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

12 Months Ended

Dec. 31, 2015

Schedule of changes in the allowance for credit losses

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



	Year Ended December 31, 2015
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses as of January 1, 2015		$544			$651			$1,195
Charge-offs	(36		)	(444		)	(480		)
Recoveries	49			147			196
Net recoveries (charge-offs)	13			(297		)	(284		)
Provision charged to income	39			266			305
Allowance for loan and lease losses as of December 31, 2015	596			620			1,216
Reserve for unfunded lending commitments as of January 1, 2015	61			—			61
Credit for unfunded lending commitments	(3		)	—			(3		)
Reserve for unfunded lending commitments as of December 31, 2015	58			—			58
Total allowance for credit losses as of December 31, 2015		$654			$620			$1,274



	Year Ended December 31, 2014
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses as of January 1, 2014		$498			$723			$1,221
Charge-offs	(43		)	(450		)	(493		)
Recoveries	58			112			170
Net (charge-offs) recoveries	15			(338		)	(323		)
Provision charged to income	31			266			297
Allowance for loan and lease losses as of December 31, 2014	544			651			1,195
Reserve for unfunded lending commitments as of January 1, 2014	39			—			39
Provision for unfunded lending commitments	22			—			22
Reserve for unfunded lending commitments as of December 31, 2014	61			—			61
Total allowance for credit losses as of December 31, 2014		$605			$651			$1,256



	Year Ended December 31, 2013
(in millions)	Commercial			Retail			Unallocated			Total
Allowance for loan and lease losses as of January 1, 2013		$509			$657			$89			$1,255
Charge-offs	(108		)	(595		)	—			(703		)
Recoveries	87			115			—			202
Net charge-offs	(21		)	(480		)	—			(501		)
Sales/Other	(6		)	(6		)	(1		)	(13		)
Provision charged to income	(19		)	396			103			480
Transfer of unallocated reserve to qualitative reserve	35			60			(95		)	—
Loss emergence period change	—			96			(96		)	—
Allowance for loan and lease losses as of December 31, 2013	498			723			—			1,221
Reserve for unfunded lending commitments as of January 1, 2013	40			—			—			40
Credit for unfunded lending commitments	(1		)	—			—			(1		)
Reserve for unfunded lending commitments as of December 31, 2013	39			—			—			39
Total allowance for credit losses as of December 31, 2013		$537			$723			$—			$1,260

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:



	December 31, 2015						December 31, 2014
(in millions)	Commercial		Retail		Total		Commercial		Retail		Total
Individually evaluated		$218		$1,165		$1,383		$205		$1,208		$1,413
Formula-based evaluation	45,996		51,663		97,659		43,021		48,976		91,997
Total		$46,214		$52,828		$99,042		$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:



	December 31, 2015						December 31, 2014
(in millions)	Commercial		Retail		Total		Commercial		Retail		Total
Individually evaluated		$36		$101		$137		$20		$109		$129
Formula-based evaluation	618		519		1,137		585		542		1,127
Allowance for credit losses		$654		$620		$1,274		$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:



	December 31, 2015
			Criticized
(in millions)	Pass		Special Mention		Substandard		Doubtful		Total
Commercial		$31,276		$911		$1,002		$75		$33,264
Commercial real estate	8,450		272		171		78		8,971
Leases	3,880		55		44		—		3,979
Total		$43,606		$1,238		$1,217		$153		$46,214



	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:



	December 31, 2015
(in millions)	Current		1-29 Days Past Due		30-89 Days Past Due		90 Days or More Past Due		Total
Residential mortgages		$12,905		$97		$70		$246		$13,318
Home equity loans	2,245		164		44		104		2,557
Home equity lines of credit	13,982		407		80		205		14,674
Home equity loans serviced by others ⁽¹⁾	886		60		20		20		986
Home equity lines of credit serviced by others ⁽¹⁾	296		48		16		29		389
Automobile	12,670		964		159		35		13,828
Student	4,175		113		30		41		4,359
Credit cards	1,554		44		20		16		1,634
Other retail	1,013		53		12		5		1,083
Total		$49,726		$1,950		$451		$701		$52,828

⁽¹⁾ The Company’s SBO portfolio consists of purchased 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 purchased 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:



	December 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		$70		$1		$71		$113		$1		$114
Commercial real estate	77		—		77		50		—		50
Leases	—		—		—		—		—		—
Total commercial	147		1		148		163		1		164
Residential mortgages	331		—		331		345		—		345
Home equity loans	135		—		135		203		—		203
Home equity lines of credit	272		—		272		257		—		257
Home equity loans serviced by others ⁽¹⁾	38		—		38		47		—		47
Home equity lines of credit serviced by others ⁽¹⁾	32		—		32		25		—		25
Automobile	42		—		42		21		—		21
Student	35		6		41		11		6		17
Credit cards	16		—		16		16		1		17
Other retail	3		2		5		5		—		5
Total retail	904		8		912		930		7		937
Total		$1,051		$9		$1,060		$1,093		$8		$1,101

