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

12 Months Ended

Dec. 31, 2019

Receivables [Abstract]

Schedule of changes in the allowance for credit losses

The following tables present a summary of changes in the ACL:

	Year Ended December 31, 2019
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses, beginning of period		$690			$552			$1,242
Charge-offs	(140		)	(475		)	(615		)
Recoveries	24			161			185
Net charge-offs	(116		)	(314		)	(430		)
Provision charged to income	100			340			440
Allowance for loan and lease losses, end of period	674			578			1,252
Reserve for unfunded lending commitments, beginning of period	91			—			91
Provision for unfunded lending commitments	(47		)	—			(47		)
Reserve for unfunded lending commitments, end of period	44			—			44
Total allowance for credit losses, end of period		$718			$578			$1,296

	Year Ended December 31, 2018
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses, beginning of period		$685			$551			$1,236
Charge-offs	(52		)	(442		)	(494		)
Recoveries	19			158			177
Net charge-offs	(33		)	(284		)	(317		)
Provision charged to income	38			285			323
Allowance for loan and lease losses, end of period	690			552			1,242
Reserve for unfunded lending commitments, beginning of period	88			—			88
Provision for unfunded lending commitments	3			—			3
Reserve for unfunded lending commitments, end of period	91			—			91
Total allowance for credit losses, end of period		$781			$552			$1,333

	Year Ended December 31, 2017
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses, beginning of period		$663			$573			$1,236
Charge-offs	(75		)	(437		)	(512		)
Recoveries	40			167			207
Net charge-offs	(35		)	(270		)	(305		)
Provision charged to income(1)	57			248			305
Allowance for loan and lease losses, end of period	685			551			1,236
Reserve for unfunded lending commitments, beginning of period	72			—			72
Provision for unfunded lending commitments	16			—			16
Reserve for unfunded lending commitments, end of period	88			—			88
Total allowance for credit losses, end of period		$773			$551			$1,324

⁽¹⁾ Includes an increase of approximately $50 million to commercial and corresponding decrease to retail for the impact of the enhancement to the assessment of qualitative risks, factors and events that may not be measured in the modeled results.

Schedule of loans and leases based on evaluation method

The following table presents the recorded investment in loans and leases based on the Company’s evaluation methodology:

	December 31, 2019						December 31, 2018
(in millions)	Commercial		Retail		Total		Commercial		Retail		Total
Individually evaluated		$399		$667		$1,066		$391		$723		$1,114
Formula-based evaluation	57,139		60,883		118,022		56,392		59,154		115,546
Total loans and leases		$57,538		$61,550		$119,088		$56,783		$59,877		$116,660

Schedule of allowance for credit losses by evaluation method

The following table presents a summary of the ACL by evaluation methodology:

	December 31, 2019						December 31, 2018
(in millions)	Commercial		Retail		Total		Commercial		Retail		Total
Individually evaluated		$85		$25		$110		$38		$26		$64
Formula-based evaluation	633		553		1,186		743		526		1,269
Allowance for credit losses		$718		$578		$1,296		$781		$552		$1,333

Schedule of classes of commercial loans and leases based on regulatory classifications

The following tables present the recorded investment in commercial loans and leases based on regulatory classification ratings:

	December 31, 2019
			Criticized
(in millions)	Pass		Special Mention		Substandard		Doubtful		Total
Commercial		$38,950		$1,351		$934		$244		$41,479
Commercial real estate	13,169		318		33		2		13,522
Leases	2,383		109		42		3		2,537
Total commercial loans and leases		$54,502		$1,778		$1,009		$249		$57,538

	December 31, 2018
			Criticized
(in millions)	Pass		Special Mention		Substandard		Doubtful		Total
Commercial		$38,600		$1,231		$828		$198		$40,857
Commercial real estate	12,523		412		82		6		13,023
Leases	2,823		39		41		—		2,903
Total commercial loans and leases		$53,946		$1,682		$951		$204		$56,783

