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

12 Months Ended

Dec. 31, 2016

Schedule of changes in the allowance for credit losses

A summary of changes in the allowance for credit losses is presented below:



	Year ended December 31, 2016
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses, beginning of period		$596			$620			$1,216
Charge-offs	(79		)	(457		)	(536		)
Recoveries	33			168			201
Net charge-offs	(46		)	(289		)	(335		)
Provision charged to income	113			242			355
Allowance for loan and lease losses, end of period	663			573			1,236
Reserve for unfunded lending commitments, beginning of period	58			—			58
Provision (credit) for unfunded lending commitments	14			—			14
Reserve for unfunded lending commitments as of period end	72			—			72
Total allowance for credit losses as of period end		$735			$573			$1,308



	Year Ended December 31, 2015
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses, beginning of period		$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, end of period	596			620			1,216
Reserve for unfunded lending commitments, beginning of period	61			—			61
Provision (credit) for unfunded lending commitments	(3		)	—			(3		)
Reserve for unfunded lending commitments as of period end	58			—			58
Total allowance for credit losses as of period end		$654			$620			$1,274



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

Schedule of loans and leases based on evaluation method

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



	December 31, 2016						December 31, 2015
(in millions)	Commercial		Retail		Total		Commercial		Retail		Total
Individually evaluated		$424		$799		$1,223		$218		$1,165		$1,383
Formula-based evaluation	51,227		55,219		106,446		45,996		51,663		97,659
Total		$51,651		$56,018		$107,669		$46,214		$52,828		$99,042

Schedule of allowance for credit losses by evaluation method

A summary of the allowance for credit losses by evaluation method is presented below:



	December 31, 2016						December 31, 2015
(in millions)	Commercial		Retail		Total		Commercial		Retail		Total
Individually evaluated		$63		$43		$106		$36		$101		$137
Formula-based evaluation	672		530		1,202		618		519		1,137
Allowance for credit losses		$735		$573		$1,308		$654		$620		$1,274

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

The recorded investment in commercial loans and leases based on regulatory classification ratings is presented below:



	December 31, 2016
			Criticized
(in millions)	Pass		Special Mention		Substandard		Doubtful		Total
Commercial		$35,010		$1,015		$1,027		$222		$37,274
Commercial real estate	10,146		370		58		50		10,624
Leases	3,583		52		103		15		3,753
Total		$48,739		$1,437		$1,188		$287		$51,651



	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 presented below:



	December 31, 2016
			Days Past Due
(in millions)	Current		1-29		30-59		60-89		90 or More		Total
Residential mortgages		$14,807		$108		$53		$12		$135		$15,115
Home equity loans	1,628		127		23		7		73		1,858
Home equity lines of credit	13,432		396		57		20		195		14,100
Home equity loans serviced by others	673		41		14		5		17		750
Home equity lines of credit serviced by others	158		25		3		2		31		219
Automobile	12,509		1,177		172		38		42		13,938
Student	6,379		151		24		13		43		6,610
Credit cards	1,611		43		12		9		16		1,691
Other retail	1,676		45		8		4		4		1,737
Total		$52,873		$2,113		$366		$110		$556		$56,018



	December 31, 2015
			Days Past Due
(in millions)	Current		1-29		30-59		60-89		90 or More		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	886		60		14		6		20		986
Home equity lines of credit serviced by others	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

Schedule of nonperforming loans and leases by class

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



	Nonperforming ⁽¹⁾				Accruing and 90 days or more past due
(in millions)	December 31, 2016		December 31, 2015		December 31, 2016		December 31, 2015
Commercial		$322		$71		$2		$1
Commercial real estate	50		77		—		—
Leases	15		—		—		—
Total commercial	387		148		2		1
Residential mortgages^{(2) (3)}	144		331		18		—
Home equity loans	98		135		—		—
Home equity lines of credit	243		272		—		—
Home equity loans serviced by others	32		38		—		—
Home equity lines of credit serviced by others	33		32		—		—
Automobile	50		42		—		—
Student	38		41		5		6
Credit cards	16		16		—		—
Other retail	4		5		1		2
Total retail	658		912		24		8
Total		$1,045		$1,060		$26		$9

⁽¹⁾ Effective March 31, 2016, the Company began excluding loans 90 days or more past due and still accruing 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⁾ 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. As of December 31, 2016, $18 million of these loans were accruing and 90 days or more past due.

