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Asset Quality
3 Months Ended
Mar. 31, 2022
Credit Loss [Abstract]  
Asset Quality
4. Asset Quality

ALLL

We estimate the appropriate level of the ALLL on at least a quarterly basis. The methodology is described in Note 1 ("Summary of Significant Accounting Policies") under the heading "Allowance for Loan and Lease Losses" beginning on page 109 of our 2021 Form 10-K.

The ALLL at March 31, 2022, represents our current estimate of lifetime credit losses inherent in the loan portfolio at that date. The changes in the ALLL by loan category for the periods indicated are as follows:

Three months ended March 31, 2022:
Dollars in millionsDecember 31, 2021ProvisionCharge-offsRecoveriesMarch 31, 2022
Commercial and Industrial $445 $63 $(30)$11 $489 
Commercial real estate:
Real estate — commercial mortgage182 (7)(4)1 172 
Real estate — construction29 (4)  25 
Total commercial real estate loans211 (11)(4)1 197 
Commercial lease financing32 1 (2) 31 
Total commercial loans688 53 (36)12 717 
Real estate — residential mortgage95 12 1  108 
Home equity loans110 (6)(1)1 104 
Consumer direct loans105 11 (7)2 111 
Credit cards61 7 (7)2 63 
Consumer indirect loans2  (1)1 2 
Total consumer loans373 24 (15)6 388 
Total ALLL — continuing operations1,061 77 
(a)
(51)18 1,105 
Discontinued operations28 1 (2) 27 
Total ALLL — including discontinued operations$1,089 $78 $(53)$18 $1,132 
(a)Excludes a provision for losses on lending-related commitments of $6 million.

Three months ended March 31, 2021:
Dollars in millionsDecember 31, 2020ProvisionCharge-offsRecoveriesMarch 31, 2021
Commercial and Industrial $678 $(17)$(73)$$596 
Commercial real estate:
Real estate — commercial mortgage327 (37)(35)256 
Real estate — construction47 (2)— — 45 
Total commercial real estate loans374 (39)(35)301 
Commercial lease financing47 (4)(4)40 
Total commercial loans1,099 (60)(112)10 937 
Real estate — residential mortgage102 (3)— 100 
Home equity loans171 (13)(2)157 
Consumer direct loans128 (8)126 
Credit cards87 (3)(6)80 
Consumer indirect loans39 (7)38 
Total consumer loans527 (14)(23)11 501 
Total ALLL — continuing operations1,626 (74)
(a)
(135)21 1,438 
Discontinued operations36 (3)(1)33 
Total ALLL — including discontinued operations$1,662 $(77)$(136)$22 $1,471 
(a)Excludes a credit for losses on lending-related commitments of $19 million.


As described in Note 1 ("Summary of Significant Accounting Policies"), under the heading “Allowance for Loan and Lease Losses” beginning on page 109 of our 2021 Form 10-K, we estimate the ALLL using relevant available information, from internal and external sources, relating to past events, current conditions, and reasonable and supportable forecasts. In our estimation of expected credit losses, we use a two year reasonable and supportable period across all products. Following this two year period in which supportable forecasts can be generated, for all modeled loan portfolios, we revert expected credit losses to a level that is consistent with our historical information by reverting the macroeconomic variables (model inputs) to their long run average. We revert to historical loss rates for less complex estimation methods for smaller portfolios. A 20 year fixed length look back period is used to calculate the long run average of the macroeconomic variables. A four quarter reversion period is used where the macroeconomic variables linearly revert to their long run average following the two year reasonable and supportable period.
We develop our reasonable and supportable forecasts using relevant data including, but not limited to, changes in economic output, unemployment rates, property values, and other factors associated with the credit losses on financial assets. Some macroeconomic variables apply to all portfolio segments, while others are more portfolio specific. The following table discloses key macroeconomic variables for each loan portfolio.
SegmentPortfolio
Key Macroeconomic Variables (a)
CommercialCommercial and industrialBBB corporate bond rate (spread), GDP, industrial production, and unemployment rate
Commercial real estateBBB corporate bond rate (spread), property and real estate price indices, and unemployment rate
Commercial lease financingBBB corporate bond rate (spread), GDP, and unemployment rate
ConsumerReal estate — residential mortgageGDP, home price index, unemployment rate, and 30 year mortgage rate
Home equityHome price index, unemployment rate, and 30 year mortgage rate
Consumer directUnemployment rate and U.S. household income
Consumer indirectNew vehicle sales, used vehicle prices, and unemployment rate
Credit cardsUnemployment rate and U.S. household income
Discontinued operationsUnemployment rate
(a)Variables include all transformations and interactions with other risk drivers. Additionally, variables may have varying impacts at different points in the economic cycle.

