ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK

3 Months Ended

Mar. 31, 2020

Receivables [Abstract]

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK

NOTE 4 - ALLOWANCE FOR CREDIT LOSSES, NONACCRUING LOANS AND LEASES, AND CONCENTRATIONS OF CREDIT RISK

Allowance for Credit Losses    

Management’s estimate of expected credit losses in the Company’s loan and lease portfolios is recorded in the ALLL and the reserve for unfunded lending commitments (collectively the ACL). See Note 5 in the Company’s 2019 Form 10-K for a detailed discussion of the ACL reserve methodology and estimation techniques as of December 31, 2019. Upon adoption of CECL effective January 1, 2020, the Company’s ACL reserve methodology changed to estimate expected credit losses over the contractual life of the loans and leases.

The ACL is maintained at a level the Company believes to be appropriate to absorb expected lifetime credit losses over the contractual life of the loan and lease portfolios and on the unfunded lending commitments. The determination of the ACL is based on periodic evaluation of the loan and lease portfolios and unfunded lending commitments that are not unconditionally cancelable considering a number of relevant underlying factors, including key assumptions and evaluation of quantitative and qualitative information.

Key assumptions used in the ACL measurement process include the use of a two-year reasonable and supportable economic forecast period followed by a one-year period during which the expected credit losses revert to long-term historical macroeconomic inputs.

The evaluation of quantitative and qualitative information is performed through assessments of groups of assets that share similar risk characteristics and certain individual loans and leases that do not share similar risk characteristics with the collective group. Loans are grouped generally by product type (e.g., commercial, commercial real estate, residential mortgage, etc.), and significant loan portfolios are assessed for credit losses using econometric models.

The quantitative evaluation of the adequacy of the ACL utilizes a single economic forecast and is primarily based on econometric models that use known or estimated data as of the balance sheet date and forecasted data over the reasonable and supportable period. Known and estimated data include current PD, LGD and EAD (for commercial loans and leases), timing and amount of expected draws (for unfunded lending commitments), mix and level of loan balances, delinquency levels, assigned risk ratings, previous loss experience, current business conditions, amounts and timing of expected future cash flows, and factors particular to a specific commercial credit such as

competition, business and management performance. Forward-looking economic assumptions include real gross domestic product, unemployment rate, interest rate curve, and changes in collateral values. This data is aggregated to estimate expected credit losses over the contractual life of the loans and leases, adjusted for expected prepayments. In highly volatile economic environments historical information, such as commercial customer financial statements or consumer credit ratings, may not be as important to estimating future expected losses as forecasted inputs to the models.

The ACL may also be affected materially by a variety of qualitative factors that the Company considers to reflect current judgment of various events and risks that are not measured in the statistical procedures including uncertainty related to the economic forecasts used in the modeled credit loss estimates, loan growth, back testing results, credit underwriting policy exceptions, regulatory and audit findings, and peer comparisons. The qualitative allowance for economic forecast risk is further informed by multiple alternative scenarios to arrive at a composite scenario supporting the period-end ACL balance.

The measurement process results in specific or pooled allowances for loans, leases and unfunded lending commitments, and qualitative allowances that are judgmentally determined and applied across the portfolio.

There are certain loan portfolios that may not need an econometric model to enable the Company to calculate management’s best estimate of the expected credit losses. Less data intensive, non-modeled approaches to estimating losses are considered more efficient and practical for portfolios that have lower levels of outstanding balances (e.g., runoff or closed portfolios, new products or products that are not significant to the Company’s overall credit risk exposure).

Loans and leases that do not share similar risk characteristics are individually assessed for expected credit losses. Nonaccruing commercial and commercial real estate loans with an outstanding balance of $5 million or greater and all commercial and commercial real estate TDRs (regardless of size) are assessed on an individual loan level basis. Generally, the measurement of ACL on individual loans and leases is the present value of its future cash flows or the fair value of its underlying collateral, if the loan or lease is collateral dependent. Loans that are deemed to be collateral dependent are written down to the fair value, less costs to sell, if sale of the collateral is expected as of the evaluation date and are reassessed each subsequent period to determine if a change to the ACL is required. Subsequent evaluations may result in an increase or decrease to the ACL, based on a corresponding change in the fair value of the collateral during the period. Any subsequent decrease to the ACL (because of an increase to the collateral-dependent loan’s fair value) is limited to the total amount previously written off for that loan. For retail TDRs that are not collateral dependent, the ACL is developed using the present value of expected future cash flows compared to the amortized cost basis in the loans. Expected re-default factors are considered in this analysis. Retail TDRs that are deemed collateral dependent are written down to fair market value less cost to sell.

