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

3 Months Ended

Mar. 31, 2018

Schedule of changes in the allowance for credit losses

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



	Three Months Ended March 31, 2018
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses, beginning of period		$685			$551			$1,236
Charge-offs	(3		)	(113		)	(116		)
Recoveries	6			40			46
Net recoveries (charge-offs)	3			(73		)	(70		)
Provision charged to income	23			57			80
Allowance for loan and lease losses, end of period	711			535			1,246
Reserve for unfunded lending commitments, beginning of period	88			—			88
Provision for unfunded lending commitments	(2		)	—			(2		)
Reserve for unfunded lending commitments, end of period	86			—			86
Total allowance for credit losses, end of period		$797			$535			$1,332



	Three Months Ended March 31, 2017
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses, beginning of period		$663			$573			$1,236
Charge-offs	(24		)	(109		)	(133		)
Recoveries	5			41			46
Net charge-offs	(19		)	(68		)	(87		)
Provision charged to income	9			66			75
Allowance for loan and lease losses, end of period	653			571			1,224
Reserve for unfunded lending commitments, beginning of period	72			—			72
Provision for unfunded lending commitments	21			—			21
Reserve for unfunded lending commitments, end of period	93			—			93
Total allowance for credit losses, end of period		$746			$571			$1,317

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:



	March 31, 2018						December 31, 2017
(in millions)	Commercial		Retail		Total		Commercial		Retail		Total
Individually evaluated		$403		$748		$1,151		$370		$761		$1,131
Formula-based evaluation	52,741		57,533		110,274		51,661		57,825		109,486
Total		$53,144		$58,281		$111,425		$52,031		$58,586		$110,617

Schedule of allowance for credit losses by evaluation method

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



	March 31, 2018						December 31, 2017
(in millions)	Commercial		Retail		Total		Commercial		Retail		Total
Individually evaluated		$47		$28		$75		$47		$34		$81
Formula-based evaluation	750		507		1,257		726		517		1,243
Allowance for credit losses		$797		$535		$1,332		$773		$551		$1,324

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:



	March 31, 2018
			Criticized
(in millions)	Pass		Special Mention		Substandard		Doubtful		Total
Commercial		$35,511		$1,644		$910		$212		$38,277
Commercial real estate	11,195		505		47		28		11,775
Leases	2,972		77		43		—		3,092
Total commercial loans and leases		$49,678		$2,226		$1,000		$240		$53,144



	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

Schedule of retail loan investments categorized by delinquency status

The recorded investment in classes of retail loans, categorized by delinquency status is presented below:



	March 31, 2018
			Days Past Due
(in millions)	Current		1-29		30-59		60-89		90 or More		Total
Residential mortgages		$17,092		$89		$35		$9		$121		$17,346
Home equity loans	1,144		87		12		5		50		1,298
Home equity lines of credit	12,575		343		55		19		198		13,190
Home equity loans serviced by others	449		25		10		1		19		504
Home equity lines of credit serviced by others	107		17		4		1		7		136
Automobile	11,540		994		173		37		50		12,794
Education	8,162		112		22		15		13		8,324
Credit cards	1,728		43		11		8		18		1,808
Other retail	2,777		61		21		11		11		2,881
Total		$55,574		$1,771		$343		$106		$487		$58,281



	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

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				Accruing and 90 days or more past due
(in millions)	March 31, 2018		December 31, 2017		March 31, 2018		December 31, 2017
Commercial		$244		$238		$1		$5
Commercial real estate	30		27		—		3
Leases	—		—		2		—
Total commercial loans and leases	274		265		3		8
Residential mortgages⁽¹⁾	128		128		14		16
Home equity loans	66		72		—		—
Home equity lines of credit	235		233		—		—
Home equity loans serviced by others	23		25		—		—
Home equity lines of credit serviced by others	17		18		—		—
Automobile	60		70		—		—
Education	41		38		3		3
Credit card	18		17		—		—
Other retail	6		5		6		5
Total retail loans	594		606		23		24
Total retail loans		$868		$871		$26		$32

⁽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 $14 million and $15 million as of March 31, 2018 and December 31, 2017, 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 $24 million and $30 million as of March 31, 2018 and December 31, 2017, respectively. These loans are included in the Company’s Consolidated Balance Sheets.

