4. Asset Quality

We assess the credit quality of the loan portfolio by monitoring net credit losses, levels of nonperforming assets and delinquencies, and credit quality ratings as defined by management.

Our nonperforming assets and past due loans were as follows:


in millions	March 31, 2014		December 31, 2013		March 31, 2013
Total nonperforming loans ^(a)	$	449	$	508	$	650
Nonperforming loans held for sale		1		1		23
OREO		12		15		21
Other nonperforming assets		7		7		11

Total nonperforming assets	$	469	$	531	$	705

Nonperforming assets from discontinued operations — education lending^(b)	$	20	$	25	$	15

Restructured loans included in nonperforming loans	$	178	$	214	$	178
Restructured loans with an allocated specific allowance ^(c)		51		71		52
Specifically allocated allowance for restructured loans ^(d)		32		35		30
Accruing loans past due 90 days or more	$	89	$	71	$	83
Accruing loans past due 30 through 89 days		267		318		368

(a)	March 31, 2014, December 31, 2013, and March 31, 2013, loan balances exclude $16 million, $16 million, and $22 million of PCI loans, respectively.

(b)	Includes restructured loans of approximately $15 million, $13 million, and $4 million at March 31, 2014, December 31, 2013, and March 31, 2013, respectively. See Note 11 (“Acquisitions and Discontinued Operations”) for further discussion.

(c)	Included in individually impaired loans allocated a specific allowance.

(d)	Included in allowance for individually evaluated impaired loans.

We evaluate purchased loans for impairment in accordance with the applicable accounting guidance. Purchased loans that have evidence of deterioration in credit quality since origination and for which it is probable, at acquisition, that all contractually required payments will not be collected are deemed PCI and initially recorded at fair value without recording an allowance for loan losses. At the date of acquisition, the estimated gross contractual amount receivable of all PCI loans totaled $41 million. The estimated cash flows not expected to be collected (the nonaccretable amount) were $11 million, and the accretable amount was approximately $5 million. The difference between the fair value and the cash flows expected to be collected from the purchased loans is accreted to interest income over the remaining term of the loans.

At March 31, 2014, the outstanding unpaid principal balance and carrying value of all PCI loans was $23 million and $16 million, respectively. Changes in the accretable yield during the first quarter of 2014 included accretion and net reclassifications of less than $1 million, resulting in an ending balance of $5 million at March 31, 2014.

At March 31, 2014, the approximate carrying amount of our commercial nonperforming loans outstanding represented 53% of their original contractual amount, total nonperforming loans outstanding represented 70% of their original contractual amount owed, and nonperforming assets in total were carried at 68% of their original contractual amount.

At March 31, 2014, our twenty largest nonperforming loans totaled $75 million, representing 17% of total loans on nonperforming status. At March 31, 2013, the twenty largest nonperforming loans totaled $194 million, representing 30% of total loans on nonperforming status.

Nonperforming loans and loans held for sale reduced expected interest income by $4 million for the three months ended March 31, 2014, and $23 million for the year ended December 31, 2013.

The following tables set forth a further breakdown of individually impaired loans as of March 31, 2014, December 31, 2013, and March 31, 2013:


			Unpaid				Average
March 31, 2014	Recorded		Principal		Specific		Recorded
in millions	Investment ^(a)		Balance ^(b)		Allowance		Investment
With no related allowance recorded:
Commercial, financial and agricultural	$	33	$	60		—	$	33
Commercial real estate:
Commercial mortgage		23		28		—		22
Construction		7		17		—		27

Total commercial real estate loans		30		45		—		49

Total commercial loans		63		105		—		82

Real estate — residential mortgage		26		26		—		26

Home equity:
Key Community Bank		70		70		—		69
Other		2		2		—		2

Total home equity loans		72		72		—		71
Consumer other:
Marine		2		2		—		3

Total consumer other		2		2		—		3

Total consumer loans		100		100		—		100

Total loans with no related allowance recorded		163		205		—		182

With an allowance recorded:
Commercial, financial and agricultural		7		10	$	2		12
Commercial real estate:
Commercial mortgage		2		2		1		4
Construction		—		—		—		1

Total commercial real estate loans		2		2		1		5

Total commercial loans		9		12		3		17


Real estate — residential mortgage		28		28		5		28

Home equity:
Key Community Bank		36		36		16		36
Other		11		11		2		11

Total home equity loans		47		47		18		47

Consumer other — Key Community Bank		3		3		—		3
Credit cards		4		4		1		4
Consumer other:
Marine		49		49		7		49
Other		1		1		—		1

Total consumer other		50		50		7		50

Total consumer loans		132		132		31		132

Total loans with an allowance recorded		141		144		34		149

Total	$	304	$	349	$	34	$	331

(a)	The Recorded Investment represents the face amount of the loan increased or decreased by applicable accrued interest, net deferred loan fees and costs, and unamortized premium or discount, and reflects direct charge-offs. This amount is a component of total loans on our consolidated balance sheet.

