COMMITMENTS AND CONTINGENCIES (Tables)

9 Months Ended

Sep. 30, 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)	September 30, 2020		December 31, 2019
Commitments to extend credit		$73,173		$72,743
Letters of credit	2,132		2,190
Risk participation agreements	103		37
Loans sold with recourse	48		37
Marketing rights	29		33
Total		$75,485		$75,040