FAIR VALUE MEASUREMENTS

The Corporation utilizes fair value measurements to record fair value adjustments to certain assets and liabilities and to determine fair value disclosures. The determination of fair values of financial instruments often requires the use of estimates. In cases where quoted market values in an active market are not available, the Corporation uses present value techniques and other valuation methods to estimate the fair values of its financial instruments. These valuation methods require considerable judgment and the resulting estimates of fair value can be significantly affected by the assumptions made and methods used.

Fair value is an estimate of the exchange price that would be received to sell an asset or paid to transfer a liability in an orderly transaction (i.e., not a forced transaction, such as a liquidation or distressed sale) between market participants at the measurement date. However, the calculated fair value estimates in many instances cannot be substantiated by comparison to independent markets and, in many cases, may not be realizable in a current sale of the financial instrument.

Trading securities, investment securities available-for-sale, derivatives and deferred compensation plan liabilities are recorded at fair value on a recurring basis. Additionally, from time to time, the Corporation may be required to record other assets and liabilities at fair value on a nonrecurring basis, such as impaired loans, other real estate (primarily foreclosed property), nonmarketable equity securities and certain other assets and liabilities. These nonrecurring fair value adjustments typically involve write-downs of individual assets or application of lower of cost or fair value accounting.

The Corporation categorizes assets and liabilities recorded at fair value into a three-level hierarchy, based on the markets in which the assets and liabilities are traded and the reliability of the assumptions used to determine fair value. These levels are:



	Level 1		Valuation is based upon quoted prices for identical instruments traded in active markets.

	Level 2		Valuation is based upon quoted prices for similar instruments in active markets, quoted prices for identical or similar instruments in markets that are not active, and model-based valuation techniques for which all significant assumptions are observable in the market.

	Level 3		Valuation is generated from model-based techniques that use at least one significant assumption not observable in the market. These unobservable assumptions reflect estimates of assumptions that market participants would use in pricing the asset or liability. Valuation techniques include use of option pricing models, discounted cash flow models and similar techniques.

The Corporation generally utilizes third-party pricing services to value Level 1 and Level 2 trading and investment securities, as well as certain derivatives designated as fair value hedges. Management reviews the methodologies and assumptions used by the third-party pricing services and evaluates the values provided, principally by comparison with other available market quotes for similar instruments and/or analysis based on internal models using available third-party market data. The Corporation may occasionally adjust certain values provided by the third-party pricing service when management believes, as the result of its review, that the adjusted price most appropriately reflects the fair value of the particular security.

Following is a description of the valuation methodologies and key inputs used to measure financial assets and liabilities recorded at fair value, as well as a description of the methods and significant assumptions used to estimate fair value disclosures for financial instruments not recorded at fair value in their entirety on a recurring basis. For financial assets and liabilities recorded at fair value, the description includes an indication of the level of the fair value hierarchy in which the assets or liabilities are classified. Transfers of assets or liabilities between levels of the fair value hierarchy are recognized at the beginning of the reporting period, when applicable.

Cash and due from banks, federal funds sold and interest-bearing deposits with banks

Due to the short-term nature, the carrying amount of these instruments approximates the estimated fair value.

Trading securities and associated deferred compensation plan liabilities

Securities held for trading purposes and associated deferred compensation plan liabilities are recorded at fair value and included in “other short-term investments” and “accrued expenses and other liabilities,” respectively, on the consolidated balance sheets. Level 1 securities held for trading purposes include assets related to employee deferred compensation plans, which are invested in mutual funds, U.S. Treasury securities that are traded by dealers or brokers in active over-the-counter markets and other securities traded on an active exchange, such as the New York Stock Exchange. Deferred compensation plan liabilities represent the fair value of the obligation to the employee, which corresponds to the fair value of the invested assets. Level 2 trading securities include municipal bonds and residential mortgage-backed securities issued by U.S. government-sponsored entities and corporate debt securities. Securities classified as Level 3 include securities in less liquid markets and securities not rated by a credit agency. The methods used to value trading securities are the same as the methods used to value investment securities available-for-sale, discussed below.

Loans held-for-sale

Loans held-for-sale, included in “other short-term investments” on the consolidated balance sheets, are recorded at the lower of cost or fair value. The fair value of loans held-for-sale is based on what secondary markets are currently offering for portfolios with similar characteristics. As such, the Corporation classifies loans held-for-sale subjected to nonrecurring fair value adjustments as Level 2.

