COMMITMENTS AND CONTINGENCIES (Tables)

9 Months Ended

Sep. 30, 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 in the Company’s 2018 Form 10-K.

(in millions)	September 30, 2019		December 31, 2018
Commitments to extend credit		$70,825		$69,553
Letters of credit	2,148		2,125
Marketing rights	33		37
Risk participation agreements	47		19
Loans sold with recourse	32		5
Total		$73,085		$71,739