ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK (Tables)

3 Months Ended

Mar. 31, 2015

Schedule of changes in the allowance for credit losses

The following is a summary of changes in the allowance for credit losses:



	Three Months Ended March 31, 2015
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses as of January 1, 2015		$544			$651			$1,195
Charge-offs	(6		)	(109		)	(115		)
Recoveries	28			33			61
Net recoveries (charge-offs)	22			(76		)	(54		)
Sales/Other	—			(2		)	(2		)
Provision charged to income	12			51			63
Allowance for loan and lease losses as of March 31, 2015	578			624			1,202
Reserve for unfunded lending commitments as of January 1, 2015	61			—			61
Credit for unfunded lending commitments	(5		)	—			(5		)
Reserve for unfunded lending commitments as of March 31, 2015	56			—			56
Total allowance for credit losses as of March 31, 2015		$634			$624			$1,258



	Three Months Ended March 31, 2014
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses as of January 1, 2014		$498			$723			$1,221
Charge-offs	(6		)	(122		)	(128		)
Recoveries	14			27			41
Net recoveries (charge-offs)	8			(95		)	(87		)
Provision charged to income	21			104			125
Allowance for loan and lease losses as of March 31, 2014	527			732			1,259
Reserve for unfunded lending commitments as of January 1, 2014	39			—			39
Credit for unfunded lending commitments	(4		)	—			(4		)
Reserve for unfunded lending commitments as of March 31, 2014	35			—			35
Total allowance for credit losses as of March 31, 2014		$562			$732			$1,294

Schedule of loans and leases based on evaluation method

The recorded investment in loans and leases based on the Company’s evaluation methodology is as follows:



	March 31, 2015						December 31, 2014
(in millions)	Commercial		Retail		Total		Commercial		Retail		Total
Individually evaluated		$194		$1,202		$1,396		$205		$1,208		$1,413
Formula-based evaluation	43,788		49,310		93,098		43,021		48,976		91,997
Total		$43,982		$50,512		$94,494		$43,226		$50,184		$93,410

Schedule of allowance for credit losses by evaluation method

The following is a summary of the allowance for credit losses by evaluation method:



	March 31, 2015						December 31, 2014
(in millions)	Commercial		Retail		Total		Commercial		Retail		Total
Individually evaluated		$35		$107		$142		$20		$109		$129
Formula-based evaluation	599		517		1,116		585		542		1,127
Allowance for credit losses		$634		$624		$1,258		$605		$651		$1,256

Schedule of classes of commercial loans and leases based on regulatory classifications

The recorded investment in classes of commercial loans and leases based on regulatory classification ratings is as follows:



	March 31, 2015
			Criticized
(in millions)	Pass		Special Mention		Substandard		Doubtful		Total
Commercial		$30,623		$903		$626		$97		$32,249
Commercial real estate	7,547		198		52		66		7,863
Leases	3,813		6		51		—		3,870
Total		$41,983		$1,107		$729		$163		$43,982



	December 31, 2014
			Criticized
(in millions)	Pass		Special Mention		Substandard		Doubtful		Total
Commercial		$30,022		$876		$427		$106		$31,431
Commercial real estate	7,354		329		61		65		7,809
Leases	3,924		12		50		—		3,986
Total		$41,300		$1,217		$538		$171		$43,226

Schedule of retail loan investments categorized by delinquency status

The recorded investment in classes of retail loans, categorized by delinquency status is as follows:



	March 31, 2015
(in millions)	Current		1-29 Days Past Due		30-89 Days Past Due		90 Days or More Past Due		Total
Residential mortgages		$11,373		$80		$97		$258		$11,808
Home equity loans	2,817		193		57		145		3,212
Home equity lines of credit	14,471		386		77		193		15,127
Home equity loans serviced by others ⁽¹⁾	1,082		67		22		21		1,192
Home equity lines of credit serviced by others ⁽¹⁾	455		59		11		19		544
Automobile	12,378		695		85		21		13,179
Student	2,725		70		27		30		2,852
Credit cards	1,517		37		18		16		1,588
Other retail	929		61		15		5		1,010
Total		$47,747		$1,648		$409		$708		$50,512

⁽¹⁾ The Company’s SBO portfolio consists of home equity loans and lines that were originally serviced by others. The Company now services a portion of this portfolio internally.