Expected recoveries are considered in management’s estimate of the ACL and may result in a negative adjustment (i.e., reduction) to the ACL balance. A loan is collateral dependent if repayment is expected to be provided substantially through the operation or sale of the collateral when the borrower is experiencing financial difficulty as of the evaluation date. Generally, repayment would be expected to be provided substantially by the sale or continued operation of the underlying collateral if cash flows to repay the loan from all other available sources (including guarantors) are expected to be no more than nominal. If repayment is dependent only on the operation of the collateral, the fair value of the collateral would not be adjusted for estimated costs to sell. If a loan is considered collateral dependent, the ACL is calculated as the difference between the fair value of collateral (adjusted for the costs to sell if the sale of the collateral is expected) and the amortized cost basis as of the evaluation date. It is possible to have a negative ACL for a collateral dependent loan if the fair value of the collateral increases in a subsequent reporting period. The negative ACL cannot exceed the total amount previously charged off.

Accrued interest receivable on loans and leases is excluded from asset balances used to calculate the ACL. All accrued and uncollected interest is immediately reversed against interest income when a loan or lease is placed on nonaccrual status. Uncollectible interest is written off timely in accordance with regulatory guidelines. Generally, loans and leases are placed on nonaccrual status when contractually past due 90 days or more, or earlier if management believes that the probability of collection is insufficient to warrant further accrual. Residential mortgages are placed on nonaccrual status when contractually past due 120 days or more, or sooner if deemed collateral-dependent, unless guaranteed by the Federal Housing Administration. The amount of accrued interest receivable reversed against interest income for the three months ended March 31, 2020 was $1 million and $5 million for commercial and retail, respectively.

The Company estimates expected credit losses associated with off-balance sheet financial instruments such as standby letters of credit, financial guarantees and unfunded loan commitments that are not unconditionally cancelable. Off-balance sheet financial instruments are subject to individual reviews and are analyzed and segregated by risk according to the Company’s internal risk rating scale. These risk classifications, in conjunction with historical loss experience, current and future economic conditions, timing and amount of expected draws, and performance trends within specific portfolio segments, result in the estimate of the reserve for unfunded lending commitments. The Company does not recognize a reserve for future draws from credit lines that are unconditionally cancelable (e.g., credit cards).

The ALLL and the reserve for unfunded lending commitments are reported on the Consolidated Balance Sheets in the allowance for loan and lease losses and in other liabilities, respectively. Provision for credit losses related to the loans and leases portfolio and the unfunded lending commitments are reported in the Consolidated Statements of Operations as provision for credit losses.

The following table presents a summary of changes in the ALLL and the reserve for unfunded lending commitments:

	Three Months Ended March 31, 2020
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses, beginning of period		$674			$578			$1,252
Cumulative effect of change in accounting principle	(176		)	629			453
Allowance for loan and lease losses, beginning of period, adjusted	498			1,207			1,705
Charge-offs	(47		)	(127		)	(174		)
Recoveries	3			34			37
Net charge-offs	(44		)	(93		)	(137		)
Provision charged to income	298			305			603
Allowance for loan and lease losses, end of period		$752			$1,419			$2,171
Reserve for unfunded lending commitments, beginning of period		$44			$—			$44
Cumulative effective of change in accounting principle	(3		)	1			(2		)
Reserve for unfunded lending commitments, beginning of period, adjusted	41			1			42
Provision for unfunded lending commitments	(3		)	—			(3		)
Reserve for unfunded lending commitments, end of period		$38			$1			$39

The following table provides additional detail on the cumulative effect of change in accounting principle on the ACL:

	December 31, 2019						January 1, 2020							March 31, 2020
(in millions)	Amortized Cost Basis		ACL Balance		Coverage		Impact of Adoption of CECL			ACL Balance		Coverage		Amortized Cost Basis		ACL Balance		Coverage
Commercial		$41,479		$575	1.4	%		($199	)		$376	0.9	%		$49,092		$613	1.2	%
Commercial real estate	13,522		124		0.9		(57		)	67		0.5		14,502		74		0.5
Leases	2,537		19		0.7		77			96		3.8		2,438		103		4.2
Total commercial loans and leases	57,538		718		1.2		(179		)	539		0.9		66,032		790		1.2
Residential	19,083		35		0.2		95			130		0.7		18,721		153		0.8
Home equity	13,154		83		0.6		73			156		1.2		12,992		169		1.3
Automobile	12,120		123		1.0		83			206		1.7		12,157		278		2.3
Education	10,347		116		1.1		298			414		4.0		10,887		473		4.3
Other retail	6,846		221		3.2		81			302		4.4		6,739		347		5.1
Total retail loans	61,550		578		0.9		630			1,208		2.0		61,496		1,420		2.3
Total loans and leases		$119,088		$1,296	1.1	%		$451			$1,747	1.5	%		$127,528		$2,210	1.7	%

