COMMITMENTS AND CONTINGENCIES (Tables)

3 Months Ended

Mar. 31, 2019

Commitments and Contingencies Disclosure [Abstract]

Schedule of outstanding off balance sheet arrangements

A summary of outstanding off-balance sheet arrangements is presented below. For more information on these arrangements, see Note 18 “Commitments and Contingencies” to the Company’s audited Consolidated Financial Statements in the Annual Report on Form 10-K for the year ended December 31, 2018.

(in millions)	March 31, 2019		December 31, 2018
Commitments to extend credit		$68,564		$69,553
Letters of credit	2,089		2,125
Marketing rights	37		37
Risk participation agreements	27		19
Loans sold with recourse	22		5
Total		$70,739		$71,739