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

3 Months Ended

Mar. 31, 2016

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, 2016
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses as of January 1, 2016		$596			$620			$1,216
Charge-offs	(13		)	(113		)	(126		)
Recoveries	4			39			43
Net charge-offs	(9		)	(74		)	(83		)
Provision charged to income	46			45			91
Allowance for loan and lease losses as of March 31, 2016	633			591			1,224
Reserve for unfunded lending commitments as of January 1, 2016	58			—			58
Credit for unfunded lending commitments	—			—			—
Reserve for unfunded lending commitments as of March 31, 2016	58			—			58
Total allowance for credit losses as of March 31, 2016		$691			$591			$1,282



	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
Provision 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

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, 2016						December 31, 2015
(in millions)	Commercial		Retail		Total		Commercial		Retail		Total
Individually evaluated		$439		$775		$1,214		$218		$1,165		$1,383
Formula-based evaluation	47,533		52,244		99,777		45,996		51,663		97,659
Total		$47,972		$53,019		$100,991		$46,214		$52,828		$99,042

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, 2016						December 31, 2015
(in millions)	Commercial		Retail		Total		Commercial		Retail		Total
Individually evaluated		$42		$82		$124		$36		$101		$137
Formula-based evaluation	649		509		1,158		618		519		1,137
Allowance for credit losses		$691		$591		$1,282		$654		$620		$1,274

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, 2016
			Criticized
(in millions)	Pass		Special Mention		Substandard		Doubtful		Total
Commercial		$32,567		$928		$1,086		$90		$34,671
Commercial real estate	8,864		272		184		86		9,406
Leases	3,767		72		56		—		3,895
Total		$45,198		$1,272		$1,326		$176		$47,972



	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

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, 2016
(in millions)	Current		1-29 Days Past Due		30-59 Days Past Due		60-89 Days Past Due		90 Days or More Past Due		Total
Residential mortgages		$13,058		$77		$52		$7		$151		$13,345
Home equity loans	2,055		147		26		5		80		2,313
Home equity lines of credit	13,870		380		53		17		206		14,526
Home equity loans serviced by others ⁽¹⁾	840		55		14		1		20		930
Home equity lines of credit serviced by others ⁽¹⁾	250		40		9		5		35		339
Automobile	12,827		860		104		20		36		13,847
Student	4,848		87		17		9		45		5,006
Credit cards	1,511		37		10		7		16		1,581
Other retail	1,069		49		9		2		3		1,132
Total		$50,328		$1,732		$294		$73		$592		$53,019

⁽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, 2015
(in millions)	Current		1-29 Days Past Due		30-59 Days Past Due		60-89 Days Past Due		90 Days or More Past Due		Total
Residential mortgages		$12,905		$97		$54		$16		$246		$13,318
Home equity loans	2,245		164		32		12		104		2,557
Home equity lines of credit	13,982		407		60		20		205		14,674
Home equity loans serviced by others ⁽¹⁾	886		60		14		6		20		986
Home equity lines of credit serviced by others ⁽¹⁾	296		48		10		6		29		389
Automobile	12,670		964		127		32		35		13,828
Student	4,175		113		19		11		41		4,359
Credit cards	1,554		44		11		9		16		1,634
Other retail	1,013		53		8		4		5		1,083
Total		$49,726		$1,950		$335		$116		$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.

Schedule of nonperforming loans and leases by class

The following table presents nonperforming loans and leases and loans accruing 90 days or more past due:



	Nonperforming ⁽¹⁾				Accruing and 90 days or more past due
(in millions)	March 31, 2016		December 31, 2015		March 31, 2016		December 31, 2015
Commercial		$284		$71		$2		$1
Commercial real estate	86		77		2		—
Leases	—		—		—		—
Total commercial	370		148		4		1
Residential mortgages^{(2) (3) (4)}	174		331		22		—
Home equity loans ⁽²⁾	99		135		—		—
Home equity lines of credit	261		272		—		—
Home equity loans serviced by others ⁽⁵⁾	37		38		—		—
Home equity lines of credit serviced by others ⁽⁵⁾	38		32		—		—
Automobile	42		42		—		—
Student	40		41		5		6
Credit card	16		16		—		—
Other retail	2		5		1		2
Total retail	709		912		28		8
Total		$1,079		$1,060		$32		$9

⁽¹⁾ Effective March 31, 2016, the Company began excluding loans 90 days or more past due and still accruing, which includes loans guaranteed by government-sponsored entities, from nonperforming loans and leases. Nonperforming loans and leases as of December 31, 2015 included loans and leases on nonaccrual of $1.051 billion and loans and leases accruing and 90 days or more past due of $9 million.

