10-Q

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

______________________________

FORM 10-Q

______________________________

(Mark One)

☒ QUARTERLY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the quarterly period ended March 31, 2021

Or

☐ TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from              to             

Commission file number 1-10706

____________________________________________________________________________________

Comerica Incorporated

(Exact name of registrant as specified in its charter)

___________________________________________________________________________________

Delaware	38-1998421
(State or other jurisdiction of incorporation or organization)	(I.R.S. Employer Identification No.)

Comerica Bank Tower

1717 Main Street, MC 6404

Dallas, Texas 75201

(Address of principal executive offices)

(Zip Code)

(214) 462-6831

(Registrant’s telephone number, including area code) 

_________________________________________________________________________

Securities registered pursuant to Section 12(b) of the Act:

Title of each class	Trading symbol	Name of each exchange on which registered
Common Stock, $5 par value	CMA	New York Stock Exchange

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. Yes ý No o

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§ 232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files). Yes ý No o

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or an emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” and "emerging growth company" in Rule 12b-2 of the Exchange Act.

Large accelerated filer	☒	Accelerated filer	☐
Non-accelerated filer	☐	Smaller reporting company	☐
Emerging growth company	☐

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. o

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). Yes ☐ No ☒

Indicate the number of shares outstanding of each of the issuer's classes of common stock, as of the latest practicable date.

$5 par value common stock:

Outstanding as of April 26, 2021: 139,612,779 shares

COMERICA INCORPORATED AND SUBSIDIARIES

TABLE OF CONTENTS

PART I. FINANCIAL INFORMATION
ITEM 1. Financial Statements
Consolidated Balance Sheets at March 31, 2021 (unaudited) and December 31, 2020	1
Consolidated Statements of Comprehensive Income for the Three Months Ended March 31, 2021 and 2020 (unaudited)	2
Consolidated Statements of Changes in Shareholders’ Equity for the Three Months Ended March 31, 2021 and 2020 (unaudited)	3
Consolidated Statements of Cash Flows for the Three Months Ended March 31, 2021 and 2020 (unaudited)	4
Notes to Consolidated Financial Statements (unaudited)	5
ITEM 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations	32
ITEM 3. Quantitative and Qualitative Disclosures about Market Risk	58
ITEM 4. Controls and Procedures	58
PART II. OTHER INFORMATION
ITEM 1. Legal Proceedings	58
ITEM 1A. Risk Factors	58
ITEM 2. Unregistered Sales of Equity Securities and Use of Proceeds	58
ITEM 6. Exhibits	59
Signature	60

Part I. FINANCIAL INFORMATION

Item 1. Financial Statements

CONSOLIDATED BALANCE SHEETS

Comerica Incorporated and Subsidiaries

(in millions, except share data)	March 31, 2021		December 31, 2020
	(unaudited)		(recast)
ASSETS
Cash and due from banks	$	1,064	$	1,031
Interest-bearing deposits with banks	13,807		14,736
Other short-term investments	176		172
Investment securities available-for-sale	15,595		15,028
Commercial loans	30,886		32,753
Real estate construction loans	4,244		4,082
Commercial mortgage loans	9,993		9,912
Lease financing	577		594
International loans	990		926
Residential mortgage loans	1,799		1,830
Consumer loans	2,093		2,194
Total loans	50,582		52,291
Allowance for loan losses	(777)		(948)
Net loans	49,805		51,343
Premises and equipment	456		459
Accrued income and other assets	5,388		5,360
Total assets	$	86,291	$	88,129
LIABILITIES AND SHAREHOLDERS’ EQUITY
Noninterest-bearing deposits	$	38,822	$	39,420
Money market and interest-bearing checking deposits	29,880		28,540
Savings deposits	2,934		2,710
Customer certificates of deposit	2,141		2,133
Foreign office time deposits	30		66
Total interest-bearing deposits	34,985		33,449
Total deposits	73,807		72,869
Accrued expenses and other liabilities	1,480		1,482
Medium- and long-term debt	2,852		5,728
Total liabilities	78,139		80,079
Fixed rate reset non-cumulative perpetual preferred stock, series A, no par value, $100,000 liquidation preference per share:
Authorized - 4,000 shares
Issued - 4,000 shares at 3/31/2021 and 12/31/2020	394		394
Common stock - $5 par value:
Authorized - 325,000,000 shares
Issued - 228,164,824 shares	1,141		1,141
Capital surplus	2,183		2,185
Accumulated other comprehensive (loss) income	(105)		64
Retained earnings	9,975		9,727
Less cost of common stock in treasury - 88,579,635 shares at 3/31/2021 and 88,997,430 shares at 12/31/2020	(5,436)		(5,461)
Total shareholders’ equity	8,152		8,050
Total liabilities and shareholders’ equity	$	86,291	$	88,129

See notes to consolidated financial statements (unaudited).

