MORTGAGE BANKING

In its mortgage banking business, the Company sells residential mortgages to government-sponsored entities and other parties, who may issue securities backed by pools of such loans. The Company retains no beneficial interests in these sales, but may retain the servicing rights for the loans sold. The Company is obligated to subsequently repurchase a loan if the purchaser discovers a standard representation or warranty violation such as noncompliance with eligibility requirements, customer fraud, or servicing violations. This primarily occurs during a loan file review.

The Company received proceeds from the sale of residential mortgages held for sale of $828 million and $753 million for the three months ended September 30, 2017 and 2016, respectively, and $2.4 billion and $1.8 billion for the nine months ended September 30, 2017 and 2016, respectively.

The Company recognized gains on sales of residential mortgages held for sale of $25 million and $26 million for the three months ended September 30, 2017 and 2016, respectively, and $54 million and $56 million for the nine months ended September 30, 2017 and 2016, respectively.

Pursuant to the standard representations and warranties obligations discussed above, the Company repurchased residential mortgages totaling $1 million and $2 million for the three months ended September 30, 2017 and 2016, respectively. The Company repurchased $2 million and $6 million of residential mortgages for the nine months ended September 30, 2017 and 2016, respectively.

Mortgage servicing fees, a component of mortgage banking fees, were $13 million and $12 million for the three months ended September 30, 2017 and 2016, respectively, and $40 million and $38 million for the nine months ended September 30, 2017 and 2016, respectively.

The Company recorded valuation charge-offs for its MSRs of zero and $2 million for the three months ended September 30, 2017 and 2016, respectively, and valuation recoveries of $1 million and charge-offs of $6 million for the nine months ended September 30, 2017 and 2016, respectively.

MSRs are presented in other assets on the Consolidated Balance Sheets. Changes related to MSRs are presented below:



	As of and for the Three Months Ended September 30,						As of and for the Nine Months Ended September 30,
(in millions)	2017			2016			2017			2016
MSRs:
Balance as of beginning of period		$170			$166			$167			$173
Amount capitalized	9			10			28			20
Amortization	(8		)	(9		)	(24		)	(26		)
Carrying amount before valuation allowance	171			167			171			167
Valuation allowance for servicing assets:
Balance as of beginning of period	4			13			5			9
Valuation charge-offs (recoveries)	—			2			(1		)	6
Balance at end of period	4			15			4			15
Net carrying value of MSRs		$167			$152			$167			$152

The fair value of MSRs is estimated using a valuation model that calculates the present value of estimated future net servicing cash flows, taking into consideration actual and expected mortgage loan prepayment rates, discount rates, contractual servicing fee income, servicing costs, default rates, ancillary income, and other economic factors, which are determined based on current market conditions. The valuation model uses a static discounted cash flow methodology incorporating current market interest rates. A static model does not attempt to forecast or predict the future direction of interest rates; rather it estimates the amount and timing of future servicing cash flows using current market interest rates. The current mortgage interest rate influences the expected prepayment rate and therefore, the length of the cash flows associated with the servicing asset, while the discount rate determines the present value of those cash flows. Expected mortgage loan prepayment assumptions are obtained using the QRM Multi Component prepayment model. The Company periodically obtains third-party valuations of its MSRs to assess the reasonableness of the fair value calculated by the valuation model.

The key economic assumptions used to estimate the value of MSRs are presented in the following table:



	September 30, 2017			December 31, 2016
	Weighted Average			Weighted Average
(dollars in millions)	Weighted Average	Range		Weighted Average	Range
Fair value	$183	Min	Max	$182	Min	Max
Weighted average life (in years)	5.7	2.4	7.0	5.7	2.6	7.3
Weighted average constant prepayment rate	10.8%	9.2%	21.2%	10.8%	8.8%	22.3%
Weighted average discount rate	9.9%	9.1%	12.1%	9.7%	9.1%	12.1%

The key economic assumptions used in estimating the fair value of MSRs capitalized during the period are presented below:



	Three Months Ended September 30,		Nine Months Ended September 30,
	2017	2016	2017	2016
Weighted average life (in years)	6.5	5.7	6.6	5.9
Weighted average constant prepayment rate	10.8%	12.3%	10.2%	11.7%
Weighted average discount rate	9.9%	9.8%	9.9%	9.8%

The sensitivity analysis below presents the impact to current fair value of an immediate 50 basis point and 100 basis point adverse change in the key economic assumptions and presents the decline in fair value that would occur if the adverse change were realized. These sensitivities are hypothetical, with the effect of a variation in a particular assumption on the fair value of the mortgage servicing rights calculated independently without changing any other assumption. In reality, changes in one factor may result in changes in another (e.g., changes in interest rates, which drive changes in prepayment rates, could result in changes in the discount rates), which may amplify or counteract the sensitivities. The primary risk inherent in the Company’s MSRs is an increase in prepayments of the underlying mortgage loans serviced, which is dependent upon market movements of interest rates.



(in millions)	September 30, 2017		December 31, 2016
Prepayment rate:
Decline in fair value from a 50 basis point decrease in interest rates		$9		$9
Decline in fair value from a 100 basis point decrease in interest rates	18		25
Weighted average discount rate:
Decline in fair value from a 50 basis point increase in weighted average discount rate		$3		$3
Decline in fair value from a 100 basis point increase in weighted average discount rate	6		6