(b)	The Unpaid Principal Balance represents the customer’s legal obligation to us.


			Unpaid				Average
December 31, 2013	Recorded		Principal		Specific		Recorded
in millions	Investment ^(a)		Balance ^(b)		Allowance		Investment
With no related allowance recorded:
Commercial, financial and agricultural	$	33	$	69		—	$	33
Commercial real estate:
Commercial mortgage		21		25		—		55
Construction		48		131		—		48

Total commercial real estate loans		69		156		—		103

Total commercial loans		102		225		—		136

Real estate — residential mortgage		27		27		—		24

Home equity:
Key Community Bank		67		67		—		66
Other		2		2		—		2

Total home equity loans		69		69		—		68

Consumer other:
Marine		3		3		—		2

Total consumer other		3		3		—		2

Total consumer loans		99		99		—		94

Total loans with no related allowance recorded		201		324		—		230

With an allowance recorded:
Commercial, financial and agricultural		17		20	$	8		25
Commercial real estate:
Commercial mortgage		6		6		2		7
Construction		2		12		—		1

Total commercial real estate loans		8		18		2		8

Total commercial loans		25		38		10		33


Real estate — residential mortgage		29		29		9		23

Home equity:
Key Community Bank		35		35		10		29
Other		10		11		1		9

Total home equity loans		45		46		11		38

Consumer other — Key Community Bank		3		3		1		2
Credit cards		5		5		1		3
Consumer other:
Marine		49		49		10		55
Other		1		1		—		1

Total consumer other		50		50		10		56

Total consumer loans		132		133		32		122

Total loans with an allowance recorded		157		171		42		155

Total	$	358	$	495	$	42	$	385

(a)	The Recorded Investment represents the face amount of the loan increased or decreased by applicable accrued interest, net deferred loan fees and costs, and unamortized premium or discount, and reflects direct charge-offs. This amount is a component of total loans on our consolidated balance sheet.

(b)	The Unpaid Principal Balance represents the customer’s legal obligation to us.


			Unpaid				Average
March 31, 2013	Recorded		Principal		Specific		Recorded
in millions	Investment ^(a)		Balance ^(b)		Allowance		Investment
With no related allowance recorded:
Commercial, financial and agricultural	$	93	$	131		—	$	63
Commercial real estate:
Commercial mortgage		87		140		—		88
Construction		48		175		—		48

Total commercial real estate loans		135		315		—		136

Total commercial loans		228		446		—		199

Real estate — residential mortgage		15		15		—		18

Home equity:
Key Community Bank		64		64		—		65
Other		2		2		—		2

Total home equity loans		66		66		—		67

Consumer other:
Marine		3		3		—		1

Total consumer other		3		3		—		1

Total consumer loans		84		84		—		86

Total loans with no related allowance recorded		312		530		—		285

With an allowance recorded:
Commercial, financial and agricultural		15		23	$	8		24
Commercial real estate:
Commercial mortgage		9		9		3		8
Construction		—		9		—		—

Total commercial real estate loans		9		18		3		8

Total commercial loans		24		41		11		32


Real estate — residential mortgage		18		18		1		18

Home equity:
Key Community Bank		26		25		14		24
Other		10		10		—		10

Total home equity loans		36		35		14		34

Consumer other — Key Community Bank		3		3		1		2
Credit cards		4		4		1		3
Consumer other:
Marine		47		47		5		53
Other		1		1		1		1

Total consumer other		48		48		6		54

Total consumer loans		109		108		23		111

Total loans with an allowance recorded		133		149		34		143

Total	$	445	$	679	$	34	$	428

(a)	The Recorded Investment represents the face amount of the loan increased or decreased by applicable accrued interest, net deferred loan fees and costs, and unamortized premium or discount, and reflects direct charge-offs. This amount is a component of total loans on our consolidated balance sheet.

(b)	The Unpaid Principal Balance represents the customer’s legal obligation to us.

For the three months ended March 31, 2014, and 2013, interest income recognized on the outstanding balances of accruing impaired loans totaled $2 million and $2 million, respectively.

At March 31, 2014, aggregate restructured loans (accrual and nonaccrual loans) totaled $294 million, compared to $338 million at December 31, 2013, and $294 million at March 31, 2013. We added $30 million in restructured loans during the first three months of 2014, which were offset by $74 million in payments and charge-offs.

