Note 5 Asset Quality and Allowances for Loan and Lease Losses and Unfunded Loan Commitments and Letters of Credit

We closely monitor economic conditions and loan performance trends to manage and evaluate our exposure to credit risk. Trends in delinquency rates are a key indicator, among other considerations, of credit risk within the loan portfolios. The measurement of delinquency status is based on the contractual terms of each loan. Loans that are 30 days or more past due in terms of payment are considered delinquent. Loan delinquencies exclude loans held for sale and purchased impaired loans.

The level of nonperforming assets represents another key indicator of the potential for future credit losses. Nonperforming assets include nonperforming loans, TDRs, and other real estate owned (OREO) and foreclosed assets, but exclude loans held for sale, purchased impaired loans and loans accounted for under the fair value option. See Note 6 Purchased Impaired Loans for further information.

See Note 1 Accounting Policies for additional delinquency, nonperforming, and charge-off information.

The following tables display the delinquency status of our loans and our nonperforming assets at June 30, 2011 and December 31, 2010.

Age Analysis of Past Due Accruing Loans

			Accruing
			Current or Less											90 Days
			Than 30 Days				30-59 Days			60-89 Days				Or More				Total Past			Nonperforming				Purchased				Total
In millions			Past Due				Past Due			Past Due				Past Due				Due (a)			Loans				Impaired				Loans
June 30, 2011
	Commercial			$	57,140		$	149			$	75			$	42		$	266			$	1,047		$	167		$	58,620
	Commercial real estate				13,518			98				71				12			181				1,667			953			16,319
	Equipment lease financing				6,163			9				2				1			12				35						6,210
	Residential real estate (b)				8,493			324				187				2,071			2,582				666			3,241			14,982
	Home equity				29,651			141				91				182			414				421			2,893			33,379
	Credit card				3,639			39				23				45			107				8						3,754
	Other consumer (c)				16,445			185				104				293			582				26			2			17,055
		Total		$	135,049		$	945			$	553			$	2,646		$	4,144			$	3,870		$	7,256		$	150,319
	Percentage of total loans				89.84	%		.63	%			.37	%			1.76	%		2.76	%			2.57	%		4.83	%		100.00	%
December 31, 2010
	Commercial			$	53,273		$	251			$	92			$	59		$	402			$	1,253		$	249		$	55,177
	Commercial real estate				14,713			128				62				43			233				1,835			1,153			17,934
	Equipment lease financing				6,276			37				2				1			40				77						6,393
	Residential real estate (b)				9,150			331				225				2,121			2,677				818			3,354			15,999
	Home equity				30,334			159				91				174			424				448			3,020			34,226
	Credit card				3,765			46				32				77			155										3,920
	Other consumer (c)				16,312			260				101				234			595				35			4			16,946
		Total		$	133,823		$	1,212			$	605			$	2,709		$	4,526			$	4,466		$	7,780		$	150,595
	Percentage of total loans				88.86	%		.81	%			.40	%			1.80	%		3.01	%			2.97	%		5.16	%		100.00	%
(a)		Past due loan amounts exclude purchased impaired loans as they are considered performing loans due to the accretion of interest income.
(b)		Past due loan amounts at June 30, 2011, include government insured or guaranteed residential real estate mortgages, totaling $.1 billion for 30 to 59 days past due, $.1 billion for 60 to 89 days past due and $1.9 billion for 90 days or more past due. Past due loan amounts at December 31, 2010, include government insured or guaranteed residential real estate mortgages, totaling $.1 billion for 30 to 59 days past due, $.1 billion for 60 to 89 days past due and $2.0 billion for 90 days or more past due.
(c)		Past due loan amounts at June 30, 2011, include government insured or guaranteed other consumer loans, totaling $.1 billion for 30 to 59 days past due, $.1 billion for 60 to 89 days past due and $.3 billion for 90 days or more past due. Past due loan amounts at December 31, 2010, include government insured or guaranteed other consumer loans, totaling $.2 billion for 30 to 59 days past due, $.1 billion for 60 to 89 days past due and $.2 billion for 90 days or more past due.