⁽²⁾ $97 million of previously nonperforming troubled debt restructured loans were transferred from loans and leases to other loans held for sale on March 31, 2016, including $66 million of residential mortgages and $31 million of home equity loans.

⁽³⁾ Effective March 31, 2016, the Company began excluding first lien residential mortgage loans that are 100% guaranteed by the Federal Housing Administration from nonperforming balances; $22 million of these loans are presented above as accruing and 90 days or more past due.

⁽⁴⁾Effective March 31, 2016, the Company began excluding guaranteed residential mortgage loans sold to GNMA for which the Company had the right but not the obligation to repurchase from nonperforming balances; these totaled $37 million; these loans are consolidated on the Company’s Consolidated Balance Sheets.

⁽⁵⁾ 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:



(in millions)	March 31, 2016		December 31, 2015
Other nonperforming assets, net of valuation allowance:
Commercial		$1		$1
Retail	47		45
Other nonperforming assets, net of valuation allowance		$48		$46

Summary of key performance indicators

A summary of key performance indicators is as follows:



	March 31, 2016		December 31, 2015
Nonperforming commercial loans and leases as a percentage of total loans and leases ⁽¹⁾	0.37	%	0.15	%
Nonperforming retail loans as a percentage of total loans and leases ⁽¹⁾	0.70		0.92
Total nonperforming loans and leases as a percentage of total loans and leases ⁽¹⁾	1.07	%	1.07	%

Nonperforming commercial assets as a percentage of total assets ⁽¹⁾	0.26	%	0.11	%
Nonperforming retail assets as a percentage of total assets ⁽¹⁾	0.54		0.69
Total nonperforming assets as a percentage of total assets ⁽¹⁾	0.80	%	0.80	%

⁽¹⁾December 31, 2015 ratios included loans accruing and 90 days or more past due of $1 million and $8 million for commercial and retail, respectively.

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, 2016								December 31, 2015
(in millions)	30-59 Days Past Due		60-89 Days Past Due		90 Days or More Past Due		Total Past Due		30-59 Days Past Due		60-89 Days Past Due		90 Days or More Past Due		Total Past Due
Commercial		$13		$7		$287		$307		$9		$4		$71		$84
Commercial real estate	40		—		88		128		30		3		77		110
Leases	15		—		—		15		9		1		—		10
Total commercial	68		7		375		450		48		8		148		204
Residential mortgages	52		7		151		210		54		16		246		316
Home equity loans	26		5		80		111		32		12		104		148
Home equity lines of credit	53		17		206		276		60		20		205		285
Home equity loans serviced by others ⁽¹⁾	14		1		20		35		14		6		20		40
Home equity lines of credit serviced by others ⁽¹⁾	9		5		35		49		10		6		29		45
Automobile	104		20		36		160		127		32		35		194
Student	17		9		45		71		19		11		41		71
Credit cards	10		7		16		33		11		9		16		36
Other retail	9		2		3		14		8		4		5		17
Total retail	294		73		592		959		335		116		701		1,152
Total		$362		$80		$967		$1,409		$383		$124		$849		$1,356

⁽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:



	March 31, 2016
(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		$163		$30		$208		$414		$371
Commercial real estate	56		12		12		69		68
Total commercial	219		42		220		483		439
Residential mortgages ⁽¹⁾	35		4		111		183		146
Home equity loans ⁽¹⁾	55		6		84		165		139
Home equity lines of credit	25		3		165		227		190
Home equity loans serviced by others ⁽²⁾	48		7		22		84		70
Home equity lines of credit serviced by others ⁽²⁾	3		—		7		14		10
Automobile	3		—		11		19		14
Student	163		47		1		164		164
Credit cards	27		11		—		27		27
Other retail	13		4		2		17		15
Total retail	372		82		403		900		775
Total		$591		$124		$623		$1,383		$1,214

⁽¹⁾ Excluded from the table above are retail TDR principal balances held for sale with a total recorded investment of $373 million, including residential mortgages of $288 million and home equity loans of $85 million.