A further breakdown of TDRs included in nonperforming loans by loan category as of March 31, 2014, follows:


			Pre-modification		Post-modification
			Outstanding		Outstanding
March 31, 2014	Number		Recorded		Recorded
dollars in millions	of loans		Investment		Investment
LOAN TYPE
Nonperforming:
Commercial, financial and agricultural		28	$	58	$	33
Commercial real estate:
Real estate — commercial mortgage		11		40		14
Real estate — construction		5		16		2

Total commercial real estate loans		16		56		16

Total commercial loans		44		114		49
Real estate — residential mortgage		687		42		42
Home equity:
Key Community Bank		1,190		73		69
Other		132		4		4

Total home equity loans		1,322		77		73
Consumer other — Key Community Bank		33		1		1
Credit cards		10		—		—
Consumer other:
Marine		210		14		12
Other		41		1		1

Total consumer other		251		15		13

Total consumer loans		2,303		135		129

Total nonperforming TDRs		2,347		249		178

Prior-year accruing ^(a)
Commercial, financial and agricultural		42		7		4
Commercial real estate:
Real estate — commercial mortgage		4		18		8

Total commercial real estate loans		4		18		8

Total commercial loans		46		25		12
Real estate — residential mortgage		111		12		12
Home equity:
Key Community Bank		708		40		37
Other		312		9		8

Total home equity loans		1,020		49		45
Consumer other — Key Community Bank		51		2		2
Credit cards		785		5		5
Consumer other:
Marine		430		62		39
Other		68		2		1

Total consumer other		498		64		40

Total consumer loans		2,465		132		104

Total prior-year accruing TDRs		2,511		157		116

Total TDRs		4,858	$	406	$	294

(a)	All TDRs that were restructured prior to January 1, 2014, and are fully accruing.

A further breakdown of TDRs included in nonperforming loans by loan category as of December 31, 2013, follows:


			Pre-modification		Post-modification
			Outstanding		Outstanding
December 31, 2013	Number		Recorded		Recorded
dollars in millions	of loans		Investment		Investment
LOAN TYPE
Nonperforming:
Commercial, financial and agricultural		33	$	72	$	34
Commercial real estate:
Real estate — commercial mortgage		11		41		14
Real estate — construction		6		19		4

Total commercial real estate loans		17		60		18

Total commercial loans		50		132		52
Real estate — residential mortgage		676		43		43
Home equity:
Key Community Bank		1,708		91		86
Other		227		6		6

Total home equity loans		1,935		97		92
Consumer other — Key Community Bank		49		2		1
Credit cards		629		5		4
Consumer other:
Marine		360		24		21
Other		50		1		1

Total consumer other		410		25		22

Total consumer loans		3,699		172		162

Total nonperforming TDRs		3,749		304		214

Prior-year accruing ^(a)
Commercial, financial and agricultural		50		7		3
Commercial real estate:
Real estate — commercial mortgage		4		18		10
Real estate — construction		1		23		42

Total commercial real estate loans		5		41		52

Total commercial loans		55		48		55
Real estate — residential mortgage		119		12		12
Home equity:
Key Community Bank		161		17		17
Other		212		7		6

Total home equity loans		373		24		23
Consumer other — Key Community Bank		31		1		1
Credit cards		240		2		1
Consumer other:
Marine		272		51		31
Other		54		1		1

Total consumer other		326		52		32

Total consumer loans		1,089		91		69

Total prior-year accruing TDRs		1,144		139		124

Total TDRs		4,893	$	443	$	338

(a)	All TDRs that were restructured prior to January 1, 2013, and are fully accruing.

A further breakdown of TDRs included in nonperforming loans by loan category as of March 31, 2013, follows:


			Pre-modification		Post- modification
			Outstanding		Outstanding
March 31, 2013	Number		Recorded		Recorded
dollars in millions	of loans		Investment		Investment
LOAN TYPE
Nonperforming:
Commercial, financial and agricultural		48	$	58	$	25
Commercial real estate:
Real estate — commercial mortgage		17		61		23
Real estate — construction		6		30		4

Total commercial real estate loans		23		91		27

Total commercial loans		71		149		52
Real estate — residential mortgage		347		21		21
Home equity:
Key Community Bank		1,479		75		74
Other		229		6		6

Total home equity loans		1,708		81		80
Consumer other — Key Community Bank		59		2		2
Credit cards		360		2		2
Consumer other:
Marine		302		41		20
Other		36		1		1

Total consumer other		338		42		21

Total consumer loans		2,812		148		126

Total nonperforming TDRs		2,883		297		178

Prior-year accruing ^(a)
Commercial, financial and agricultural		106		11		5
Commercial real estate:
Real estate — commercial mortgage		4		22		15
Real estate — construction		1		23		29

Total commercial real estate loans		5		45		44

Total commercial loans		111		56		49
Real estate — residential mortgage		121		12		12
Home equity:
Key Community Bank		147		15		15
Other		190		6		5

Total home equity loans		337		21		20
Consumer other — Key Community Bank		24		1		1
Credit cards		308		2		2
Consumer other:
Marine		263		30		30
Other		57		2		2

Total consumer other		320		32		32

Total consumer loans		1,110		68		67

Total prior-year accruing TDRs		1,221		124		116

Total TDRs		4,104	$	421	$	294

(a)	All TDRs that were restructured prior to January 1, 2013, and are fully accruing.