Nonperforming Assets

Dollars in millions				June 30, 2011				December 31, 2010
Nonperforming loans
	Commercial				$	1,047			$	1,253
	Commercial real estate					1,667				1,835
	Equipment lease financing					35				77
			TOTAL COMMERCIAL LENDING			2,749				3,165
	Consumer (a)
		Home equity				421				448
		Residential real estate (b)				666				818
		Credit card (c)				8
		Other consumer				26				35
			TOTAL CONSUMER LENDING			1,121				1,301
Total nonperforming loans (d)						3,870				4,466
OREO and foreclosed assets
	Other real estate owned (OREO) (e)					546				589
	Foreclosed and other assets					65				68
			TOTAL FORECLOSED AND OTHER ASSETS			611				657
Total nonperforming assets					$	4,481			$	5,123
Nonperforming loans to total loans						2.57	%			2.97	%
Nonperforming assets to total loans, OREO and foreclosed assets						2.97				3.39
Nonperforming assets to total assets						1.70				1.94
(a)	Excludes most consumer loans and lines of credit, not secured by residential real estate, which are charged off after 120 to 180 days past due and are not placed
	on nonperforming status.
(b)	Effective in 2011, nonperforming residential real estate excludes loans of $85 million accounted for under the fair value option as of June 30, 2011. The comparable balance at December 31, 2010 was not material.
(c)	Effective in the second quarter 2011, the commercial nonaccrual policy was applied to certain small business credit card balances. This change resulted in loans being placed on nonaccrual status when they become 90 days or more past due, rather than being excluded and charged off at 180 days past due.
(d)	Nonperforming loans do not include purchased impaired loans or loans held for sale.
(e)	Other real estate owned excludes $273 million and $178 million at June 30, 2011, and December 31, 2010, respectively, related to serviced loans insured by the Federal
	Housing Administration (FHA) or guaranteed by the Department of Veterans Affairs (VA).

Nonperforming loans also include loans whose contractual terms have been restructured in a manner that grants a concession to a borrower experiencing financial difficulties. In accordance with applicable accounting guidance, these loans are considered TDRs. See Note 1 Accounting Policies for additional information. TDRs typically result from our loss mitigation activities and could include interest rate reductions, principal forgiveness and other actions intended to minimize the economic loss and to avoid foreclosure or repossession of collateral. We typically do not forgive principal for our TDRs, but in those situations where principal is forgiven, the entire amount of such principal forgiveness is immediately charged off to the extent it was not done so prior to modification. Government insured or guaranteed/held for sale loans, purchased impaired loans and loans accounted for under the fair value option are not classified as TDRs. Consumer loans modified in the second quarter of 2011 that are government insured or guaranteed/held for sale totaling $194 million are not classified as TDRs.

Total nonperforming loans in the table above include TDRs of $845 million at June 30, 2011 and $784 million at December 31, 2010. TDRs returned to performing (accrual) status totaled $752 million and $543 million at June 30, 2011 and December 31, 2010, respectively, and are excluded from nonperforming loans. These loans have demonstrated a period of at least six months of consecutive performance under the modified terms. At June 30, 2011 and December 31, 2010, remaining commitments to lend additional funds to debtors whose terms have been modified in a commercial or consumer TDR were immaterial. The following table provides a summary of TDRs by segment and performing status.

Troubled Debt Restructurings By Type

			June 30		Dec. 31
In millions			2011		2010
Total consumer lending		$	1,614	$	1,422
Total commercial lending			305		236
	Total TDRs	$	1,919	$	1,658
Nonperforming status		$	845	$	784
Accrual status			752		543
Credit card (a)			322		331
	Total TDRs	$	1,919	$	1,658
(a)	Credit cards and certain consumer small business and other credit agreements whose terms have been modified primarily through interest rate reductions are also
	classified as TDRs. However, these loans are excluded from nonperforming loans since our policy is to exempt these loans from being placed on nonaccrual status as
	permitted by regulatory guidance. As such, generally under modified terms, these loans are directly charged off in the period that they become 120 to 180 days past due.

Some loan modifications classified as TDRs may not ultimately result in the full collection of principal and interest, as modified, and result in potential incremental losses. These potential incremental losses have been factored into our overall ALLL estimate. The level of any re-defaults will likely be affected by future economic conditions. Once a loan becomes a TDR, it will continue to be reported as a TDR until it is ultimately repaid in full, or foreclosed and sold. We held specific reserves in the ALLL for the TDR portfolio of $577 million and $509 million at June 30, 2011, and December 31, 2010, respectively.

