loans accounted for at amortized cost where: –The loan is 90 days or more past due. –The loan is rated substandard or worse due to the determination that full collection of principal and interest is not probable as demonstrated by the following conditions: •The collection of principal or interest is 90 days or more past due, •Reasonable doubt exists as to the certainty of the borrower’s future debt service ability, according to the terms of the credit arrangement, regardless of whether 90 days have passed or not, •The borrower has filed, or will likely file for bankruptcy, and it is not probable the borrower will be able to repay contractual payments due under the loan, •The bank advances additional funds to cover principal or interest, •We are in the process of liquidating a commercial borrower, or •We are pursuing remedies under a guarantee.
Loans excluded from nonperforming classification but accounted for as nonaccrual			• Loans accounted for under the fair value option and full collection of principal and interest is not probable. • Loans accounted for at the lower of cost or market less costs to sell (held for sale) and full collection of principal and interest is not probable.
Loans excluded from nonperforming classification and nonaccrual accounting			• Loans that are well secured and in the process of collection. • Certain government insured or guaranteed loans where substantially all principal and interest is insured. • Commercial purchasing card assets that do not accrue interest.


Consumer
Loans classified as nonperforming and accounted for as nonaccrual			• Loans accounted for at amortized cost where full collection of contractual principal and interest is not deemed probable as demonstrated in the policies below: – The loan is 90 days past due for home equity and installment loans, and 180 days past due for well- secured residential real estate loans, – The loan had been modified and classified as a TDR prior to the adoption of ASU 2022-02, – The loan has been modified due to a borrower experiencing financial difficulty and is not government insured or guaranteed, – The loan has been modified to defer prior payments in forbearance to the end of the loan term, – Notification of bankruptcy has been received, – The bank holds a subordinate lien position in the loan and the first lien mortgage loan is seriously stressed (i.e., 90 days or more past due), – Other loans within the same borrower relationship have been placed on nonaccrual or charge-offs have been taken on them, – The bank has ordered the repossession of non-real estate collateral securing the loan, or – The bank has charged-off the loan to the value of the collateral.
Loans excluded from nonperforming classification but accounted for as nonaccrual			• Loans accounted for under the fair value option and full collection of principal and interest is not probable. • Loans accounted for at the lower of cost or market less costs to sell (held for sale) and full collection of principal and interest is not probable.
Loans excluded from nonperforming classification and nonaccrual accounting			• Certain government insured or guaranteed loans where substantially all principal and interest is insured. • Residential real estate loans that are well secured and in the process of collection. • Consumer loans and lines of credit, not secured by residential real estate or automobiles, as permitted by regulatory guidance.

Recently Adopted Accounting Standards


Accounting Standards Update	Description	Financial Statement Impact
Reference Rate Reform - ASU 2020-04 Issued March 2020 Reference Rate Reform Scope - ASU 2021-01 Issued January 2021 Reference Rate Reform Deferral of Sunset Date – ASU 2022-06 Issued December 2022	• Provides optional expedients and exceptions for applying generally accepted accounting principles to contracts, hedging relationships and other transactions that reference LIBOR or another reference rate expected to be discontinued because of reference rate reform (codified in ASC 848). • Includes optional expedients related to contract modifications that allow an entity to account for modifications (if certain criteria are met) as if the modifications were only minor (assets within the scope of ASC 310, Receivables), were not substantial (assets within the scope of ASC 470, Debt) and/or did not result in remeasurements or reclassifications (assets within the scope of ASC 842, Leases, and other Topics) of the existing contract. • Includes optional expedients related to hedging relationships within the scope of ASC 815, Derivatives & Hedging, whereby changes to the critical terms of a hedging relationship do not require dedesignation if certain criteria are met. In addition, potential sources of ineffectiveness as a result of reference rate reform may be disregarded when performing some effectiveness assessments. • Includes optional expedients and exceptions for contract modifications and hedge accounting that apply to derivative instruments impacted by the market-wide discounting transition. • Guidance in these ASUs is effective as of March 12, 2020 through December 31, 2024.	• ASU 2020-04 was adopted March 12, 2020. ASU 2021-01 was retrospectively adopted October 1, 2020. ASU 2022-06 was adopted upon issuance. • During the fourth quarter of 2020, we elected to apply certain optional expedients for contract modifications and hedging relationships to derivative instruments impacted by the market-wide discounting transition. These optional expedients remove the requirement to remeasure contract modifications or dedesignate hedging relationships due to reference rate reform. The elections made in the fourth quarter of 2020 apply only to derivative instruments impacted by the market-wide discounting transition, not all derivative instruments. • During the first quarter of 2021, we elected to apply certain optional expedients to derivative instruments that were modified in the first quarter due to the adoption of fallback language recommended by the ISDA to address the anticipated cessation of LIBOR. These optional expedients remove the requirement to remeasure contract modifications or dedesignate hedging relationships due to reference rate reform. We applied these optional expedients consistently to all eligible LIBOR cessation-related contract modifications and hedging relationships since election. • During the fourth quarter of 2021, we elected to apply certain optional expedients for contract modifications to receivables modified in the fourth quarter due to the cessation of 1-week and 2-month USD LIBOR tenors and non-USD Interbank Offered Rates. These optional expedients remove the requirement to assess whether the contract modification was more-than-minor in accordance with ASC 310. We also elected to apply certain optional expedients related to assessing hedge effectiveness to our cash flow hedge relationships affected by reference rate reform. We applied these optional expedients consistently to all eligible LIBOR cessation-related contract modifications and hedging relationships since election. • During the second quarter of 2023, we elected and applied certain optional expedients for contract modifications and hedging relationships impacted by the central clearing counterparties conversion processes for LIBOR-indexed derivative instruments. These optional expedients remove the requirement to remeasure contract modifications or dedesignate hedging relationships due to reference rate reform. The elections made apply only to derivatives instruments impacted by the central clearinghouse conversion process. • During the second quarter of 2023, we applied certain optional expedients for investment security, debt and preferred stock instrument contract modifications impacted by LIBOR cessation. These optional expedients remove the requirement to remeasure contract modifications. • We did not elect any additional optional expedients for contract modifications and hedge relationships affected by reference rate reform before the expiration of this guidance on December 31, 2024.