	December 31, 2014
(in millions)	Current		1-29 Days Past Due		30-89 Days Past Due		90 Days or More Past Due		Total
Residential mortgages		$11,352		$114		$97		$269		$11,832
Home equity loans	2,997		222		60		145		3,424
Home equity lines of credit	14,705		447		73		198		15,423
Home equity loans serviced by others ⁽¹⁾	1,101		78		26		23		1,228
Home equity lines of credit serviced by others ⁽¹⁾	455		66		10		19		550
Automobile	11,839		758		93		16		12,706
Student	2,106		108		25		17		2,256
Credit cards	1,615		39		22		17		1,693
Other retail	985		65		18		4		1,072
Total		$47,155		$1,897		$424		$708		$50,184

⁽¹⁾ The Company’s SBO portfolio consists of home equity loans and lines that were originally serviced by others. The Company now services a portion of this portfolio internally.

Schedule of nonperforming loans and leases by class

A summary of nonperforming loans and leases by class is as follows:



	March 31, 2015						December 31, 2014
(in millions)	Nonaccruing		Accruing and 90 Days or More Delinquent		Total Nonperforming Loans and Leases		Nonaccruing		Accruing and 90 Days or More Delinquent		Total Nonperforming Loans and Leases
Commercial		$94		$3		$97		$113		$1		$114
Commercial real estate	60		—		60		50		—		50
Leases	1		—		1		—		—		—
Total commercial	155		3		158		163		1		164
Residential mortgages	347		—		347		345		—		345
Home equity loans	210		—		210		203		—		203
Home equity lines of credit	270		—		270		257		—		257
Home equity loans serviced by others ⁽¹⁾	44		—		44		47		—		47
Home equity lines of credit serviced by others ⁽¹⁾	25		—		25		25		—		25
Automobile	30		—		30		21		—		21
Student	26		4		30		11		6		17
Credit cards	16		—		16		16		1		17
Other retail	4		2		6		5		—		5
Total retail	972		6		978		930		7		937
Total		$1,127		$9		$1,136		$1,093		$8		$1,101

⁽¹⁾ The Company’s SBO portfolio consists of home equity loans and lines that were originally serviced by others. The Company now services a portion of this portfolio internally.

Schedule of nonperforming assets

A summary of other nonperforming assets is as follows:



(in millions)	March 31, 2015		December 31, 2014
Nonperforming assets, net of valuation allowance:
Commercial		$1		$3
Retail	37		39
Nonperforming assets, net of valuation allowance		$38		$42

Summary of key performance indicators

A summary of key performance indicators is as follows:



	March 31, 2015		December 31, 2014
Nonperforming commercial loans and leases as a percentage of total loans and leases	0.17	%	0.18	%
Nonperforming retail loans as a percentage of total loans and leases	1.03		1.00
Total nonperforming loans and leases as a percentage of total loans and leases	1.20	%	1.18	%

Nonperforming commercial assets as a percentage of total assets	0.12	%	0.13	%
Nonperforming retail assets as a percentage of total assets	0.74		0.73
Total nonperforming assets as a percentage of total assets	0.86	%	0.86	%

Analysis of age of past due amounts

The following is an analysis of the age of the past due amounts (accruing and nonaccruing):



