Fair value, also referred to as an exit price, is defined as the price that would be received for an asset or paid to transfer a liability in an orderly transaction between market participants on the measurement date. The fair value accounting guidance provides a three-level fair value hierarchy for classifying financial instruments. This hierarchy is based on the markets in which the assets or liabilities trade and whether the inputs to the valuation techniques used to measure fair value are observable or unobservable. The fair value measurement of a financial asset or liability is assigned a level based on the lowest level of any input that is significant to the fair value measurement in its entirety. The three levels of the fair value hierarchy are described below:


Level 1:						Valuation is based on quoted prices (unadjusted) in active markets for identical assets or liabilities.
Level 2:						Valuation is based on observable market-based inputs other than Level 1 prices, such as quoted prices for similar assets or liabilities, quoted prices in markets that are not active, or other inputs that are observable or can be corroborated by observable market data for substantially the full term of the assets or liabilities.
Level 3:						Valuation is generated from techniques that use significant assumptions not observable in the market. Valuation techniques include pricing models, discounted cash flow (“DCF”) methodologies or similar techniques.

The accounting guidance for fair value measurements requires that we maximize the use of observable inputs and minimize the use of unobservable inputs in determining fair value. The accounting guidance provides for the irrevocable option to elect, on a contract-by-contract basis, to measure certain financial assets and liabilities at fair value at inception of the contract and record any subsequent changes in fair value in earnings.

The determination and classification of financial instruments in the fair value hierarchy is performed at the end of each reporting period. We consider all available information, including observable market data, indications of market liquidity and orderliness, and our understanding of the valuation techniques and significant inputs. For additional information on the valuation techniques used in estimating the fair value of our financial assets and liabilities on a recurring basis, see “Note 16—Fair Value Measurement” in our 2021 Form 10-K.


	June 30, 2022
	Fair Value Measurements Using						Netting Adjustments(1)
(Dollars in millions)	Level 1		Level 2		Level 3				Total
Assets:
Securities available for sale:
U.S. Treasury securities	$	8,624	$	0	$	0	—		$	8,624
RMBS	0		65,287		240		—		65,527
CMBS	0		7,561		13		—		7,574
Other securities	191		1,106		0		—		1,297
Total securities available for sale	8,815		73,954		253		—		83,022
Loans held for sale	0		767		0		—		767
Other assets:
Derivative assets(2)	792		3,577		131		$	(1,067)	3,433
Other(3)	441		3		37		—		481
Total assets	$	10,048	$	78,301	$	421	$	(1,067)	$	87,703
Liabilities:
Other liabilities:
Derivative liabilities(2)	$	1,416	$	3,104	$	143	$	(1,395)	$	3,268
Total liabilities	$	1,416	$	3,104	$	143	$	(1,395)	$	3,268


	December 31, 2021
	Fair Value Measurements Using						Netting Adjustments(1)
(Dollars in millions)	Level 1		Level 2		Level 3				Total
Assets:
Securities available for sale:
U.S. Treasury securities	$	9,442	$	0	$	0	—		$	9,442
RMBS	0		73,358		258		—		73,616
CMBS	0		9,360		9		—		9,369
Other securities	206		2,628		0		—		2,834
Total securities available for sale	9,648		85,346		267		—		95,261
Loans held for sale	0		1,026		0		—		1,026
Other assets:
Derivative assets(2)	406		2,200		84		$	(542)	2,148
Other(3)	526		6		41		—		573
Total assets	$	10,580	$	88,578	$	392	$	(542)	$	99,008
Liabilities:
Other liabilities:
Derivative liabilities(2)	$	838	$	965	$	65	$	(544)	$	1,324
Total liabilities	$	838	$	965	$	65	$	(544)	$	1,324

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(1)Represents balance sheet netting of derivative assets and liabilities, and related payables and receivables for cash collateral held or placed with the same counterparty. See “Note 8—Derivative Instruments and Hedging Activities” for additional information.

(2)Does not reflect $8 million and $11 million recognized as a net valuation allowance on derivative assets and liabilities for non-performance risk as of June 30, 2022 and December 31, 2021, respectively. Non-performance risk is included in derivative assets and liabilities, which are part of other assets and other liabilities on the consolidated balance sheets, and is recorded through non-interest income in the consolidated statements of income.

