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Asset Quality
9 Months Ended
Sep. 30, 2025
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 112 of our 2024 Form 10-K.

The ALLL at September 30, 2025, 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 September 30, 2025:
Dollars in millionsJune 30, 2025ProvisionCharge-offsRecoveriesSeptember 30, 2025
Commercial and Industrial $678 $119 $(87)$21 $731 
Commercial real estate:
Real estate — commercial mortgage319 (15)(27) 277 
Real estate — construction57 (7)  50 
Total commercial real estate loans376 (22)(27) 327 
Commercial lease financing32 (7)  25 
Total commercial loans1,086 90 (114)21 1,083 
Real estate — residential mortgage68 (1) 1 68 
Home equity loans69 (1)  68 
Other consumer loans141 15 (15)2 143 
Credit cards82 9 (11)2 82 
Total consumer loans360 22 (26)5 361 
Total ALLL — continuing operations1,446 112 
(a)
(140)26 1,444 
Discontinued operations12  (1)1 12 
Total ALLL — including discontinued operations$1,458 $112 $(141)$27 $1,456 
(a)Excludes a credit related to reserves on lending-related commitments of $5 million.


Three months ended September 30, 2024:
Dollars in millionsJune 30, 2024ProvisionCharge-offsRecoveriesSeptember 30, 2024
Commercial and Industrial $682 $101 $(131)$$659 
Commercial real estate:
Real estate — commercial mortgage383 (19)(7)358 
Real estate — construction66 (2)— — 64 
Total commercial real estate loans449 (21)(7)422 
Commercial lease financing29 — — — 29 
Total commercial loans1,160 80 (138)1,110 
Real estate — residential mortgage115 (5)— 111 
Home equity loans71 (1)72 
Other consumer loans128 15 (17)128 
Credit cards73 10 (11)73 
Total consumer loans387 21 (29)384 
Total ALLL — continuing operations1,547 101 
(a)
(167)13 1,494 
Discontinued operations14 — (1)— 13 
Total ALLL — including discontinued operations$1,561 $101 $(168)$13 $1,507 
(a)Excludes a credit related to reserves on lending-related commitments of $6 million.
Nine months ended September 30, 2025:
Dollars in millionsDecember 31, 2024ProvisionCharge-offsRecoveriesSeptember 30, 2025
Commercial and Industrial $639 $285 $(243)$50 $731 
Commercial real estate:
Real estate — commercial mortgage320 25 (69)1 277 
Real estate — construction51 (1)  50 
Total commercial real estate loans371 24 (69)1 327 
Commercial lease financing27  (2) 25 
Total commercial loans1,037 309 (314)51 1,083 
Real estate — residential mortgage90 (24)(1)3 68 
Home equity loans70 (3)(1)2 68 
Other consumer loans136 43 (42)6 143 
Credit cards76 36 (35)5 82 
Total consumer loans372 52 (79)16 361 
Total ALLL — continuing operations1,409 361 
(a)
(393)67 1,444 
Discontinued operations13  (2)1 12 
Total ALLL — including discontinued operations$1,422 $361 $(395)$68 $1,456 
(a)Excludes a provision for losses on lending-related commitments of $2 million.

Nine months ended September 30, 2024:

Dollars in millionsDecember 31, 2023ProvisionCharge-offsRecoveriesSeptember 30, 2024
Commercial and Industrial $556 $336 $(279)$46 $659 
Commercial real estate:
Real estate — commercial mortgage419 (41)(22)358 
Real estate — construction52 12 — — 64 
Total commercial real estate loans471 (29)(22)422 
Commercial lease financing33 (3)(6)29 
Total commercial loans1,060 304 (307)53 1,110 
Real estate — residential mortgage162 (53)(2)111 
Home equity loans86 (14)(2)72 
Other consumer loans122 49 (49)128 
Credit cards78 26 (35)73 
Total consumer loans448 (88)16 384 
Total ALLL — continuing operations1,508 312 
(a)
(395)69 1,494 
Discontinued operations16 (1)(3)13 
Total ALLL — including discontinued operations$1,524 $311 $(398)$70 $1,507 
(a)Excludes a credit for losses on lending-related commitments of $16 million.