In addition to macroeconomic drivers, portfolio attributes such as remaining term, outstanding balance, risk ratings, utilization, FICO, LTV, and delinquency also drive ALLL changes. Our ALLL models were designed to capture the correlation between economic and portfolio changes. As such, evaluating shifts in individual portfolio attributes and macroeconomic variables in isolation may not be indicative of past or future performance.

Economic Outlook

As of March 31, 2022, economic growth is expected to be healthy, but the Russian-Ukrainian conflict has provided additional stress on global supply chains, adding uncertainty to the outlook and stress to existing inflationary pressures. Inflation in the United States is at high levels; monetary policy is projected to become more restrictive, which is expected to reduce inflation throughout the remainder of 2022. Employment levels continue to be very strong, with unemployment rates expected to remain at relatively low levels. We utilized the Moody’s February 2022 Consensus forecast as our baseline forecast to estimate our expected credit losses as of March 31, 2022. We determined such forecast to be a reasonable view of the outlook for the economy given all available information at quarter end.

The baseline scenario continues to reflect moderate economic growth over the next two years in markets in which we operate. U.S. GDP continues to grow, albeit at a slower pace, at a 0.5% annualized rate in the first quarter of 2022 and at an annual rate of approximately 4% and 3% for 2022 and 2023, respectively. The national unemployment rate forecast is 3.9% in the first quarter of 2022, and is expected to decline to 3.6% by the fourth quarter of 2022 and continue at that level through the fourth quarter of 2023.

We recognize the baseline forecast may not fully capture the increased economic uncertainty emerging as of quarter-end, specifically due to the Russia/Ukraine conflict and monetary policy pressures. These considerations were addressed through qualitative adjustments.

As a result of the current economic uncertainty, our future loss estimates may vary considerably from our March 31, 2022, assumptions.

Commercial Loan Portfolio

The ALLL from continuing operations for the commercial segment increased by $29 million, or 4.2%, from December 31, 2021. The overall increase in the allowance is driven by loan growth, and economic uncertainties (geopolitical and monetary policy), offset by reductions in COVID-related reserves.

The primary changes to the outlook are due to Russia/Ukraine crisis, as well as the associated risk around the global supply chain and inflation. Improvements in real estate price indices led to a reduction in reserve for our commercial real estate portfolio.

As of March 31, 2022, there was an immaterial ALLL associated with $886 million of outstanding PPP loans. This ALLL relates to a small number of loans denied by the SBA for forgiveness.
Consumer Loan Portfolio

The ALLL from continuing operations for the consumer segment increased by $15 million, or 4.0%, from December 31, 2021. The overall increase in the allowance is driven by higher uncertainty in the economic outlook, in addition to loan growth.

The most meaningful changes in the economic outlook contributing to the increase in reserves are the ongoing conflict in Ukraine and US inflationary/monetary policy pressures. The potential incremental risk associated with these economic factors is largely considered through qualitative reserve adjustments. As it relates to the changes in the ALLL due to portfolio factors, shifts are largely driven by targeted growth in the consumer real estate and Laurel Road student lending portfolios.

Credit Risk Profile

The prevalent risk characteristic for both commercial and consumer loans is the risk of loss arising from an obligor’s inability or failure to meet contractual payment or performance terms. Evaluation of this risk is stratified and monitored by the loan risk rating grades assigned for the commercial loan portfolios and the refreshed FICO score assigned for the consumer loan portfolios. The internal risk grades assigned to loans follow our definitions of Pass and Criticized, which are consistent with published definitions of regulatory risk classifications. Loans with a pass rating represent those loans not classified on our rating scale for problem credits, as minimal credit risk has been identified. Criticized loans are those loans that either have a potential weakness deserving management's close attention or have a well-defined weakness that may put full collection of contractual cash flows at risk. Borrower FICO scores provide information about the credit quality of our consumer loan portfolio as they provide an indication as to the likelihood that a debtor will repay its debts. The scores are obtained from a nationally recognized consumer rating agency and are presented in the tables below at the dates indicated.