We have two overall portfolio segments – Commercial Lending and Consumer Lending. Each of these two segments is comprised of one or more loan classes. Classes are characterized by similarities in initial measurement, risk attributes and the manner in which we monitor and assess credit risk. The commercial segment is comprised of the commercial, commercial real estate, equipment lease financing, and commercial purchased impaired loan classes. The consumer segment is comprised of the residential real estate, home equity, credit card, other consumer, and consumer purchased impaired loan classes. Asset quality indicators for each of these loan classes are discussed in more detail below.

For commercial 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 risk granularity in the monitoring process on an ongoing basis. We adjust our risk-rating process through updates based on actual experience. The combination of the PD and LGD ratings assigned to a commercial loan, capturing both the combination of expectations of default and loss severity, reflects the relative estimated likelihood of loss for that loan at the reporting date. Loans with low PD and LGD have the lowest likelihood of loss. Conversely, loans with high PD and LGD have the highest likelihood of loss.

Based upon the amount of the lending arrangement and of the credit risk described above, we follow a formal schedule of periodic review. Generally, for higher risk loans this occurs on a quarterly basis, although we have established practices to review such credit risk more frequently, if circumstances warrant.

We manage credit risk associated with our commercial real estate projects and commercial mortgage activities similar to commercial loans by analyzing PD and LGD. However, due to the nature of the collateral, for commercial real estate projects and commercial mortgages, the LGDs tend to be significantly lower than those seen in the commercial class. Additionally, risks connected 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 class, a formal schedule of periodic review is performed to assess geographic, product and loan type concentrations, in addition to industry risk and market and economic concerns. Often as a result of these overviews, more in-depth reviews and increased scrutiny is placed on areas of higher risk, adverse changes in risk ratings, deteriorating operating trends, and/or areas that concern management. The goal of these reviews is to assess risk and take actions to mitigate our exposure to such risks.

Similar to the other classes of loans within Commercial Lending, loans within the equipment lease financing class undergo a rigorous underwriting process. During this process, a PD and LGD are assigned based on the credit risk.

Based upon the dollar amount of the lease and of the level of credit risk, we follow a formal schedule of periodic review. Generally, this occurs on a quarterly basis, 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.

The credit impacts of purchased impaired loans are primarily determined through the estimation of expected cash flows. Commercial cash flow estimates are influenced by a number of credit related items, which include but are not limited to: changes in estimated collateral value, receipt of additional collateral, secondary trading prices, circumstances of possible and/or ongoing liquidation, capital availability, business operations and payment patterns.

We attempt to proactively manage these factors by using various procedures that are customized to the risk of a given loan. These procedures include a review by our Special Asset Committee (SAC), ongoing outreach, contact, and assessment of obligor financial conditions, collateral inspection and appraisal.

Commercial Lending Asset Quality Indicators
					Criticized Commercial Loans
				Pass		Special								Total
In millions				Rated (a)	Mention (b)		Substandard (c)			Doubtful (d)				Loans
June 30, 2011
	Commercial		$	52,966	$	1,771		$	3,410		$	306	$	58,453
	Commercial real estate			10,412		1,141			3,443			369		15,365
	Equipment lease financing			5,969		101			120			20		6,210
	Purchased impaired loans			98		79			747			197		1,121
		Total commercial lending (e)	$	69,445	$	3,092		$	7,720		$	892	$	81,149
December 31, 2010
	Commercial		$	48,556	$	1,926		$	3,883		$	563	$	54,928
	Commercial real estate			11,014		1,289			3,914			564		16,781
	Equipment lease financing			6,121		64			162			46		6,393
	Purchased impaired loans			106		35			883			378		1,402
		Total commercial lending (e)	$	65,797	$	3,314		$	8,842		$	1,551	$	79,504
(a)	Pass Rated loans include loans not classified as "Special Mention", "Substandard", or "Doubtful".
(b)	Special Mention rated loans have a potential weakness that deserves management’s close attention. If left uncorrected, these potential weaknesses may result in deterioration
	of repayment prospects at some future date. These loans do not expose us to sufficient risk to warrant adverse classification at this time.
(c)	Substandard rated loans have a well-defined weakness or weaknesses that jeopardize the collection or liquidation of debt. They are characterized by the distinct possibility
	that we will sustain some loss if the deficiencies are not corrected.
(d)	Doubtful rated loans possess all the inherent weaknesses of a Substandard loan with the additional characteristics that the weakness makes collection or liquidation in full
	improbable due to existing facts, conditions, and values.
(e)	Loans are included above based on their contractual terms as "Pass", "Special Mention", "Substandard" or "Doubtful".

