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VARIABLE INTEREST ENTITIES (Tables)

3 Months Ended

Mar. 31, 2025

Equity Method Investments and Joint Ventures [Abstract]

The following table summarizes the carrying amount of assets and liabilities for the Company’s consolidated VIEs:


(dollars in millions)	March 31, 2025	December 31, 2024
Assets:

Interest-bearing deposits in banks	$197	$209
Net loans and leases	3,313	3,843

Other assets	21	21
Total assets	$3,531	$4,073
Liabilities:
Long-term borrowed funds	$2,885	$3,375
Other liabilities	7	8
Total liabilities	$2,892	$3,383

A summary of these investments is presented below:


(dollars in millions)	March 31, 2025	December 31, 2024
Lending to special purpose entities included in loans and leases	$4,221	$4,215
LIHTC investments included in other assets	2,685	2,631
LIHTC unfunded commitments included in other liabilities	1,142	1,109
Asset-backed investments included in HTM securities	392	412
Renewable energy investments included in other assets	256	269
NMTC investments included in other assets	2	2

Schedule of proportionally amortized tax credit investments

The following table summarizes the impact to the Consolidated Statements of Operations relative to the Company’s tax credit programs for which it has elected to apply the proportional amortization method of accounting:


	Three Months Ended March 31,
(dollars in millions)	2025	2024
Tax credits recognized	$106	$97
Other tax benefits recognized	23	23
Amortization	(102)	(99)
Net benefit (expense) included in income tax expense	27	21
Other income	2	1
Allocated income (loss) on investments	(3)	(3)
Net benefit (expense) included in noninterest income	(1)	(2)
Net benefit (expense) included in the Consolidated Statements of Operations(1)	$26	$19

(1) Includes the impact of tax credit investments when the election to apply the proportional amortization method was in effect during the periods presented. For 2025 and 2024, this includes LIHTC, renewable energy and NMTC investments.

- Definition

Tabular disclosure of the significant judgments and assumptions made in determining whether a variable interest (as defined) held by the entity requires the variable interest entity (VIE) (as defined) to be consolidated and (or) disclose information about its involvement with the VIE, individually or in aggregate (as applicable); the nature of restrictions, if any, on the consolidated VIE's assets and on the settlement of its liabilities reported by an entity in its statement of financial position, including the carrying amounts of such assets and liabilities; the nature of, and changes in, the risks associated with involvement in the VIE; how involvement with the VIE affects the entity's financial position, financial performance, and cash flows; the lack of recourse if creditors (or beneficial interest holders) of the consolidated VIE have no recourse to the general credit of the primary beneficiary (if applicable); the terms of arrangements, giving consideration to both explicit arrangements and implicit variable interests, if any, that could require the entity to provide financial support to the VIE, including events or circumstances that could expose the entity to a loss; the methodology used by the entity for determining whether or not it is the primary beneficiary of the variable interest entity; the significant factors considered and judgments made in determining that the power to direct the activities of a VIE that most significantly impact the VIE's economic performance are shared (as defined); the carrying amounts and classification of assets and liabilities of the VIE included in the statement of financial position; the entity's maximum exposure to loss, if any, as a result of its involvement with the VIE, including how the maximum exposure is determined and significant sources of the entity's exposure to the VIE; a comparison of the carrying amounts of the assets and liabilities and the entity's maximum exposure to loss; information about any liquidity arrangements, guarantees, and (or) other commitments by third parties that may affect the fair value or risk of the entity's variable interest in the VIE; whether or not the entity has provided financial support or other support (explicitly or implicitly) to the VIE that it was not previously contractually required to provide or whether the entity intends to provide that support, including the type and amount of the support and the primary reasons for providing the support; and supplemental information the entity determines necessary to provide.

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