⁽¹⁾ The Company’s SBO portfolio consists of purchased 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:



	December 31,
(in millions)	2015		2014
Nonperforming assets, net of valuation allowance:
Commercial		$1		$3
Retail	45		39
Nonperforming assets, net of valuation allowance		$46		$42

Summary of key performance indicators

A summary of key performance indicators is as follows:



	December 31,
	2015		2014
Nonperforming commercial loans and leases as a percentage of total loans and leases	0.15	%	0.18	%
Nonperforming retail loans as a percentage of total loans and leases	0.92		1.00
Total nonperforming loans and leases as a percentage of total loans and leases	1.07	%	1.18	%

Nonperforming commercial assets as a percentage of total assets	0.11	%	0.13	%
Nonperforming retail assets as a percentage of total assets	0.69		0.73
Total nonperforming assets as a percentage of total assets	0.80	%	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):



	December 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		$13		$71		$84		$57		$114		$171
Commercial real estate	33		77		110		26		50		76
Leases	10		—		10		3		—		3
Total commercial	56		148		204		86		164		250
Residential mortgages	70		246		316		97		269		366
Home equity loans	44		104		148		60		145		205
Home equity lines of credit	80		205		285		73		198		271
Home equity loans serviced by others ⁽¹⁾	20		20		40		26		23		49
Home equity lines of credit serviced by others ⁽¹⁾	16		29		45		10		19		29
Automobile	159		35		194		93		16		109
Student	30		41		71		25		17		42
Credit cards	20		16		36		22		17		39
Other retail	12		5		17		18		4		22
Total retail	451		701		1,152		424		708		1,132
Total		$507		$849		$1,356		$510		$872		$1,382

⁽¹⁾ The Company’s SBO portfolio consists of purchased 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:



	December 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		$92		$23		$58		$144		$150
Commercial real estate	56		13		12		70		68
Total commercial	148		36		70		214		218
Residential mortgages	121		16		320		608		441
Home equity loans	85		11		139		283		224
Home equity lines of credit	27		2		167		234		194
Home equity loans serviced by others ⁽¹⁾	50		8		24		88		74
Home equity lines of credit serviced by others ⁽¹⁾	3		1		7		14		10
Automobile	3		—		11		19		14
Student	163		48		2		165		165
Credit cards	28		11		—		28		28
Other retail	13		4		2		18		15
Total retail	493		101		672		1,457		1,165
Total		$641		$137		$742		$1,671		$1,383

⁽¹⁾ The Company’s SBO portfolio consists of purchased 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 purchased 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:



	Year Ended December 31,
	2015				2014				2013
(in millions)	Interest Income Recognized		Average Recorded Investment		Interest Income Recognized		Average Recorded Investment		Interest Income Recognized		Average Recorded Investment
Commercial		$4		$135		$9		$198		$1		$157
Commercial real estate	1		44		2		98		1		149
Total commercial	5		179		11		296		2		306
Residential mortgages	15		415		14		429		7		419
Home equity loans	9		222		8		246		5		228
Home equity lines of credit	4		173		4		149		2		90
Home equity loans serviced by others ⁽¹⁾	4		75		5		91		5		102
Home equity lines of credit serviced by others ⁽¹⁾	—		9		—		11		—		12
Automobile	—		11		—		7		—		8
Student	7		157		8		153		7		140
Credit cards	2		26		2		31		3		41
Other retail	1		16		1		21		1		25
Total retail	42		1,104		42		1,138		30		1,065
Total		$47		$1,283		$53		$1,434		$32		$1,371

⁽¹⁾ The Company’s SBO portfolio consists of purchased 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 year ended December 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 December 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	25		$19		$19	160		$22		$22
Commercial real estate	1	—		—		1	—		—
Total commercial	26	19		19		161	22		22
Residential mortgages	153	31		31		40	7		6
Home equity loans	96	5		5		191	35		35
Home equity lines of credit	4	1		1		23	2		2
Home equity loans serviced by others ⁽³⁾	29	2		2		—	—		—
Home equity lines of credit serviced by others ⁽³⁾	2	—		—		1	—		—
Automobile	108	2		2		5	—		—
Student	—	—		—		—	—		—
Credit cards	2,413	13		13		—	—		—
Other retail	3	—		—		—	—		—
Total retail	2,808	54		54		260	44		43
Total	2,834		$73		$73	421		$66		$65



	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	16		$34		$34		($1	)		$1
Commercial real estate	1	4		4		—			—
Total commercial	17	38		38		(1		)	1
Residential mortgages	275	33		33		(1		)	—
Home equity loans	448	28		28		—			1
Home equity lines of credit	320	21		19		—			2
Home equity loans serviced by others ⁽³⁾	124	6		5		—			1
Home equity lines of credit serviced by others ⁽³⁾	41	3		2		—			—
Automobile	812	14		12		—			2
Student	1,204	22		22		4			—
Credit cards	—	—		—		2			—
Other retail	20	—		—		—			—
Total retail	3,244	127		121		5			6
Total	3,261		$165		$159		$4			$7

