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

12 Months Ended

Dec. 31, 2017

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, 2017
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses, beginning of period		$663			$573			$1,236
Charge-offs	(75		)	(437		)	(512		)
Recoveries	40			167			207
Net charge-offs	(35		)	(270		)	(305		)
Provision charged to income⁽¹⁾	57			248			305
Allowance for loan and lease losses, end of period	685			551			1,236
Reserve for unfunded lending commitments, beginning of period	72			—			72
Provision for unfunded lending commitments	16			—			16
Reserve for unfunded lending commitments, end of period	88			—			88
Total allowance for credit losses, end of period		$773			$551			$1,324

⁽¹⁾ Includes an increase of approximately $50 million to commercial and corresponding decrease to retail for the impact of the enhancement to the assessment of qualitative risks, factors and events that may not be measured in the modeled results.



	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 for unfunded lending commitments	14			—			14
Reserve for unfunded lending commitments, end of period	72			—			72
Total allowance for credit losses, end of period		$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

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, 2017						December 31, 2016
(in millions)	Commercial		Retail		Total		Commercial		Retail		Total
Individually evaluated		$370		$761		$1,131		$424		$799		$1,223
Formula-based evaluation	51,661		57,825		109,486		51,227		55,219		106,446
Total		$52,031		$58,586		$110,617		$51,651		$56,018		$107,669

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, 2017						December 31, 2016
(in millions)	Commercial		Retail		Total		Commercial		Retail		Total
Individually evaluated		$47		$34		$81		$63		$43		$106
Formula-based evaluation	726		517		1,243		672		530		1,202
Allowance for credit losses		$773		$551		$1,324		$735		$573		$1,308

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, 2017
			Criticized
(in millions)	Pass		Special Mention		Substandard		Doubtful		Total
Commercial		$35,430		$1,143		$785		$204		$37,562
Commercial real estate	10,706		500		74		28		11,308
Leases	3,069		73		19		—		3,161
Total commercial loans and leases		$49,205		$1,716		$878		$232		$52,031



	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 commercial loans and leases		$48,739		$1,437		$1,188		$287		$51,651

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, 2017
			Days Past Due
(in millions)	Current		1-29		30-59		60-89		90 or More		Total
Residential mortgages		$16,714		$147		$46		$18		$120		$17,045
Home equity loans	1,212		102		20		4		54		1,392
Home equity lines of credit	12,756		438		78		23		188		13,483
Home equity loans serviced by others	477		29		10		4		22		542
Home equity lines of credit serviced by others	116		21		4		1		7		149
Automobile	11,596		1,273		220		55		60		13,204
Education	7,898		160		23		12		41		8,134
Credit cards	1,747		63		12		9		17		1,848
Other retail	2,679		68		20		12		10		2,789
Total retail loans		$55,195		$2,301		$433		$138		$519		$58,586



	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
Education	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 retail loans		$52,873		$2,113		$366		$110		$556		$56,018

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, 2017		December 31, 2016		December 31, 2017		December 31, 2016
Commercial		$238		$322		$5		$2
Commercial real estate	27		50		3		—
Leases	—		15		—		—
Total commercial loans and leases	265		387		8		2
Residential mortgages⁽¹⁾	128		144		16		18
Home equity loans	72		98		—		—
Home equity lines of credit	233		243		—		—
Home equity loans serviced by others	25		32		—		—
Home equity lines of credit serviced by others	18		33		—		—
Automobile	70		50		—		—
Education	38		38		3		5
Credit card	17		16		—		—
Other retail	5		4		5		1
Total retail loans	606		658		24		24
Total		$871		$1,045		$32		$26

⁽¹⁾ Nonperforming balances exclude first lien residential mortgage loans that are 100% guaranteed by the Federal Housing Administration. These loans, which are accruing and 90 days or more past due, totaled $15 million and $18 million as of December 31, 2017 and 2016, respectively. Nonperforming balances also exclude guaranteed residential mortgage loans sold to GNMA for which the Company has the right, but not the obligation, to repurchase. These loans totaled $30 million and $32 million as of December 31, 2017 and 2016, respectively. These loans are included in the Company’s Consolidated Balance Sheets.