Most extensions of credit are subject to loan grading or scoring. Loan grades are assigned at the time of origination, verified by credit risk management, and periodically re-evaluated thereafter. This risk rating methodology blends our judgment with quantitative modeling. Commercial loans generally are assigned two internal risk ratings. The first rating reflects the probability that the borrower will default on an obligation; the second rating reflects expected recovery rates on the credit facility. Default probability is determined based on, among other factors, the financial strength of the borrower, an assessment of the borrower’s management, the borrower’s competitive position within its industry sector, and our view of industry risk in the context of the general economic outlook. Types of exposure, transaction structure, and collateral, including credit risk mitigants, affect the expected recovery assessment.
Commercial Credit Exposure
Credit Risk Profile by Creditworthiness Category and Vintage (a)
As of March 31, 2022Term LoansRevolving Loans Amortized Cost BasisRevolving Loans Converted to Term Loans Amortized Cost Basis
Amortized Cost Basis by Origination Year and Internal Risk Rating
Dollars in millions20222021202020192018PriorTotal
Commercial and Industrial
Risk Rating:
Pass$1,952 $11,488 $4,372 $3,497 $2,515 $4,511 $22,623 $117 $51,075 
Criticized (Accruing)— 34 111 116 173 294 803 23 1,554 
Criticized (Nonaccruing)— 15 31 126 186 
Total commercial and industrial1,952 11,523 4,486 3,628 2,697 4,836 23,552 141 52,815 
Real estate — commercial mortgage
Risk Rating:
Pass1,474 4,805 1,153 2,045 994 3,185 850 59 14,565 
Criticized (Accruing)— 18 20 87 71 290 33 — 519 
Criticized (Nonaccruing)— — 29 40 
Total real estate — commercial mortgage
1,474 4,823 1,174 2,133 1,070 3,504 886 60 15,124 
Real estate — construction
Risk Rating:
Pass144 472 602 476 209 112 2,019 
Criticized (Accruing)— — 31 — — 46 
Criticized (Nonaccruing)— — — — — — — — — 
Total real estate — construction144 472 606 483 240 116 2,065 
Commercial lease financing
Risk Rating:
Pass159 985 693 619 262 1,131 — — 3,849 
Criticized (Accruing)— — 11 23 15 15 — — 64 
Criticized (Nonaccruing)— — — — — 
Total commercial lease financing159 985 704 643 278 1,147 — 3,916 
Total commercial loans$3,729 $17,803 $6,970 $6,887 $4,285 $9,603 $24,439 $204 $73,920 

