Loans and Related Allowance for Credit Losses

3 Months Ended

Mar. 31, 2022

Accounts, Notes, Loans and Financing Receivable, Gross, Allowance, and Net [Abstract]

Loans and Related Allowance for Credit Losses

Note 4:  Loans and Related Allowance for Credit Losses

Table 4.1 presents total loans outstanding by portfolio segment and class of financing receivable. Outstanding balances include unearned income, net deferred loan fees or costs, and unamortized discounts and premiums. These amounts were less

than 1% of our total loans outstanding at March 31, 2022, and December 31, 2021.

Outstanding balances exclude accrued interest receivable on loans, except for certain revolving loans, such as credit card loans.

See Note 7 (Other Assets) for additional information on accrued interest receivable. Amounts considered to be uncollectible are reversed through interest income. During first quarter 2022, we reversed accrued interest receivable of $12 million for our commercial portfolio segment and $32 million for our consumer portfolio segment, compared with $16 million and $51 million, respectively, for the same period a year ago.

Table 4.1: Loans Outstanding

(in millions)	Mar 31, 2022		Dec 31, 2021
Commercial:
Commercial and industrial	$	362,137	350,436
Real estate mortgage	129,495		127,733
Real estate construction	20,613		20,092
Lease financing	14,469		14,859
Total commercial	526,714		513,120
Consumer:
Residential mortgage – first lien	245,242		242,270
Residential mortgage – junior lien	15,392		16,618
Credit card	38,639		38,453
Auto	57,083		56,659
Other consumer	28,737		28,274
Total consumer	385,093		382,274
Total loans	$	911,807	895,394

Our non-U.S. loans are reported by respective class of financing receivable in the table above. Substantially all of our non-U.S. loan portfolio is commercial loans. Table 4.2 presents total non-U.S. commercial loans outstanding by class of financing receivable.

Table 4.2: Non-U.S. Commercial Loans Outstanding

(in millions)	Mar 31, 2022		Dec 31, 2021
Non-U.S. commercial loans:
Commercial and industrial	$	80,435	77,365
Real estate mortgage	7,072		7,070
Real estate construction	1,577		1,582
Lease financing	690		680
Total non-U.S. commercial loans	$	89,774	86,697

Loan Purchases, Sales, and Transfers

Table 4.3 presents the proceeds paid or received for purchases and sales of loans and transfers from loans held for investment to mortgages/loans held for sale. The table excludes loans for

which we have elected the fair value option and government insured/guaranteed residential mortgage – first lien loans because their loan activity normally does not impact the ACL.

Table 4.3: Loan Purchases, Sales, and Transfers

	2022				2021
(in millions)	Commercial		Consumer	Total	Commercial	Consumer	Total
Quarter ended March 31,
Purchases	$	100	—	100	48	1	49
Sales	(582)		—	(582)	(273)	(188)	(461)
Transfers (to)/from LHFS	21		(9)	12	(435)	63	(372)

Commitments to Lend

A commitment to lend is a legally binding agreement to lend to a customer, usually at a stated interest rate, if funded, and for specific purposes and time periods. We generally require a fee to extend such commitments. Certain commitments either provide us with funding discretion or are subject to loan agreements with covenants regarding the financial performance of the customer or borrowing base formulas on an ongoing basis that must be met before we are required to fund the commitment. We may reduce or cancel consumer commitments, including home equity lines and credit card lines, in accordance with the contracts and applicable law. For unconditionally cancelable commitments at our discretion, we do not recognize an ACL.

We may, as a representative for other lenders, advance funds or provide for the issuance of letters of credit under syndicated loan or letter of credit agreements. Any advances are generally repaid in less than a week and would normally require default of both the customer and another lender to expose us to loss. The unfunded amount of these temporary advance arrangements totaled approximately $90.6 billion at March 31, 2022.

We issue commercial letters of credit to assist customers in purchasing goods or services, typically for international trade. At March 31, 2022, and December 31, 2021, we had $1.9 billion and $1.5 billion, respectively, of outstanding issued commercial letters of credit. We also originate multipurpose lending commitments under which borrowers have the option to draw on the facility for different purposes in one of several forms, including a standby letter of credit. See Note 11 (Guarantees and Other Commitments) for additional information on standby letters of credit.

When we enter into commitments, we are exposed to credit risk. The maximum credit risk for these commitments will generally be lower than the contractual amount because a significant portion of these commitments are not funded. We manage the potential risk in commitments to lend by limiting the total amount of commitments, both by individual customer and in total, by monitoring the size and maturity structure of these commitments and by applying the same credit standards for these commitments as for all of our credit activities.

For loans and commitments to lend, we generally require collateral or a guarantee. We may require various types of collateral, including commercial and consumer real estate, autos, other short-term liquid assets such as accounts receivable or inventory and long-lived assets, such as equipment and other business assets. Collateral requirements for each loan or commitment may vary based on the loan product and our assessment of a customer’s credit risk according to the specific credit underwriting, including credit terms and structure.

The contractual amount of our unfunded credit commitments, including unissued standby and commercial letters of credit, is summarized by portfolio segment and class of financing receivable in Table 4.4. The table excludes the issued standby and commercial letters of credit and temporary advance arrangements described above.

