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 representation or warranty violation such as noncompliance with eligibility or servicing requirements, or customer fraud that should have been identified in a loan file review.

The following table summarizes activity related to residential mortgage loans sold with servicing rights retained for the three and nine months ended September 30, 2018 and 2017.



	Three Months Ended September 30,				Nine Months Ended September 30,
(in millions)	2018		2017		2018		2017
Residential mortgage loans sold with servicing retained		$1,848		$828		$3,173		$2,372
Gain on sales ⁽¹⁾	29		25		59		54
Contractually specified servicing, late and other ancillary fees⁽¹⁾	38		13		69		40

⁽¹⁾ Reported in mortgage banking fees in the Consolidated Statements of Operations.

The Company recognizes the right to service residential mortgage loans for others, or MSRs, as separate assets, which are presented in other assets on the Consolidated Balance Sheets, when purchased, or when servicing is contractually separated from the underlying mortgage loans by sale with servicing rights retained. MSRs are initially recorded at fair value. Subsequent to the initial recognition, MSRs are measured using either the fair value method or the amortization method. MSRs accounted for under the amortization method are subsequently accounted for at lower of cost or fair value, net of accumulated amortization, which is recorded in proportion to, and over the period of, net servicing income.

As of August 1, 2018, the Company maintains two separate classes of MSRs which at the time of initial capitalization, are differentiated by how the risk associated with valuation changes of the MSRs is managed. The acquired FAMC portfolio is accounted for under the fair value method while the Company’s MSR portfolio held before the FAMC acquisition is accounted for under the amortization method. The Company implemented an active hedging strategy to manage the risk associated with changes in the value of the MSR portfolio accounted for under the fair value method, which includes the purchase of freestanding derivatives. Any change in fair value during the period for MSRs carried under the fair value method, as well as amortization and impairment of MSRs under the amortization method, is recorded in mortgage banking fees in the Consolidated Statements of Operations.

The following tables summarize changes in MSRs recorded using the amortization method and the fair value method for the three and nine months ended September 30, 2018 and 2017.

Amortization Method



	As of and for the Three Months Ended September 30,						As of and for the Nine Months Ended September 30,
(in millions)	2018			2017			2018			2017
MSRs:
Balance as of beginning of period		$217			$170			$201			$167
Amount capitalized	11			9			26			28
Purchases	—			—			16			—
Amortization	(9		)	(8		)	(24		)	(24		)
Carrying amount before valuation allowance	219			171			219			171
Valuation allowance for servicing assets:
Balance as of beginning of period	—			4			3			5
Valuation recoveries	—			—			(3		)	(1		)
Balance at end of period	—			4			—			4
Net carrying value of MSRs		$219			$167			$219			$167

For the purposes of impairment evaluation and measurement of MSRs under the amortization method, MSRs are stratified based on predominant risk characteristics (such as interest rate, loan size, origination date, term, or geographic location) of the underlying loans. An allowance is established in the event the recorded value of an individual stratum exceeds fair value.

Fair Value Method



	As of and for the Three Months Ended September 30, 2018			As of and for the Nine Months Ended September 30, 2018
(in millions)	As of and for the Three Months Ended September 30, 2018			As of and for the Nine Months Ended September 30, 2018
MSRs:
Fair value as of beginning of the period		$—			$—
Acquired MSRs	590			590
Amounts capitalized	29			29
Changes in unpaid principal balance during the period ⁽¹⁾	(12		)	(12		)
Changes in fair value during the period ⁽²⁾	5			5
Fair value at end of the period		$612			$612

⁽¹⁾ Represents changes in value due to i) passage of time including the impact from both regularly scheduled loan principal payments and partial paydowns, and ii)

loans that paid off during the period.

⁽²⁾ Represents changes in value primarily due to market driven changes in interest rates and prepayment speeds.

The fair value of MSRs is estimated using 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 interest rates. The valuation does not attempt to forecast or predict the future direction of interest rates.

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 movements in market interest rates.

For MSRs under the amortization method, the key economic assumptions used to estimate the fair value are presented below:



	September 30, 2018			December 31, 2017
	Actual	Decline in fair value due to		Actual	Decline in fair value due to
(dollars in millions)	Actual	Decline in fair value due to		Actual	Decline in fair value due to
Fair value	$261	50 bps adverse change	100 bps adverse change	$218	50 bps adverse change	100 bps adverse change
Weighted average life (in years)	6.9	50 bps adverse change	100 bps adverse change	5.9	50 bps adverse change	100 bps adverse change
Weighted average constant prepayment rate	7.7%	$18	$43	10.0%	$22	$46
Weighted average discount rate	9.3%	5	10	9.9%	4	8

For MSRs under the fair value method, the key economic assumptions used to estimate the fair value are presented below:



	September 30, 2018
	Actual	Decline in fair value due to
(dollars in millions)	Actual	Decline in fair value due to
Fair value	$612	50 bps adverse change	100 bps adverse change
Weighted average life (in years)	8.7	50 bps adverse change	100 bps adverse change
Weighted average constant prepayment rate	7.3%	$54	$123
Weighted average option adjusted spread	625 bps	14	27

The Company economically hedges the value of certain MSRs using derivative instruments. Refer to Note 9 “Derivatives” for additional information.