Investment securities available-for-sale

Investment securities available-for-sale are recorded at fair value on a recurring basis. Fair value measurement is based upon quoted prices, if available. If quoted prices are not available or the market is deemed to be inactive at the measurement date, an adjustment to the quoted prices may be necessary. In some circumstances, the Corporation may conclude that a change in valuation technique or the use of multiple valuation techniques may be appropriate to estimate an instrument’s fair value. Level 1 securities include those traded on an active exchange, such as the New York Stock Exchange, U.S. Treasury securities that are traded by dealers or brokers in active over-the-counter markets and money market funds. Level 2 securities include residential mortgage-backed securities issued by U.S. government agencies and U.S. government-sponsored enterprises, corporate debt securities and state and municipal securities. The fair value of Level 2 securities was determined using quoted prices of securities with similar characteristics or pricing models based on observable market data inputs, primarily interest rates, spreads and prepayment information. Securities classified as Level 3, of which the substantial majority is auction-rate securities, represent securities in less liquid markets requiring significant management assumptions when determining fair value. Due to the lack of a robust secondary auction-rate securities market with active fair value indicators, fair value at December 31, 2011 and December 31, 2010 was determined using an income approach based on a discounted cash flow model utilizing two significant assumptions: discount rate (including a liquidity risk premium) and workout period. The discount rate was calculated using credit spreads of the underlying collateral or similar securities plus a liquidity risk premium. The liquidity risk premium was based on observed industry auction-rate securities valuations by third parties and incorporated the rate at which the various types of similar ARS had been redeemed or sold since acquisition in 2008. The workout period was based on an assessment of publicly available information on efforts to re-establish functioning markets for these securities and the Corporation’s redemption experience. As of December 31, 2011, approximately 65 percent of the aggregate ARS par value had been redeemed or sold since acquisition.

Loans

The Corporation does not record loans at fair value on a recurring basis. However, periodically, the Corporation records nonrecurring adjustments to the carrying value of loans based on fair value measurements. Loans for which it is probable that payment of interest or principal will not be made in accordance with the contractual terms of the original loan agreement are considered impaired. Impaired loans are reported as nonrecurring fair value measurements when an allowance is established based on the fair value of collateral. When the fair value of the collateral is based on an observable market price or a current appraised value, the Corporation classifies the impaired loan as nonrecurring Level 2. When management determines that the fair value of the collateral requires additional adjustments, either as a result of non-current appraisal value or when there is no observable market price, the Corporation classifies the impaired loan as nonrecurring Level 3.

Business loans consist of commercial, real estate construction, commercial mortgage, lease financing and international loans. The estimated fair value for variable rate business loans that reprice frequently is based on carrying values adjusted for estimated credit losses and other adjustments that would be expected to be made by a market participant in an active market. The fair value for other business loans and retail loans are estimated using a discounted cash flow model that employs interest rates currently offered on the loans, adjusted by an amount for estimated credit losses and other adjustments that would be expected to be made by a market participant in an active market. The rates take into account the expected yield curve, as well as an adjustment for prepayment risk, when applicable.

Customers’ liability on acceptances outstanding and acceptances outstanding

The carrying amount of these instruments approximates the estimated fair value, due to their short-term nature.

Derivative assets and derivative liabilities

Derivative instruments held or issued for risk management or customer-initiated activities are traded in over-the-counter markets where quoted market prices are not readily available. Fair value for over-the-counter derivative instruments is measured using internally developed models that use primarily market observable inputs, such as yield curves and option volatilities. Included in the fair value of over-the-counter derivative instruments are credit valuation adjustments reflecting counterparty credit risk and credit risk of the Corporation. These adjustments are determined by applying a credit spread for the counterparty or the Corporation, as appropriate, to the total expected exposure of the derivative after considering collateral and other master netting arrangements. These adjustments, which are considered Level 3 inputs, are based on estimates of current credit spreads to evaluate the likelihood of default. The Corporation assessed the significance of the impact of the credit valuation adjustments on the overall valuation of its derivative positions and determined that the credit valuation adjustments were not significant to the overall valuation of its derivatives. As a result, the Corporation classified its over-the-counter derivative valuations in Level 2 of the fair value hierarchy. Examples of Level 2 derivative instruments are interest rate swaps and energy derivative and foreign exchange contracts.