⁽²⁾ 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, 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.

Schedule of additional information on impaired loans

Additional information on impaired loans is as follows:



	Three Months Ended March 31,
	2016				2015
(in millions)	Interest Income Recognized		Average Recorded Investment		Interest Income Recognized		Average Recorded Investment
Commercial		$1		$201		$1		$142
Commercial real estate	—		66		—		51
Total commercial	1		267		1		193
Residential mortgages	1		142		4		441
Home equity loans	2		134		2		268
Home equity lines of credit	1		187		1		156
Home equity loans serviced by others ⁽¹⁾	1		71		1		88
Home equity lines of credit serviced by others ⁽¹⁾	—		10		—		11
Automobile	—		13		—		11
Student	2		163		2		164
Credit cards	—		27		1		30
Other retail	—		14		—		19
Total retail	7		761		11		1,188
Total		$8		$1,028		$12		$1,381

⁽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 three months ended March 31, 2016, the charge-offs related to the modifications, and the impact on the ALLL. The reported balances include loans that became TDRs during 2016 and were paid off in full, charged off, or sold prior to March 31, 2016.



	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	5		$1		$1	26		$4		$4
Commercial real estate	—	—		—		—	—		—
Total commercial	5	1		1		26	4		4
Residential mortgages	22	3		3		6	1		1
Home equity loans	14	1		1		16	2		2
Home equity lines of credit	7	1		1		19	2		2
Home equity loans serviced by others ⁽³⁾	3	—		—		—	—		—
Home equity lines of credit serviced by others ⁽³⁾	—	—		—		1	—		—
Automobile	21	1		1		5	—		—
Student	—	—		—		—	—		—
Credit cards	529	3		3		—	—		—
Other retail	—	—		—		—	—		—
Total retail	596	9		9		47	5		5
Total	601		$10		$10	73		$9		$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	5		$21		$20		($1	)		$18
Commercial real estate	—	—		—		—			—
Total commercial	5	21		20		(1		)	18
Residential mortgages	64	8		8		—			—
Home equity loans	87	6		6		—			—
Home equity lines of credit	32	2		2		—			—
Home equity loans serviced by others ⁽³⁾	18	1		1		—			—
Home equity lines of credit serviced by others ⁽³⁾	8	—		—		—			—
Automobile	191	3		3		—			—
Student	186	4		4		1			—
Credit cards	—	—		—		—			—
Other retail	3	—		—		—			—
Total retail	589	24		24		1			—
Total	594		$45		$44		$—			$18

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

Schedule of defaults

The table below summarizes TDRs that defaulted during the three months ended March 31, 2016 and 2015 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, 2016 and 2015. 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,
	2016			2015
(dollars in millions)	Number of Contracts	Balance Defaulted		Number of Contracts	Balance Defaulted
Commercial	3		$—	6		$—
Commercial real estate	—	—		—	—
Total commercial	3	—		6	—
Residential mortgages	54	8		49	7
Home equity loans	49	3		51	3
Home equity lines of credit	25	3		40	2
Home equity loans serviced by others ⁽¹⁾	10	1		16	—
Home equity lines of credit serviced by others ⁽¹⁾	5	—		1	—
Automobile	15	—		23	—
Student	13	—		65	2
Credit cards	121	1		102	1
Other retail	—	—		2	—
Total retail	292	16		349	15
Total	295		$16	355		$15

⁽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:



	March 31, 2016
(in millions)	Residential Mortgages		Home Equity Loans and Lines of Credit		Home Equity Products Serviced by Others		Credit Cards		Student		Total
High loan-to-value		$519		$815		$695		$—		$—		$2,029
Interest only/negative amortization	1,181		—		—		—		1		1,182
Low introductory rate	—		—		—		93		—		93
Multiple characteristics and other	4		—		—		—		—		4
Total		$1,704		$815		$695		$93		$1		$3,308



	December 31, 2015
(in millions)	Residential Mortgages		Home Equity Loans and Lines of Credit		Home Equity Products Serviced by Others		Credit Cards		Student		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