Summary of key performance indicators

A summary of nonperforming loan and lease key performance indicators is presented below:



	March 31, 2018		December 31, 2017
Nonperforming commercial loans and leases as a percentage of total loans and leases	0.25	%	0.24	%
Nonperforming retail loans as a percentage of total loans and leases	0.53		0.55
Total nonperforming loans and leases as a percentage of total loans and leases	0.78	%	0.79	%

Nonperforming commercial assets as a percentage of total assets	0.18	%	0.17	%
Nonperforming retail assets as a percentage of total assets	0.41	%	0.43	%
Total nonperforming assets as a percentage of total assets	0.59	%	0.60	%

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:



	March 31, 2018								December 31, 2017
	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		$30		$23		$63		$116		$26		$4		$243		$273
Commercial real estate	42		1		28		71		38		20		30		88
Leases	3		—		2		5		4		1		—		5
Total commercial loans and leases	75		24		93		192		68		25		273		366
Residential mortgages	35		9		121		165		46		18		120		184
Home equity loans	12		5		50		67		20		4		54		78
Home equity lines of credit	55		19		198		272		78		23		188		289
Home equity loans serviced by others	10		1		19		30		10		4		22		36
Home equity lines of credit serviced by others	4		1		7		12		4		1		7		12
Automobile	173		37		50		260		220		55		60		335
Education	22		15		13		50		23		12		41		76
Credit cards	11		8		18		37		12		9		17		38
Other retail	21		11		11		43		20		12		10		42
Total retail loans	343		106		487		936		433		138		519		1,090
Total		$418		$130		$580		$1,128		$501		$163		$792		$1,456

Schedule of impaired loans by class

A summary of impaired loans by class is presented below:



	March 31, 2018
(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		$211		$42		$167		$447		$378
Commercial real estate	25		5		—		40		25
Leases	—		—		—		—		—
Total commercial loans and leases	236		47		167		487		403
Residential mortgages	27		2		124		197		151
Home equity loans	38		3		78		156		116
Home equity lines of credit	16		1		182		242		198
Home equity loans serviced by others	28		2		22		65		50
Home equity lines of credit serviced by others	2		—		7		13		9
Automobile	2		—		22		30		24
Education	144		12		25		169		169
Credit cards	24		7		—		25		24
Other retail	4		1		3		9		7
Total retail loans	285		28		463		906		748
Total		$521		$75		$630		$1,393		$1,151



	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

Schedule of additional information on impaired loans

Additional information on impaired loans is presented below:



	Three Months Ended March 31,
	2018				2017
(in millions)	Interest Income Recognized		Average Recorded Investment		Interest Income Recognized		Average Recorded Investment
Commercial		$2		$293		$1		$396
Commercial real estate	—		27		—		45
Leases	—		—		—		—
Total commercial loans and leases	2		320		1		441
Residential mortgages	1		149		1		176
Home equity loans	2		118		2		146
Home equity lines of credit	2		194		2		198
Home equity loans serviced by others	1		50		1		57
Home equity lines of credit serviced by others	—		9		—		9
Automobile	—		22		—		19
Education	2		171		2		152
Credit cards	—		24		—		25
Other retail	—		8		—		11
Total retail loans	8		745		8		793
Total		$10		$1,065		$9		$1,234

Troubled debt restructurings on financing receivables

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



(in millions)	March 31, 2018		December 31, 2017
Commercial		$202		$129
Retail	748		761
Unfunded commitments tied to TDRs	35		39

The table below summarizes how loans were modified during the three months ended March 31, 2018, the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during the three months ended March 31, 2018 and were paid off in full, charged off, or sold prior to March 31, 2018.