	March 31, 2015						December 31, 2014
(in millions)	30-89 Days Past Due		90 Days or More Past Due		Total Past Due		30-89 Days Past Due		90 Days or More Past Due		Total Past Due
Commercial		$42		$97		$139		$57		$114		$171
Commercial real estate	19		60		79		26		50		76
Leases	9		1		10		3		—		3
Total commercial	70		158		228		86		164		250
Residential mortgages	97		258		355		97		269		366
Home equity loans	57		145		202		60		145		205
Home equity lines of credit	77		193		270		73		198		271
Home equity loans serviced by others ⁽¹⁾	22		21		43		26		23		49
Home equity lines of credit serviced by others ⁽¹⁾	11		19		30		10		19		29
Automobile	85		21		106		93		16		109
Student	27		30		57		25		17		42
Credit cards	18		16		34		22		17		39
Other retail	15		5		20		18		4		22
Total retail	409		708		1,117		424		708		1,132
Total		$479		$866		$1,345		$510		$872		$1,382

⁽¹⁾ The Company’s SBO portfolio consists of home equity loans and lines that were originally serviced by others. The Company now services a portion of this portfolio internally.

Schedule of impaired loans by class

The following is a summary of impaired loan information by class:



	March 31, 2015
(in millions)	Impaired Loans With a Related Allowance		Allowance on Impaired Loans		Impaired Loans Without a Related Allowance		Unpaid Contractual Balance		Total Recorded Investment in Impaired Loans
Commercial		$97		$30		$41		$163		$138
Commercial real estate	20		5		36		64		56
Total commercial	117		35		77		227		194
Residential mortgages	129		17		316		605		445
Home equity loans	100		11		173		337		273
Home equity lines of credit	27		2		130		191		157
Home equity loans serviced by others ⁽¹⁾	59		9		29		100		88
Home equity lines of credit serviced by others ⁽¹⁾	4		1		7		14		11
Automobile	2		—		10		18		12
Student	165		49		1		166		166
Credit cards	31		13		—		31		31
Other retail	16		5		3		22		19
Total retail	533		107		669		1,484		1,202
Total		$650		$142		$746		$1,711		$1,396

⁽¹⁾ The Company’s SBO portfolio consists of home equity loans and lines that were originally serviced by others. The Company now services a portion of this portfolio internally.



	December 31, 2014
(in millions)	Impaired Loans With a Related Allowance		Allowance on Impaired Loans		Impaired Loans Without a Related Allowance		Unpaid Contractual Balance		Total Recorded Investment in Impaired Loans
Commercial		$124		$19		$36		$178		$160
Commercial real estate	7		1		38		62		45
Total commercial	131		20		74		240		205
Residential mortgages	157		18		288		605		445
Home equity loans	129		11		141		335		270
Home equity lines of credit	75		3		86		193		161
Home equity loans serviced by others ⁽¹⁾	75		9		16		102		91
Home equity lines of credit serviced by others ⁽¹⁾	4		1		7		14		11
Automobile	2		1		9		16		11
Student	167		48		—		167		167
Credit cards	32		13		—		32		32
Other retail	17		5		3		23		20
Total retail	658		109		550		1,487		1,208
Total		$789		$129		$624		$1,727		$1,413

⁽¹⁾The Company’s SBO portfolio consists of home equity loans and lines that were originally serviced by others. The Company now services a portion of this portfolio internally.

Schedule of additional information on impaired loans

Additional information on impaired loans is as follows:



	Three Months Ended March 31,
	2015				2014
(in millions)	Interest Income Recognized		Average Recorded Investment		Interest Income Recognized		Average Recorded Investment
Commercial		$1		$142		$—		$102
Commercial real estate	—		51		1		117
Total commercial	1		193		1		219
Residential mortgages	4		441		3		442
Home equity loans	2		268		2		248
Home equity lines of credit	1		156		1		159
Home equity loans serviced by others ⁽¹⁾	1		88		1		101
Home equity lines of credit serviced by others ⁽¹⁾	—		11		—		11
Automobile	—		11		—		9
Student	2		164		2		158
Credit cards	1		30		1		39
Other retail	—		19		—		23
Total retail	11		1,188		10		1,190
Total		$12		$1,381		$11		$1,409

⁽¹⁾ The Company’s SBO portfolio consists of home equity loans and lines that were originally serviced by others. The Company now services a portion of this portfolio internally.