The Corporation also holds a portfolio of warrants for generally nonmarketable equity securities. These warrants are primarily from high technology, non-public companies obtained as part of the loan origination process. Warrants which contain a net exercise provision or a non-contingent put right embedded in the warrant agreement are accounted for as derivatives and recorded at fair value using a Black-Scholes valuation model with five inputs: risk-free rate, expected life, volatility, exercise price, and the per share market value of the underlying company. The Corporation classifies warrants accounted for as derivatives as recurring Level 3.

The Corporation holds a derivative contract associated with the 2008 sale of its remaining ownership of Visa Inc. (Visa) Class B shares. Under the terms of the derivative contract, the Corporation will compensate the counterparty primarily for dilutive adjustments made to the conversion factor of the Visa Class B to Class A shares based on the ultimate outcome of litigation involving Visa. Conversely, the Corporation will be compensated by the counterparty for any increase in the conversion factor from anti-dilutive adjustments. The fair value of the derivative contract was based on unobservable inputs consisting of management’s estimate of the litigation outcome, timing of litigation settlements and payments related to the derivative. The Corporation classifies the derivative liability as recurring Level 3.

Nonmarketable equity securities

The Corporation has a portfolio of indirect (through funds) private equity and venture capital investments. These funds generally cannot be redeemed and the majority is not readily marketable. Distributions from these funds are received by the Corporation as a result of the liquidation of underlying investments of the funds and/or as income distributions. It is estimated that the underlying assets of the funds will be liquidated over a period of up to 15 years. The value of these investments is at risk to changes in equity markets, general economic conditions and a variety of other factors. The investments are accounted for on the cost or equity method and are individually reviewed for impairment on a quarterly basis by comparing the carrying value to the estimated fair value. These investments may be carried at fair value on a nonrecurring basis when they are deemed to be impaired and written down to fair value. For such investments, fair value measurement guidance permits the use of net asset value, provided the net asset value is calculated by the fund in compliance with fair value measurement guidance applicable to investment companies. Where there is not a readily determinable fair value, the Corporation estimates fair value for indirect private equity and venture capital investments based on the Corporation’s percentage ownership in the net asset value of the entire fund, as reported by the fund, after indication that the fund adheres to applicable fair value measurement guidance. For those funds where the net asset value is not reported by the fund, the Corporation derives the fair value of the fund by estimating the fair value of each underlying investment in the fund. In addition to using qualitative information about each underlying investment, as provided by the fund, the Corporation gives consideration to information pertinent to the specific nature of the debt or equity investment, such as relevant market conditions, offering prices, operating results, financial conditions, exit strategy and other qualitative information, as available. The lack of an independent source to validate fair value estimates, including the impact of future capital calls and transfer restrictions, is an inherent limitation in the valuation process. Commitments to fund additional investments in nonmarketable equity securities recorded at fair value on a nonrecurring basis were $1 million at both December 31, 2011 and 2010.

The Corporation also holds restricted equity investments, primarily Federal Home Loan Bank (FHLB) and Federal Reserve Bank (FRB) stock. Restricted equity securities are not readily marketable and are recorded at cost (par value) and evaluated for impairment based on the ultimate recoverability of the par value. No significant observable market data for these instruments is available. The Corporation considers the profitability and asset quality of the issuer, dividend payment history and recent redemption experience, when determining the ultimate recoverability of the par value. The Corporation’s investment in FHLB stock totaled $92 million and $128 million at December 31, 2011 and 2010, respectively, and its investment in FRB stock totaled $85 million and $59 million at December 31, 2011 and 2010, respectively. The Corporation believes its investments in FHLB and FRB stock are ultimately recoverable at par.

The Corporation classifies nonmarketable equity securities subjected to nonrecurring fair value adjustments as Level 3.

Other real estate

Other real estate is included in “accrued income and other assets” on the consolidated balance sheets and includes primarily foreclosed property. Foreclosed property is initially recorded at fair value, less costs to sell, at the date of foreclosure, establishing a new cost basis. Subsequently, foreclosed property is carried at the lower of cost or fair value, less costs to sell. Other real estate may be carried at fair value on a nonrecurring basis when fair value is less than cost. Fair value is based upon independent market prices, appraised value or management’s estimate of the value. Foreclosed property carried at fair value based on an observable market price or a current appraised value is classified by the Corporation as nonrecurring Level 2. When management determines that the fair value of the foreclosed property requires additional adjustments, either as a result of a non-current appraisal or when there is no observable market price, the Corporation classifies the foreclosed property as nonrecurring Level 3.