Table 4.4: Unfunded Credit Commitments

(in millions)	Mar 31, 2022		Dec 31, 2021
Commercial:
Commercial and industrial	$	412,645	404,292
Real estate mortgage	9,499		11,515
Real estate construction	19,389		19,943
Total commercial	441,533		435,750
Consumer:
Residential mortgage – first lien	32,442		32,992
Residential mortgage – junior lien	25,924		27,447
Credit card	135,021		130,743
Other consumer	59,489		59,789
Total consumer	252,876		250,971
Total unfunded credit commitments	$	694,409	686,721

Allowance for Credit Losses

Table 4.5 presents the allowance for credit losses (ACL) for loans, which consists of the allowance for loan losses and the allowance for unfunded credit commitments. The ACL for loans decreased

$1.1 billion from December 31, 2021, reflecting reduced uncertainty around the economic impact of the COVID-19 pandemic on our loan portfolios and increased uncertainty related to the risks of high inflation.

Table 4.5: Allowance for Credit Losses for Loans

	Quarter ended March 31,
($ in millions)	2022			2021
Balance, beginning of period	$	13,788		19,713
Provision for credit losses	(775)			(1,117)
Interest income on certain loans (1)	(29)			(41)
Loan charge-offs:
Commercial:
Commercial and industrial	(56)			(159)
Real estate mortgage	—			(52)
Real estate construction	—			—
Lease financing	(4)			(21)
Total commercial	(60)			(232)
Consumer:
Residential mortgage – first lien	(25)			(17)
Residential mortgage – junior lien	(22)			(19)
Credit card	(267)			(335)
Auto	(165)			(129)
Other consumer	(108)			(147)
Total consumer	(587)			(647)
Total loan charge-offs	(647)			(879)
Loan recoveries:
Commercial:
Commercial and industrial	79			71
Real estate mortgage	5			6
Real estate construction	—			—
Lease financing	5			6
Total commercial	89			83
Consumer:
Residential mortgage – first lien	28			41
Residential mortgage – junior lien	40			38
Credit card	91			99
Auto	69			77
Other consumer	25			28
Total consumer	253			283
Total loan recoveries	342			366
Net loan charge-offs	(305)			(513)
Other	2			1
Balance, end of period	$	12,681		18,043
Components:
Allowance for loan losses	$	11,504		16,928
Allowance for unfunded credit commitments	1,177			1,115
Allowance for credit losses	$	12,681		18,043
Net loan charge-offs as a percentage of average total loans	0.14		%	0.24
Allowance for loan losses as a percentage of total loans	1.26			1.96
Allowance for credit losses for loans as a percentage of total loans	1.39			2.09

(1)Loans with an allowance measured by discounting expected cash flows using the loan’s effective interest rate over the remaining life of the loan recognize changes in allowance attributable to the passage of time as interest income.

Table 4.6 summarizes the activity in the ACL by our commercial and consumer portfolio segments. 

Table 4.6: Allowance for Credit Losses for Loans Activity by Portfolio Segment

	2022				2021
(in millions)	Commercial		Consumer	Total	Commercial	Consumer	Total
Quarter ended March 31,
Balance, beginning of period	$	7,791	5,997	13,788	11,516	8,197	19,713
Provision for credit losses	(665)		(110)	(775)	(667)	(450)	(1,117)
Interest income on certain loans (1)	(9)		(20)	(29)	(19)	(22)	(41)
Loan charge-offs	(60)		(587)	(647)	(232)	(647)	(879)
Loan recoveries	89		253	342	83	283	366
Net loan charge-offs	29		(334)	(305)	(149)	(364)	(513)
Other	2		—	2	1	—	1
Balance, end of period	$	7,148	5,533	12,681	10,682	7,361	18,043

(1)Loans with an allowance measured by discounting expected cash flows using the loan’s effective interest rate over the remaining life of the loan recognize changes in allowance attributable to the passage of time as interest income.

Credit Quality

We monitor credit quality by evaluating various attributes and utilize such information in our evaluation of the appropriateness of the ACL for loans. The following sections provide the credit quality indicators we most closely monitor. The credit quality indicators are generally based on information as of our financial statement date.

COMMERCIAL CREDIT QUALITY INDICATORS We manage a consistent process for assessing commercial loan credit quality. Commercial loans are generally subject to individual risk assessment using our internal borrower and collateral quality

ratings, which is our primary credit quality indicator. Our ratings are aligned to regulatory definitions of pass and criticized categories with the criticized segmented among special mention, substandard, doubtful and loss categories.

Table 4.7 provides the outstanding balances of our commercial loan portfolio by risk category and credit quality information by origination year for term loans. Revolving loans may convert to term loans as a result of a contractual provision in the original loan agreement or if modified in a troubled

debt restructuring (TDR). At March 31, 2022, we had $501.2 billion and $25.5 billion of pass and criticized commercial loans, respectively.