Troubled debt restructurings on financing receivables

The following table summarizes how loans were modified during the three months ended March 31, 2015, the charge-offs related to the modifications, and the impact on the ALLL. The reported balances include loans that became TDRs during 2015, and were paid off in full, charged off, or sold prior to March 31, 2015.



	Primary Modification Types
	Interest Rate Reduction ⁽¹⁾					Maturity Extension ⁽²⁾
(dollars in millions)	Number of Contracts	Pre-Modification Outstanding Recorded Investment		Post-Modification Outstanding Recorded Investment		Number of Contracts	Pre-Modification Outstanding Recorded Investment		Post-Modification Outstanding Recorded Investment
Commercial	6		$1		$1	28		$10		$10
Commercial real estate	1	—		—		—	—		—
Total commercial	7	1		1		28	10		10
Residential mortgages	33	6		6		10	2		2
Home equity loans	21	1		1		37	5		5
Home equity lines of credit	—	—		—		3	—		—
Home equity loans serviced by others ⁽³⁾	17	1		1		—	—		—
Automobile	20	1		1		1	—		—
Credit cards	604	3		3		—	—		—
Total retail	695	12		12		51	7		7
Total	702		$13		$13	79		$17		$17



	Primary Modification Types
	Other ⁽⁴⁾
(dollars in millions)	Number of Contracts	Pre-Modification Outstanding Recorded Investment		Post-Modification Outstanding Recorded Investment		Net Change to ALLL Resulting from Modification			Charge-offs Resulting from Modification
Commercial	1		$2		$2		($1	)		$—
Commercial real estate	1	4		4		—			—
Total commercial	2	6		6		(1		)	—
Residential mortgages	64	6		6		(1		)	—
Home equity loans	197	10		10		—			—
Home equity lines of credit	135	8		7		—			1
Home equity loans serviced by others ⁽³⁾	46	2		2		—			1
Home equity lines of credit serviced by others ⁽³⁾	7	—		—		—			—
Automobile	297	5		4		—			1
Student	381	8		7		2			—
Other retail	11	—		—		—			—
Total retail	1,138	39		36		1			3
Total	1,140		$45		$42		$—			$3

⁽¹⁾ Includes modifications that consist of multiple concessions, one of which is an interest rate reduction.

⁽²⁾ Includes modifications that consist of multiple concessions, one of which is a maturity extension (unless one of the other concessions was an interest rate reduction).

⁽³⁾ The Company’s SBO portfolio consists of home equity loans and lines that were originally serviced by others. The Company now services a portion of this portfolio internally.

⁽⁴⁾ Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forbearance, capitalizing arrearages, and principal forgiveness. Also included are the following: deferrals, trial modifications, certain bankruptcies, loans in forbearance and prepayment plans. Modifications can include the deferral of accrued interest resulting in post-modification balances being higher than pre-modification.

The following table summarizes how loans were modified during the three months ended March 31, 2014, the charge-offs related to the modifications, and the impact on the ALLL. The reported balances include loans that became TDRs during 2014, and were paid off in full, charged off, or sold prior to March 31, 2014.



	Primary Modification Types
	Interest Rate Reduction ⁽¹⁾					Maturity Extension ⁽²⁾
(dollars in millions)	Number of Contracts	Pre-Modification Outstanding Recorded Investment		Post-Modification Outstanding Recorded Investment		Number of Contracts	Pre-Modification Outstanding Recorded Investment		Post-Modification Outstanding Recorded Investment
Commercial	7		$1		$1	13		$1		$1
Commercial real estate	1	—		—		—	—		—
Total commercial	8	1		1		13	1		1
Residential mortgages	42	6		6		12	2		1
Home equity loans	31	2		2		58	3		3
Home equity lines of credit	1	—		—		70	4		4
Home equity loans serviced by others ⁽³⁾	14	1		1		—	—		—
Home equity lines of credit serviced by others ⁽³⁾	2	—		—		—	—		—
Automobile	22	—		—		—	—		—
Credit cards	577	3		3		—	—		—
Other retail	2	—		—		—	—		—
Total retail	691	12		12		140	9		8
Total	699		$13		$13	153		$10		$9