As described in Note 1 ("Summary of Significant Accounting Policies"), under the heading “Allowance for Loan and Lease Losses” beginning on page 112 of our 2024 Form 10-K, we estimate the ALLL using relevant available information, from internal and external sources, relating to past events, current economic and portfolio 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), fixed investment, business bankruptcies, GDP, industrial production, unemployment rate, and Producer Price Index
Commercial real estateProperty & real estate price indices, unemployment rate, business bankruptcies, GDP, and SOFR
Commercial lease financingBBB corporate bond rate (spread), GDP, and unemployment rate
ConsumerReal estate — residential mortgageGDP, home price index, unemployment rate, 30 year mortgage rate and U.S. household income
Home equityHome price index, unemployment rate, and 30 year mortgage rate
Other consumerUnemployment rate, prime rate and U.S. household income
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 September 30, 2025, the economy continues to be resilient, but shows signs of slowing down. Growth is weakening, inflationary pressures continue, and policy uncertainty adds to the existing economic pressures.

We utilized the Moody’s August 2025 Consensus forecast as the baseline forecast to estimate our expected credit losses as of September 30, 2025. This baseline scenario reflects slowing growth over the next two years, but no recession. U.S. GDP is expected to grow at an annual rate of 1.7% for 2025 and 2026. The expected National Unemployment Rate is forecasted to peak at 4.5% in mid-2026. The U.S. Consumer Price Index is forecasted to remain close to 3% through late 2026. The Federal Funds Rate decreases gradually over the next year, settling near 3%.

The geopolitical environment remains both uncertain and complex, which poses potential downside-risks to the economic outlook over the next two years, although to what extent remains highly uncertain. These economic uncertainty considerations continue to be addressed through a qualitative reserve adjustment, which leverages downside economic assumptions.

As a result of the current economic uncertainty, our future loss estimates may vary considerably from our September 30, 2025 assumptions.

Commercial Loan Portfolio

The ALLL from continuing operations for the commercial segment decreased $3 million, or 0.3%, from June 30, 2025. The stable reserve levels are reflective of the uncertain economic environment, where economic drivers remain largely unchanged, as the full impacts of tariffs and other policy changes are lagged in making their way through the economy. Changes in loan balances and portfolio mix resulted in a decrease in reserves for our commercial real estate loan segment, which was partially offset by an increase in the reserves for our commercial and industrial segment.

Consumer Loan Portfolio

The ALLL from continuing operations for the consumer segment increased by $1 million, or 0.3%,from June 30, 2025. The stable reserve levels are reflective of the continued strong credit performance, particularly for the residential mortgage loan book which represents the largest segment of the consumer portfolio.
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 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)(b)
As of September 30, 2025Term 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 millions20252024202320222021PriorTotal
Commercial and Industrial
Risk Rating:
Pass$6,584 $6,163 $2,577 $5,613 $3,015 $4,348 $24,582 $143 $53,025 
Criticized (Accruing)85 204 172 637 291 563 1,556 5 3,513 
Criticized (Nonaccruing)6 21 17 53 23 8 124 1 253 
Total commercial and industrial6,675 6,388 2,766 6,303 3,329 4,919 26,262 149 56,791 
Current year gross write-offs8 8 18 30 8 21 150  243 
Real estate — commercial mortgage
Risk Rating:
Pass2,015 930 619 2,191 1,651 3,235 1,183 28 11,852 
Criticized (Accruing)22 109 119 430 228 365 28 11 1,312 
Criticized (Nonaccruing)   127 46 38 3  214 
Total real estate — commercial mortgage
2,037 1,039 738 2,748 1,925 3,638 1,214 39 13,378 
Current year gross write-offs19 6  6 26 9 3  69 
Real estate — construction
Risk Rating:
Pass193 476 835 467 219 73 262 2 2,527 
Criticized (Accruing)  5 115 42 128   290 
Criticized (Nonaccruing)         
Total real estate — construction193 476 840 582 261 201 262 2 2,817 
Current year gross write-offs         
Commercial lease financing
Risk Rating:
Pass203 238 333 514 295 677   2,260 
Criticized (Accruing) 2 34 15 2 20   73 
Criticized (Nonaccruing)         
Total commercial lease financing203 240 367 529 297 697  2,333 
Current year gross write-offs     2   2 
Total commercial loans$9,108 $8,143 $4,711 $10,162 $5,812 $9,455 $27,738 $190 $75,319 
Total commercial loan current year gross write-offs$27 $14 $18 $36 $34 $32 $153 $ $314 

