COMMITMENTS AND CONTINGENCIES (Tables)

12 Months Ended

Dec. 31, 2018

Commitments and Contingencies Disclosure [Abstract]

Schedule of outstanding off balance sheet arrangements

A summary of outstanding off-balance sheet arrangements is presented below:

	December 31,
(in millions)	2018		2017
Undrawn commitments to extend credit		$69,553		$62,959
Letters of credit	2,125		2,136
Marketing rights	37		41
Risk participation agreements	19		16
Residential mortgage loans sold with recourse	5		7
Total		$71,739		$65,159