Table 4.7: Commercial Loan Categories by Risk Categories and Vintage

	Term loans by origination year							Revolving loans	Revolving loans converted to term loans	Total
(in millions)	2022		2021	2020	2019	2018	Prior
March 31, 2022
Commercial and industrial
Pass	$	25,954	49,141	16,084	19,801	6,756	11,769	221,270	643	351,418
Criticized	330		1,470	819	946	1,121	928	5,094	11	10,719
Total commercial and industrial	26,284		50,611	16,903	20,747	7,877	12,697	226,364	654	362,137
Real estate mortgage
Pass	9,636		36,066	15,336	17,767	11,912	21,815	5,009	—	117,541
Criticized	450		3,260	1,083	2,616	1,497	2,804	244	—	11,954
Total real estate mortgage	10,086		39,326	16,419	20,383	13,409	24,619	5,253	—	129,495
Real estate construction
Pass	913		6,255	3,866	4,216	2,055	561	1,043	1	18,910
Criticized	195		475	205	534	227	67	—	—	1,703
Total real estate construction	1,108		6,730	4,071	4,750	2,282	628	1,043	1	20,613
Lease financing
Pass	611		4,152	2,777	2,245	1,203	2,361	—	—	13,349
Criticized	77		275	217	249	154	148	—	—	1,120
Total lease financing	688		4,427	2,994	2,494	1,357	2,509	—	—	14,469
Total commercial loans	$	38,166	101,094	40,387	48,374	24,925	40,453	232,660	655	526,714
	Term loans by origination year							Revolving loans	Revolving loans converted to term loans	Total
	2021		2020	2019	2018	2017	Prior
December 31, 2021
Commercial and industrial
Pass	$	65,562	15,193	20,553	7,400	3,797	13,985	211,452	679	338,621
Criticized	1,657		884	1,237	1,256	685	551	5,528	17	11,815
Total commercial and industrial	67,219		16,077	21,790	8,656	4,482	14,536	216,980	696	350,436
Real estate mortgage
Pass	38,196		15,929	19,013	12,618	7,451	16,026	5,411	3	114,647
Criticized	3,462		1,119	2,975	1,834	875	2,421	400	—	13,086
Total real estate mortgage	41,658		17,048	21,988	14,452	8,326	18,447	5,811	3	127,733
Real estate construction
Pass	5,895		4,058	4,549	2,167	379	329	1,042	2	18,421
Criticized	510		266	586	234	68	7	—	—	1,671
Total real estate construction	6,405		4,324	5,135	2,401	447	336	1,042	2	20,092
Lease financing
Pass	4,100		3,012	2,547	1,373	838	1,805	—	—	13,675
Criticized	284		246	282	184	86	102	—	—	1,184
Total lease financing	4,384		3,258	2,829	1,557	924	1,907	—	—	14,859
Total commercial loans	$	119,666	40,707	51,742	27,066	14,179	35,226	223,833	701	513,120

Table 4.8 provides past due information for commercial loans, which we monitor as part of our credit risk management

practices; however, delinquency is not a primary credit quality indicator for commercial loans.

Table 4.8: Commercial Loan Categories by Delinquency Status

(in millions)	Commercial and industrial		Real estate mortgage	Real estate construction	Lease financing	Total
March 31, 2022
By delinquency status:
Current-29 days past due (DPD) and still accruing	$	360,333	127,757	20,513	14,221	522,824
30-89 DPD and still accruing	819		625	95	131	1,670
90+ DPD and still accruing	186		80	1	—	267
Nonaccrual loans	799		1,033	4	117	1,953
Total commercial loans	$	362,137	129,495	20,613	14,469	526,714
December 31, 2021
By delinquency status:
Current-29 DPD and still accruing	$	348,033	126,184	19,900	14,568	508,685
30-89 DPD and still accruing	1,217		285	179	143	1,824
90+ DPD and still accruing	206		29	—	—	235
Nonaccrual loans	980		1,235	13	148	2,376
Total commercial loans	$	350,436	127,733	20,092	14,859	513,120

CONSUMER CREDIT QUALITY INDICATORS  We have various classes of consumer loans that present unique credit risks. Loan delinquency, FICO credit scores and loan-to-value (LTV) for residential mortgage loans are the primary credit quality indicators that we monitor and utilize in our evaluation of the appropriateness of the ACL for the consumer loan portfolio segment.

Many of our loss estimation techniques used for the ACL for loans rely on delinquency-based models; therefore, delinquency is an important indicator of credit quality in the establishment of our ACL for consumer loans.

Table 4.9 provides the outstanding balances of our consumer loan portfolio by delinquency status. Credit quality information is provided with the year of origination for term loans. Revolving loans may convert to term loans as a result of a contractual provision in the original loan agreement or if modified in a TDR. The revolving loans converted to term loans in the credit card loan category represent credit card loans with modified terms that require payment over a specific term.

Payment deferral activities in the residential mortgage portfolio instituted in response to the COVID-19 pandemic could continue to delay the recognition of delinquencies for residential mortgage customers who otherwise would have moved into past due status.