We use several credit quality indicators, including credit scores, LTV ratios, delinquency rates, loan types and geography to monitor and manage credit risk within the residential real estate and home equity classes. We evaluate mortgage loan performance by source originators and loan servicers. A summary of asset quality indicators follows:

Credit Scores: We use a national third-party provider to update FICO credit scores for residential real estate and home equity loans on at least an annual basis. The updated scores are incorporated into a series of credit monitoring reports and the statistical models that estimate the individual loan risk values.

LTV: We regularly update the property values of real estate collateral and calculate a LTV ratio. This ratio updates our statistical models that estimate individual and class/segment level risk. The LTV ratio tends to indicate potential loss on a given loan and the borrower's likelihood to make payment according to the contractual obligations.

At least annually, we obtain updated property valuations on the real estate secured loans. For open credit lines secured by real estate or facilities in regions experiencing significant declines in property values, more frequent valuations may occur. The property values are monitored to determine LTV migration and those LTV migrations are stratified within various markets. We continue to enhance our capabilities in this area, which may result in more frequent valuations and analysis.

Delinquency Rates: We monitor levels of delinquency rates for residential real estate and home equity loans.

Geography: Geographic concentrations are monitored to evaluate and manage exposures. Loan purchase programs are sensitive to, and focused within, certain regions to manage geographic exposures and associated risks.

A combination of FICO scores, LTV ratios and geographic location assigned to residential real estate and home equity loans are used to estimate the likelihood of loss for that loan at the reporting date. Loans with higher FICO scores and lower LTVs tend to have the lower likelihood of loss. Conversely, loans with lower FICO scores, higher LTVs, and in certain geographic locations tend to have a higher likelihood of loss. Certain geographic distribution information of our higher risk real estate secured portfolio is presented in the footnotes to the table below.

Consumer Higher Risk Real Estate Secured Asset Quality Indicators

				Higher Risk Loans (a)					All Other Loans				Home Equity and Residential Real Estate Loans
						% of Total					% of Total
Dollars in millions			Amount			Loans		Amount			Loans				Amount
June 30, 2011
	Home equity (b)			$	987	3	%		$	32,392	97	%		$	33,379
	Residential real estate (c)				538	4	%			14,444	96	%			14,982
		Total (d)		$	1,525	3	%		$	46,836	97	%		$	48,361
December 31, 2010
	Home equity (b)			$	1,203	4	%		$	33,023	96	%		$	34,226
	Residential real estate (c)				671	4	%			15,328	96	%			15,999
		Total (d)		$	1,874	4	%		$	48,351	96	%		$	50,225
(a)	Higher risk loans are defined as loans with both a recent FICO credit score of less than or equal to 660 and a LTV ratio greater than or equal to 90%. Higher risk loans
	exclude loans held for sale and government insured or guaranteed loans.
(b)	Within the higher risk home equity class at June 30, 2011, approximately 11% were in some stage of delinquency and 6% were in late stage (90+ days) delinquency status.
	The majority of the June 30, 2011 balance related to higher risk home equity loans is geographically distributed throughout the following areas: Pennsylvania 30%, Ohio
	13%, New Jersey 11%, Illinois 7%, and Michigan 6%. All other states, none of which comprise more than 5%, make up the remainder of the balance.
	At December 31, 2010, approximately 10% were in some stage of delinquency and 6% were in late stage (90+ days) delinquency status. The majority of the December 31,
	2010 balance related to higher risk home equity loans is geographically distributed throughout the following areas: Pennsylvania 28%, Ohio 13%, New Jersey 11%, Illinois
	7%, Michigan 6%, and Kentucky 5%. All other states, none of which comprise more than 4% make up the remainder of the balance.
(c)	Within the higher risk residential real estate class at June 30, 2011, approximately 43% were in some stage of delinquency and 34% were in late stage (90+ days)
	delinquency status. The majority of the June 30, 2011 balance related to higher risk residential real estate loans is geographically distributed throughout the following
	areas: California 23%, Illinois 13%, Florida 11%, Ohio 5%, and Pennsylvania 5%. All other states, none of which comprise more than 4%, make up the remainder of
	the balance. At December 31, 2010, approximately 49% were in some stage of delinquency and 38% were in late stage (90+ days) delinquency status. The majority of the
	December 31, 2010 balance related to higher risk residential real estate loans is geographically distributed throughout the following areas: California 23%, Florida 11%,
	Illinois 11%, and Maryland 8%. All other states, none of which comprise more than 5%, make up the remainder of the balance.
(d)	Total loans include purchased impaired loans of $6.1 billion at June 30, 2011 and $6.4 billion at December 31, 2010.