⁽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 purchased 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 year ended December 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 December 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	25		$8		$7	131		$21		$22
Commercial real estate	9	1		2		15	3		2
Total commercial	34	9		9		146	24		24
Residential mortgages	126	17		17		40	6		5
Home equity loans	125	8		9		85	5		6
Home equity lines of credit	7	—		—		276	17		16
Home equity loans serviced by others ⁽³⁾	42	2		2		—	—		—
Home equity lines of credit serviced by others ⁽³⁾	4	—		—		1	—		—
Automobile	75	1		1		18	—		—
Student	—	—		—		—	—		—
Credit cards	2,165	12		12		—	—		—
Other retail	3	—		—		—	—		—
Total retail	2,547	40		41		420	28		27
Total	2,581		$49		$50	566		$52		$51



	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	27		$52		$74		$3			$—
Commercial real estate	1	7		7		—			3
Total commercial	28	59		81		3			3
Residential mortgages	393	47		46		(4		)	1
Home equity loans	1,046	63		62		(1		)	2
Home equity lines of credit	356	25		21		—			5
Home equity loans serviced by others ⁽³⁾	138	5		5		(1		)	—
Home equity lines of credit serviced by others ⁽³⁾	39	2		2		—			—
Automobile	1,039	17		13		—			5
Student	1,675	31		31		5			—
Credit cards	—	—		—		—			—
Other retail	57	2		1		(1		)	—
Total retail	4,743	192		181		(2		)	13
Total	4,771		$251		$262		$1			$16

⁽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 purchased home equity loans and lines that were originally serviced by others. The Company now services a portion of this portfolio internally.

The following table summarizes how loans were modified during the year ended December 31, 2013, the charge-offs related to the modifications, and the impact on the ALLL. The reported balances include loans that became TDRs during 2013 and were paid off in full, charged off, or sold prior to December 31, 2013.



	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	126		$13		$13	134		$18		$18
Commercial real estate	11	7		7		3	1		1
Total commercial	137	20		20		137	19		19
Residential mortgages	200	32		33		46	5		6
Home equity loans	196	15		16		94	6		6
Home equity lines of credit	18	1		1		2,081	80		70
Home equity loans serviced by others ⁽³⁾	31	2		2		5	—		—
Home equity lines of credit serviced by others ⁽³⁾	3	—		—		1	—		—
Automobile	238	2		2		2	—		—
Student	—	—		—		—	—		—
Credit cards	2,729	15		15		—	—		—
Other retail	21	—		—		—	—		—
Total retail	3,436	67		69		2,229	91		82
Total	3,573		$87		$89	2,366		$110		$101



	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	6		$1		$1		$—			$1
Commercial real estate	1	—		—		(2		)	—
Total commercial	7	1		1		(2		)	1
Residential mortgages	430	64		63		5			2
Home equity loans	995	57		51		2			5
Home equity lines of credit	771	53		46		—			16
Home equity loans serviced by others ⁽³⁾	269	12		10		—			3
Home equity lines of credit serviced by others ⁽³⁾	43	2		1		—			1
Automobile	1,323	13		10		—			3
Student	2,620	48		47		—			—
Credit cards	—	—		—		—			—
Other retail	148	3		3		—			1
Total retail	6,599	252		231		7			31
Total	6,606		$253		$232		$5			$32

⁽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 purchased 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 year ended December 31, 2015, 2014 and 2013 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 December 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.



	Year Ended December 31,
	2015			2014			2013
(dollars in millions)	Number of Contracts	Balance Defaulted		Number of Contracts	Balance Defaulted		Number of Contracts	Balance Defaulted
Commercial	23		$2	37		$12	18		$1
Commercial real estate	—	—		3	1		3	1
Total commercial	23	2		40	13		21	2
Residential mortgages	168	21		301	35		526	60
Home equity loans	184	13		329	24		740	43
Home equity lines of credit	131	7		229	12		394	21
Home equity loans serviced by others ⁽¹⁾	43	1		60	2		187	3
Home equity lines of credit serviced by others ⁽¹⁾	22	1		20	—		42	2
Automobile	87	1		112	1		208	1
Student	171	3		355	7		885	17
Credit cards	455	3		579	3		548	3
Other retail	4	—		12	—		33	1
Total retail	1,265	50		1,997	84		3,563	151
Total	1,288		$52	2,037		$97	3,584		$153

⁽¹⁾ The Company’s SBO portfolio consists of purchased home equity loans and lines 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:



	December 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		$649		$1,038		$785		$—		$2,472
Interest only/negative amortization	1,110		—		—		—		1,110
Low introductory rate	—		3		—		96		99
Multiple characteristics and other	14		—		—		—		14
Total		$1,773		$1,041		$785		$96		$3,695



	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