Table 4.9: Consumer Loan Categories by Delinquency Status and Vintage

	Term loans by origination year							Revolving loans	Revolving loans converted to term loans
(in millions)	2022		2021	2020	2019	2018	Prior			Total
March 31, 2022
Residential mortgage – first lien
By delinquency status:
Current-29 DPD	$	18,386	68,443	39,567	22,814	6,951	69,780	4,671	1,788	232,400
30-59 DPD	49		97	20	31	12	430	13	32	684
60-89 DPD	—		13	5	1	5	122	5	17	168
90-119 DPD	—		3	2	—	6	59	3	10	83
120-179 DPD	—		2	11	1	1	77	6	13	111
180+ DPD	—		—	41	39	40	929	30	147	1,226
Government insured/guaranteed loans (1)	1		25	124	167	283	9,970	—	—	10,570
Total residential mortgage – first lien	18,436		68,583	39,770	23,053	7,298	81,367	4,728	2,007	245,242
Residential mortgage – junior lien
By delinquency status:
Current-29 DPD	5		31	19	28	24	652	9,695	4,516	14,970
30-59 DPD	—		—	—	1	—	10	18	38	67
60-89 DPD	—		—	—	—	—	4	7	20	31
90-119 DPD	—		—	—	—	—	2	5	12	19
120-179 DPD	—		—	—	—	—	4	5	17	26
180+ DPD	—		—	—	—	—	35	51	193	279
Total residential mortgage – junior lien	5		31	19	29	24	707	9,781	4,796	15,392
Credit cards
By delinquency status:
Current-29 DPD	—		—	—	—	—	—	37,844	195	38,039
30-59 DPD	—		—	—	—	—	—	169	10	179
60-89 DPD	—		—	—	—	—	—	119	8	127
90-119 DPD	—		—	—	—	—	—	100	6	106
120-179 DPD	—		—	—	—	—	—	185	3	188
180+ DPD	—		—	—	—	—	—	—	—	—
Total credit cards	—		—	—	—	—	—	38,417	222	38,639
Auto
By delinquency status:
Current-29 DPD	7,230		26,314	10,965	7,331	2,721	1,511	—	—	56,072
30-59 DPD	9		251	158	125	60	67	—	—	670
60-89 DPD	—		94	57	45	20	25	—	—	241
90-119 DPD	—		41	24	17	7	9	—	—	98
120-179 DPD	—		1	1	—	—	—	—	—	2
180+ DPD	—		—	—	—	—	—	—	—	—
Total auto	7,239		26,701	11,205	7,518	2,808	1,612	—	—	57,083
Other consumer
By delinquency status:
Current-29 DPD	985		1,892	579	576	153	198	24,155	132	28,670
30-59 DPD	—		5	2	3	1	1	10	3	25
60-89 DPD	—		3	1	1	1	1	4	1	12
90-119 DPD	—		3	1	1	1	—	3	1	10
120-179 DPD	—		—	—	—	—	—	7	3	10
180+ DPD	—		—	—	—	—	1	1	8	10
Total other consumer	985		1,903	583	581	156	201	24,180	148	28,737
Total consumer loans	$	26,665	97,218	51,577	31,181	10,286	83,887	77,106	7,173	385,093

(continued on following page)

(continued from previous page)

	Term loans by origination year							Revolving loans	Revolving loans converted to term loans
(in millions)	2021		2020	2019	2018	2017	Prior			Total
December 31, 2021
Residential mortgage – first lien
By delinquency status:
Current-29 DPD	$	69,994	41,527	24,887	7,660	13,734	61,576	5,248	1,673	226,299
30-59 DPD	129		27	30	12	24	418	14	29	683
60-89 DPD	10		7	2	—	3	126	7	15	170
90-119 DPD	—		1	1	1	5	53	4	9	74
120-179 DPD	1		16	2	2	1	63	4	14	103
180+ DPD	—		62	72	71	92	1,294	36	156	1,783
Government insured/guaranteed loans (1)	14		134	209	349	364	12,088	—	—	13,158
Total residential mortgage – first lien	70,148		41,774	25,203	8,095	14,223	75,618	5,313	1,896	242,270
Residential mortgage – junior lien
By delinquency status:
Current-29 DPD	28		20	30	26	21	700	10,883	4,426	16,134
30-59 DPD	—		—	—	—	1	10	29	46	86
60-89 DPD	—		—	—	—	—	4	10	21	35
90-119 DPD	—		—	—	1	—	3	4	12	20
120-179 DPD	—		—	—	—	—	5	7	14	26
180+ DPD	—		—	1	—	—	40	59	217	317
Total residential mortgage – junior lien	28		20	31	27	22	762	10,992	4,736	16,618
Credit cards
By delinquency status:
Current-29 DPD	—		—	—	—	—	—	37,686	192	37,878
30-59 DPD	—		—	—	—	—	—	176	7	183
60-89 DPD	—		—	—	—	—	—	118	5	123
90-119 DPD	—		—	—	—	—	—	98	5	103
120-179 DPD	—		—	—	—	—	—	165	1	166
180+ DPD	—		—	—	—	—	—	—	—	—
Total credit cards	—		—	—	—	—	—	38,243	210	38,453
Auto
By delinquency status:
Current-29 DPD	29,246		12,412	8,476	3,271	1,424	714	—	—	55,543
30-59 DPD	220		193	165	81	46	57	—	—	762
60-89 DPD	69		67	53	25	14	21	—	—	249
90-119 DPD	31		27	22	9	6	8	—	—	103
120-179 DPD	—		1	1	—	—	—	—	—	2
180+ DPD	—		—	—	—	—	—	—	—	—
Total auto	29,566		12,700	8,717	3,386	1,490	800	—	—	56,659
Other consumer
By delinquency status:
Current-29 DPD	2,221		716	703	203	107	125	23,988	143	28,206
30-59 DPD	3		2	3	1	—	2	10	4	25
60-89 DPD	2		1	2	1	—	1	5	1	13
90-119 DPD	1		1	2	1	—	—	4	—	9
120-179 DPD	—		—	—	—	—	—	8	2	10
180+ DPD	—		—	—	—	—	1	1	9	11
Total other consumer	2,227		720	710	206	107	129	24,016	159	28,274
Total consumer loans	$	101,969	55,214	34,661	11,714	15,842	77,309	78,564	7,001	382,274

(1)Represents loans whose repayments are predominantly insured by the Federal Housing Administration (FHA) or guaranteed by the Department of Veterans Affairs (VA). Loans insured/guaranteed by the FHA/VA and 90+ DPD totaled $3.8 billion and $5.7 billion at March 31, 2022, and December 31, 2021, respectively.