Schedule of retail loan investments categorized by delinquency status

The following tables present the recorded investment in classes of retail loans, categorized by delinquency status:

	December 31, 2019
			Days Past Due
(in millions)	Current		1-29		30-59		60-89		90 or More		Total
Residential mortgages		$18,818		$129		$35		$17		$84		$19,083
Home equity loans	713		64		10		4		21		812
Home equity lines of credit	11,383		346		72		32		146		11,979
Home equity loans serviced by others	244		23		7		3		12		289
Home equity lines of credit serviced by others	50		11		2		1		10		74
Automobile	10,787		1,001		227		81		24		12,120
Education	10,088		202		30		15		12		10,347
Credit cards	2,076		74		15		11		22		2,198
Other retail	4,492		87		30		20		19		4,648
Total retail loans		$58,651		$1,937		$428		$184		$350		$61,550

	December 31, 2018
			Days Past Due
(in millions)	Current		1-29		30-59		60-89		90 or More		Total
Residential mortgages		$18,664		$131		$37		$13		$133		$18,978
Home equity loans	945		75		12		3		38		1,073
Home equity lines of credit	12,042		386		65		22		195		12,710
Home equity loans serviced by others	355		21		7		3		13		399
Home equity lines of credit serviced by others	79		15		2		1		7		104
Automobile	10,729		1,039		207		59		72		12,106
Education	8,694		159		23		13		11		8,900
Credit cards	1,894		53		14		10		20		1,991
Other retail	3,481		76		26		18		15		3,616
Total retail loans		$56,883		$1,955		$393		$142		$504		$59,877

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 (1)(2)				Accruing and 90 days or more past due
(in millions)	December 31, 2019		December 31, 2018		December 31, 2019		December 31, 2018
Commercial		$240		$194		$2		$1
Commercial real estate	2		7		—		—
Leases	3		—		—		—
Total commercial loans and leases	245		201		2		1
Residential mortgages	93		105		13		15
Home equity loans	33		50		—		—
Home equity lines of credit	187		231		—		—
Home equity loans serviced by others	14		17		—		—
Home equity lines of credit serviced by others	12		15		—		—
Automobile	67		81		—		—
Education	18		38		2		2
Credit card	22		20		—		—
Other retail	12		8		8		7
Total retail loans	458		565		23		24
Total		$703		$766		$25		$25

⁽¹⁾ Nonperforming balances exclude first lien residential mortgage loans that are 100% guaranteed by the Federal Housing Administration. These loans are included in the Company’s Consolidated Balance Sheets.

⁽²⁾ Beginning in the fourth quarter of 2019, nonperforming balances exclude both fully and partially guaranteed residential mortgage loans sold to Ginnie Mae for which the Company has the right, but not the obligation, to repurchase. Prior periods have been adjusted to exclude partially guaranteed amounts to conform with the current period presentation. These loans are included in the Company’s Consolidated Balance Sheets.

Summary of key performance indicators

The following table presents a summary of nonperforming loan and lease key performance indicators:

	December 31,
	2019		2018
Nonperforming commercial loans and leases as a percentage of total loans and leases	0.21	%	0.17	%
Nonperforming retail loans as a percentage of total loans and leases	0.38		0.49
Total nonperforming loans and leases as a percentage of total loans and leases (1)	0.59	%	0.66	%
Nonperforming commercial assets as a percentage of total assets	0.15	%	0.13	%
Nonperforming retail assets as a percentage of total assets	0.30		0.37
Total nonperforming assets as a percentage of total assets	0.45	%	0.50	%

⁽¹⁾ Beginning in the fourth quarter of 2019, nonperforming balances exclude both fully and partially guaranteed residential mortgage loans sold to Ginnie Mae for which the Company has the right, but not the obligation, to repurchase. Prior periods have been adjusted to exclude partially guaranteed amounts to conform with the current period presentation. These loans are included in the Company’s Consolidated Balance Sheets.