In addition to the higher risk asset quality indicators above, we regularly monitor the portions of the real estate secured portfolio where LTVs are greater than 100%. The following table presents these balances, as well as the percentage of the applicable home equity or residential real estate loan classes.

We monitor a variety of asset quality information in the management of the credit card and other consumer loan classes. Other consumer loan classes include education, automobile, and other secured and unsecured lines and loans. Along with the trending of delinquencies and losses for each class, FICO credit score updates are obtained at least annually, as well as a variety of credit bureau attributes.

The combination of FICO scores and delinquency status are used to estimate the likelihood of loss for consumer exposure at the reporting date. 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.

Estimates of the expected cash flows primarily determine the credit impacts of consumer purchased impaired loans. Consumer cash flow estimates are influenced by a number of credit related items, which include, but are not limited to, estimated real estate values, payment patterns, FICO scores, economic environment, LTV ratios and the date of origination. These key factors are monitored regularly to help ensure that concentrations of risk are mitigated and cash flows are maximized.

Credit Card and Other Consumer Loan Classes Asset Quality Indicators

		Credit Card (a)				Other Consumer (b)
				% of Total Loans				% of Total Loans
				Using FICO				Using FICO
Dollars in millions			Amount	Credit Metric			Amount	Credit Metric
June 30, 2011
	FICO score greater than 719	$	1,917	52	%	$	4,806	62	%
	650 to 719		1,069	28			1,905	25
	620 to 649		190	5			316	4
	Less than 620		306	8			491	6
	No FICO score available or required (c)		272	7			223	3
Total loans using FICO credit metric			3,754	100	%		7,741	100	%
	Other internal credit metrics (b)						9,314
Total loan balance		$	3,754			$	17,055
Weighted average current FICO score (d)				720				732
December 31, 2010
	FICO score greater than 719	$	1,895	48	%	$	4,135	58	%
	650 to 719		1,149	29			1,984	28
	620 to 649		183	5			295	4
	Less than 620		424	11			652	9
	No FICO score available or required (c)		269	7			81	1
Total loans using FICO credit metric			3,920	100	%		7,147	100	%
	Other internal credit metrics (b)						9,799
Total loan balance		$	3,920			$	16,946
Weighted average current FICO score (d)				709				713
(a)	At June 30, 2011, we had $46 million of credit card loans that are higher risk (i.e., loans with both FICO scores less than 660 and in late stage (90+ days) delinquency status).
	The majority of the June 30, 2011 balance related to higher risk credit card loans is geographically distributed throughout the following areas: Ohio 23%, Michigan 18%,
	Pennsylvania 16%, Illinois 9%, and Indiana 8%. All other states, none of which comprise more than 6%, make up the remainder of the balance. At December 31, 2010,
	we had $70 million of credit card loans that are higher risk. The majority of the December 31, 2010 balance related to higher risk credit card loans is geographically
	distributed throughout the following areas: Ohio 20%, Michigan 14%, Pennsylvania 14%, Illinois 8%, and Indiana 7%. All other states, none of which comprise
	more than 5%, make up the remainder of the balance.
(b)	Other consumer loans for which FICO scores are used as an asset quality indicator include non-government guaranteed or insured education loans, automobile loans
	and other secured and unsecured lines and loans. Other consumer loans for which other internal credit metrics are used as an asset quality indicator include primarily
	government guaranteed or insured education loans, as well as consumer loans to high net worth individuals. Other internal credit metrics may include delinquency status,
	geography or other factors.
(c)	Credit card loans with no FICO score available or required refers to new accounts issued to borrowers with limited credit history, accounts for which we cannot obtain an
	updated FICO (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 portfolio and, when necessary, takes actions to mitigate the credit risk.
(d)	Weighted average current FICO score excludes accounts with no FICO score available or required.