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. All commercial and consumer loan TDRs, regardless of size, are individually evaluated for impairment to determine the probable loss content and are assigned a specific loan allowance if deemed appropriate. This designation has the effect of moving the loan from the general reserve methodology (i.e., collectively evaluated) to the specific reserve methodology (i.e., individually evaluated) and may impact the ALLL through a charge-off or increased loan loss provision. These components affect the ultimate allowance level. Additional information regarding TDRs for discontinued operations is provided in Note 11 (“Acquisitions and Discontinued Operations”).

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 first three months of 2014, two commercial loan TDRs with a combined recorded investment of $11 million and 157 consumer loan TDRs with a combined recorded investment of $4 million experienced payment defaults from modifications resulting in TDR status during 2013. During the first three months of 2013, there were no significant commercial loan TDRs, and 240 consumer loan TDRs with a combined recorded investment of $14 million that experienced payment defaults from modifications resulting in TDR status during 2012. As TDRs are individually evaluated for impairment under the specific reserve methodology, subsequent defaults do not generally have a significant additional impact on the ALLL.

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. Our concession types are primarily interest rate reductions, forgiveness of principal, and other modifications. The commercial TDR other concession category includes modification of loan terms, covenants, or conditions. The consumer TDR other concession category primarily includes those borrowers that are discharged through Chapter 7 bankruptcy and have not been formally re-affirmed.

The following table shows the concession types for our commercial and consumer accruing and nonaccruing TDRs and other selected financial data.


	March 31,		December 31,		March 31,
in millions	2014		2013		2013
Commercial loans:
Interest rate reduction	$	49	$	95	$	85
Forgiveness of principal		5		5		10
Other		7		7		6

Total	$	61	$	107	$	101


Consumer loans:
Interest rate reduction	$	142	$	130	$	95
Forgiveness of principal		5		5		6
Other		86		96		92

Total	$	233	$	231	$	193


Total commercial and consumer TDRs ^(a)	$	294	$	338	$	294
Total loans		55,445		54,457		52,574

(a)	Commitments outstanding to lend additional funds to borrowers whose loan terms have been modified in TDRs are $2 million, $15 million, and $33 million at March 31, 2014, December 31, 2013, and March 31, 2013, respectively.

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 117 of our 2013 Form 10-K.

At March 31, 2014, approximately $54.6 billion, or 98.5%, of our total loans were current. At March 31, 2014, total past due loans and nonperforming loans of $805 million represented approximately 1.5% of total loans.

The following aging analysis of past due and current loans as of March 31, 2014, December 31, 2013, and March 31, 2013, provides further information regarding Key’s credit exposure.


							90 and				Total Past
			30-59		60-89		Greater				Due and		Purchased
March 31, 2014			Days Past		Days Past		Days Past		Nonperforming		Nonperforming		Credit		Total
in millions	Current		Due		Due		Due		Loans		Loans		Impaired		Loans
LOAN TYPE
Commercial, financial and agricultural	$	26,071	$	67	$	8	$	18	$	60	$	153		—	$	26,224
Commercial real estate:
Commercial mortgage		7,806		9		7		17		37		70	$	1		7,877
Construction		987		3		5		1		11		20		—		1,007

Total commercial real estate loans		8,793		12		12		18		48		90		1		8,884
Commercial lease financing		4,338		15		12		13		18		58		—		4,396

Total commercial loans	$	39,202	$	94	$	32	$	49	$	126	$	301	$	1	$	39,504


Real estate — residential mortgage	$	2,043	$	13	$	6	$	3	$	105	$	127	$	13	$	2,183
Home equity:
Key Community Bank		10,010		45		25		11		188		269		2		10,281
Other		296		5		2		1		11		19		—		315

Total home equity loans		10,306		50		27		12		199		288		2		10,596
Consumer other — Key Community Bank		1,415		8		5		6		2		21		—		1,436
Credit cards		671		7		4		15		1		27		—		698
Consumer other:
Marine		928		12		6		4		15		37		—		965
Other		59		2		1		—		1		4		—		63

Total consumer other		987		14		7		4		16		41		—		1,028

Total consumer loans	$	15,422	$	92	$	49	$	40	$	323	$	504	$	15	$	15,941


Total loans	$	54,624	$	186	$	81	$	89	$	449	$	805	$	16	$	55,445


							90 and				Total Past
			30-59		60-89		Greater				Due and		Purchased
December 31, 2013			Days Past		Days Past		Days Past		Nonperforming		Nonperforming		Credit		Total
in millions	Current		Due		Due		Due		Loans		Loans		Impaired		Loans
LOAN TYPE
Commercial, financial and agricultural	$	24,823	$	39	$	8	$	16	$	77	$	140		—	$	24,963
Commercial real estate:
Commercial mortgage		7,638		20		7		17		37		81	$	1		7,720
Construction		1,068		10		—		1		14		25		—		1,093