As of December 31, 2024Term 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 millions20242023202220212020PriorTotal
Commercial and Industrial
Risk Rating:
Pass$6,345 $3,097 $7,119 $3,934 $1,617 $3,969 $22,709 $115 $48,905 
Criticized (Accruing)172 219 597 419 208 476 1,550 41 3,682 
Criticized (Nonaccruing)23 13 68 30 31 153 322 
Total commercial and industrial6,540 3,329 7,784 4,383 1,827 4,476 24,412 158 52,909 
Current year gross write-offs12 65 106 31 144 — 363 
Real estate — commercial mortgage
Risk Rating:
Pass1,052 748 2,818 2,202 594 3,194 1,001 41 11,650 
Criticized (Accruing)31 85 571 281 93 316 30 1,416 
Criticized (Nonaccruing)— — 123 52 66 — — 244 
Total real estate — commercial mortgage
1,083 833 3,512 2,535 690 3,576 1,031 50 13,310 
Current year gross write-offs— — — 32 — 40 
Real estate — construction
Risk Rating:
Pass199 846 1,021 340 87 67 42 2,604 
Criticized (Accruing)— 17 112 58 68 77 — — 332 
Criticized (Nonaccruing)— — — — — — — — — 
Total real estate — construction199 863 1,133 398 155 144 42 2,936 
Current year gross write-offs— — — — — — — — — 
Commercial lease financing
Risk Rating:
Pass301 430 626 368 217 679 — — 2,621 
Criticized (Accruing)34 33 16 21 — — 115 
Criticized (Nonaccruing)— — — — — — — — — 
Total commercial lease financing303 464 659 377 233 700 — — 2,736 
Current year gross write-offs— — — — — — — 
Total commercial loans$8,125 $5,489 $13,088 $7,693 $2,905 $8,896 $25,485 $210 $71,891 
Total commercial loan current year gross write-offs$$12 $66 $112 $$70 $145 $— $410 
(a)Accrued interest of $351 million and $322 million as of September 30, 2025, and December 31, 2024, respectively, presented in “Accrued income and other assets” on the Consolidated Balance Sheets, was excluded from the amortized cost basis disclosed in these tables.
(b)Gross write-off information is presented on a year-to-date basis for the nine months ended September 30, 2025 and the twelve months ended December 31, 2024.
Consumer Credit Exposure
Credit Risk Profile by FICO Score and Vintage (a)(b)
As of September 30, 2025Term LoansRevolving Loans Amortized Cost BasisRevolving Loans Converted to Term Loans Amortized Cost Basis
Amortized Cost Basis by Origination Year and FICO Score
Dollars in millions20252024202320222021PriorTotal
Real estate — residential mortgage
FICO Score:
750 and above$256 $260 $638 $5,427 $6,846 $3,482 $ $ $16,909 
660 to 74944 38 84 531 603 448   1,748 
Less than 6602 10 21 84 65 149   331 
No Score2 3 2 1  10 2  20 
Total real estate — residential mortgage304 311 745 6,043 7,514 4,089 2  19,008 
Current period gross write-offs     1   1 
Home equity loans
FICO Score:
750 and above35 27 25 121 701 1,217 1,783 195 4,104 
660 to 74913 15 14 45 158 269 732 62 1,308 
Less than 6601 2 5 15 43 107 248 23 444 
No Score     1 6  7 
Total home equity loans49 44 44 181 902 1,594 2,769 280 5,863 
Current period gross write-offs      1  1 
Other consumer loans
FICO Score:
750 and above137 80 112 1,024 1,076 635 83  3,147 
660 to 74986 54 82 234 228 188 175  1,047 
Less than 66010 12 23 57 55 50 53  260 
No Score17 12 6 12 13 8 257  325 
Total consumer direct loans250 158 223 1,327 1,372 881 568  4,779 
Current period gross write-offs3 4 6 6 6 6 11  42 
Credit cards
FICO Score:
750 and above      460  460 
660 to 749      366  366 
Less than 660      106  106 
No Score      1  1 
Total credit cards      933  933 
Current period gross write-offs      35  35 
Total consumer loans$603 $513 $1,012 $7,551 $9,788 $6,564 $4,272 $280 $30,583 
Total consumer loan current period gross write-offs$3 $4 $6 $6 $6 $7 $47 $ $79 
As of December 31, 2024Term LoansRevolving Loans Amortized Cost BasisRevolving Loans Converted to Term Loans Amortized Cost Basis
Amortized Cost Basis by Origination Year and FICO Score
Dollars in millions20242023202220212020PriorTotal
Real estate — residential mortgage
FICO Score:
750 and above$281 $669 $5,720 $7,203 $2,247 $1,510 $— $— $17,630 
660 to 74967 116 597 655 199 280 — — 1,914 
Less than 66013 81 63 24 134 — — 319 
No Score— 15 — 23 
Total real estate — residential mortgage355 800 6,399 7,921 2,471 1,939 — 19,886 
Current period gross write-offs— — — — — 
Home equity loans
FICO Score:
750 and above33 31 139 775 612 731 1,886 251 4,458 
660 to 74917 17 50 181 129 186 772 80 1,432 
Less than 66015 40 31 82 263 25 463 
No Score— — — — — — 
Total home equity loans52 53 204 996 772 1,000 2,925 356 6,358 
Current period gross write-offs— — — — — — 
Other consumer loans
FICO Score:
750 and above107 143 1,149 1,210 527 245 88 — 3,469 
660 to 74970 109 275 268 128 108 184 — 1,142 
Less than 66023 59 59 29 24 56 — 259 
No Score35 12 18 17 12 196 — 297 
Total consumer direct loans221 287 1,501 1,554 691 389 524 — 5,167 
Current period gross write-offs— 17 12 15 — 64 
Credit cards
FICO Score:
750 and above— — — — — — 476 — 476 
660 to 749— — — — — — 372 — 372 
Less than 660— — — — — — 109 — 109 
No Score— — — — — — — 
Total credit cards— — — — — — 958 — 958 
Current period gross write-offs— — — — — — 47 — 47 
Total consumer loans$628 $1,140 $8,104 $10,471 $3,934 $3,328 $4,408 $356 $32,369 
Total consumer current period gross write-offs$$$18 $12 $$$63 $— $116 
(a)Accrued interest of $121 million and $134 million as of September 30, 2025, and December 31, 2024, respectively, presented in “Accrued income and other assets” on the Consolidated Balance Sheets, was excluded from the amortized cost basis disclosed in this table.
(b)Gross write-off information is presented on a year-to-date basis for the nine months ended September 30, 2025 and the twelve months ended December 31, 2024.