Analysis of age of past due amounts

The following table presents the aging of both accruing and nonaccruing loan and lease past due amounts:

	December 31, 2019								December 31, 2018
	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		$45		$27		$67		$139		$85		$3		$78		$166
Commercial real estate	1		1		—		2		8		32		5		45
Leases	37		—		2		39		7		—		—		7
Total commercial loans and leases	83		28		69		180		100		35		83		218
Residential mortgages	35		17		84		136		37		13		133		183
Home equity loans	10		4		21		35		12		3		38		53
Home equity lines of credit	72		32		146		250		65		22		195		282
Home equity loans serviced by others	7		3		12		22		7		3		13		23
Home equity lines of credit serviced by others	2		1		10		13		2		1		7		10
Automobile	227		81		24		332		207		59		72		338
Education	30		15		12		57		23		13		11		47
Credit cards	15		11		22		48		14		10		20		44
Other retail	30		20		19		69		26		18		15		59
Total retail loans	428		184		350		962		393		142		504		1,039
Total		$511		$212		$419		$1,142		$493		$177		$587		$1,257

Schedule of impaired loans by class

The following tables present a summary of impaired loans by class:

	December 31, 2019
(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		$243		$85		$137		$458		$380
Commercial real estate	—		—		19		19		19
Total commercial loans	243		85		156		477		399
Residential mortgages	29		2		125		196		154
Home equity loans	22		1		65		121		87
Home equity lines of credit	27		2		173		242		200
Home equity loans serviced by others	15		1		16		41		31
Home equity lines of credit serviced by others	1		—		5		9		6
Automobile	1		—		20		30		21
Education	112		9		22		135		134
Credit cards	27		9		1		29		28
Other retail	3		1		3		8		6
Total retail loans	237		25		430		811		667
Total		$480		$110		$586		$1,288		$1,066

	December 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		$186		$31		$167		$450		$353
Commercial real estate	32		7		6		38		38
Total commercial loans	218		38		173		488		391
Residential mortgages	28		2		127		201		155
Home equity loans	34		3		76		148		110
Home equity lines of credit	21		1		181		244		202
Home equity loans serviced by others	22		1		19		54		41
Home equity lines of credit serviced by others	1		—		7		11		8
Automobile	1		—		22		31		23
Education	130		11		23		153		153
Credit cards	24		7		1		25		25
Other retail	4		1		2		8		6
Total retail loans	265		26		458		875		723
Total		$483		$64		$631		$1,363		$1,114

Schedule of additional information on impaired loans

The following table presents additional information on impaired loans:

	Year Ended December 31,
	2019				2018				2017
(in millions)	Interest Income Recognized		Average Recorded Investment		Interest Income Recognized		Average Recorded Investment		Interest Income Recognized		Average Recorded Investment
Commercial		$11		$311		$9		$312		$4		$380
Commercial real estate	1		39		1		32		—		37
Total commercial loans	12		350		10		344		4		417
Residential mortgages	5		126		5		146		4		136
Home equity loans	5		84		6		107		6		121
Home equity lines of credit	7		172		7		181		6		176
Home equity loans serviced by others	2		30		3		42		3		49
Home equity lines of credit serviced by others	—		6		—		9		—		9
Automobile	1		17		1		20		1		18
Education	8		125		8		154		9		173
Credit cards	2		21		1		21		2		22
Other retail	—		5		—		7		—		9
Total retail loans	30		586		31		687		31		713
Total		$42		$936		$41		$1,031		$35		$1,130

Troubled debt restructurings on financing receivables

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

	December 31,
(in millions)	2019		2018
Commercial		$297		$304
Retail	667		723
Unfunded commitments related to TDRs	42		30

The following tables summarize how loans were modified during the years ended December 31, 2019, 2018 and 2017. The reported balances represent the post-modification outstanding recorded investment and can include loans that became TDRs during the period and were paid off in full, charged off, or sold prior to period end. Pre-modification balances for modified loans approximate the post-modification balances shown.