(3)As of June 30, 2022 and December 31, 2021, other includes retained interests in securitizations of $37 million and $41 million, deferred compensation plan assets of $432 million and $490 million, and equity securities of $12 million (including unrealized loss of $19 million) and $42 million (including unrealized loss of $36 million), respectively.

The table below presents a reconciliation for all assets and liabilities measured and recognized at fair value on a recurring basis using significant unobservable inputs (Level 3) for the three and six months ended June 30, 2022 and 2021. Generally, transfers into Level 3 were primarily driven by the usage of unobservable assumptions in the pricing of these financial instruments as evidenced by wider pricing variations among pricing vendors and transfers out of Level 3 were primarily driven by the usage of assumptions corroborated by market observable information as evidenced by tighter pricing among multiple pricing sources.


	Fair Value Measurements Using Significant Unobservable Inputs (Level 3)
	Three Months Ended June 30, 2022
			Total Gains (Losses) (Realized/Unrealized)																		Net Unrealized Gains (Losses) Included in Net Income Related to Assets and Liabilities Still Held as of June 30, 2022(1)
(Dollars in millions)	Balance, April 1, 2022		Included in Net Income(1)		Included in OCI		Purchases		Sales		Issuances		Settlements		Transfers Into Level 3		Transfers Out of Level 3		Balance, June 30, 2022
Securities available for sale:(2)
RMBS	$	211	$	3	$	(8)	$	0	$	0	$	0	$	(15)	$	72	$	(23)	$	240	$	2
CMBS	21		0		(1)		0		0		0		(4)		0		(3)		13		0

Total securities available for sale	232		3		(9)		0		0		0		(19)		72		(26)		253		2


	Fair Value Measurements Using Significant Unobservable Inputs (Level 3)
	Three Months Ended June 30, 2022
		Total Gains (Losses) (Realized/Unrealized)									Net Unrealized Gains (Losses) Included in Net Income Related to Assets and Liabilities Still Held as of June 30, 2022(1)
(Dollars in millions)	Balance, April 1, 2022	Included in Net Income(1)	Included in OCI	Purchases	Sales	Issuances	Settlements	Transfers Into Level 3	Transfers Out of Level 3	Balance, June 30, 2022
Other assets:

Retained interests in securitizations	39	(2)	0	0	0	0	0	0	0	37	(2)
Net derivative assets (liabilities)(3)	22	(46)	0	0	0	8	4	0	0	(12)	(18)


	Fair Value Measurements Using Significant Unobservable Inputs (Level 3)
	Six Months Ended June 30, 2022
			Total Gains (Losses) (Realized/Unrealized)																		Net Unrealized Gains (Losses) Included in Net Income Related to Assets and Liabilities Still Held as of June 30, 2022(1)
(Dollars in millions)	Balance, January 1, 2022		Included in Net Income(1)		Included in OCI		Purchases		Sales		Issuances		Settlements		Transfers Into Level 3		Transfers Out of Level 3		Balance, June 30, 2022
Securities available for sale:(2)
RMBS	$	258	$	13	$	(20)	$	0	$	0	$	0	$	(43)	$	84	$	(52)	$	240	$	5
CMBS	9		0		(1)		0		0		0		(5)		13		(3)		13		(1)

Total securities available for sale	267		13		(21)		0		0		0		(48)		97		(55)		253		4
Other assets:

Retained interests in securitizations	41		(4)		0		0		0		0		0		0		0		37		(4)
Net derivative assets (liabilities)(3)	19		(41)		0		0		0		36		2		(28)		0		(12)		(38)


	Fair Value Measurements Using Significant Unobservable Inputs (Level 3)
	Three Months Ended June 30, 2021
			Total Gains (Losses) (Realized/Unrealized)																		Net Unrealized Gains (Losses) Included in Net Income Related to Assets and Liabilities Still Held as of June 30, 2021(1)
(Dollars in millions)	Balance, April 1, 2021		Included in Net Income(1)		Included in OCI		Purchases		Sales		Issuances		Settlements		Transfers Into Level 3		Transfers Out of Level 3		Balance, June 30, 2021
Securities available for sale:(2)
RMBS	$	326	$	4	$	2	$	0	$	0	$	0	$	(25)	$	45	$	(63)	$	289	$	4
CMBS	10		0		0		0		0		0		0		0		(1)		9		0

Total securities available for sale	336		4		2		0		0		0		(25)		45		(64)		298		4
Other assets:

Retained interests in securitizations	50		(4)		0		0		0		0		0		0		0		46		(4)
Net derivative assets (liabilities)(3)	34		11		0		0		0		(16)		(15)		6		(1)		19		11


	Fair Value Measurements Using Significant Unobservable Inputs (Level 3)
	Six Months Ended June 30, 2021
			Total Gains (Losses) (Realized/Unrealized)																		Net Unrealized Gains (Losses) Included in Net Income Related to Assets and Liabilities Still Held as of June 30, 2021(1)
(Dollars in millions)	Balance, January 1, 2021		Included in Net Income(1)		Included in OCI		Purchases		Sales		Issuances		Settlements		Transfers Into Level 3		Transfers Out of Level 3		Balance, June 30, 2021
Securities available for sale:(2)
RMBS	$	328	$	11	$	4	$	0	$	0	$	0	$	(51)	$	84	$	(87)	$	289	$	8
CMBS	111		0		(2)		0		0		0		(6)		0		(94)		9		0

Total securities available for sale	439		11		2		0		0		0		(57)		84		(181)		298		8
Other assets:

Retained interests in securitizations	55		(9)		0		0		0		0		0		0		0		46		(9)
Net derivative assets (liabilities)(3)	31		(10)		0		0		0		22		(29)		6		(1)		19		8

_________

(1)Realized gains (losses) on securities available for sale are included in net securities gains (losses) and retained interests in securitizations are reported as a component of non-interest income in our consolidated statements of income. Gains (losses) on derivatives are included as a component of net interest income or non-interest income in our consolidated statements of income.

(2)For the three and six months ended June 30, 2022 included in OCI related to Level 3 securities available for sale still held as of June 30, 2022 were net unrealized losses of $11 million and $20 million . For the three and six months ended June 30, 2021, included in OCI related to Level 3 securities available for sale still held as of June 30, 2021 were net unrealized losses of $1 million and net unrealized gains of $2 million, respectively.

Generally, uncertainties in fair value measurements of financial instruments, such as changes in unobservable inputs, may have a significant impact on fair value. Certain of these unobservable inputs will, in isolation, have a directionally consistent impact on the fair value of the instrument for a given change in that input. Alternatively, the fair value of the instrument may move in an opposite direction for a given change in another input. In general, an increase in the discount rate, default rates, loss severity or credit spreads, in isolation, would result in a decrease in the fair value measurement. In addition, an increase in default rates would generally be accompanied by a decrease in recovery rates, slower prepayment rates and an increase in liquidity spreads, and would lead to a decrease in the fair value measurement.

The following table presents the significant unobservable inputs used to determine the fair values of our Level 3 financial instruments on a recurring basis. We utilize multiple vendor pricing services to obtain fair value for our securities. Several of our vendor pricing services are only able to provide unobservable input information for a limited number of securities due to software licensing restrictions. Other vendor pricing services are able to provide unobservable input information for all securities for which they provide a valuation. As a result, the unobservable input information for the securities available for sale presented below represents a composite summary of all information we are able to obtain. The unobservable input information for all other Level 3 financial instruments is based on the assumptions used in our internal valuation models.

Quantitative Information about Level 3 Fair Value Measurements

(Dollars in millions)

Fair Value at
June 30,
2022

Significant
Valuation
Techniques

Significant
Unobservable
Inputs

Range

Weighted

Average(1)

Securities available for sale:

RMBS

240

Discounted cash flows (vendor pricing)

Yield
Voluntary prepayment rate
Default rate
Loss severity

0-14%

6-25%

0-11%

30-80%

10%

61%

CMBS

Discounted cash flows (vendor pricing)

Yield

2-4%

Other assets:

Retained interests in securitizations(2)

Discounted cash flows

Life of receivables (months)
Voluntary prepayment rate
Discount rate
Default rate
Loss severity

30-37

9-18%

4-8%

1-3%

80-291%

N/A

Net derivative assets (liabilities)

(12)

Discounted cash flows

Swap rates

Quantitative Information about Level 3 Fair Value Measurements

(Dollars in millions)

Fair Value at
December 31,
2021

Significant
Valuation
Techniques

Significant
Unobservable
Inputs

Range

Weighted

Average(1)

Securities available for sale:

RMBS

258

Discounted cash flows (vendor pricing)