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 111 of our 2024 Form 10-K.
The following aging analysis of past due and current loans as of September 30, 2025, and December 31, 2024, provides further information regarding Key’s credit exposure.

Aging Analysis of Loan Portfolio(a)
As of September 30, 2025
Current (b)(c)
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 (b)
Total
Loans (d)
Dollars in millions
LOAN TYPE
Commercial and industrial$56,431 $45 $24 $38 $253 $360 $56,791 
Commercial real estate:
Commercial mortgage13,030 79 8 47 214 348 13,378 
Construction2,794  22 1  23 2,817 
Total commercial real estate loans15,824 79 30 48 214 371 16,195 
Commercial lease financing2,332 1    1 2,333 
Total commercial loans$74,587 $125 $54 $86 $467 $732 $75,319 
Real estate — residential mortgage$18,891 $13 $6 $ $98 $117 $19,008 
Home equity loans5,754 18 5 4 82 109 5,863 
Other consumer loans4,741 15 9 10 4 38 4,779 
Credit cards907 5 4 10 7 26 933 
Total consumer loans$30,293 $51 $24 $24 $191 $290 $30,583 
Total loans$104,880 $176 $78 $110 $658 $1,022 $105,902 
(a)Amounts in table represent amortized cost and exclude loans held for sale.
(b)Accrued interest of $472 million presented in “Accrued income and other assets” on the Consolidated Balance Sheets is excluded from the amortized cost basis disclosed in this table.
(c)Includes balances of $69 million in Commercial mortgage and $5 million in Real estate - residential mortgage associated with loans sold to GNMA that are 90 days or more past due where Key has the right but not the obligation to repurchase and whose payments are insured by the Federal Housing Administration or guaranteed by the United States Department of Veteran Affairs.
(d)Net of unearned income, net of deferred fees and costs, and unamortized discounts and premiums.