In addition to the adoption of CECL, macroeconomic assumptions shifted as the COVID-19 pandemic and related economic impacts surfaced during the quarter ended March 31, 2020, resulting in a significant impact to the ACL. The significant increase in the ACL as of March 31, 2020 as compared to the January 1, 2020 ACL was driven

by the COVID-19 pandemic and the resulting economic impacts, with a total reserve build of $463 million and an ending balance of $2.2 billion.

To determine the ACL as of March 31, 2020, the Company utilized the Moody’s March 27th Baseline forecast to integrate the effects of COVID-19 in the loss estimates. Estimated Losses were adjusted for the expected benefit of COVID-19-related fiscal and monetary stimulus measures and the expected beneficial impacts of customer assistance actions. These actions include company forbearance and other customer accommodation efforts encouraged by the CARES Act and regulatory interagency guidance that the Company believes will stabilize credit profiles in both the commercial and consumer portfolios.

The economic forecast risk component of the qualitative reserve was informed by a composite economic scenario approach utilizing the Moody’s March 27th Baseline scenario as the most likely outcome and two less likely outcomes - an alternate Moody’s pandemic scenario and an internally generated pandemic scenario. All scenarios assumed a deep recession in the second quarter 2020 with significantly declining GDP and elevated unemployment followed by a strong recovery in the second half of 2020.

The following table presents a summary of changes in the ALLL and the reserve for unfunded lending commitments:

	Three Months Ended March 31, 2019
(in millions)	Commercial			Retail			Total
Allowance for loan and lease losses, beginning of period		$690			$552			$1,242
Charge-offs	(26		)	(112		)	(138		)
Recoveries	2			47			49
Net charge-offs	(24		)	(65		)	(89		)
Provision charged to income	25			67			92
Allowance for loan and lease losses, end of period		$691			$554			$1,245
Reserve for unfunded lending commitments, beginning of period		$91			$—			$91
Provision for unfunded lending commitments	(7		)	—			(7		)
Reserve for unfunded lending commitments, end of period		$84			$—			$84

Credit Quality Indicators

Loan and lease portfolio segments and classes, excluding LHFS, are presented by credit quality indicator and vintage year. Citizens defines the vintage date for the purpose of this disclosure as the date of the most recent credit decision. In general, renewals are categorized as new credit decisions and reflect the renewal date as the vintage date. Loans modified in a TDR are considered to be a continuation of the original loan and vintage date corresponds with the initial loan origination date.

For commercial loans and leases, Citizens utilizes regulatory classification ratings to monitor credit quality. Loans with a “pass” rating are those that the Company believes will be fully repaid in accordance with the contractual loan terms. Commercial loans and leases that are “criticized” are those that have some weakness or potential weakness that indicate an increased probability of future loss. “Criticized” loans are grouped into three categories, “special mention,” “substandard” and “doubtful.” Special mention loans have potential weaknesses that, if left uncorrected, may result in deterioration of the Company’s credit position at some future date. Substandard loans are inadequately protected loans; these loans have well-defined weaknesses that could hinder normal repayment or collection of the debt. Doubtful loans have the same weaknesses as substandard, with the added characteristics that the possibility of loss is high and collection of the full amount of the loan is improbable.