Loan servicing rights

Loan servicing rights, included in “accrued income and other assets” on the consolidated balance sheets and primarily related to Small Business Administration loans, are subject to impairment testing. A valuation model is used for impairment testing, which utilizes a discounted cash flow analysis using interest rates and prepayment speed assumptions currently quoted for comparable instruments and a discount rate determined by management. If the valuation model reflects a value less than the carrying value, loan servicing rights are adjusted to fair value through a valuation allowance as determined by the model. As such, the Corporation classifies loan servicing rights subjected to nonrecurring fair value adjustments as Level 3.

Deposit liabilities

The estimated fair value of checking, savings and certain money market deposit accounts is represented by the amounts payable on demand. The estimated fair value of term deposits is calculated by discounting the scheduled cash flows using the period-end rates offered on these instruments.

Short-term borrowings

The carrying amount of federal funds purchased, securities sold under agreements to repurchase and other short-term borrowings approximates the estimated fair value.

Medium- and long-term debt

The carrying value of variable-rate FHLB advances approximates the estimated fair value. The estimated fair value of the Corporation’s remaining variable- and fixed-rate medium- and long-term debt is based on quoted market values. If quoted market values are not available, the estimated fair value is based on the market values of debt with similar characteristics.

Credit-related financial instruments

The estimated fair value of unused commitments to extend credit and standby and commercial letters of credit is represented by the estimated cost to terminate or otherwise settle the obligations with the counterparties. This amount is approximated by the fees currently charged to enter into similar arrangements, considering the remaining terms of the agreements and any changes in the credit quality of counterparties since the agreements were executed. This estimate of fair value does not take into account the significant value of the customer relationships and the future earnings potential involved in such arrangements as the Corporation does not believe that it would be practicable to estimate a representational fair value for these items.

ASSETS AND LIABILITIES RECORDED AT FAIR VALUE ON A RECURRING BASIS

The following tables present the recorded amount of assets and liabilities measured at fair value on a recurring basis as of December 31, 2011 and 2010.



(in millions)	Total		Level 1		Level 2		Level 3
December 31, 2011
Trading securities:
Deferred compensation plan assets	$	90	$	90	$	—	$	—
Residential mortgage-backed securities (a)	2		—		2		—
Other government-sponsored enterprise securities	9		—		9		—
State and municipal securities	12		—		12		—
Corporate debt securities	1		—		1		—
Other securities	1		1		—		—
Total trading securities	115		91		24		—
Investment securities available-for-sale:
U.S. Treasury and other U.S. government agency securities	20		20		—		—
Residential mortgage-backed securities (a)	9,512		—		9,512		—
State and municipal securities (b)	24		—		—		24
Corporate debt securities:
Auction-rate debt securities	1		—		—		1
Other corporate debt securities	46		—		46		—
Equity and other non-debt securities:
Auction-rate preferred securities	408		—		—		408
Money market and other mutual funds	93		93		—		—
Total investment securities available-for-sale	10,104		113		9,558		433
Derivative assets:
Interest rate contracts	602		—		602		—
Energy derivative contracts	115		—		115		—
Foreign exchange contracts	40		—		40		—
Warrants	3		—		—		3
Total derivative assets	760		—		757		3
Total assets at fair value	$	10,979	$	204	$	10,339	$	436
Derivative liabilities:
Interest rate contracts	$	253	$	—	$	253	$	—
Energy derivative contracts	115		—		115		—
Foreign exchange contracts	35		—		35		—
Other	6		—		—		6
Total derivative liabilities	409		—		403		6
Deferred compensation plan liabilities	90		90		—		—
Total liabilities at fair value	$	499	$	90	$	403	$	6


(a)	Residential mortgage-backed securities issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.


(b)	Primarily auction-rate securities.