1

CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME (unaudited)

Comerica Incorporated and Subsidiaries 

	Three Months Ended March 31,
(in millions, except per share data)	2021		2020
			(recast)
INTEREST INCOME
Interest and fees on loans	$	386	$	517
Interest on investment securities	69		74
Interest on short-term investments	4		18
Total interest income	459		609
INTEREST EXPENSE
Interest on deposits	7		56
Interest on medium- and long-term debt	9		40
Total interest expense	16		96
Net interest income	443		513
Provision for credit losses	(182)		411
Net interest income after provision for credit losses	625		102
NONINTEREST INCOME
Card fees	71		59
Fiduciary income	53		54
Service charges on deposit accounts	48		49
Derivative income	30		20
Commercial lending fees	18		17
Bank-owned life insurance	11		12
Letter of credit fees	10		9
Brokerage fees	4		7
Net securities losses	—		(1)
Other noninterest income	25		11
Total noninterest income	270		237
NONINTEREST EXPENSES
Salaries and benefits expense	282		242
Outside processing fee expense	64		57
Occupancy expense	39		37
Software expense	39		37
Equipment expense	12		12
Advertising expense	6		7
FDIC insurance expense	6		8
Other noninterest expenses	(1)		17
Total noninterest expenses	447		417
Income (loss) before income taxes	448		(78)
Provision (benefit) for income taxes	98		(19)
NET INCOME (LOSS)	350		(59)
Less:
Income allocated to participating securities	1		—
Preferred stock dividends	6		—
Net income (loss) attributable to common shares	$	343	$	(59)
Earnings (losses) per common share:
Basic	$	2.46	$	(0.42)
Diluted	2.43		(0.42)
Comprehensive income	181		344
Cash dividends declared on common stock	95		94
Cash dividends declared per common share	0.68		0.68

See notes to consolidated financial statements (unaudited).

2

CONSOLIDATED STATEMENTS OF CHANGES IN SHAREHOLDERS’ EQUITY (unaudited)

Comerica Incorporated and Subsidiaries

								Accumulated
	Nonredeemable		Common Stock					Other						Total
	Preferred		Shares			Capital		Comprehensive		Retained		Treasury		Shareholders'
(in millions, except per share data)	Stock		Outstanding	Amount		Surplus		Income (Loss)		Earnings		Stock		Equity
BALANCE AT DECEMBER 31, 2019 (recast)	$	—	142.1	$	1,141	$	2,174	$	(316)	$	9,619	$	(5,291)	$	7,327
Cumulative effect of change in accounting principle	—		—	—		—		—		13		—		13
Net loss	—		—	—		—		—		(59)		—		(59)
Other comprehensive income, net of tax	—		—	—		—		403		—		—		403
Cash dividends declared on common stock ($0.68 per share)	—		—	—		—		—		(94)		—		(94)
Purchase of common stock	—		(3.4)	—		—		—		—		(195)		(195)
Net issuance of common stock under employee stock plans	—		0.3	—		(14)		—		(3)		16		(1)
Share-based compensation	—		—	—		8		—		—		—		8
BALANCE AT MARCH 31, 2020 (recast)	$	—	139.0	$	1,141	$	2,168	$	87	$	9,476	$	(5,470)	$	7,402
BALANCE AT DECEMBER 31, 2020 (recast)	$	394	139.2	$	1,141	$	2,185	$	64	$	9,727	$	(5,461)	$	8,050
Net income	—		—	—		—		—		350		—		350
Other comprehensive loss, net of tax	—		—	—		—		(169)		—		—		(169)
Cash dividends declared on common stock ($0.68 per share)	—		—	—		—		—		(95)		—		(95)
Cash dividends declared on preferred stock	—		—	—		—		—		(6)		—		(6)
Purchase of common stock	—		(0.1)	—		—		—		—		(3)		(3)
Net issuance of common stock under employee stock plans	—		0.5	—		(24)		—		(1)		28		3
Share-based compensation	—		—	—		22		—		—		—		22
BALANCE AT MARCH 31, 2021	$	394	139.6	$	1,141	$	2,183	$	(105)	$	9,975	$	(5,436)	$	8,152

See notes to consolidated financial statements (unaudited).