The following table presents the amortized cost basis of commercial loans and leases, by vintage date and regulatory classification rating, as of March 31, 2020:

	Term Loans by Origination Year												Revolving Loans
(in millions)	2020		2019		2018		2017		2016		Prior to 2016		Within the Revolving Period		Converted to Term		Total
Commercial
Pass		$1,480		$7,457		$5,444		$3,079		$1,901		$3,035		$23,655		$174		$46,225
Special Mention	—		126		264		88		75		177		766		4		1,500
Substandard	2		60		150		136		99		104		493		18		1,062
Doubtful	—		27		9		23		10		87		145		4		305
Total commercial	1,482		7,670		5,867		3,326		2,085		3,403		25,059		200		49,092
Commercial real estate
Pass	898		3,322		3,750		1,937		1,187		1,257		1,394		—		13,745
Special Mention	48		72		181		78		56		93		197		—		725
Substandard	—		—		19		2		—		3		—		—		24
Doubtful	—		—		1		5		—		2		—		—		8
Total commercial real estate	946		3,394		3,951		2,022		1,243		1,355		1,591		—		14,502
Leases
Pass	90		370		291		200		261		1,107		—		—		2,319
Special Mention	—		2		6		5		4		2		—		—		19
Substandard	—		6		33		6		21		33		—		—		99
Doubtful	—		—		—		—		—		1		—		—		1
Total leases	90		378		330		211		286		1,143		—		—		2,438
Total commercial loans and leases
Pass	2,468		11,149		9,485		5,216		3,349		5,399		25,049		174		62,289
Special Mention	48		200		451		171		135		272		963		4		2,244
Substandard	2		66		202		144		120		140		493		18		1,185
Doubtful	—		27		10		28		10		90		145		4		314
Total commercial loans and leases		$2,518		$11,442		$10,148		$5,559		$3,614		$5,901		$26,650		$200		$66,032

For retail loans, Citizens utilizes credit scores provided by FICO which are generally refreshed on a quarterly basis and the loan’s payment and delinquency status to monitor credit quality. FICO credit scores are considered the strongest indicator of credit losses over the contractual life of the loan as the scores are based on current and historical national industry-wide consumer level credit performance data, and assist management in predicting the borrower’s future payment performance.

The following table presents the amortized cost basis of retail loans, by vintage date and FICO scores, as of March 31, 2020:

	Term Loans by Origination Year												Revolving Loans
(in millions)	2020		2019		2018		2017		2016		Prior to 2016		Within the Revolving Period		Converted to Term		Total
Residential mortgages
800+		$328		$1,694		$950		$1,541		$2,001		$2,459		$—		$—		$8,973
740-799	634		2,026		647		828		1,017		1,220		—		—		6,372
680-739	192		687		280		294		367		614		—		—		2,434
620-679	12		102		44		56		79		237		—		—		530
<620	4		16		35		46		44		251		—		—		396
No FICO available(1)	2		2		—		—		—		12		—		—		16
Total residential mortgages	1,172		4,527		1,956		2,765		3,508		4,793		—		—		18,721
Home equity
800+	1		10		15		9		6		288		4,314		339		4,982
740-799	1		7		8		7		4		238		3,423		302		3,990
680-739	—		3		8		9		6		224		1,915		272		2,437
620-679	—		1		6		15		9		160		570		174		935
<620	—		3		10		33		21		166		207		207		647
No FICO available(1)	—		—		—		—		—		1		—		—		1
Total home equity	2		24		47		73		46		1,077		10,429		1,294		12,992
Automobile
800+	302		935		541		441		289		175		—		—		2,683
740-799	393		1,304		738		529		312		174		—		—		3,450
680-739	355		1,233		676		441		252		135		—		—		3,092
620-679	191		758		391		248		145		84		—		—		1,817
<620	26		314		277		227		151		99		—		—		1,094
No FICO available(1)	2		1		—		—		—		18		—		—		21
Total automobile	1,269		4,545		2,623		1,886		1,149		685		—		—		12,157
Education
800+	221		1,159		880		853		669		848		—		—		4,630
740-799	294		1,364		793		567		397		562		—		—		3,977
680-739	105		553		321		222		156		298		—		—		1,655
620-679	5		86		69		55		45		130		—		—		390
<620	—		12		23		25		22		86		—		—		168
No FICO available(1)	—		—		—		—		—		67		—		—		67
Total education	625		3,174		2,086		1,722		1,289		1,991		—		—		10,887
Other retail
800+	138		574		234		90		21		58		300		—		1,415
740-799	223		849		318		130		32		41		664		—		2,257
680-739	162		609		216		84		19		22		648		—		1,760
620-679	78		272		84		28		6		8		229		—		705
<620	6		75		44		16		3		5		117		—		266
No FICO available(1)	19		3		—		—		—		—		314		—		336
Total other retail	626		2,382		896		348		81		134		2,272		—		6,739
Retail
800+	990		4,372		2,620		2,934		2,986		3,828		4,614		339		22,683
740-799	1,545		5,550		2,504		2,061		1,762		2,235		4,087		302		20,046
680-739	814		3,085		1,501		1,050		800		1,293		2,563		272		11,378
620-679	286		1,219		594		402		284		619		799		174		4,377
<620	36		420		389		347		241		607		324		207		2,571
No FICO available(1)	23		6		—		—		—		98		314		—		441
Total retail		$3,694		$14,652		$7,608		$6,794		$6,073		$8,680		$12,701		$1,294		$61,496

⁽¹⁾ Represents loans for which an updated FICO score was unavailable (e.g., due to recent profile changes).