Accounting Standards Update	Description	Financial Statement Impact
Improvements to Reportable Segment Disclosures - ASU 2023-07 Issued November 2023	• Requires that a public entity disclose significant segment expenses that are regularly provided to the CODM and included within each reported measure of segment profit or loss. • Requires that a public entity disclose an amount for other segment items by reportable segment and a description of its composition. • Requires that a public entity provide all annual disclosures about a reportable segment’s profit or loss and assets currently required by ASC 280 in interim periods. • Clarifies that if the CODM uses more than one measure of a segment’s profit or loss in assessing segment performance and deciding how to allocate resources, a public entity may report one or more of those additional measures of segment profit. • Requires that a public entity disclose the title and position of the CODM and an explanation of how the CODM uses the reported measure(s) of segment profit or loss in assessing segment performance and deciding how to allocate resources. • Requires a retrospective transition approach for all prior periods presented in the financial statements.	• Adopted for annual periods beginning in 2024 and interim periods beginning in the first quarter of 2025, using a retrospective transition approach. • The presentation of our business segment results has been updated to reflect significant segment-level expense information and can be found within Note 22 Segment Reporting. • This ASU did not impact our Consolidated Income Statement, Consolidated Statement of Comprehensive Income, Consolidated Balance Sheet, Consolidated Statement of Cash Flows or Consolidated Statement of Changes in Equity.

Credit Quality Indicators by Loan Class

The following matrix provides key credit risk characteristics that we use to estimate these risk parameters.

Loan Class

Probability of Default

Loss Given Default

Exposure at Default

Commercial

Commercial and industrial / Equipment lease financing

•For wholesale obligors: internal risk ratings based on borrower characteristics and industry

•For retail small balance obligors: credit score, delinquency status, and product type

•Collateral type, LTV, industry, size and outstanding exposure for secured loans

•Capital structure, industry and size for unsecured loans

•For retail small balance obligors, product type and credit scores

•Outstanding balances, commitment, contractual maturities and historical prepayment experience for loans

•Current utilization and historical pre-default draw experience for lines

Commercial real estate (CRE)

•Property performance metrics, property type, market and risk pool and internal risk ratings based on borrower characteristics

•Property type, LTV, market, risk pool and costs to sell

•Outstanding balances, commitment, contractual maturities and historical prepayment experience for loans

Consumer

Home equity / Residential real estate

•Borrower credit scores, delinquency status, origination vintage, LTV and contractual maturity

•Collateral characteristics, LTV and costs to sell

•Outstanding balances, contractual maturities and historical prepayment experience for loans

•Current utilization and historical pre-default draw experience for lines

Automobile

•Borrower credit scores, delinquency status, borrower income, LTV and contractual maturity

•New vs. used, LTV and borrower credit scores

•Outstanding balances, contractual maturities and historical prepayment experience

Credit card

•Borrower credit scores, delinquency status, utilization, payment behavior and months on book

•Borrower credit scores and credit line amount

•Paydown curves are developed using a pro-rata method and estimated using borrower behavior segments, payment ratios and borrower credit scores

Education / Other consumer

•Modeled using either discrete risk parameters or analytical approaches based on net charge-offs and paydown rates

The following matrix describes the key economic variables that are consumed during our forecast period by loan class, as well as other assumptions that are used for our reversion and long-run average approaches.


Loan Class	Forecast Period - Key Economic Variables	Reversion Method	Long-Run Average
Commercial
Commercial and industrial / Equipment lease financing	•GDP and Gross Domestic Investment measures, employment related variables and personal income and consumption measures	•Immediate reversion	•Average parameters determined based on internal and external historical data •Modeled parameters using long-run economic conditions for retail small balance obligors
Commercial real estate (CRE)	• CRE Price Index, unemployment rates, GDP, corporate bond yield and interest rates	• Immediate reversion	• Average parameters determined based on internal and external historical data
Consumer
Home equity / Residential real estate	•Unemployment rates, HPI and interest rates	•Straight-line over 3 years	•Modeled parameters using long-run economic conditions
Automobile	•Unemployment rates, HPI, disposable personal income and Manheim used car index	•Straight-line over 1 year	•Average parameters determined based on internal historical data
Credit card	•Unemployment rates, personal consumption expenditure and HPI	•Straight-line over 2 years	•Modeled parameters using long-run economic conditions
Education / Other consumer	•Modeled using either discrete risk parameters or analytical approaches based on net charge-offs and paydown rates

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.

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.

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.