RESTRUCTURING CHARGES

The Corporation launched an initiative in 2016 designed to reduce overhead and increase revenue (the "GEAR Up" initiative). The actions in the initiative include, but are not limited to, a reduction in workforce, a new retirement program, streamlining operational processes, real estate optimization including consolidating banking centers as well as reducing office and operations space, selective outsourcing of technology functions, reduction of technology system applications, enhanced sales tools and training, expanded product offerings and improved customer analytics to drive opportunities.

Certain actions associated with the GEAR Up initiative result in restructuring charges. Generally, costs associated with or incurred to generate revenue as part of the initiative are recorded according to the nature of the cost and are not included in restructuring charges. The Corporation considers the following costs associated with the initiative to be restructuring charges:


•	Employee costs: Primarily severance costs in accordance with the Corporation’s severance plan.


•	Facilities costs: Costs pertaining to consolidating banking centers and other facilities, such as lease termination costs and decommissioning costs. Also includes accelerated depreciation and impairment of owned property to be sold.


•	Technology costs: Impairment and other costs associated with optimizing technology infrastructure and reducing the number of applications.


•	Other costs: Includes primarily professional fees, as well as other contract termination fees and legal fees incurred in the execution of the initiative.

Restructuring charges are recorded as a component of noninterest expenses on the Consolidated Statements of Comprehensive Income. The following table presents changes in restructuring reserves, cumulative charges incurred to date and total expected restructuring charges:



(in millions)	Employee Costs			Facilities Costs			Technology Costs			Other Costs			Total

Three Months Ended September 30, 2018
Balance at beginning of period	$	4		$	—		$	11		$	—		$	15
Restructuring charges	2			1			8			1			12
Payments	(3		)	(1		)	(12		)	(1		)	(17		)
Balance at end of period	$	3		$	—		$	7		$	—		$	10

Three Months Ended September 30, 2017
Balance at beginning of period	$	6		$	—		$	3		$	2		$	11
Restructuring charges	1			—			5			1			7
Payments	(1		)	—			(4		)	(1		)	(6		)
Balance at end of period	$	6		$	—		$	4		$	2		$	12

Nine Months Ended September 30, 2018
Balance at beginning of period	$	8		$	—		$	6		$	1		$	15
Restructuring charges	7			3			28			1			39
Payments	(12		)	(3		)	(27		)	(2		)	(44		)
Balance at end of period	$	3		$	—		$	7		$	—		$	10

Nine Months Ended September 30, 2017
Balance at beginning of period	$	10		$	4		$	—		$	4		$	18
Restructuring charges	5			5			17			5			32
Payments	(9		)	(9		)	(8		)	(7		)	(33		)
Adjustments for non-cash charges (a)	—			—			(5		)	—			(5		)
Balance at end of period	$	6		$	—		$	4		$	2		$	12

Total restructuring charges incurred to date	$	69		$	20		$	54		$	34		$	177
Total expected restructuring charges (b)	70			20			60 - 65			35			185 - 190


(a)	Adjustments for non-cash charges primarily relate to impairments of previously capitalized software costs in Technology Costs.


(b)	Restructuring activities are expected to be substantially completed by 12/31/2018.

Restructuring charges directly attributable to a business segment are assigned to that business segment. For example, facilities costs pertaining to the consolidation of banking centers primarily impacted the Retail Bank. Restructuring charges incurred by areas whose services support the overall Corporation are allocated based on the methodology described in note 22 to the consolidated financial statements in the Corporation's 2017 Annual Report. Total restructuring charges assigned to the Business Bank, Retail Bank and Wealth Management were $6 million, $4 million and $2 million, respectively, for the three months ended September 30, 2018 and $23 million, $11 million and $5 million, respectively, for nine months ended September 30, 2018. Total restructuring charges assigned to the Business Bank, Retail Bank and Wealth Management were $4 million, $2 million and $1 million, respectively, for the three months ended September 30, 2017 and $20 million, $7 million and $5 million, respectively, for the nine months ended September 30, 2017.