Nonaccrual and Past Due Assets

The following table presents nonaccrual loans and leases and loans accruing and 90 days or more past due:

	As of December 31, 2019		As of March 31, 2020
(in millions)	Nonaccrual loans and leases		Nonaccrual loans and leases		90+ days past due and accruing		Nonaccrual with no related ACL
Commercial		$240		$305		$—		$46
Commercial real estate	2		8		—		6
Leases	3		1		—		—
Total commercial loans and leases	245		314		—		52
Residential mortgages	93		101		14		55
Home equity	246		242		—		90
Automobile	67		69		—		30
Education	18		21		2		4
Other retail	34		33		11		1
Total retail	458		466		27		180
Total loans and leases		$703		$780		$27		$232

Interest income is generally not recognized for loans and leases that are on nonaccrual status. The Company reverses accrued interest receivable with a charge to interest income upon classifying the loan or lease as nonaccrual.

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

	March 31, 2020										December 31, 2019
	Days Past Due										Days Past Due
(in millions)	Current-29		30-59		60-89		90 or More		Total		Current-29		30-59		60-89		90 or More		Total
Commercial		$48,909		$97		$28		$58		$49,092		$41,340		$45		$27		$67		$41,479
Commercial real estate	14,494		1		6		1		14,502		13,520		1		1		—		13,522
Leases	2,431		6		—		1		2,438		2,498		37		—		2		2,537
Total commercial loans and leases	65,834		104		34		60		66,032		57,358		83		28		69		57,538
Residential mortgages	18,586		25		16		94		18,721		18,947		35		17		84		19,083
Home equity	12,681		92		34		185		12,992		12,834		91		40		189		13,154
Automobile	11,856		206		72		23		12,157		11,788		227		81		24		12,120
Education	10,835		24		13		15		10,887		10,290		30		15		12		10,347
Other retail	6,622		46		29		42		6,739		6,729		45		31		41		6,846
Total retail loans	60,580		393		164		359		61,496		60,588		428		184		350		61,550
Total		$126,414		$497		$198		$419		$127,528		$117,946		$511		$212		$419		$119,088

The Company estimates expected credit losses based on the fair value of collateral for collateralized loans that management believes will not be paid under the terms of the original loan contract. These loans are considered to be collateral dependent, and the estimated credit loss is calculated as the difference between the loan’s amortized cost basis and the fair value of the collateral as of each evaluation date.

Collateral values for residential mortgage and home equity loans are based on refreshed valuations which are updated at least every 90 days less estimated costs to sell. At March 31, 2020 and December 31, 2019, the Company had collateral-dependent residential mortgage and home equity loans totaling $271 million and $227 million, respectively.

For collateral-dependent commercial loans, the ACL is individually assessed based on the fair value of the collateral. Various types of collateral are used, including real estate, inventory, equipment, accounts receivable, securities and cash, among others. For commercial real estate loans, collateral values are generally based on

appraisals which are updated based on management judgment under the specific circumstances on a case-by-case basis. At March 31, 2020 and December 31, 2019, the Company had collateral-dependent commercial loans totaling $155 million and $85 million, respectively.

The amortized cost basis of mortgage loans collateralized by residential real estate property for which formal foreclosure proceedings were in process was $144 million and $152 million as of March 31, 2020 and December 31, 2019, respectively.

Troubled Debt Restructurings

TDR is the classification given to a loan that has been restructured in a manner that grants a concession to a borrower experiencing financial hardship that the Company would not otherwise make. The CARES Act and bank regulatory agencies issued guidance during the first quarter of 2020 stating certain loan modifications to borrowers experiencing financial distress as a result of COVID-19 may not be accounted for as TDRs under U.S. GAAP. For COVID-19 related loan modifications which occurred from March 1, 2020 through March 31,2020, and met the loan modification criteria under either the CARES Act or the guidance issued by the bank regulatory agencies, Citizens elected to suspend TDR accounting for such loan modifications; therefore, while not material, modified loans that met the required guidelines for relief are not considered TDRs and are excluded from the disclosures below. The following table summarizes TDRs by class and total unfunded commitments:

(in millions)	March 31, 2020		December 31, 2019
Commercial		$283		$297
Retail	664		667
Unfunded commitments related to TDRs	30		42

The following tables below summarize how loans were modified during the three months ended March 31, 2020 and 2019. The reported balances represent the post-modification outstanding amortized cost basis 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.