Yield
Voluntary prepayment rate
Default rate
Loss severity

0-21%

5-40%

1-11%

30-100%

11%

65%

CMBS

Discounted cash flows (vendor pricing)

Yield

1-2%

Other assets:

Retained interests in securitizations(2)

Discounted cash flows

Life of receivables (months)
Voluntary prepayment rate
Discount rate
Default rate
Loss severity

29-36

9-18%

2-8%

3-4%

72-151%

N/A

Net derivative assets (liabilities)

Discounted cash flows

Swap rates

1-2%

__________

We are required to measure and recognize certain assets at fair value on a nonrecurring basis on the consolidated balance sheets. These assets are not measured at fair value on an ongoing basis but are subject to fair value adjustments in certain circumstances (for example, from the application of lower of cost or fair value accounting or when we evaluate for impairment).

The following table presents the carrying value of the assets measured at fair value on a nonrecurring basis and still held as of June 30, 2022 and December 31, 2021, and for which a nonrecurring fair value measurement was recorded during the six and twelve months then ended.


	December 31, 2021
	Estimated Fair Value Hierarchy				Total
(Dollars in millions)	Level 2		Level 3
Loans held for investment	$	0	$	194	$	194
Loans held for sale	118		0		118
Other assets(1)	0		325		325
Total	$	118	$	519	$	637

__________

(1)As of June 30, 2022, other assets included investments accounted for under measurement alternative of $1 million, repossessed assets of $52 million and long-lived assets held for sale of $38 million. As of December 31, 2021, other assets included equity method investments of $50 million, investments accounted for under measurement alternative of $29 million, repossessed assets of $40 million and long-lived assets held for sale of $206 million.

In the above table, loans held for investment are generally valued based in part on the estimated fair value of the underlying collateral and the non-recoverable rate, which is considered to be a significant unobservable input. The non-recoverable rate ranged from 0% to 100%, with a weighted average of 20%, and from 0% to 100%, with a weighted average of 13%, as of June 30, 2022 and December 31, 2021, respectively. The weighted average non-recoverable rate is calculated based on the estimated market value of the underlying collateral. The significant unobservable inputs and related quantitative information related to fair value of the other assets are not meaningful to disclose as they vary significantly across properties and collateral.

The following table presents the carrying value and estimated fair value, including the level within the fair value hierarchy, of our financial instruments that are not measured at fair value on a recurring basis on our consolidated balance sheets as of June 30, 2022 and December 31, 2021.


	June 30, 2022
	Carrying Value		Estimated Fair Value		Estimated Fair Value Hierarchy
(Dollars in millions)					Level 1		Level 2		Level 3
Financial assets:
Cash and cash equivalents	$	21,553	$	21,553	$	4,825	$	16,728	$	0
Restricted cash for securitization investors	697		697		697		0		0

Net loans held for investment	284,893		287,254		0		0		287,254
Loans held for sale	108		110		0		110		0
Interest receivable	1,611		1,611		0		1,611		0
Other investments(1)	1,735		1,735		0		1,735		0
Financial liabilities:
Deposits with defined maturities	22,225		22,026		0		22,026		0
Securitized debt obligations	17,466		17,446		0		17,446		0
Senior and subordinated notes	30,489		30,152		0		30,152		0
Federal funds purchased and securities loaned or sold under agreements to repurchase	440		440		0		440		0
Other borrowings(2)	10,500		10,501		0		10,501		0
Interest payable	333		333		0		333		0


	December 31, 2021
	Carrying Value		Estimated Fair Value		Estimated Fair Value Hierarchy
(Dollars in millions)					Level 1		Level 2		Level 3
Financial assets:
Cash and cash equivalents	$	21,746	$	21,746	$	4,164	$	17,582	$	0
Restricted cash for securitization investors	308		308		308		0		0
Net loans held for investment	265,910		270,508		0		0		270,508
Loans held for sale	4,862		5,091		0		5,091		0
Interest receivable	1,460		1,460		0		1,460		0
Other investments(1)	1,344		1,344		0		1,344		0
Financial liabilities:
Deposits with defined maturities	17,923		18,062		0		18,062		0
Securitized debt obligations	14,994		15,122		0		15,122		0
Senior and subordinated notes	27,219		27,842		0		27,842		0
Federal funds purchased and securities loaned or sold under agreements to repurchase	820		820		0		820		0

Interest payable	281		281		0		281		0

__________