Summary of key performance indicators

A summary of key performance indicators is presented below:



	December 31,
	2017		2016
Nonperforming commercial loans and leases as a percentage of total loans and leases	0.24	%	0.36	%
Nonperforming retail loans as a percentage of total loans and leases	0.55		0.61
Total nonperforming loans and leases as a percentage of total loans and leases	0.79	%	0.97	%

Nonperforming commercial assets as a percentage of total assets	0.17	%	0.26	%
Nonperforming retail assets as a percentage of total assets	0.43		0.47
Total nonperforming assets as a percentage of total assets	0.60	%	0.73	%

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, 2017								December 31, 2016
	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		$26		$4		$243		$273		$36		$4		$324		$364
Commercial real estate	38		20		30		88		1		2		50		53
Leases	4		1		—		5		1		—		15		16
Total commercial loans and leases	68		25		273		366		38		6		389		433
Residential mortgages	46		18		120		184		53		12		135		200
Home equity loans	20		4		54		78		23		7		73		103
Home equity lines of credit	78		23		188		289		57		20		195		272
Home equity loans serviced by others	10		4		22		36		14		5		17		36
Home equity lines of credit serviced by others	4		1		7		12		3		2		31		36
Automobile	220		55		60		335		172		38		42		252
Education	23		12		41		76		24		13		43		80
Credit cards	12		9		17		38		12		9		16		37
Other retail	20		12		10		42		8		4		4		16
Total retail loans	433		138		519		1,090		366		110		556		1,032
Total		$501		$163		$792		$1,456		$404		$116		$945		$1,465

Schedule of impaired loans by class

A summary of impaired loans by class is presented below:



	December 31, 2017
(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		$183		$42		$159		$403		$342
Commercial real estate	25		5		3		40		28
Leases	—		—		—		—		—
Total commercial loans and leases	208		47		162		443		370
Residential mortgages	25		2		126		197		151
Home equity loans	41		4		80		162		121
Home equity lines of credit	16		1		181		241		197
Home equity loans serviced by others	29		2		22		67		51
Home equity lines of credit serviced by others	2		—		7		14		9
Automobile	2		—		21		30		23
Education	154		17		21		175		175
Credit cards	24		7		1		25		25
Other retail	5		1		4		10		9
Total retail loans	298		34		463		921		761
Total		$506		$81		$625		$1,364		$1,131



	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
Leases	—		—		—		—		—
Total commercial loans and leases	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
Education	154		25		1		155		155
Credit cards	26		6		—		26		26
Other retail	10		2		1		13		11
Total retail loans	348		43		451		968		799
Total		$634		$106		$589		$1,443		$1,223

Schedule of additional information on impaired loans

Additional information on impaired loans is presented below:



	Year Ended December 31,
	2017				2016				2015
(in millions)	Interest Income Recognized		Average Recorded Investment		Interest Income Recognized		Average Recorded Investment		Interest Income Recognized		Average Recorded Investment
Commercial		$4		$380		$5		$295		$4		$135
Commercial real estate	—		37		—		53		1		44
Leases	—		—		—		3		—		—
Total commercial loans and leases	4		417		5		351		5		179
Residential mortgages	4		136		4		161		15		415
Home equity loans	6		121		7		144		9		222
Home equity lines of credit	6		176		6		178		4		173
Home equity loans serviced by others	3		49		3		60		4		75
Home equity lines of credit serviced by others	—		9		—		9		—		9
Automobile	1		18		—		14		—		11
Education	9		173		7		150		7		157
Credit cards	2		22		2		23		2		26
Other retail	—		9		1		12		1		16
Total retail loans	31		713		30		751		42		1,104
Total		$35		$1,130		$35		$1,102		$47		$1,283

Troubled debt restructurings on financing receivables

The table below summarizes TDRs by class and total unfunded commitments:



	December 31,
(in millions)	2017		2016
Commercial		$129		$120
Retail	761		799
Unfunded commitments tied to TDRs	39		42

The table below summarizes how loans were modified during the year ended December 31, 2017, the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during 2017 and were paid off in full, charged off, or sold prior to December 31, 2017.