	Primary Modification Types
	Other ⁽⁴⁾
(dollars in millions)	Number of Contracts	Pre-Modification Outstanding Recorded Investment		Post-Modification Outstanding Recorded Investment		Net Change to ALLL Resulting from Modification			Charge-offs Resulting from Modification
Commercial	1		$—		$—		($1	)		$—
Total commercial	1	—		—		(1		)	—
Residential mortgages	132	15		14		(1		)	—
Home equity loans	210	14		14		—			—
Home equity lines of credit	81	6		5		—			2
Home equity loans serviced by others ⁽³⁾	46	3		2		—			—
Home equity lines of credit serviced by others ⁽³⁾	13	—		—		—			—
Automobile	145	2		2		—			1
Student	457	8		8		—			—
Other retail	9	—		—		—			—
Total retail	1,093	48		45		(1		)	3
Total	1,094		$48		$45		($2	)		$3

⁽¹⁾ Includes modifications that consist of multiple concessions, one of which is an interest rate reduction.

⁽²⁾ Includes modifications that consist of multiple concessions, one of which is a maturity extension (unless one of the other concessions was an interest rate reduction).

⁽³⁾ The Company’s SBO portfolio consists of home equity loans and lines that were originally serviced by others. The Company now services a portion of this portfolio internally.

⁽⁴⁾ Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forbearance, capitalizing arrearages, and principal forgiveness. Also included are the following: deferrals, trial modifications, certain bankruptcies, loans in forbearance and prepayment plans. Modifications can include the deferral of accrued interest resulting in post modification balances being higher than pre-modification.

Schedule of defaults

The table below summarizes TDRs that defaulted during the three months ended March 31, 2015 and 2014 within 12 months of their modification date. For purposes of this table, a payment default is defined as being past due 90 days or more under the modified terms. Amounts represent the loan’s recorded investment at the time of payment default. Loan data includes loans meeting the criteria that were paid off in full, charged off, or sold prior to March 31, 2015 and 2014. If a TDR of any loan type becomes 90 days past due after being modified, the loan is written down to the fair value of collateral less cost to sell. The amount written off is charged to the ALLL.



	Three Months Ended March 31,
	2015			2014
(dollars in millions)	Number of Contracts	Balance Defaulted		Number of Contracts	Balance Defaulted
Commercial	6		$—	11		$1
Commercial real estate	—	—		1	1
Total commercial	6	—		12	2
Residential mortgages	49	7		40	4
Home equity loans	51	3		84	6
Home equity lines of credit	40	2		90	4
Home equity loans serviced by others ⁽¹⁾	16	—		16	—
Home equity lines of credit serviced by others ⁽¹⁾	1	—		9	—
Automobile	23	—		32	—
Student	65	2		97	2
Credit cards	102	1		166	1
Other retail	2	—		6	—
Total retail	349	15		540	17
Total	355		$15	552		$19

⁽¹⁾ The Company’s SBO portfolio consists of loans that were originally serviced by others. The Company now services a portion of this portfolio internally.

Schedule of loans that may increase credit exposure

The following table presents balances of loans with these characteristics:



	March 31, 2015
(in millions)	Residential Mortgages		Home Equity Loans and Lines of Credit		Home Equity Products serviced by others		Credit Cards		Total
High loan-to-value		$697		$1,429		$1,042		$—		$3,168
Interest only/negative amortization	937		—		—		—		937
Low introductory rate	—		—		—		87		87
Multiple characteristics and other	21		—		—		—		21
Total		$1,655		$1,429		$1,042		$87		$4,213



	December 31, 2014
(in millions)	Residential Mortgages		Home Equity Loans and Lines of Credit		Home Equity Products serviced by others		Credit Cards		Total
High loan-to-value		$773		$1,743		$1,025		$—		$3,541
Interest only/negative amortization	894		—		—		—		894
Low introductory rate	—		—		—		98		98
Multiple characteristics and other	24		—		—		—		24
Total		$1,691		$1,743		$1,025		$98		$4,557