Allowances for Loan and Lease Losses and Unfunded Loan Commitments and Letters of Credit

We maintain the ALLL and the Allowance for Unfunded Loan Commitments and Letters of Credit at levels that we believe to be appropriate to absorb estimated probable credit losses incurred in the portfolios as of the balance sheet date. We use the two main portfolio segments – Commercial Lending and Consumer Lending – and we develop and document the ALLL under separate methodologies for each of these segments as further discussed and presented below.

For all loans, except purchased impaired loans, the ALLL is the sum of three components: (1) asset specific/individual impaired reserves, (2) quantitative (formulaic or pooled) reserves, and (3) qualitative (judgmental) reserves. See Note 6 Purchased Impaired Loans for additional ALLL information. While we make allocations to specific loans and pools of loans, the total reserve is available for all loan and lease losses. Although quantitative modeling factors as discussed below are constantly changing as the financial strength of the borrower and overall economic conditions change, there were no significant changes to our ALLL methodology during the first six months of 2011.

Commercial nonperforming loans and all TDRs are considered impaired and are allocated a specific reserve. See Note 1 Accounting Policies for additional information.

The estimates of the quantitative component of ALLL for incurred losses within the commercial lending portfolio segment are determined through a statistical loss model utilizing PD, LGD, and EAD. Based upon loan risk ratings we assign PDs and LGDs. Each of these statistical parameters is determined based on historical data and observable factors including those pertaining to specific borrowers that have proven to be statistically significant in the estimation of incurred losses. PD is influenced by such factors as liquidity, industry, obligor financial structure, access to capital, and cash flow. LGD is influenced by collateral type, LTV, and guarantees by related parties.

Quantitative estimates within the consumer lending portfolio segment are calculated using a roll-rate model based on statistical relationships, calculated from historical data that estimate the movement of loan outstandings through the various stages of delinquency and ultimately charge-off. In general, the estimated rates at which loan outstandings roll from one stage of delinquency to another are dependent on various factors such as FICO scores, LTV ratios, the current economic environment, and geography.

While our quantitative reserve methodologies strive to reflect all risk factors, there continues to be a certain element of uncertainty associated with, but not limited to, potential imprecision in the estimation process due to the inherent time lag of obtaining information and normal variations between estimates and actual outcomes. We adjust the ALLL in consideration of these factors. The ALLL also includes factors that may not be directly measured in the determination of asset specific or quantitative reserves. Such qualitative factors include:

Rollforward of Allowance for Loan and Lease Losses and Associated Loan Data

				Commercial			Consumer
In millions				Lending			Lending				Total
June 30, 2011
	ALLOWANCE FOR LOAN AND LEASE LOSSES
		January 1		$	2,567		$	2,320		$	4,887
		Charge-offs			(671)			(587)			(1,258)
		Recoveries			242			69			311
			Net charge-offs		(429)			(518)			(947)
		Provision for credit losses			242			459			701
		Net change in allowance for unfunded loan commitments and letters of credit			11			(25)			(14)
			June 30	$	2,391		$	2,236		$	4,627
		TDRs individually evaluated for impairment		$	27		$	550		$	577
		Other loans individually evaluated for impairment			705						705
		Loans collectively evaluated for impairment			1,382			1,014			2,396
		Purchased impaired loans			277			672			949
			June 30	$	2,391		$	2,236		$	4,627
	LOAN PORTFOLIO
		TDRs individually evaluated for impairment		$	305		$	1,614		$	1,919
		Other loans individually evaluated for impairment			2,445						2,445
		Loans collectively evaluated for impairment			77,279			61,420			138,699
		Purchased impaired loans			1,120			6,136			7,256
			June 30	$	81,149		$	69,170		$	150,319
	Segment ALLL as a percentage of total ALLL				51.67	%		48.33	%		100.00	%
	Ratio of the allowance for loan and lease losses to total loans				2.95	%		3.23	%		3.08	%
June 30, 2010
	ALLOWANCE FOR LOAN AND LEASE LOSSES
		January 1		$	3,345		$	1,727		$	5,072
		Charge-offs			(1,052)			(760)			(1,812)
		Recoveries			211			70			281
			Net charge-offs		(841)			(690)			(1,531)
		Provision for credit losses			665			909			1,574
		Adoption of ASU 2009-17, Consolidations						141			141
		Other			2						2
		Net change in allowance for unfunded loan commitments and letters of credit			78						78
			June 30	$	3,249		$	2,087		$	5,336
		TDRs individually evaluated for impairment		$	14		$	145		$	159
		Other loans individually evaluated for impairment			987						987
		Loans collectively evaluated for impairment			1,903			1,428			3,331
		Purchased impaired loans			345			514			859
			June 30	$	3,249		$	2,087		$	5,336
	LOAN PORTFOLIO
		TDRs individually evaluated for impairment		$	54		$	775		$	829
		Other loans individually evaluated for impairment			3,736						3,736
		Loans collectively evaluated for impairment			75,831			64,819			140,650
		Purchased impaired loans			1,605			7,522			9,127
			June 30	$	81,226		$	73,116		$	154,342
	Segment ALLL as a percentage of total ALLL				60.89	%		39.11	%		100.00	%
	Ratio of the allowance for loan and lease losses to total loans				4.00	%		2.85	%		3.46	%