Of the $2.2 billion of consumer loans not government insured/guaranteed that are 90 days or more past due at March 31, 2022, $409 million was accruing, compared with

$2.7 billion past due and $424 million accruing at December 31, 2021.

We obtain Fair Isaac Corporation (FICO) scores at loan origination and the scores are generally updated at least quarterly, except in limited circumstances, including compliance with the Fair Credit Reporting Act (FCRA). FICO scores are not available for certain loan types or may not be required if we deem it unnecessary due to strong collateral and other borrower attributes. Substantially all loans not requiring a FICO score are

securities-based loans originated by our retail brokerage business.

Table 4.10 provides the outstanding balances of our consumer loan portfolio by FICO score. Substantially all of the scored consumer portfolio has an updated FICO score of 680 or above.

Table 4.10: Consumer Loan Categories by FICO and Vintage

	Term loans by origination year							Revolving loans	Revolving loans converted to term loans
(in millions)	2022		2021	2020	2019	2018	Prior			Total
March 31, 2022
By FICO:
Residential mortgage – first lien
800+	$	6,959	41,019	27,546	15,795	4,757	43,819	2,327	533	142,755
760-799	8,055		18,449	8,173	4,520	1,219	11,509	927	280	53,132
720-759	2,485		6,500	2,683	1,699	593	6,619	595	256	21,430
680-719	707		1,811	795	558	250	3,739	359	208	8,427
640-679	164		490	243	149	93	1,819	167	142	3,267
600-639	32		103	62	57	32	1,012	80	84	1,462
< 600	1		23	22	14	18	1,007	103	129	1,317
No FICO available	32		163	122	94	53	1,873	170	375	2,882
Government insured/guaranteed loans (1)	1		25	124	167	283	9,970	—	—	10,570
Total residential mortgage – first lien	18,436		68,583	39,770	23,053	7,298	81,367	4,728	2,007	245,242
Residential mortgage – junior lien
800+	—		—	—	—	—	170	4,987	1,561	6,718
760-799	—		—	—	—	—	102	1,884	809	2,795
720-759	—		—	—	—	—	114	1,290	777	2,181
680-719	—		—	—	—	—	105	752	634	1,491
640-679	—		—	—	—	—	56	293	323	672
600-639	—		—	—	—	—	33	141	192	366
< 600	—		—	—	—	—	42	147	210	399
No FICO available	5		31	19	29	24	85	287	290	770
Total residential mortgage – junior lien	5		31	19	29	24	707	9,781	4,796	15,392
Credit card
800+	—		—	—	—	—	—	4,468	2	4,470
760-799	—		—	—	—	—	—	6,070	8	6,078
720-759	—		—	—	—	—	—	8,383	27	8,410
680-719	—		—	—	—	—	—	9,129	49	9,178
640-679	—		—	—	—	—	—	5,866	46	5,912
600-639	—		—	—	—	—	—	2,284	32	2,316
< 600	—		—	—	—	—	—	2,124	57	2,181
No FICO available	—		—	—	—	—	—	93	1	94
Total credit card	—		—	—	—	—	—	38,417	222	38,639
Auto
800+	1,486		4,161	1,836	1,485	586	301	—	—	9,855
760-799	1,323		4,418	1,850	1,323	471	220	—	—	9,605
720-759	1,214		4,229	1,826	1,279	473	237	—	—	9,258
680-719	1,227		4,316	1,953	1,217	427	226	—	—	9,366
640-679	1,034		4,003	1,548	859	303	179	—	—	7,926
600-639	641		2,741	952	524	198	144	—	—	5,200
< 600	314		2,804	1,237	816	337	291	—	—	5,799
No FICO available	—		29	3	15	13	14	—	—	74
Total auto	7,239		26,701	11,205	7,518	2,808	1,612	—	—	57,083
Other consumer
800+	222		393	147	103	25	46	1,171	25	2,132
760-799	244		407	114	89	23	23	715	18	1,633
720-759	209		383	103	89	29	20	629	20	1,482
680-719	153		295	80	79	28	19	586	18	1,258
640-679	68		156	37	43	16	12	306	16	654
600-639	14		46	11	15	7	6	111	10	220
< 600	3		29	12	19	9	7	108	11	198
No FICO available	72		194	79	144	19	68	1,167	30	1,773
FICO not required	—		—	—	—	—	—	19,387	—	19,387
Total other consumer	985		1,903	583	581	156	201	24,180	148	28,737
Total consumer loans	$	26,665	97,218	51,577	31,181	10,286	83,887	77,106	7,173	385,093

(continued on following page)

(continued from previous page)

