COMMITMENTS AND CONTINGENCIES (Tables)

3 Months Ended

Mar. 31, 2020

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 2019 Form 10-K.

(in millions)	March 31, 2020		December 31, 2019
Commitments to extend credit		$64,827		$72,743
Letters of credit	2,064		2,190
Risk participation agreements	106		37
Loans sold with recourse	49		37
Marketing rights	31		33
Total		$67,077		$75,040