As of December 31, 2024
Current (b)(c)
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 (b)
Total
Loans (d)
Dollars in millions
LOAN TYPE
Commercial and industrial$52,473 $48 $21 $45 $322 $436 $52,909 
Commercial real estate:
Commercial mortgage13,018 29 16 243 292 13,310 
Construction2,932 — — — 2,936 
Total commercial real estate loans15,950 29 20 243 296 16,246 
Commercial lease financing2,728 — 2,736 
Total commercial loans$71,151 $53 $56 $66 $565 $740 $71,891 
Real estate — residential mortgage$19,766 $20 $$— $92 $120 $19,886 
Home equity loans6,232 26 89 126 6,358 
Other consumer loans5,129 15 38 5,167 
Credit cards928 12 30 958 
Total consumer loans$32,055 $67 $30 $24 $193 $314 $32,369 
Total loans$103,206 $120 $86 $90 $758 $1,054 $104,260 
(a)Amounts in table represent amortized cost and exclude loans held for sale.
(b)Accrued interest of $456 million presented in “Accrued income and other assets” on the Consolidated Balance Sheets is excluded from the amortized cost basis disclosed in this table.
(c)Includes balances of $75 million in Commercial mortgage and $7 million in Real estate - residential mortgage associated with loans sold to GNMA that are 90 days or more past due where Key has the right but not the obligation to repurchase and whose payments are insured by the Federal Housing Administration or guaranteed by the United States Department of Veteran Affairs.
(d)Net of unearned income, net of deferred fees and costs, and unamortized discounts and premiums.


At September 30, 2025, the carrying amount of our commercial nonperforming loans outstanding represented 70% of their original contractual amount owed, total nonperforming loans outstanding represented 76% of their original contractual amount owed, and nonperforming assets in total were carried at 79% of their original contractual amount owed.

Nonperforming loans reduced expected interest income by $12 million and $39 million for the three and nine months ended September 30, 2025, respectively, and $14 million and $41 million for the three and nine months ended September 30, 2024, respectively.

The amortized cost basis of nonperforming loans on nonaccrual status for which there is no related allowance for credit losses was $361 million at September 30, 2025 and $381 million at December 31, 2024.

As of September 30, 2025, 48% of our nonperforming loans were contractually current versus 43% as of December 31, 2024.
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.

At September 30, 2025 and September 30, 2024, the recorded investment of consumer residential mortgage and home equity loans in the process of foreclosure was $66 million and $73 million, respectively.

There were no significant changes in the extent to which collateral secures our collateral-dependent financial assets during the three and nine months ended September 30, 2025.

Loan Modifications Made to Borrowers Experiencing Financial Difficulty

The ALLL for loans modified for borrowers experiencing financial difficulty is determined based on Key’s ALLL policy as described within Note 1 (“Summary of Significant Accounting Policies”) of our 2024 Form 10-K.

Modifications for Borrowers Experiencing Financial Difficulty

Our strategy in working with commercial borrowers is to allow them time to improve their financial position through loan modification. Commercial borrowers that are rated substandard or worse in accordance with the regulatory definition, or that cannot otherwise restructure at market terms and conditions, are considered to be experiencing financial difficulty. A modification of a loan is subject to the normal underwriting standards and processes for other similar credit extensions, both new and existing. The modified loan is evaluated to determine if it is a new loan or a continuation of the prior loan.

Consumer loans in which a borrower requires a modification as a result of negative changes to their financial condition or to avoid default, generally indicate the borrower is experiencing financial difficulty. The primary modifications made to consumer loans are amortization, maturity date and interest rate changes. Consumer borrowers identified as experiencing financial difficulty are generally unable to refinance their loans through our normal origination channel or through other independent sources.

The following tables show the amortized cost basis at the end of the noted reporting periods of the loans modified to borrowers experiencing financial difficulty within the past 12 months of the noted periods. The tables do not include those modifications that only resulted in an insignificant payment delay. The tables do not include consumer loans that are still within a trial modification period. Trial modifications may be done for consumer borrowers where a trial payment plan period is offered in advance of a permanent loan modification. As of September 30, 2025, there were 103 loans totaling $16 million in a trial modification period. As of September 30, 2024, there were 110 loans totaling $19 million in a trial modification period.