	Term loans by origination year							Revolving loans	Revolving loans converted to term loans
(in millions)	2021		2020	2019	2018	2017	Prior			Total
December 31, 2021
By FICO:
Residential mortgage – first lien
800+	$	35,935	27,396	16,583	5,153	9,430	37,495	2,554	469	135,015
760-799	23,645		9,814	5,412	1,464	2,485	10,509	1,073	265	54,667
720-759	7,842		3,083	1,980	642	1,137	6,277	646	238	21,845
680-719	1,986		876	645	283	501	3,682	393	206	8,572
640-679	449		233	187	89	129	1,851	188	146	3,272
600-639	101		63	46	31	41	1,035	102	89	1,508
< 600	15		13	24	19	41	1,083	114	124	1,433
No FICO available	161		162	117	65	95	1,598	243	359	2,800
Government insured/guaranteed loans (1)	14		134	209	349	364	12,088	—	—	13,158
Total residential mortgage – first lien	70,148		41,774	25,203	8,095	14,223	75,618	5,313	1,896	242,270
Residential mortgage – junior lien
800+	—		—	—	—	—	188	5,512	1,481	7,181
760-799	—		—	—	—	—	110	2,154	828	3,092
720-759	—		—	—	—	—	130	1,462	790	2,382
680-719	—		—	—	—	—	118	881	633	1,632
640-679	—		—	—	—	—	65	325	338	728
600-639	—		—	—	—	—	39	160	208	407
< 600	—		—	—	—	—	43	164	215	422
No FICO available	28		20	31	27	22	69	334	243	774
Total residential mortgage – junior lien	28		20	31	27	22	762	10,992	4,736	16,618
Credit card
800+	—		—	—	—	—	—	4,247	1	4,248
760-799	—		—	—	—	—	—	6,053	7	6,060
720-759	—		—	—	—	—	—	8,475	26	8,501
680-719	—		—	—	—	—	—	9,136	50	9,186
640-679	—		—	—	—	—	—	5,850	47	5,897
600-639	—		—	—	—	—	—	2,298	31	2,329
< 600	—		—	—	—	—	—	2,067	47	2,114
No FICO available	—		—	—	—	—	—	117	1	118
Total credit card	—		—	—	—	—	—	38,243	210	38,453
Auto
800+	4,688		1,983	1,680	690	318	108	—	—	9,467
760-799	4,967		2,123	1,586	586	234	87	—	—	9,583
720-759	4,789		2,104	1,503	583	241	106	—	—	9,326
680-719	5,005		2,282	1,441	526	218	111	—	—	9,583
640-679	4,611		1,824	1,025	369	160	99	—	—	8,088
600-639	3,118		1,114	617	243	117	92	—	—	5,301
< 600	2,372		1,236	853	376	193	187	—	—	5,217
No FICO available	16		34	12	13	9	10	—	—	94
Total auto	29,566		12,700	8,717	3,386	1,490	800	—	—	56,659
Other consumer
800+	450		162	128	34	8	47	1,343	22	2,194
760-799	502		147	117	33	7	22	819	19	1,666
720-759	461		134	115	38	9	18	714	22	1,511
680-719	349		95	99	37	9	15	630	22	1,256
640-679	170		44	55	21	6	8	328	17	649
600-639	42		13	19	9	3	4	117	9	216
< 600	18		12	22	11	3	5	114	12	197
No FICO available	235		113	155	23	62	10	1,236	36	1,870
FICO not required	—		—	—	—	—	—	18,715	—	18,715
Total other consumer	2,227		720	710	206	107	129	24,016	159	28,274
Total consumer loans	$	101,969	55,214	34,661	11,714	15,842	77,309	78,564	7,001	382,274

(1)Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA.

LTV refers to the ratio comparing the loan’s unpaid principal balance to the property’s collateral value. Combined LTV (CLTV) refers to the combination of first lien mortgage and junior lien mortgage (including unused line amounts for credit line products) ratios. We obtain LTVs and CLTVs using a cascade approach which first uses values provided by automated valuation models (AVMs) for the property. If an AVM is not

available, then the value is estimated using the original appraised value adjusted by the change in Home Price Index (HPI) for the property location. If an HPI is not available, the original appraised value is used. The HPI value is normally the only method considered for high value properties, generally with an original value of $1 million or more, as the AVM values have proven less accurate for these properties. Generally, we obtain available LTVs

and CLTVs on a quarterly basis. Certain loans do not have an LTV or CLTV due to a lack of industry data availability and portfolios acquired from or serviced by other institutions.

Table 4.11 shows the most updated LTV and CLTV distribution of the residential mortgage – first lien and residential mortgage – junior lien loan portfolios.