Originated impaired loans include commercial nonperforming loans and certain consumer, residential, and commercial loans whose terms have been modified in a TDR, regardless of nonperforming status. Nonperforming leases, loans held for sale, smaller balance homogeneous type loans, as well as purchased impaired loans are excluded. See Note 6 Purchased Impaired Loans for additional information. Nonperforming equipment lease financing loans of $35 million and $77 million at June 30, 2011, and December 31, 2010, respectively, are excluded from originated impaired loans pursuant to authoritative lease accounting guidance. We did not recognize any interest income on originated impaired loans, including TDRs that have not returned to performing status, while they were impaired during the six months ended June 30, 2011 and June 30, 2010. The following table provides further detail on originated impaired loans individually evaluated for reserves and the associated ALLL. Certain commercial impaired loans do not have a related allowance as the valuation of these impaired loans exceeded the recorded investment.

Originated Impaired Loans

			Unpaid							Average
			Principal		Recorded		Associated			Recorded
In millions			Balance		Investment (a)		Allowance (b)			Investment (a)
June 30, 2011
	Impaired loans with an associated allowance
		Commercial	$	1,309	$	925		$	317	$	1,079
		Commercial real estate		1,698		1,224			415		1,386
		Residential real estate		630		570			202		540
		Home equity		751		716			267		670
		Credit card		289		289			75		292
		Other consumer		39		39			6		35
	Total impaired loans with an associated allowance		$	4,716	$	3,763		$	1,282	$	4,002
	Impaired loans without an associated allowance
		Commercial	$	238	$	121				$	89
		Commercial real estate		668		480					428
	Total impaired loans without an associated allowance		$	906	$	601				$	517
	Total impaired loans		$	5,622	$	4,364		$	1,282	$	4,519
December 31, 2010
	Impaired loans with an associated allowance
		Commercial	$	1,769	$	1,178		$	410	$	1,533
		Commercial real estate		1,927		1,446			449		1,732
		Residential real estate		521		465			122		309
		Home equity		622		622			207		448
		Credit card		301		301			149		275
		Other consumer		34		34			7		30
	Total impaired loans with an associated allowance		$	5,174	$	4,046		$	1,344	$	4,327
	Impaired loans without an associated allowance
		Commercial	$	87	$	75				$	90
		Commercial real estate		525		389					320
	Total impaired loans without an associated allowance		$	612	$	464				$	410
	Total impaired loans		$	5,786	$	4,510		$	1,344	$	4,737
(a)	Recorded investment in a loan includes the unpaid principal balance plus accrued interest and net accounting adjustments, less any charge-offs. Recorded investment does not
	include any associated valuation allowance. Average recorded investment is for the six months ended June 30, 2011, and year ended December 31, 2010.
(b)	Associated allowance amounts include $577 million and $509 million for TDRs at June 30, 2011, and December 31, 2010, respectively.

We maintain the allowance for unfunded loan commitments and letters of credit at a level we believe is appropriate to absorb estimated probable losses on these unfunded credit facilities. See Note 1 Accounting Policies for additional information.