Commitments outstanding to lend additional funds to borrowers experiencing financial difficulty whose loans were modified were $100 million and $29 million at September 30, 2025 and September 30, 2024, respectively.
As of September 30, 2025Interest Rate ReductionTerm ExtensionOther
Combination (a)
Total
Dollars in millionsAmortized Cost BasisAmortized Cost BasisAmortized Cost BasisAmortized Cost BasisAmortized Cost Basis% of Total Loan Type
LOAN TYPE
Commercial and Industrial$2 $76 $22 $16 $116 0.20 %
Commercial real estate:
Commercial mortgage 194 2 52 248 1.85 
Construction 34   34 1.21 
Total commercial real estate loans 228 2 52 282 1.74 
Total commercial loans$2 $304 $24 $68 $398 0.53 %
Real estate — residential mortgage$2 $1 $ $10 $13 0.07 %
Home equity loans4 1 1 5 11 0.19 
Other consumer loans 3  3 6 0.13 
Credit cards   3 3 0.32 
Total consumer loans$6 $5 $1 $21 $33 0.11 %
Total loans$8 $309 $25 $89 $431 0.41 %

As of September 30, 2024Interest Rate ReductionTerm ExtensionOther
Combination (a)
Total
Dollars in millionsAmortized Cost BasisAmortized Cost BasisAmortized Cost BasisAmortized Cost BasisAmortized Cost Basis% of Total Loan Type
LOAN TYPE
Commercial and Industrial$— $126 $11 $16 $153 0.29 %
Commercial real estate:
Commercial mortgage28 189 — 220 1.61 
Construction— 27 — — 27 0.87 
Total commercial real estate loans28 216 — 247 1.48 
Total commercial loans$28 $342 $14 $16 $400 0.55 %
Real estate — residential mortgage$$— $— $11 $12 0.06 %
Home equity loans11 0.17 
Other consumer loans— — 0.06 
Credit cards— — — 0.44 
Total consumer loans$$$$23 $30 0.09 %
Total loans$32 $344 $15 $39 $430 0.41 %
(a)Combination modifications consist primarily of loans modified with both an interest rate reduction and a term extension.

Financial Effects of Modifications to Borrowers Experiencing Financial Difficulty

The following table summarizes the financial impacts of loan modifications made to specific loans for the noted periods. For the three and nine months ended September 30, 2025, the weighted-average interest rate change for commercial and industrial loans was comprised solely of modifications of commercial credit card balances.

Three months ended September 30, 2025Weighted-average Interest Rate ChangeWeighted-average Term Extension (in years)
LOAN TYPE
Commercial and Industrial(0.43)%0.41
Commercial mortgage %0.45
Construction %0.35
Real estate — residential mortgage(1.63)%7.00
Home equity loans(2.85)%7.69
Other consumer loans(3.59)%1.52
Credit cards(1.16)%0.25
Nine months ended September 30, 2025Weighted-average Interest Rate ChangeWeighted-average Term Extension (in years)
LOAN TYPE
Commercial and Industrial(0.43)%0.83
Commercial mortgage %1.09
Construction %0.02
Real estate — residential mortgage(1.80)%5.87
Home equity loans(2.82)%5.95
Other consumer loans(3.77)%1.04
Credit cards(8.46)%0.75

Three months ended September 30, 2024Weighted-average Interest Rate ChangeWeighted-average Term Extension (in years)
LOAN TYPE
Commercial and Industrial(17.00)%0.42
Commercial mortgage— %0.43
Construction— %0.00
Real estate — residential mortgage(1.85)%2.47
Home equity loans(4.68)%5.60
Other consumer loans(4.18)%0.40
Credit cards(12.13)%0.25

Nine months ended September 30, 2024Weighted-average Interest Rate ChangeWeighted-average Term Extension (in years)
LOAN TYPE
Commercial and Industrial(6.29)%1.14
Commercial mortgage(1.91)%0.20
Construction— %3.20
Real estate — residential mortgage(1.73)%5.77
Home equity loans(3.75)%6.44
Other consumer loans(3.90)%0.62
Credit cards(15.21)%0.75

Amortized Cost Basis of Modified Loans That Subsequently Defaulted

Key considers modifications to borrowers experiencing financial difficulty that subsequently become 90 days or more past due under modified terms as subsequently defaulted. The following table presents the amortized cost of modified loans to borrowers experiencing financial difficulty that were within 12 months of their modification and subsequently defaulted within the noted periods.