(in millions)	Total		Level 1		Level 2		Level 3
December 31, 2010
Trading securities:
Deferred compensation plan assets	$	86	$	86	$	—	$	—
Residential mortgage-backed securities (a)	7		—		7		—
Other government-sponsored enterprise securities	1		—		1		—
State and municipal securities	19		—		19		—
Corporate debt securities	4		—		4		—
Other securities	1		—		—		1
Total trading securities	118		86		31		1
Investment securities available-for-sale:
U.S. Treasury and other U.S. government agency securities	131		131		—		—
Residential mortgage-backed securities (a)	6,709		—		6,709		—
State and municipal securities (b)	39		—		—		39
Corporate debt securities:
Auction-rate debt securities	1		—		—		1
Other corporate debt securities	26		—		25		1
Equity and other non-debt securities:
Auction-rate preferred securities	570		—		—		570
Money market and other mutual funds	84		84		—		—
Total investment securities available-for-sale	7,560		215		6,734		611
Derivative assets:
Interest rate contracts	542		—		542		—
Energy derivative contracts	103		—		103		—
Foreign exchange contracts	51		—		51		—
Warrants	7		—		—		7
Total derivative assets	703		—		696		7
Total assets at fair value	$	8,381	$	301	$	7,461	$	619
Derivative liabilities:
Interest rate contracts	$	249	$	—	$	249	$	—
Energy derivative contracts	103		—		103		—
Foreign exchange contracts	48		—		48		—
Other	1		—		—		1
Total derivative liabilities	401		—		400		1
Deferred compensation plan liabilities	86		86		—		—
Total liabilities at fair value	$	487	$	86	$	400	$	1


(a)	Residential mortgage-backed securities issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.


(b)	Primarily auction-rate securities.

There were no transfers of assets or liabilities recorded at fair value on a recurring basis into or out of Level 1, Level 2 and Level 3 fair value measurements during the years ended December 31, 2011 and 2010.

The following table summarizes the changes in Level 3 assets and liabilities measured at fair value on a recurring basis for the years ended December 31, 2011 and 2010.



			Net Realized/Unrealized Gains (Losses)
	Balance at Beginning of Period								Recorded in Other Comprehensive Income (Pre-tax)
			Recorded in Earnings																	Balance at End of Period
(in millions)			Realized			Unrealized						Purchases		Sales			Settlements
Year Ended December 31, 2011
Trading securities:
State and municipal securities	$	—	$	—		$	—		$	—		$	3	$	(3	)	$	—		$	—
Other securities	1		—			—			—			—		(1		)	—			—
Total trading securities	1		—			—			—			3		(4		)	—			—
Investment securities available-for-sale:
State and municipal securities (a)	39		—			—			2			—		(17		)	—			24
Auction-rate debt securities	1		—			—			—			—		—			—			1
Other corporate debt securities	1		—			—			—			—		—			(1		)	—
Auction-rate preferred securities	570		10			—			12			—		(184		)	—			408
Total investment securities available-for-sale	611		10			—			14			—		(201		)	(1		)	433
Derivative assets:
Warrants	7		10			—			—			—		(14		)	—			3
Derivative liabilities:
Other	1		(2		)	(5		)	—			—		—			(2		)	6
Year Ended December 31, 2010
Trading securities:
State and municipal securities	$	—	$	—		$	—		$	—		$	3	$	(3	)	$	—		$	—
Other securities	—		—			1			—			—		—			—			1
Total trading securities	—		—			1			—			3		(3		)	—			1
Investment securities available-for-sale:
State and municipal securities (a)	46		(1		)	—			(2		)	—		(4		)	—			39
Auction-rate debt securities	150		3			—			5			—		(157		)	—			1
Other corporate debt securities	7		27			—			—			—		—			(33		)	1
Auction-rate preferred securities	706		6			—			(21		)	—		(121		)	—			570
Total investment securities available-for-sale	909		35			—			(18		)	—		(282		)	(33		)	611
Derivative assets:
Warrants	7		2			1			—			1		(4		)	—			7
Derivative liabilities:
Other	—		(4		)	(1		)	—			—		—			(4		)	1


(a)	Primarily auction-rate securities

The following table presents the income statement classification of realized and unrealized gains and losses due to changes in fair value recorded in earnings for the years ended December 31, 2011 and 2010 for recurring Level 3 assets and liabilities, as shown in the previous table.