⁽³⁾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. As of December 31, 2016 these loans totaled $32 million. These loans are consolidated on the Company’s Consolidated Balance Sheets.

Schedule of nonperforming assets

A summary of other nonperforming assets is presented below:



	December 31,
(in millions)	2016		2015
Nonperforming assets, net of valuation allowance:
Commercial		$—		$1
Retail	49		45
Nonperforming assets, net of valuation allowance		$49		$46

Summary of key performance indicators

A summary of key performance indicators is presented below:



	December 31,
	2016		2015
Nonperforming commercial loans and leases as a percentage of total loans and leases ⁽¹⁾	0.36	%	0.15	%
Nonperforming retail loans as a percentage of total loans and leases ⁽¹⁾	0.61		0.92
Total nonperforming loans and leases as a percentage of total loans and leases ⁽¹⁾	0.97	%	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⁾	0.47		0.69
Total nonperforming assets as a percentage of total assets ⁽¹⁾	0.73	%	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

An analysis of the age of both accruing and nonaccruing loan and lease past due amounts is presented below:



	December 31, 2016								December 31, 2015
	Days Past Due								Days Past Due
(in millions)	30-59		60-89		90 or More		Total		30-59		60-89		90 or More		Total
Commercial		$36		$4		$324		$364		$9		$4		$71		$84
Commercial real estate	1		2		50		53		30		3		77		110
Leases	1		—		15		16		9		1		—		10
Total commercial	38		6		389		433		48		8		148		204
Residential mortgages	53		12		135		200		54		16		246		316
Home equity loans	23		7		73		103		32		12		104		148
Home equity lines of credit	57		20		195		272		60		20		205		285
Home equity loans serviced by others	14		5		17		36		14		6		20		40
Home equity lines of credit serviced by others	3		2		31		36		10		6		29		45
Automobile	172		38		42		252		127		32		35		194
Student	24		13		43		80		19		11		41		71
Credit cards	12		9		16		37		11		9		16		36
Other retail	8		4		4		16		8		4		5		17
Total retail	366		110		556		1,032		335		116		701		1,152
Total		$404		$116		$945		$1,465		$383		$124		$849		$1,356

Schedule of impaired loans by class

A summary of impaired loans by class is presented below:



	December 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		$247		$55		$134		$431		$381
Commercial real estate	39		8		4		44		43
Total commercial	286		63		138		475		424
Residential mortgages	37		2		141		235		178
Home equity loans	51		3		94		191		145
Home equity lines of credit	23		1		173		240		196
Home equity loans serviced by others	41		4		19		70		60
Home equity lines of credit serviced by others	2		—		7		13		9
Automobile	4		—		15		25		19
Student	154		25		1		155		155
Credit cards	26		6		—		26		26
Other retail	10		2		1		13		11
Total retail	348		43		451		968		799
Total		$634		$106		$589		$1,443		$1,223



	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	50		8		24		88		74
Home equity lines of credit serviced by others	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

Schedule of additional information on impaired loans

Additional information on impaired loans is presented below:



	Year Ended December 31,
	2016				2015				2014
(in millions)	Interest Income Recognized		Average Recorded Investment		Interest Income Recognized		Average Recorded Investment		Interest Income Recognized		Average Recorded Investment
Commercial		$5		$295		$4		$135		$9		$198
Commercial real estate	—		53		1		44		2		98
Leases	—		3		—		—		—		—
Total commercial	5		351		5		179		11		296
Residential mortgages	4		161		15		415		14		429
Home equity loans	7		144		9		222		8		246
Home equity lines of credit	6		178		4		173		4		149
Home equity loans serviced by others	3		60		4		75		5		91
Home equity lines of credit serviced by others	—		9		—		9		—		11
Automobile	—		14		—		11		—		7
Student	7		150		7		157		8		153
Credit cards	2		23		2		26		2		31
Other retail	1		12		1		16		1		21
Total retail	30		751		42		1,104		42		1,138
Total		$35		$1,102		$47		$1,283		$53		$1,434