	Three Months Ended March 31, 2020
	Primary Modification Types
	Interest Rate Reduction(1)			Maturity Extension(2)			Other(3)
(dollars in millions)	Number of Contracts	Amortized Cost		Number of Contracts	Amortized Cost		Number of Contracts	Amortized Cost
Commercial	—		$—	2		$—	17		$41
Commercial real estate	—	—		—	—		—	—
Total commercial loans	—	—		2	—		17	41
Residential mortgages	38	6		37	7		21	4
Home equity	46	4		6	—		71	4
Automobile	47	1		—	—		183	2
Education	—	—		—	—		91	2
Other retail	861	4		—	—		112	1
Total retail loans	992	15		43	7		478	13
Total	992		$15	45		$7	495		$54

	Three Months Ended March 31, 2019
	Primary Modification Types
	Interest Rate Reduction(1)			Maturity Extension(2)			Other(3)
(dollars in millions)	Number of Contracts	Amortized Cost		Number of Contracts	Amortized Cost		Number of Contracts	Amortized Cost
Commercial	—		$—	5		$1	12		$40
Commercial real estate	—	—		—	—		—	—
Total commercial loans	—	—		5	1		12	40
Residential mortgages	4	2		11	2		30	4
Home equity	36	4		35	6		138	9
Automobile	25	—		5	—		289	4
Education	—	—		—	—		67	2
Other retail	616	4		—	—		1	—
Total retail loans	681	10		51	8		525	19
Total	681		$10	56		$9	537		$59

⁽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.

The net change to ALLL resulting from modifications of loans for the three months ended March 31, 2020 and 2019 was $4 million and $2 million, respectively. Charge-offs may also be recorded on TDRs. Citizens recorded $2 million and $1 million for the three months ended March 31, 2020 and 2019, respectively.

A payment default refers to a loan that becomes 90 days or more past due under the modified terms. Loan data includes loans meeting the criteria that were paid off in full, charged off, or sold prior to March 31, 2020 and 2019. There were $13 million of TDRs that defaulted within 12 months of their modification date for commercial loans during the three months ended March 31, 2020 and no TDRs that defaulted within 12 months of modification for commercial loans during the three months ended March 31, 2019. For retail loans, there were $11 million and $9 million of loans which defaulted within 12 months of their restructuring date for the three months ended March 31, 2020 and 2019, respectively.

Concentrations of Credit Risk

Most of the Company’s lending activity is with customers located in the New England, Mid-Atlantic and Midwest regions. Generally, loans are collateralized by assets including real estate, inventory, accounts receivable, other personal property and investment securities. As of March 31, 2020 and December 31, 2019, Citizens had a significant amount of loans collateralized by residential and commercial real estate. There were no significant concentration risks within the commercial loan or retail loan portfolios. Exposure to credit losses arising from lending transactions may fluctuate with fair values of collateral supporting loans, which may not perform according to contractual agreements. The Company’s policy is to collateralize loans to the extent necessary; however, unsecured loans are also granted on the basis of the financial strength of the applicant and the facts surrounding the transaction.

Certain loan products, including residential mortgages, home equity loans and lines of credit, and credit cards, have contractual features that may increase credit exposure to the Company in the event of an increase in interest rates or a decline in housing values. These products include loans that exceed 90% of the value of the underlying collateral (high LTV loans), interest-only and negative amortization residential mortgages, and loans with low introductory rates. The following tables present balances of loans with these characteristics:

	March 31, 2020
(in millions)	Residential Mortgages		Home Equity		Other Retail		Total
High loan-to-value		$412		$131		$—		$543
Interest-only/negative amortization	2,126		—		—		2,126
Low introductory rate	—		—		245		245
Total		$2,538		$131		$245		$2,914

	December 31, 2019
(in millions)	Residential Mortgages		Home Equity		Other Retail		Total
High loan-to-value		$402		$151		$—		$553
Interest-only/negative amortization	2,043		—		—		2,043
Low introductory rate	—		—		235		235
Total		$2,445		$151		$235		$2,831