	December 31, 2019
	Primary Modification Types
	Interest Rate Reduction(1)			Maturity Extension(2)			Other(3)
(dollars in millions)	Number of Contracts	Recorded Investment		Number of Contracts	Recorded Investment		Number of Contracts	Recorded Investment
Commercial	3		$—	26		$5	56		$210
Commercial real estate	—	—		1	—		—	—
Total commercial loans	3	—		27	5		56	210
Residential mortgages	60	12		62	10		120	17
Home equity loans	31	2		—	—		82	4
Home equity lines of credit	163	18		72	11		350	22
Home equity loans serviced by others	2	—		—	—		14	—
Home equity lines of credit serviced by others	—	—		—	—		8	—
Automobile	160	3		21	—		1,250	17
Education	—	—		—	—		272	7
Credit cards	3,259	18		—	—		304	1
Other retail	—	—		—	—		176	1
Total retail loans	3,675	53		155	21		2,576	69
Total	3,678		$53	182		$26	2,632		$279

	December 31, 2018
	Primary Modification Types
	Interest Rate Reduction(1)			Maturity Extension(2)			Other(3)
(dollars in millions)	Number of Contracts	Recorded Investment		Number of Contracts	Recorded Investment		Number of Contracts	Recorded Investment
Commercial	7		$1	49		$22	53		$200
Commercial real estate	—	—		3	31		2	31
Total commercial loans	7	1		52	53		55	231
Residential mortgages	35	4		61	8		142	17
Home equity loans	43	4		1	—		134	5
Home equity lines of credit	76	7		178	26		413	29
Home equity loans serviced by others	4	—		—	—		23	1
Home equity lines of credit serviced by others	5	—		1	—		14	1
Automobile	158	3		46	1		1,189	17
Education	—	—		—	—		355	7
Credit cards	2,312	13		—	—		—	—
Other retail	1	—		—	—		9	—
Total retail loans	2,634	31		287	35		2,279	77
Total	2,641		$32	339		$88	2,334		$308

	December 31, 2017
	Primary Modification Types
	Interest Rate Reduction(1)			Maturity Extension(2)			Other(3)
(dollars in millions)	Number of Contracts	Recorded Investment		Number of Contracts	Recorded Investment		Number of Contracts	Recorded Investment
Commercial	7		$1	45		$22	15		$71
Commercial real estate	—	—		1	—		1	—
Total commercial loans	7	1		46	22		16	71
Residential mortgages	71	10		73	13		171	19
Home equity loans	82	6		1	—		232	13
Home equity lines of credit	50	3		235	30		395	27
Home equity loans serviced by others	15	1		—	—		52	2
Home equity lines of credit serviced by others	5	—		2	—		26	2
Automobile	130	2		29	1		1,336	20
Education	—	—		—	—		329	7
Credit cards	2,363	13		—	—		—	—
Other retail	1	—		—	—		5	—
Total retail loans	2,717	35		340	44		2,546	90
Total	2,724		$36	386		$66	2,562		$161

⁽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.

Schedule of loans that may increase credit exposure

The following tables present balances of loans with these characteristics:

	December 31, 2019
(in millions)	Residential Mortgages		Home Equity Loans and Lines of Credit		Home Equity Products Serviced by Others		Credit Cards		Total
High loan-to-value		$402		$61		$90		$—		$553
Interest only/negative amortization	2,043		—		—		—		2,043
Low introductory rate	—		—		—		235		235
Multiple characteristics and other	—		—		—		—		—
Total		$2,445		$61		$90		$235		$2,831

	December 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		$318		$87		$148		$—		$—		$553
Interest only/negative amortization	1,794		—		—		—		1		1,795
Low introductory rate	—		—		—		217		—		217
Multiple characteristics and other	1		—		—		—		—		1
Total		$2,113		$87		$148		$217		$1		$2,566