Total commercial real estate loans		8,706		30		7		18		51		106		1		8,813
Commercial lease financing		4,463		32		33		4		19		88		—		4,551

Total commercial loans	$	37,992	$	101	$	48	$	38	$	147	$	334	$	1	$	38,327


Real estate — residential mortgage	$	2,038	$	19	$	5	$	4	$	107	$	135	$	14	$	2,187
Home equity:
Key Community Bank		10,038		51		31		14		205		301		1		10,340
Other		308		6		4		1		15		26		—		334

Total home equity loans		10,346		57		35		15		220		327		1		10,674
Consumer other — Key Community Bank		1,426		8		5		7		3		23		—		1,449
Credit cards		698		11		5		4		4		24		—		722
Consumer other:
Marine		979		15		6		2		26		49		—		1,028
Other		65		2		1		1		1		5		—		70

Total consumer other		1,044		17		7		3		27		54		—		1,098

Total consumer loans	$	15,552	$	112	$	57	$	33	$	361	$	563	$	15	$	16,130


Total loans	$	53,544	$	213	$	105	$	71	$	508	$	897	$	16	$	54,457


			30-59		60-89		90 and Greater				Total Past Due and		Purchased
March 31, 2013			Days Past		Days Past		Days Past		Nonperforming		Nonperforming		Credit		Total
in millions	Current		Due		Due		Due		Loans		Loans		Impaired		Loans
LOAN TYPE
Commercial, financial and agricultural	$	23,134	$	35	$	74	$	26	$	142	$	277	$	1	$	23,412
Commercial real estate:
Commercial mortgage		7,368		35		14		11		114		174		2		7,544
Construction		1,024		5		—		1		27		33		—		1,057

Total commercial real estate loans		8,392		40		14		12		141		207		2		8,601
Commercial lease financing		4,728		34		11		11		12		68		—		4,796

Total commercial loans	$	36,254	$	109	$	99	$	49	$	295	$	552	$	3	$	36,809


Real estate — residential mortgage	$	2,037	$	15	$	5	$	7	$	96	$	123	$	16	$	2,176
Home equity:
Key Community Bank		9,512		51		28		17		199		295		2		9,809
Other		371		7		3		2		18		30		—		401

Total home equity loans		9,883		58		31		19		217		325		2		10,210
Consumer other — Key Community Bank		1,331		8		4		6		3		21		1		1,353
Credit cards		668		8		4		—		13		25		—		693
Consumer other:
Marine		1,202		18		7		2		25		52		—		1,254
Other		76		1		1		—		1		3		—		79

Total consumer other		1,278		19		8		2		26		55		—		1,333

Total consumer loans	$	15,197	$	108	$	52	$	34	$	355	$	549	$	19	$	15,765


Total loans	$	51,451	$	217	$	151	$	83	$	650	$	1,101	$	22	$	52,574

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 regulatory risk ratings assigned for the consumer loan portfolios.

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 reevaluated 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.

Credit quality indicators for loans are updated on an ongoing basis. Bond rating classifications are indicative of the credit quality of our commercial loan portfolios and are determined by converting our internally assigned risk rating grades to bond rating categories. Payment activity and the regulatory classifications of pass and substandard are indicators of the credit quality of our consumer loan portfolios.

Credit quality indicators for our commercial and consumer loan portfolios, excluding $16 million and $22 million of PCI loans at March 31, 2014, and 2013, respectively, based on bond rating, regulatory classification, and payment activity as of March 31, 2014, and 2013, are as follows:

Commercial Credit Exposure

Credit Risk Profile by Creditworthiness Category ^(a)


March 31,
in millions
	Commercial, financial and agricultural				RE — Commercial				RE — Construction				Commercial Lease				Total
RATING ^{(b), (c)}	2014		2013		2014		2013		2014		2013		2014		2013		2014		2013
AAA — AA	$	500	$	222	$	1		—	$	1	$	1	$	805	$	548	$	1,307	$	771
A		1,010		522		57	$	75		1		1		448		950		1,516		1,548
BBB — BB		23,361		21,120		7,267		6,529		826		866		2,964		3,043		34,418		31,558
B		551		672		337		426		84		23		101		165		1,073		1,286
CCC — C		802		875		214		512		95		166		78		90		1,189		1,643

Total	$	26,224	$	23,411	$	7,876	$	7,542	$	1,007	$	1,057	$	4,396	$	4,796	$	39,503	$	36,806

(a)	Credit quality indicators are updated on an ongoing basis and reflect credit quality information as of the dates indicated.