As of December 31, 2021Term LoansRevolving Loans Amortized Cost BasisRevolving Loans Converted to Term Loans Amortized Cost Basis
Amortized Cost Basis by Origination Year and Internal Risk Rating
Dollars in millions20212020201920182017PriorTotal
Commercial and Industrial
Risk Rating:
Pass$11,675 $4,941 $4,040 $2,771 $1,777 $3,108 $20,406 $72 $48,790 
Criticized (Accruing)64 71 115 175 200 121 784 14 1,544 
Criticized (Nonaccruing)21 10 19 15 122 191 
Total commercial and industrial11,740 5,013 4,176 2,956 1,996 3,244 21,312 88 50,525 
Real estate — commercial mortgage
Risk Rating:
Pass4,923 1,197 2,137 1,168 612 2,787 803 53 13,680 
Criticized (Accruing)15 22 70 62 109 206 35 520 
Criticized (Nonaccruing)— — 31 — 44 
Total real estate — commercial mortgage
4,938 1,220 2,208 1,235 721 3,024 844 54 14,244 
Real estate — construction
Risk Rating:
Pass495 565 530 223 92 32 — 1,939 
Criticized (Accruing)— 43 — — 57 
Criticized (Nonaccruing)— — — — — — — — — 
Total real estate — construction495 569 535 266 96 32 — 1,996 
Commercial lease financing
Risk Rating:
Pass1,039 748 675 301 309 927 — — 3,999 
Criticized (Accruing)— 29 13 13 — — 68 
Criticized (Nonaccruing)— — — — 
Total commercial lease financing1,039 754 705 315 323 935 — — 4,071 
Total commercial loans$18,212 $7,556 $7,624 $4,772 $3,136 $7,235 $22,159 $142 $70,836 
(a)Accrued interest of $117 million and $113 million as of March 31, 2022, and December 31, 2021, respectively, presented in Other Assets on the Consolidated Balance Sheets, was excluded from the amortized cost basis disclosed in these tables.
Consumer Credit Exposure
Credit Risk Profile by FICO Score and Vintage (a)
As of March 31, 2022Term LoansRevolving Loans Amortized Cost BasisRevolving Loans Converted to Term Loans Amortized Cost Basis
Amortized Cost Basis by Origination Year and FICO Score
Dollars in millions20222021202020192018PriorTotal
Real estate — residential mortgage
FICO Score:
750 and above$1,351 $8,320 $2,802 $705 $74 $1,135 $— $— $14,387 
660 to 749437 1,235 299 140 32 302 — — 2,445 
Less than 66012 35 16 18 16 149 — — 246 
No Score50 19 — 31 — 103 
Total real estate — residential mortgage1,850 9,609 3,117 864 123 1,617 — 17,181 
Home equity loans
FICO Score:
750 and above96 1,073 797 233 87 731 2,209 404 5,630 
660 to 74940 356 239 97 39 221 940 135 2,067 
Less than 66029 26 20 12 100 320 44 554 
No Score— — — — — 
Total home equity loans139 1,458 1,064 350 138 1,054 3,472 583 8,258 
Consumer direct loans
FICO Score:
750 and above741 1,706 1,004 456 57 131 105 — 4,200 
660 to 749220 536 262 151 39 50 203 — 1,461 
Less than 66053 32 25 13 55 — 194 
No Score22 57 34 26 14 30 211 — 394 
Total consumer direct loans990 2,352 1,332 658 119 224 574 — 6,249 
Credit cards
FICO Score:
750 and above— — — — — — 467 — 467 
660 to 749— — — — — — 376 — 376 
Less than 660— — — — — — 86 — 86 
No Score— — — — — — — 
Total credit cards— — — — — — 930 — 930 
Consumer indirect loans
FICO Score:
750 and above— — — — 28 — — 31 
660 to 749— — — — — 21 — — 21 
Less than 660— — — — — 10 — — 10 
No Score— — — — — — — — — 
Total consumer indirect loans— — — — 59 — — 62 
Total consumer loans$2,979 $13,422 $5,513 $1,872 $380 $2,954 $4,977 $583 $32,680 
As of December 31, 2021Term LoansRevolving Loans Amortized Cost BasisRevolving Loans Converted to Term Loans Amortized Cost Basis
Amortized Cost Basis by Origination Year and FICO Score
Dollars in millions20212020201920182017PriorTotal
Real estate — residential mortgage
FICO Score:
750 and above$7,906 $2,909 $777 $84 $126 $1,096 $— $— $12,898 
660 to 7491,686 351 169 39 25 308 — — 2,578 
Less than 66026 14 19 16 142 — — 226 
No Score18 — 30 — 54 
Total real estate — residential mortgage9,636 3,274 966 140 163 1,576 — 15,756 
Home equity loans
FICO Score:
750 and above1,051 830 251 96 128 666 2,244 423 5,689 
660 to 749394 263 111 44 40 204 1,004 143 2,203 
Less than 66027 24 20 13 13 92 333 46 568 
No Score— — — — — 
Total home equity loans1,472 1,119 382 153 181 964 3,584 612 8,467 
Consumer direct loans
FICO Score:
750 and above1,799 1,129 517 65 17 129 109 — 3,765 
660 to 749612 295 174 46 10 45 212 — 1,394 
Less than 66045 33 27 11 12 60 — 191 
No Score68 40 29 17 10 21 218 — 403 
Total consumer direct loans2,524 1,497 747 139 40 207 599 — 5,753 
Credit cards
FICO Score:
750 and above— — — — — — 500 — 500 
660 to 749— — — — — — 387 — 387 
Less than 660— — — — — — 84 — 84 
No Score— — — — — — — 
Total credit cards— — — — — — 972 — 972 
Consumer indirect loans
FICO Score:
750 and above— — — — 30 — — 35 
660 to 749— — — — — 26 — — 26 
Less than 660— — — — — — — 
No Score— — — — — — — — — 
Total consumer indirect loans— — — — 65 — — 70 
Total consumer loans$13,637 $5,890 $2,095 $432 $384 $2,812 $5,156 $612 $31,018 
(a)Accrued interest of $75 million and $85 million as of March 31, 2022 and December 31, 2021, respectively, presented in Other Assets on the Consolidated Balance Sheets, was excluded from the amortized cost basis disclosed in this table.