Table 4.11: Consumer Loan Categories by LTV/CLTV and Vintage

	Term loans by origination year							Revolving loans	Revolving loans converted to term loans
(in millions)	2022		2021	2020	2019	2018	Prior			Total
March 31, 2022
Residential mortgage – first lien
By LTV:
0-60%	$	7,187	27,906	24,257	15,714	5,040	64,410	3,997	1,772	150,283
60.01-80%	10,940		39,437	14,916	6,725	1,808	6,340	549	177	80,892
80.01-100%	290		1,056	354	359	121	342	111	39	2,672
100.01-120% (1)	—		25	26	18	8	45	22	5	149
> 120% (1)	—		12	5	5	1	29	12	3	67
No LTV available	18		122	88	65	37	231	37	11	609
Government insured/guaranteed loans (2)	1		25	124	167	283	9,970	—	—	10,570
Total residential mortgage – first lien	18,436		68,583	39,770	23,053	7,298	81,367	4,728	2,007	245,242
Residential mortgage – junior lien
By CLTV:
0-60%	—		—	—	—	—	450	7,388	3,707	11,545
60.01-80%	—		—	—	—	—	145	1,875	793	2,813
80.01-100%	—		—	—	—	—	43	403	223	669
100.01-120% (1)	—		—	—	—	—	9	73	34	116
> 120% (1)	—		—	—	—	—	2	25	10	37
No CLTV available	5		31	19	29	24	58	17	29	212
Total residential mortgage – junior lien	5		31	19	29	24	707	9,781	4,796	15,392
Total	$	18,441	68,614	39,789	23,082	7,322	82,074	14,509	6,803	260,634
	Term loans by origination year							Revolving loans	Revolving loans converted to term loans
	2021		2020	2019	2018	2017	Prior			Total
December 31, 2021
Residential mortgage – first lien
By LTV:
0-60%	$	26,618	22,882	16,063	5,310	11,030	57,880	4,348	1,644	145,775
60.01-80%	42,893		18,188	8,356	2,234	2,647	5,017	674	188	80,197
80.01-100%	486		437	474	147	134	339	157	42	2,216
100.01-120% (1)	10		31	24	11	7	48	33	8	172
> 120% (1)	5		10	10	4	3	35	14	3	84
No LTV available	122		92	67	40	38	211	87	11	668
Government insured/guaranteed loans (2)	14		134	209	349	364	12,088	—	—	13,158
Total residential mortgage – first lien	70,148		41,774	25,203	8,095	14,223	75,618	5,313	1,896	242,270
Residential mortgage – junior lien
By CLTV:
0-60%	—		—	—	—	—	475	7,949	3,588	12,012
60.01-80%	—		—	—	—	—	172	2,329	823	3,324
80.01-100%	—		—	—	—	—	55	554	241	850
100.01-120% (1)	—		—	—	—	—	13	104	42	159
> 120% (1)	—		—	—	—	—	3	35	13	51
No CLTV available	28		20	31	27	22	44	21	29	222
Total residential mortgage – junior lien	28		20	31	27	22	762	10,992	4,736	16,618
Total	$	70,176	41,794	25,234	8,122	14,245	76,380	16,305	6,632	258,888

(1)Reflects total loan balances with LTV/CLTV amounts in excess of 100%. In the event of default, the loss content would generally be limited to only the amount in excess of 100% LTV/CLTV.

(2)Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA.

NONACCRUAL LOANS Table 4.12 provides loans on nonaccrual status. Nonaccrual loans may have an ACL or a negative allowance for credit losses from expected recoveries of amounts previously written off. Customer payment deferral activities in

the residential mortgage portfolio instituted in response to the COVID-19 pandemic could continue to delay the recognition of nonaccrual loans for those residential mortgage customers who would have otherwise moved into nonaccrual status.

Table 4.12: Nonaccrual Loans

	Amortized cost					Recognized interest income
	Nonaccrual loans			Nonaccrual loans without related allowance for credit losses (1)		Quarter ended March 31,
(in millions)	Mar 31, 2022		Dec 31, 2021	Mar 31, 2022	Dec 31, 2021	2022	2021
Commercial:
Commercial and industrial	$	799	980	191	190	22	31
Real estate mortgage	1,033		1,235	50	66	17	11
Real estate construction	4		13	2	5	—	—
Lease financing	117		148	7	9	—	—
Total commercial	1,953		2,376	250	270	39	42
Consumer:
Residential mortgage- first lien	3,873		3,803	2,764	2,722	41	37
Residential mortgage- junior lien	802		801	555	497	14	12
Auto	208		198	—	—	8	9
Other consumer	35		34	—	—	1	1
Total consumer	4,918		4,836	3,319	3,219	64	59
Total nonaccrual loans	$	6,871	7,212	3,569	3,489	103	101

(1)Nonaccrual loans may not have an allowance for credit losses if the loss expectations are zero given solid collateral value.

LOANS IN PROCESS OF FORECLOSURE Our recorded investment in consumer mortgage loans collateralized by residential real estate property that are in process of foreclosure was $997 million and $694 million at March 31, 2022, and December 31, 2021, respectively, which included $834 million and $583 million, respectively, of loans that are government insured/guaranteed. Under the Consumer Financial Protection Bureau guidelines, we do not commence the foreclosure process on residential mortgage loans until after the loan is 120 days delinquent. Foreclosure procedures and timelines vary depending on whether the property address resides in a judicial or non-judicial state. Judicial states require the foreclosure to be processed through the state’s courts while non-judicial states are processed without court intervention. Foreclosure timelines vary according to state law.

LOANS 90 DAYS OR MORE PAST DUE AND STILL ACCRUING  Certain loans 90 days or more past due are still accruing, because they are (1) well-secured and in the process of collection or (2) residential mortgage or consumer loans exempt under regulatory rules from being classified as nonaccrual until later delinquency, usually 120 days past due.

Table 4.13 shows loans 90 days or more past due and still accruing by class for loans not government insured/guaranteed.

Table 4.13: Loans 90 Days or More Past Due and Still Accruing

($ in millions)	Mar 31, 2022		Dec 31, 2021
Total:	$	4,011	5,358
Less: FHA insured/VA guaranteed (1)	3,335		4,699
Total, not government insured/guaranteed	$	676	659
By segment and class, not government insured/guaranteed:
Commercial:
Commercial and industrial	$	186	206
Real estate mortgage	80		29
Real estate construction	1		—
Total commercial	267		235
Consumer:
Residential mortgage – first lien	14		37
Residential mortgage – junior lien	6		12
Credit card	294		269
Auto	79		88
Other consumer	16		18
Total consumer	409		424
Total, not government insured/guaranteed	$	676	659

(1)Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA.