(b)	Our bond rating to internal loan grade conversion system is as follows: AAA - AA = 1, A = 2, BBB - BB = 3 - 13, B = 14 - 16, and CCC - C = 17 - 20.

(c)	Our internal loan grade to regulatory-defined classification is as follows: Pass = 1-16, Special Mention = 17, Substandard = 18, Doubtful = 19, and Loss = 20.

Consumer Credit Exposure

Credit Risk Profile by Regulatory Classifications ^{(a), (b)}


March 31,
in millions
	Residential — Prime
GRADE	2014		2013
Pass	$	12,445	$	12,029
Substandard		319		339

Total	$	12,764	$	12,368

Credit Risk Profile Based on Payment Activity ^(a)


March 31,	Consumer — Key Community Bank				Credit cards				Consumer — Marine				Consumer — Other				Total
in millions	2014		2013		2014		2013		2014		2013		2014		2013		2014		2013
Performing	$	1,434	$	1,349	$	697	$	680	$	950	$	1,229	$	62	$	78	$	3,143	$	3,336
Nonperforming		2		3		1		13		15		25		1		1		19		42

Total	$	1,436	$	1,352	$	698	$	693	$	965	$	1,254	$	63	$	79	$	3,162	$	3,378

(a)	Credit quality indicators are updated on an ongoing basis and reflect credit quality information as of the dates indicated.

(b)	Our past due payment activity to regulatory classification conversion is as follows: pass = less than 90 days; and substandard = 90 days and greater plus nonperforming loans.

We determine 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 118 of our 2013 Form 10-K. We apply expected loss rates to existing loans with similar risk characteristics as noted in the credit quality indicator table above and exercise judgment to assess the impact of factors such as changes in economic conditions, changes in credit policies or underwriting standards, and changes in the level of credit risk associated with specific industries and markets.

For all commercial and consumer loan TDRs, regardless of size, as well as impaired commercial loans with an outstanding balance of $2.5 million and greater, we conduct further analysis to determine the probable loss content and assign a specific allowance to the loan if deemed appropriate. We estimate the extent of the individual impairment for commercial loans and TDRs by comparing the recorded investment of the loan with the estimated present value of its future cash flows, the fair value of its underlying collateral, or the loan’s observable market price. Secured consumer loan TDRs that are discharged through Chapter 7 bankruptcy and not formally re-affirmed are adjusted to reflect the fair value of the underlying collateral, less costs to sell. Non-Chapter 7 consumer loan TDRs are combined in homogenous pools and assigned a specific allocation based on the estimated present value of future cash flows using the loan’s effective interest rate. A specific allowance also may be assigned — even when sources of repayment appear sufficient — if we remain uncertain about whether the loan will be repaid in full. On at least a quarterly basis, we evaluate the appropriateness of our loss estimation methods to reduce differences between estimated incurred losses and actual losses. The ALLL at March 31, 2014, represents our best estimate of the probable credit losses inherent in the loan portfolio at that date.

Although quantitative modeling factors such as default probability and expected recovery rates are constantly changing as the financial strength of the borrower and overall economic conditions change, we have not changed the accounting policies or methodology that we use to estimate the ALLL.

Commercial loans generally are charged off in full or charged down to the fair value of the underlying collateral when the borrower’s payment is 180 days past due. Most consumer loans are charged off when payments are 120 days past due. Home equity and residential mortgage loans generally are charged down to the fair value of the underlying collateral when payment is 180 days past due. Credit card loans, and similar unsecured products, are charged off when payments are 180 days past due.

At March 31, 2014, the ALLL was $834 million, or 1.50% of loans, compared to $893 million, or 1.70% of loans, at March 31, 2013. At March 31, 2014, the ALLL was 185.7% of nonperforming loans, compared to 137.4% at March 31, 2013.

A summary of the ALLL for the periods indicated is presented in the table below:


	Three months ended March 31,
in millions	2014			2013
Balance at beginning of period — continuing operations	$	848		$	888
Charge-offs		(57	)		(90	)
Recoveries		37			41

Net loans and leases charged off		(20	)		(49	)
Provision for loan and lease losses from continuing operations		6			55
Foreign currency translation adjustment		—			(1	)

Balance at end of period — continuing operations	$	834		$	893

The changes in the ALLL by loan category for the periods indicated are as follows:


in millions	December 31, 2013		Provision			Charge-offs			Recoveries		March 31, 2014
Commercial, financial and agricultural	$	362	$	13		$	(12	)	$	10	$	373
Real estate — commercial mortgage		165		(3	)		(2	)		1		161
Real estate — construction		32		(7	)		(2	)		14		37
Commercial lease financing		62		1			(3	)		2		62