Nonperforming and Past Due Loans

Our policies for determining past due loans, placing loans on nonaccrual, applying payments on nonaccrual loans, and resuming accrual of interest for our commercial and consumer loan portfolios are disclosed in Note 1 (“Summary of Significant Accounting Policies”) under the heading “Nonperforming Loans” beginning on page 108 of our 2021 Form 10-K.
The following aging analysis of past due and current loans as of March 31, 2022, and December 31, 2021, provides further information regarding Key’s credit exposure.

Aging Analysis of Loan Portfolio(a)
March 31, 2022Current
30-59
Days Past
Due (b)
60-89
Days Past
Due (b)
90 and
Greater
Days Past
Due (b)
Non-performing
Loans
Total Past
Due and
Non-performing
Loans
Total
Loans (c)
Dollars in millions
LOAN TYPE
Commercial and industrial$52,537 $23 $31 $38 $186 $278 $52,815 
Commercial real estate:
Commercial mortgage15,072 40 52 15,124 
Construction2,064 — — — 2,065 
Total commercial real estate loans17,136 40 53 17,189 
Commercial lease financing3,908 — 3,916 
Total commercial loans$73,581 $32 $37 $41 $229 $339 $73,920 
Real estate — residential mortgage$17,098 $$$$73 $83 $17,181 
Home equity loans8,102 18 129 156 8,258 
Consumer direct loans6,229 20 6,249 
Credit cards914 16 930 
Consumer indirect loans60 — — 62 
Total consumer loans$32,403 $38 $15 $14 $210 $277 $32,680 
Total loans$105,984 $70 $52 $55 $439 $616 $106,600 
(a)Amounts in table represent amortized cost and exclude loans held for sale.
(b)Accrued interest of $193 million presented in Other Assets on the Consolidated Balance Sheets is excluded from the amortized cost basis disclosed in this table.
(c)Net of unearned income, net of deferred fees and costs, and unamortized discounts and premiums.

December 31, 2021Current
30-59
Days Past
Due (b)
60-89
Days Past
Due (b)
90 and
Greater
Days Past
Due (b)
Non-performing
Loans
Total Past
Due and
Non-performing
Loans
Total
Loans (c)
Dollars in millions
LOAN TYPE
Commercial and industrial$50,226 $19 $49 $40 $191 $299 $50,525 
Commercial real estate:
Commercial mortgage14,174 10 44 70 14,244 
Construction1,978 — 17 — 18 1,996 
Total commercial real estate loans16,152 10 26 44 88 16,240 
Commercial lease financing4,061 — — 10 4,071 
Total commercial loans$70,439 $35 $75 $48 $239 $397 $70,836 
Real estate — residential mortgage$15,669 $$$$72 $87 $15,756 
Home equity loans8,299 21 135 168 8,467 
Consumer direct loans5,736 17 5,753 
Credit cards956 16 972 
Consumer indirect loans68 — — 70 
Total consumer loans$30,728 $41 $14 $20 $215 $290 $31,018 
Total loans$101,167 $76 $89 $68 $454 $687 $101,854 

(a)Amounts in table represent amortized cost and exclude loans held for sale.
(b)Accrued interest of $198 million presented in Other Assets on the Consolidated Balance Sheets is excluded from the amortized cost basis disclosed in this table.
(c)Net of unearned income, net of deferred fees and costs, and unamortized discounts and premiums.


At March 31, 2022, the approximate carrying amount of our commercial nonperforming loans outstanding represented 62% of their original contractual amount owed, total nonperforming loans outstanding represented 73% of their original contractual amount owed, and nonperforming assets in total were carried at 81% of their original contractual amount owed.

Nonperforming loans reduced expected interest income by $5 million for the three months ended March 31, 2022, and $7 million for the three months ended March 31, 2021.

The amortized cost basis of nonperforming loans on nonaccrual status for which there is no related allowance for credit losses was $301 million at March 31, 2022.
Collateral-dependent Financial Assets

We classify financial assets as collateral-dependent when our borrower is experiencing financial difficulty, and we expect repayment to be provided substantially through the operation or sale of the collateral. Our commercial loans have collateral that includes cash, accounts receivable, inventory, commercial machinery, commercial properties, commercial real estate construction projects, enterprise value, and stock or ownership interests in the borrowing entity. When appropriate we also consider the enterprise value of the borrower as a repayment source for collateral-dependent loans. Our consumer loans have collateral that includes residential real estate, automobiles, boats, and RVs.

There were no significant changes in the extent to which collateral secures our collateral-dependent financial assets during the three months ended March 31, 2022.