	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	1		$—		$—	6		$1		$1
Commercial real estate	—	—		—		1	—		—
Leases	—	—		—		—	—		—
Total commercial loans and leases	1	—		—		7	1		1
Residential mortgages	7	1		1		7	1		1
Home equity loans	11	1		1		—	—		—
Home equity lines of credit	15	1		1		42	5		5
Home equity loans serviced by others	1	—		—		—	—		—
Home equity lines of credit serviced by others	2	—		—		—	—		—
Automobile	36	1		1		17	1		1
Education	—	—		—		—	—		—
Credit cards	594	3		3		—	—		—
Other retail	1	—		—		—	—		—
Total retail loans	667	7		7		66	7		7
Total	668		$7		$7	73		$8		$8



	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	18		$74		$75		$—		$—
Commercial real estate	—	—		—		—		—
Leases	—	—		—		—		—
Total commercial loans and leases	18	74		75		—		—
Residential mortgages	53	6		6		—		—
Home equity loans	32	2		2		—		—
Home equity lines of credit	93	7		7		—		—
Home equity loans serviced by others	7	—		—		—		—
Home equity lines of credit serviced by others	3	—		—		—		—
Automobile	269	5		4		—		1
Education	112	1		1		—		—
Credit cards	—	—		—		—		—
Other retail	4	—		—		1		—
Total retail loans	573	21		20		1		1
Total	591		$95		$95		$1		$1

⁽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 three months ended March 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 the three months ended March 31, 2017 and were paid off in full, charged off, or sold prior to March 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	2		$1		$1	7		$1		$1
Commercial real estate	—	—		—		—	—		—
Leases	—	—		—		—	—		—
Total commercial loans and leases	2	1		1		7	1		1
Residential mortgages	18	1		2		11	3		3
Home equity loans	21	1		1		1	—		—
Home equity lines of credit	16	1		1		51	6		6
Home equity loans serviced by others	6	1		1		—	—		—
Home equity lines of credit serviced by others	1	—		—		2	—		—
Automobile	40	1		1		8	—		—
Education	—	—		—		—	—		—
Credit cards	565	3		3		—	—		—
Other retail	1	—		—		—	—		—
Total retail loans	668	8		9		73	9		9
Total	670		$9		$10	80		$10		$10



	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	—		$—		$—		$—		$—
Commercial real estate	—	—		—		—		—
Leases	1	1		1		—		—
Total commercial loans and leases	1	1		1		—		—
Residential mortgages	48	4		4		—		—
Home equity loans	102	6		6		—		—
Home equity lines of credit	75	6		6		—		—
Home equity loans serviced by others	14	1		1		—		—
Home equity lines of credit serviced by others	11	1		1		—		—
Automobile	276	5		4		—		1
Education	15	1		1		—		—
Credit cards	—	—		—		1		—
Other retail	1	—		—		—		—
Total retail loans	542	24		23		1		1
Total	543		$25		$24		$1		$1

⁽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).

Schedule of defaults

The table below summarizes TDRs that defaulted within 12 months of their modification date during the three months ended March 31, 2018 and 2017, respectively. 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. 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,
	2018			2017
(dollars in millions)	Number of Contracts	Balance Defaulted		Number of Contracts	Balance Defaulted
Commercial	3		$3	1		$—
Commercial real estate	—	—		1	4
Leases	—	—		—	—
Total commercial loans and leases	3	3		2	4
Residential mortgages	26	3		45	6
Home equity loans	11	1		9	—
Home equity lines of credit	66	5		35	3
Home equity loans serviced by others	5	—		1	—
Home equity lines of credit serviced by others	1	—		3	—
Automobile	46	—		34	—
Education	5	—		7	—
Credit cards	119	1		126	1
Other retail	—	—		2	—
Total retail loans	279	10		262	10
Total	282		$13	264		$14

Schedule of loans that may increase credit exposure

The following tables present balances of loans with these characteristics:



	March 31, 2018
(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		$357		$160		$230		$—		$—		$747
Interest-only/negative amortization	1,765		—		—		—		1		1,766
Low introductory rate	—		—		—		190		—		190
Multiple characteristics and other	1		—		—		—		—		1
Total		$2,123		$160		$230		$190		$1		$2,704



	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