Total commercial loans		621		4			(19	)		27		633
Real estate — residential mortgage		37		(8	)		(3	)		1		27
Home equity:
Key Community Bank		84		3			(10	)		3		80
Other		11		2			(3	)		1		11

Total home equity loans		95		5			(13	)		4		91
Consumer other — Key Community Bank		29		2			(8	)		2		25
Credit cards		34		4			(6	)		—		32
Consumer other:
Marine		29		(2	)		(7	)		3		23
Other		3		1			(1	)		—		3

Total consumer other:		32		(1	)		(8	)		3		26

Total consumer loans		227		2			(38	)		10		201

Total ALLL — continuing operations		848		6			(57	)		37		834
Discontinued operations		39		4			(13	)		4		34

Total ALLL — including discontinued operations	$	887	$	10		$	(70	)	$	41	$	868


in millions	December 31, 2012		Provision			Charge-offs			Recoveries		March 31, 2013
Commercial, financial and agricultural	$	327	$	13		$	(14	)	$	12	$	338
Real estate — commercial mortgage		198		3			(13	)		5		193
Real estate — construction		41		(13	)		(1	)		8		35
Commercial lease financing		55		9			(6	)		4		62

Total commercial loans		621		12			(34	)		29		628
Real estate — residential mortgage		30		10			(6	)		—		34
Home equity:
Key Community Bank		105		17			(18	)		2		106
Other		25		(3	)		(6	)		2		18

Total home equity loans		130		14			(24	)		4		124
Consumer other — Key Community Bank		38		2			(9	)		2		33
Credit cards		26		14			(8	)		—		32
Consumer other:
Marine		39		2			(8	)		5		38
Other		4		—			(1	)		1		4

Total consumer other:		43		2			(9	)		6		42

Total consumer loans		267		42			(56	)		12		265

Total ALLL — continuing operations		888		54	^(a)		(90	)		41		893
Discontinued operations		55		6			(16	)		4		49

Total ALLL — including discontinued operations	$	943	$	60		$	(106	)	$	45	$	942

(a)	Includes $1 million of foreign currency translation adjustment.

Our ALLL decreased by $59 million, or 6.6%, from the first quarter of 2013 primarily because of the improvement in the credit quality of our loan portfolios. The quality of new loan originations as well as decreasing NPLs and net loan charge-offs has also resulted in a reduction in our general allowance. Our general allowance applies expected loss rates to our existing loans with similar risk characteristics as well as any adjustments to reflect our current assessment of qualitative factors such as changes in economic conditions, underwriting standards, and concentrations of credit. Our delinquency trends declined during 2013 and into 2014 due to a modest level of loan growth, relatively stable economic conditions, and continued run-off in our exit loan portfolio, reflecting our effort to maintain a moderate enterprise risk tolerance.

For continuing operations, the loans outstanding individually evaluated for impairment totaled $304 million, with a corresponding allowance of $34 million at March 31, 2014. Loans outstanding collectively evaluated for impairment totaled $55.1 billion, with a corresponding allowance of $799 million at March 31, 2014. At March 31, 2014, PCI loans evaluated for impairment totaled $16 million, with a corresponding allowance of $1 million. There was no provision for loan and lease losses on these PCI loans during the quarter ended March 31, 2014.

A breakdown of the individual and collective ALLL and the corresponding loan balances as of March 31, 2014, follows:


	Allowance						Outstanding
	Individually		Collectively		Purchased					Individually		Collectively			Purchased
March 31, 2014	Evaluated for		Evaluated for		Credit					Evaluated for		Evaluated for			Credit
in millions	Impairment		Impairment		Impaired		Loans			Impairment		Impairment			Impaired
Commercial, financial and agricultural	$	2	$	371		—	$	26,224		$	40	$	26,184			—
Commercial real estate:
Commercial mortgage		1		160		—		7,877			25		7,851		$	1
Construction		—		37		—		1,007			6		1,001			—

Total commercial real estate loans		1		197		—		8,884			31		8,852			1
Commercial lease financing		—		62		—		4,396			—		4,396			—

Total commercial loans		3		630		—		39,504			71		39,432			1
Real estate — residential mortgage		4		22	$	1		2,183			54		2,116			13
Home equity:
Key Community Bank		16		64		—		10,281			105		10,174			2
Other		2		9		—		315			13		302			—

Total home equity loans		18		73		—		10,596			118		10,476			2
Consumer other — Key Community Bank		—		25		—		1,436			4		1,432			—
Credit cards		1		31		—		698			4		694			—
Consumer other:
Marine		7		16		—		965			52		913			—
Other		1		2		—		63			1		62			—

Total consumer other		8		18		—		1,028			53		975			—

Total consumer loans		31		169		1		15,941			233		15,693			15

Total ALLL — continuing operations		34		799		1		55,445			304		55,125			16
Discontinued operations		1		33		—		4,382	^(a)		15		4,367	^(a)		—

Total ALLL — including discontinued operations	$	35	$	832	$	1	$	59,827		$	319	$	59,492		$	16

(a)	Amount includes $2.0 billion of loans carried at fair value that are excluded from ALLL consideration.

