The following table presents capital and capital ratio information evidencing the Company’s transition from Basel I regulatory accounting as of December 31, 2014 to Basel III regulatory accounting as of December 31, 2015. Basel I requirements did not include the common equity tier I capital ratio. Certain Basel III requirements are subject to phase-in through 2019, and these phase-in rules are used in this report of actual regulatory ratios. In addition, the Company has declared itself as an “AOCI opt-out” institution, which means that the Company will not be required to change its methodology for recognizing in regulatory capital only a subset of unrealized gains and losses that are classified as AOCI. As an AOCI opt-out institution, the Company is not required to recognize within regulatory capital the impacts of net unrealized gains and losses on securities AFS, accumulated net gains and losses on cash-flow hedges included in AOCI, net gains and losses on certain defined benefit pension plan assets, and net unrealized gains and losses on securities held to maturity that are included in AOCI.



	Transitional Basel III
										FDIA Requirements
		Actual				Minimum Capital Adequacy				Classification as Well-capitalized
(dollars in millions)		Amount		Ratio		Amount		Ratio		Amount		Ratio
As of December 31, 2015	Basel III
Common equity tier 1 capital⁽¹⁾			$13,389	11.7	%		$5,134	4.5	%		$7,415	6.5	%
Tier 1 capital⁽²⁾		13,636		12.0		6,845		6.0		9,127		8.0
Total capital⁽³⁾		17,505		15.3		9,127		8.0		11,408		10.0
Tier 1 leverage⁽⁴⁾		13,636		10.5		5,218		4.0		6,523		5.0
As of December 31, 2014	Basel I
Tier 1 common equity⁽¹⁾			$13,173	12.4	%	Not Applicable		Not Applicable		Not Applicable		Not Applicable
Tier 1 capital⁽²⁾		13,173		12.4			$4,239	4.0	%		$6,358	6.0	%
Total capital⁽³⁾		16,781		15.8		8,477		8.0		10,596		10.0
Tier 1 leverage⁽⁴⁾		13,173		10.6		4,982		4.0		6,227		5.0

⁽¹⁾CET1 under Basel III replaced the concept of tier 1 common capital that existed under Basel I effective January 1, 2015. “Common equity tier 1 capital ratio” as of December 31, 2015 represents CET1 divided by total risk-weighted assets as defined under Basel III Standardized approach. The “tier 1 common capital ratio” reported prior to January 1, 2015, represented tier 1 common equity divided by total risk-weighted assets as defined under the Basel I general risk-based capital rule.

⁽²⁾“Tier 1 capital ratio” is tier 1 capital, which includes CET1 capital plus non-cumulative perpetual preferred equity that qualifies as additional tier 1 capital, divided by total risk-weighted assets as defined under Basel III Standardized approach. The “tier 1 capital ratio” reported prior to January 1, 2015, represented tier 1 capital divided by total risk-weighted assets as defined under the Basel I general risk-based capital rule.

⁽³⁾“Total capital ratio” is total capital divided by total risk-weighted assets as defined under Basel III Standardized approach. The “Total capital ratio” reported prior to January 1, 2015, represented total capital divided by total risk-weighted assets as defined under the Basel I general risk-based capital rule.

⁽⁴⁾ “Tier 1 leverage ratio” is tier 1 capital divided by quarterly average total assets as defined under Basel III Standardized approach. The “tier 1 leverage ratio” reported prior to January 1, 2015, represented tier 1 capital divided by quarterly average total assets as defined under the Basel I general risk-based capital rule.