TDRs

We classify loan modifications as TDRs when a borrower is experiencing financial difficulties and we have granted a concession without commensurate financial, structural, or legal consideration. Our loan modifications are handled on a case-by-case basis and are negotiated to achieve mutually agreeable terms that maximize loan collectability and meet the borrower’s financial needs.

Commitments outstanding to lend additional funds to borrowers whose loan terms have been modified in TDRs were $1 million and $15 million at March 31, 2022, and December 31, 2021, respectively.

The consumer TDR other concession category in the table below primarily includes those borrowers’ debts that are discharged through Chapter 7 bankruptcy and have not been formally re-affirmed. At March 31, 2022, and December 31, 2021, the recorded investment of consumer residential mortgage loans in the process of foreclosure was approximately $126 million and $104 million, respectively.

The following table shows the post-modification outstanding recorded investment by concession type for our commercial and consumer accruing and nonaccruing TDRs that occurred during the periods indicated:
Three Months Ended March 31,
Dollars in millions20222021
Commercial loans:
Extension of Maturity Date$— $41 
Payment or Covenant Modification/Deferment10 
Bankruptcy Plan Modification— — 
Increase in new commitment or new money— — 
Total$$51 
Consumer loans:
Interest rate reduction$$
Other
Total$10 $
Total TDRs$11 $57 

The following table summarizes the change in the post-modification outstanding recorded investment of our accruing and nonaccruing TDRs during the periods indicated:
Three Months Ended March 31,
Dollars in millions20222021
Balance at beginning of the period$220 $363 
Additions11 59 
Payments(12)(21)
Charge-offs (25)
Balance at end of period$219 $376 
A further breakdown of TDRs included in nonperforming loans by loan category for the periods indicated are as follows:
March 31, 2022December 31, 2021
Number of
Loans
Pre-modification
Outstanding
Recorded
Investment
Post-modification
Outstanding
Recorded
Investment
Number of
Loans
Pre-modification
Outstanding
Recorded
Investment
Post-modification
Outstanding
Recorded
Investment
Dollars in millions
LOAN TYPE
Nonperforming:
Commercial and industrial37 $25 $14 36 $30 $14 
Commercial real estate:
Commercial mortgage50 23 50 25 
Total commercial real estate loans50 23 50 25 
Total commercial loans41 75 37 39 80 39 
Real estate — residential mortgage223 27 25 220 26 24 
Home equity loans514 35 31 531 36 31 
Consumer direct loans208 207 
Credit cards332 360 
Consumer indirect loans22 23 
Total consumer loans1,299 68 61 1,341 68 60 
Total nonperforming TDRs1,340 143 98 1,380 148 99 
Prior-year accruing:(a)
Commercial and industrial13 — — 11 — — 
Commercial real estate
Commercial mortgage— — — — 
Total commercial real estate loans— — — — 
Total commercial loans14 — — 12 — — 
Real estate — residential mortgage463 41 35 455 39 33 
Home equity loans1,615 97 75 1,628 97 75 
Consumer direct loans226 236 
Credit cards599 579 
Consumer indirect loans128 14 139 15 
Total consumer loans3,031 160 122 3,037 160 121 
Total prior-year accruing TDRs3,045 160 121 3,049 160 121 
Total TDRs4,385 $303 $219 4,429 $308 $220 
(a)All TDRs that were restructured prior to January 1, 2022, and January 1, 2021, are fully accruing.

Commercial loan TDRs are considered defaulted when principal and interest payments are 90 days past due. Consumer loan TDRs are considered defaulted when principal and interest payments are more than 60 days past due. During the three months ended March 31, 2022, there were four commercial loan TDRs and 38 consumer loan TDRs with a combined recorded investment of $8 million that experienced payment defaults after modifications resulting in TDR status during 2021. During the three months ended March 31, 2021, there were two commercial loan TDRs and 36 consumer loan TDRs with a combined recorded investment of $1 million that experienced payment defaults after modifications resulting in TDR status during 2020.

Liability for Credit Losses on Off Balance Sheet Exposures

The liability for credit losses inherent in unfunded lending-related commitments, such as letters of credit and unfunded loan commitments, and certain financial guarantees is included in “accrued expense and other liabilities” on the balance sheet.

Changes in the liability for credit losses on off balance sheet exposures are summarized as follows:
 Three months ended March 31,
Dollars in millions20222021
Balance at beginning of period$160 $197 
Provision (credit) for losses on off balance sheet exposures6 (19)
Balance at end of period$166 $178