	Net Securities Gains (Losses)						Other Noninterest Income				Discontinued Operations		Total
(in millions)	Realized			Unrealized			Realized		Unrealized		Realized		Realized			Unrealized
Year Ended December 31, 2011
Investment securities available-for-sale:
Auction-rate preferred securities	$	10		$	—		$	—	$	—	$	—	$	10		$	—
Derivative assets:
Warrants	—			—			10		—		—		10			—
Derivative liabilities:
Other	(2		)	(5		)	—		—		—		(2		)	(5		)
Year Ended December 31, 2010
Trading securities:
Other securities	$	—		$	—		$	—	$	1	$	—	$	—		$	1
Investment securities available-for-sale:
State and municipal securities (a)	(1		)	—			—		—		—		(1		)	—
Auction-rate debt securities	3			—			—		—		—		3			—
Other corporate debt securities	—			—			—		—		27		27			—
Auction-rate preferred securities	6			—			—		—		—		6			—
Total investment securities available-for-sale	8			—			—		—		27		35			—
Derivative assets:
Warrants	—			—			2		1		—		2			1
Derivative liabilities:
Other	(4		)	(1		)	—		—		—		(4		)	(1		)


(a)	Primarily auction-rate securities.

ASSETS AND LIABILITIES RECORDED AT FAIR VALUE ON A NONRECURRING BASIS

The Corporation may be required, from time to time, to record certain assets and liabilities at fair value on a nonrecurring basis. These include assets that are recorded at the lower of cost or fair value that were recognized at fair value below cost at the end of the period. Assets recorded at fair value on a nonrecurring basis are presented in the following table. No liabilities were recorded at fair value on a nonrecurring basis at December 31, 2011 and 2010.



(in millions)	Total		Level 2		Level 3
December 31, 2011
Loans held-for-sale:
Residential mortgage	$	8	$	8	$	—
Loans:
Commercial	191		—		191
Real estate construction	88		—		88
Commercial mortgage	317		—		317
Lease financing	3		—		3
International	8		—		8
Total loans	607		—		607
Nonmarketable equity securities	1		—		1
Other real estate	29		—		29
Loan servicing rights	3		—		3
Total assets at fair value	$	648	$	8	$	640
December 31, 2010
Loans held-for-sale:
Residential mortgage	$	6	$	6	$	—
Loans:
Commercial	200		—		200
Real estate construction	247		—		247
Commercial mortgage	398		—		398
Lease financing	7		—		7
International	2		—		2
Total loans	854		—		854
Nonmarketable equity securities	9		—		9
Other real estate	33		—		33
Loan servicing rights	5		—		5
Total assets at fair value	$	907	$	6	$	901

ESTIMATED FAIR VALUES OF FINANCIAL INSTRUMENTS NOT RECORDED AT FAIR VALUE IN THEIR ENTIRETY ON A RECURRING BASIS

The Corporation typically holds the majority of its financial instruments until maturity and thus does not expect to realize many of the estimated fair value amounts disclosed. The disclosures also do not include estimated fair value amounts for items that are not defined as financial instruments, but which have significant value. These include such items as core deposit intangibles, the future earnings potential of significant customer relationships and the value of trust operations and other fee generating businesses. The Corporation believes the imprecision of an estimate could be significant.

The carrying amount and estimated fair value of financial instruments not recorded at fair value in their entirety on a recurring basis on the Corporation’s consolidated balance sheets are as follows:



	December 31
	2011						2010
(in millions)	Carrying Amount			Estimated Fair Value			Carrying Amount			Estimated Fair Value
Assets
Cash and due from banks	$	982		$	982		$	668		$	668
Interest-bearing deposits with banks	2,574			2,574			1,415			1,415
Loans held-for-sale	34			34			23			23
Total loans, net of allowance for loan losses (a)	41,953			42,233			39,335			39,212
Customers’ liability on acceptances outstanding	22			22			9			9
Nonmarketable equity securities (b)	16			27			47			77
Loan servicing rights	3			3			5			5
Liabilities
Demand deposits (noninterest-bearing)	19,764			19,764			15,538			15,538
Interest-bearing deposits	27,991			27,992			24,933			24,945
Total deposits	47,755			47,756			40,471			40,483
Short-term borrowings	70			70			130			130
Acceptances outstanding	22			22			9			9
Medium- and long-term debt	4,944			4,794			6,138			6,008
Credit-related financial instruments	(101		)	(101		)	(99		)	(99		)


(a)	Included $607 million and $854 million of impaired loans recorded at fair value on a nonrecurring basis at December 31, 2011 and 2010, respectively.


(b)	Included $1 million and $9 million of nonmarketable equity securities recorded at fair value on a nonrecurring basis at December 31, 2011 and 2010, respectively.