Three months ended September 30, 2025
Dollars in millionsInterest Rate ReductionTerm ExtensionOtherCombinationTotal
LOAN TYPE
Credit cards$ $ $ $1 $1 
Total consumer loans$ $ $ $1 $1 
Total loans$ $ $ $1 $1 

Nine months ended September 30, 2025
Dollars in millionsInterest Rate ReductionTerm ExtensionOtherCombinationTotal
LOAN TYPE
Commercial and Industrial$ $2 $7 $ $9 
Commercial real estate
Commercial mortgage 19   19 
Total commercial real estate loans 19   19 
Total commercial loans$ $21 $7 $ $28 
Real estate — residential mortgage$ $ $ $1 $1 
Credit cards   2 2 
Total consumer loans$ $ $ $3 $3 
Total loans$ $21 $7 $3 $31 
Three months ended September 30, 2024
Dollars in millionsInterest Rate ReductionTerm ExtensionOtherCombinationTotal
LOAN TYPE
Commercial and Industrial$— $$— $— $
Commercial real estate
Commercial mortgage$28 $— $— $$29 
Total commercial loans28 — 30 
Total loans$28 $$— $$30 

Nine months ended September 30, 2024
Dollars in millionsInterest Rate ReductionTerm ExtensionOtherCombinationTotal
LOAN TYPE
Commercial and Industrial$— $17 $— $$18 
Commercial real estate
Commercial mortgage28 — — 29 
Total commercial real estate loans28 — — 29 
Total commercial loans$28 $17 $— $$47 
Home equity loans$— $— $— $$
Total consumer loans$— $— $— $$
Total loans$28 $17 $— $$48 

Key closely monitors the performance of loans that are modified for borrowers experiencing financial difficulty to understand the effectiveness of its modification efforts. The following table presents the amortized cost as of September 30, 2025, of loans modified during the 12 months then ended, by aging.

As of September 30, 2025Current30-89 Days 
Past Due
90 and Greater
Days Past Due
Total
Dollars in millions
LOAN TYPE
Commercial and Industrial$102 $4 $10 $116 
Commercial real estate
Commercial mortgage244 2 2 248 
Construction34   34 
Total commercial real estate loans278 2 2 282 
Commercial lease financing    
Total commercial loans$380 $6 $12 $398 
Real estate — residential mortgage$12 $1 $ $13 
Home equity loans9 1 1 11 
Other consumer loans6   6 
Credit cards3   3 
Total consumer loans$30 $2 $1 $33 
Total loans$410 $8 $13 $431 
The following table presents the amortized cost as of September 30, 2024, of loans modified during the 12 months then ended, by aging.

As of September 30, 2024Current30-89 Days 
Past Due
90 and Greater
Days Past Due
Total
Dollars in millions
LOAN TYPE
Commercial and Industrial$132 $18 $$153 
Commercial real estate
Commercial mortgage189 — 31 220 
Construction27 — — 27 
Total commercial real estate loans348 18 34 400 
Commercial lease financing— — — — 
Total commercial loans$348 $18 $34 $400 
Real estate — residential mortgage$$$— $12 
Home equity loans11 
Other consumer loans— — 
Credit cards— — 
Total consumer loans$25 $$$30 
Total loans$373 $22 $35 $430 

Liability for Credit Losses on Lending-related Commitments

The liability for credit losses on lending-related commitments is included in “accrued expense and other liabilities” on the balance sheet. This includes credit risk for recourse associated with loans sold under the Fannie Mae Delegated Underwriting and Servicing program and credit losses inherent in unfunded lending-related commitments, such as letters of credit and unfunded loan commitments, and certain financial guarantees.

Changes in the liability for credit losses on lending-related commitments are summarized as follows:
 Three months ended September 30,Nine months ended September 30,
Dollars in millions2025202420252024
Balance at beginning of period$297 $286 $290 $296 
Provision (credit) for losses on lending-related commitments(5)(6)2 (16)
Balance at end of period$292 $280 $292 $280