TROUBLED DEBT RESTRUCTURINGS (TDRs)  When, for economic or legal reasons related to a borrower’s financial difficulties, we grant a concession for other than an insignificant period of time to a borrower that we would not otherwise consider, the related loan is classified as a TDR, the balance of which totaled $9.7 billion and $10.2 billion at March 31, 2022 and December 31, 2021, respectively. We do not consider loan resolutions such as foreclosure or short sale to be a TDR. In addition, COVID-related modifications are generally not classified as TDRs due to the relief under the CARES Act and the Interagency Statement. For additional information on the TDR relief, see Note 1 (Summary of Significant Accounting Policies) in our 2021 Form 10-K.

We may require some consumer borrowers experiencing financial difficulty to make trial payments generally for a period of three to four months, according to the terms of a planned permanent modification, to determine if they can perform according to those terms. These arrangements represent trial modifications, which we classify and account for as TDRs. While loans are in trial payment programs, their original terms are not considered modified and they continue to advance through delinquency status and accrue interest according to their original terms.

Commitments to lend additional funds on loans whose terms have been modified in a TDR amounted to $471 million and $431 million at March 31, 2022, and December 31, 2021, respectively.

Table 4.14 summarizes our TDR modifications for the periods presented by primary modification type and includes the financial effects of these modifications. For those loans that modify more than once, the table reflects each modification that occurred during the period. Loans that both modify and are paid off or written-off within the period, as well as changes in recorded investment during the period for loans modified in prior periods, are not included in the table.

Table 4.14: TDR Modifications

	Primary modification type (1)					Financial effects of modifications
($ in millions)	Principal forgiveness		Interest rate reduction	Other concessions (2)	Total	Charge- offs (3)	Weighted average interest rate reduction		Recorded investment related to interest rate reduction (4)
Quarter ended March 31, 2022
Commercial:
Commercial and industrial	$	—	6	73	79	—	9.94	%	$	6
Real estate mortgage	—		5	27	32	—	1.45		5
Real estate construction	—		—	—	—	—	—		—
Lease financing	—		—	—	—	—	—		—
Total commercial	—		11	100	111	—	6.37		11
Consumer:
Residential mortgage – first lien	1		60	315	376	1	1.58		60
Residential mortgage – junior lien	—		8	21	29	—	2.34		8
Credit card	—		70	—	70	—	19.12		70
Auto	1		3	40	44	9	4.91		3
Other consumer	—		3	1	4	—	11.64		3
Trial modifications (5)	—		—	211	211	—	—		—
Total consumer	2		144	588	734	10	10.43		144
Total	$	2	155	688	845	10	10.15	%	$	155
Quarter ended March 31, 2021
Commercial:
Commercial and industrial	$	—	1	230	231	6	0.89	%	$	1
Real estate mortgage	—		4	100	104	—	0.93		4
Real estate construction	—		—	1	1	—	—		—
Lease financing	—		—	3	3	—	—		—
Total commercial	—		5	334	339	6	0.92		5
Consumer:
Residential mortgage – first lien	—		7	532	539	—	1.87		7
Residential mortgage – junior lien	—		5	13	18	1	2.41		5
Credit card	—		32	—	32	—	18.87		32
Auto	—		1	14	15	7	3.87		1
Other consumer	—		7	1	8	—	12.20		7
Trial modifications (5)	—		—	—	—	—	—		—
Total consumer	—		52	560	612	8	14.01		52
Total	$	—	57	894	951	14	12.82	%	$	57

(1)Amounts represent the recorded investment in loans after recognizing the effects of the TDR, if any. TDRs may have multiple types of concessions, but are presented only once in the first modification type based on the order presented in the table above. The reported amounts include loans remodified of $118 million and $256 million for first quarter 2022 and 2021, respectively.

(2)Other concessions include loans with payment (principal and/or interest) deferral, loans discharged in bankruptcy, loan renewals, term extensions and other interest and noninterest adjustments, but exclude modifications that also forgive principal and/or reduce the contractual interest rate. The reported amounts include loans that are new TDRs that may have COVID-related payment deferrals and exclude COVID-related payment deferrals on loans previously reported as TDRs given limited current financial effects other than payment deferral.

(3)Charge-offs include write-downs of the investment in the loan in the period it is contractually modified. The amount of charge-off will differ from the modification terms if the loan has been charged down prior to the modification based on our policies. In addition, there may be cases where we have a charge-off/down with no legal principal modification.

(4)Recorded investment related to interest rate reduction reflects the effect of reduced interest rates on loans with an interest rate concession as one of their concession types, which includes loans reported as a principal primary modification type that also have an interest rate concession.

(5)Trial modifications are granted a delay in payments due under the original terms during the trial payment period. However, these loans continue to advance through delinquency status and accrue interest according to their original terms. Any subsequent permanent modification generally includes interest rate related concessions; however, the exact concession type and resulting financial effect are usually not known until the loan is permanently modified. Trial modifications for the period are presented net of previously reported trial modifications that became permanent in the current period.

Table 4.15 summarizes permanent modification TDRs that have defaulted in the current period within 12 months of their permanent modification date. We are reporting these defaulted

TDRs based on a payment default definition of 90 days past due for the commercial portfolio segment and 60 days past due for the consumer portfolio segment.

Table 4.15: Defaulted TDRs

	Recorded investment of defaults
	Quarter ended March 31,
(in millions)	2022		2021
Commercial:
Commercial and industrial	$	49	41
Real estate mortgage	2		16
Real estate construction	—		—
Lease financing	—		—
Total commercial	51		57
Consumer:
Residential mortgage – first lien	7		3
Residential mortgage – junior lien	—		1
Credit card	5		10
Auto	6		11
Other consumer	—		1
Total consumer	18		26
Total	$	69	83