REGULATORY MATTERS (Tables)

9 Months Ended

Sep. 30, 2016

Schedule of Compliance with Regulatory Capital Requirements under Banking Regulations

The following table presents the Company’s capital and capital ratios under Basel III Transitional rules as of September 30, 2016 and December 31, 2015. 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 is not 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 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 September 30, 2016
Common equity tier 1 capital ^{(1) (5)}		$13,763	11.3	%		$6,233	5.125	%		$7,905	6.5	%
Tier 1 capital ^{(2) (5)}	14,010		11.5		8,057		6.625		9,729		8.0
Total capital ⁽³⁾⁽⁵⁾	17,290		14.2		10,489		8.625		12,161		10.0
Tier 1 leverage ⁽⁴⁾	14,010		10.1		5,537		4.000		6,921		5.0
As of December 31, 2015
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

⁽¹⁾“Common equity tier 1 capital ratio” represents CET1 divided by total risk-weighted assets as defined under Basel III Standardized approach.

⁽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.

⁽³⁾“Total capital ratio” is total capital divided by total risk-weighted assets as defined under Basel III Standardized approach.

⁽⁴⁾ “Tier 1 leverage ratio” is tier 1 capital divided by quarterly average total assets as defined under Basel III Standardized approach.

⁽⁵⁾“Minimum Capital ratio” for 2016 includes capital conservation buffer of 0.625%.