COMMITMENTS AND CONTINGENCIES (Tables)

12 Months Ended

Dec. 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:

	December 31,
(in millions)	2019		2018
Commitments to extend credit		$72,743		$69,553
Letters of credit	2,190		2,125
Risk participation agreements	37		19
Loans sold with recourse	37		5
Marketing rights	33		37
Total		$75,040		$71,739