Troubled debt restructurings on financing receivables

The table below summarizes how loans were modified during the year ended December 31, 2016, the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during 2016 and were paid off in full, charged off, or sold prior to December 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	12		$1		$1	81		$20		$21
Commercial real estate	1	—		—		1	5		5
Total commercial	13	1		1		82	25		26
Residential mortgages	71	10		10		60	10		10
Home equity loans	97	6		6		39	4		5
Home equity lines of credit	49	4		4		121	13		12
Home equity loans serviced by others	18	1		1		—	—		—
Home equity lines of credit serviced by others	8	—		—		5	1		1
Automobile	138	3		3		41	1		1
Student	—	—		—		—	—		—
Credit cards	2,187	12		12		—	—		—
Other retail	4	—		—		—	—		—
Total retail	2,572	36		36		266	29		29
Total	2,585		$37		$37	348		$54		$55



	Primary Modification Types
	Other ⁽³⁾
(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	14		$48		$48		$3			$—
Commercial real estate	—	—		—		—			—
Total commercial	14	48		48		3			—
Residential mortgages	247	26		26		(1		)	—
Home equity loans	279	18		17		(1		)	—
Home equity lines of credit	304	23		22		—			1
Home equity loans serviced by others	60	2		2		—			—
Home equity lines of credit serviced by others	24	1		1		—			—
Automobile	1,081	20		18		—			3
Student	479	12		12		4			—
Credit cards	—	—		—		3			—
Other retail	13	—		—		—			—
Total retail	2,487	102		98		5			4
Total	2,501		$150		$146		$8			$4

⁽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⁾ Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forgiveness, 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 table below 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 can 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	29	2		2		—	—		—
Home equity lines of credit serviced by others	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 ⁽³⁾
(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	124	6		5		—			1
Home equity lines of credit serviced by others	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).

The table below 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 can 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	42	2		2		—	—		—
Home equity lines of credit serviced by others	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 ⁽³⁾
(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	138	5		5		(1		)	—
Home equity lines of credit serviced by others	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⁾ Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forgiveness, 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 within 12 months of their modification date during 2016, 2015 and 2014. For purposes of this table, a payment default refers to a loan that becomes 90 days or more past due 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, 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.



	Year Ended December 31,
	2016			2015			2014
(dollars in millions)	Number of Contracts	Balance Defaulted		Number of Contracts	Balance Defaulted		Number of Contracts	Balance Defaulted
Commercial	22		$13	23		$2	37		$12
Commercial real estate	1	—		—	—		3	1
Total commercial	23	13		23	2		40	13
Residential mortgages	187	24		168	21		301	35
Home equity loans	50	3		184	13		329	24
Home equity lines of credit	155	13		131	7		229	12
Home equity loans serviced by others	37	1		43	1		60	2
Home equity lines of credit serviced by others	17	—		22	1		20	—
Automobile	110	2		87	1		112	1
Student	59	1		171	3		355	7
Credit cards	433	3		455	3		579	3
Other retail	3	—		4	—		12	—
Total retail	1,051	47		1,265	50		1,997	84
Total	1,074		$60	1,288		$52	2,037		$97

Schedule of loans that may increase credit exposure

The following tables present balances of loans with these characteristics:



	December 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		$566		$550		$476		$—		$—		$1,592
Interest only/negative amortization	1,582		—		—		—		1		1,583
Low introductory rate	—		—		—		112		—		112
Multiple characteristics and other	3		—		—		—		—		3
Total		$2,151		$550		$476		$112		$1		$3,290



	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