A breakdown of the individual and collective ALLL and the corresponding loan balances as of December 31, 2013, follows:


	Allowance						Outstanding
	Individually		Collectively		Purchased					Individually		Collectively			Purchased
December 31, 2013	Evaluated for		Evaluated for		Credit					Evaluated for		Evaluated for			Credit
in millions	Impairment		Impairment		Impaired		Loans			Impairment		Impairment			Impaired
Commercial, financial and agricultural	$	8	$	354		—	$	24,963		$	50	$	24,913			—
Commercial real estate:
Commercial mortgage		2		163		—		7,720			27		7,692		$	1
Construction		—		32		—		1,093			50		1,043			—

Total commercial real estate loans		2		195		—		8,813			77		8,735			1
Commercial lease financing		—		62		—		4,551			—		4,551			—

Total commercial loans		10		611		—		38,327			127		38,199			1
Real estate — residential mortgage		9		27	$	1		2,187			56		2,117			14
Home equity:
Key Community Bank		10		74		—		10,340			102		10,237			1
Other		1		10		—		334			12		322			—

Total home equity loans		11		84		—		10,674			114		10,559			1
Consumer other — Key Community Bank		1		28		—		1,449			3		1,446			—
Credit cards		1		33		—		722			5		717			—
Consumer other:
Marine		10		19		—		1,028			52		976			—
Other		—		3		—		70			1		69			—

Total consumer other		10		22		—		1,098			53		1,045			—

Total consumer loans		32		194		1		16,130			231		15,884			15

Total ALLL — continuing operations		42		805		1		54,457			358		54,083			16
Discontinued operations		1		38		—		4,497	^(a)		13		4,484	^(a)		—

Total ALLL — including discontinued operations	$	43	$	843	$	1	$	58,954		$	371	$	58,567		$	16

(a)	Amount includes $2.1 billion of loans carried at fair value that are excluded from ALLL consideration.

A breakdown of the individual and collective ALLL and the corresponding loan balances as of March 31, 2013, follows:


	Allowance						Outstanding
	Individually		Collectively		Purchased					Individually		Collectively		Purchased
March 31, 2013	Evaluated for		Evaluated for		Credit					Evaluated for		Evaluated for		Credit
in millions	Impairment		Impairment		Impaired		Loans			Impairment		Impairment		Impaired
Commercial, financial and agricultural	$	8	$	330		—	$	23,412		$	108	$	23,303	$	1
Commercial real estate:
Commercial mortgage		3		190		—		7,544			96		7,446		2
Construction		—		35		—		1,057			48		1,009		—

Total commercial real estate loans		3		225		—		8,601			144		8,455		2
Commercial lease financing		—		62		—		4,796			—		4,796		—

Total commercial loans		11		617		—		36,809			252		36,554		3
Real estate — residential mortgage		1		33		—		2,176			33		2,127		16
Home equity:
Key Community Bank		14		92		—		9,809			90		9,717		2
Other		—		18		—		401			12		389		—

Total home equity loans		14		110		—		10,210			102		10,106		2
Consumer other — Key Community Bank		1		32		—		1,353			4		1,348		1
Credit cards		1		31		—		693			3		690		—
Consumer other:
Marine		5		33		—		1,254			50		1,204		—
Other		1		3		—		79			1		78		—

Total consumer other		6		36		—		1,333			51		1,282		—

Total consumer loans		23		242		—		15,765			193		15,553		19

Total ALLL — continuing operations		34		859		—		52,574			445		52,107		22
Discontinued operations		1		48		—		5,086	^(a)		4		5,082		—

Total ALLL — including discontinued operations	$	35	$	907		—	$	57,660		$	449	$	57,189	$	22

(a)	Amount includes $2.5 billion of loans carried at fair value that are excluded from ALLL consideration.

The liability for credit losses inherent in lending-related unfunded commitments, such as letters of credit and unfunded loan commitments, is included in “accrued expense and other liabilities” on the balance sheet. We establish the amount of this reserve by considering both historical trends and current market conditions quarterly, or more often if deemed necessary. Our liability for credit losses on lending-related commitments has increased by $3 million from March 31, 2013, to $35 million at March 31, 2014. When combined with our ALLL, our total allowance for credit losses represented 1.57% of loans at March 31, 2014, compared to 1.76% at March 31, 2013.

Changes in the liability for credit losses on unfunded lending-related commitments are summarized as follows:


	Three months ended March 31,
in millions	2014			2013
Balance at beginning of period	$	37		$	29
Provision (credit) for losses on lending-related commitments		(2	)		3

Balance at end of period	$	35		$	32