	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	7		$1		$1	45		$22		$22
Commercial real estate	—	—		—		1	—		—
Leases	—	—		—		—	—		—
Total commercial loans and leases	7	1		1		46	22		22
Residential mortgages	71	9		10		73	12		13
Home equity loans	82	5		6		1	—		—
Home equity lines of credit	50	3		3		235	30		30
Home equity loans serviced by others	15	1		1		—	—		—
Home equity lines of credit serviced by others	5	—		—		2	—		—
Automobile	130	2		2		29	1		1
Education	—	—		—		—	—		—
Credit cards	2,363	13		13		—	—		—
Other retail	1	—		—		—	—		—
Total retail loans	2,717	33		35		340	43		44
Total	2,724		$34		$36	386		$65		$66



	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	15		$70		$71		($1	)		$—
Commercial real estate	1	—		—		—			—
Leases	—	—		—		—			—
Total commercial loans and leases	16	70		71		(1		)	—
Residential mortgages	171	19		19		(1		)	—
Home equity loans	232	13		13		—			—
Home equity lines of credit	395	27		27		—			1
Home equity loans serviced by others	52	2		2		—			—
Home equity lines of credit serviced by others	26	2		2		—			—
Automobile	1,336	24		20		—			4
Education	329	7		7		2			—
Credit cards	—	—		—		3			—
Other retail	5	—		—		(2		)	—
Total retail loans	2,546	94		90		2			5
Total	2,562		$164		$161		$1			$5

⁽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, and capitalizing arrearages. 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, 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
Leases	—	—		—		—	—		—
Total commercial loans and leases	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
Education	—	—		—		—	—		—
Credit cards	2,187	12		12		—	—		—
Other retail	4	—		—		—	—		—
Total retail loans	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	—	—		—		—			—
Leases	—	—		—		—			—
Total commercial loans and leases	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
Education	479	12		12		4			—
Credit cards	—	—		—		3			—
Other retail	13	—		—		—			—
Total retail loans	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).

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	—		—
Leases	—	—		—		—	—		—
Total commercial loans and leases	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	—		—
Education	—	—		—		—	—		—
Credit cards	2,413	13		13		—	—		—
Other retail	3	—		—		—	—		—
Total retail loans	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		—			—
Leases	—	—		—		—			—
Total commercial loans and leases	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
Education	1,204	22		22		4			—
Credit cards	—	—		—		2			—
Other retail	20	—		—		—			—
Total retail loans	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).

⁽³⁾ Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forgiveness, and capitalizing arrearages. 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 2017, 2016 and 2015. 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, 2017 and 2016. 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,
	2017			2016			2015
(dollars in millions)	Number of Contracts	Balance Defaulted		Number of Contracts	Balance Defaulted		Number of Contracts	Balance Defaulted
Commercial	8		$5	22		$13	23		$2
Commercial real estate	1	4		1	—		—	—
Leases	—	—		—	—		—	—
Total commercial loans and leases	9	9		23	13		23	2
Residential mortgages	152	19		187	24		168	21
Home equity loans	43	2		50	3		184	13
Home equity lines of credit	200	14		155	13		131	7
Home equity loans serviced by others	23	—		37	1		43	1
Home equity lines of credit serviced by others	10	1		17	—		22	1
Automobile	140	1		110	2		87	1
Education	44	1		59	1		171	3
Credit cards	491	3		433	3		455	3
Other retail	4	—		3	—		4	—
Total retail loans	1,107	41		1,051	47		1,265	50
Total	1,116		$50	1,074		$60	1,288		$52

Schedule of loans that may increase credit exposure

The following tables present balances of loans with these characteristics:



	December 31, 2017
(in millions)	Residential Mortgages		Home Equity Loans and Lines of Credit		Home Equity Products Serviced by Others		Credit Cards		Education		Total
High loan-to-value		$366		$166		$264		$—		$—		$796
Interest only/negative amortization	1,763		—		—		—		1		1,764
Low introductory rate	—		—		—		197		—		197
Multiple characteristics and other	1		—		—		—		—		1
Total		$2,130		$166		$264		$197		$1		$2,758



	December 31, 2016
(in millions)	Residential Mortgages		Home Equity Loans and Lines of Credit		Home Equity Products Serviced by Others		Credit Cards		Education		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