3

CONSOLIDATED STATEMENTS OF CASH FLOWS (unaudited)

Comerica Incorporated and Subsidiaries

	Three Months Ended March 31,
(in millions)	2021		2020
			(recast)
OPERATING ACTIVITIES
Net income (loss)	$	350	$	(59)
Adjustments to reconcile net income (loss) to net cash provided by operating activities:
Provision for credit losses	(182)		411
Provision (benefit) for deferred income taxes	39		(71)
Depreciation and amortization	25		26
Net periodic defined benefit credit	(20)		(13)
Share-based compensation expense	22		8
Net amortization of securities	8		1
Net securities losses	—		1
Net change in:
Accrued income receivable	(5)		8
Accrued expenses payable	26		(12)
Other, net	(104)		399
Net cash provided by operating activities	159		699
INVESTING ACTIVITIES
Investment securities available-for-sale:
Maturities and redemptions	992		598
Purchases	(1,750)		(920)
Net change in loans	1,685		(3,174)
Net increase in premises and equipment	(18)		(15)
Federal Home Loan Bank stock:
Purchases	—		(31)
Redemptions	115		—
Proceeds from bank-owned life insurance settlements	5		8
Other, net	(21)		—
Net cash provided by (used in) investing activities	1,008		(3,534)
FINANCING ACTIVITIES
Net change in:
Deposits	824		(29)
Short-term borrowings	—		2,192
Medium- and long-term debt:
Maturities and redemptions	(2,800)		—
Preferred stock cash dividends paid	(6)		—
Common stock:
Repurchases	(8)		(199)
Cash dividends paid	(95)		(95)
Issuances under employee stock plans	10		3
Other, net	12		—
Net cash (used in) provided by financing activities	(2,063)		1,872
Net decrease in cash and cash equivalents	(896)		(963)
Cash and cash equivalents at beginning of period	15,767		5,818
Cash and cash equivalents at end of period	$	14,871	$	4,855
Interest paid	$	20	$	102
Income taxes paid	1		3

See notes to consolidated financial statements (unaudited).

4

NOTE 1 - BASIS OF PRESENTATION AND ACCOUNTING POLICIES

Organization

The accompanying unaudited consolidated financial statements were prepared in accordance with United States (U.S.) generally accepted accounting principles (GAAP) for interim financial information and with the instructions to Form 10-Q and Article 10 of Regulation S-X. Accordingly, the statements do not include all of the information and footnotes required by GAAP for complete financial statements. In the opinion of management, all adjustments (consisting of normal recurring accruals) considered necessary for a fair presentation were included. The results of operations for the three months ended March 31, 2021 are not necessarily indicative of the results that may be expected for the year ending December 31, 2021. Certain items in prior periods were reclassified to conform to the current presentation. For further information, refer to the consolidated financial statements and footnotes thereto included in the Annual Report of Comerica Incorporated and Subsidiaries (the Corporation) on Form 10-K for the year ended December 31, 2020.

Defined Benefit Pension and Other Postretirement Costs

Effective January 1, 2021, the Corporation elected to change the accounting methodology for determining the market-related value of assets (MRVA) for certain classes of assets in the qualified defined benefit pension plan. The MRVA is used to calculate the Corporation's expected return on plan assets, a component of defined pension benefit cost (credit). These classes are currently comprised of the fixed income securities and private placement assets held in the portfolio, utilized by the Corporation to mitigate the impacts to financial results from changes in fair value of the pension liability. Previously, MRVA was measured using a historical five-year average fair value. Under the new methodology, the Corporation calculates MRVA using fair value of plan assets. Although both methods are permitted under U.S. GAAP, the Corporation believes the new policy is preferable for these classes of assets as it results in more timely recognition of the performance of pension assets in the results from operations.

The change in accounting methodology is applied retrospectively to all prior periods presented in the consolidated financial statements. The impact of the change to the qualified defined benefit plan on the Corporation's consolidated financial statements is as follows:

Consolidated Balance Sheets

	March 31, 2021		December 31, 2020
(in millions)	Accounting Change Impact		Previously Reported		Accounting Change Impact		Recast Amounts
Accumulated other comprehensive income (loss)	$	(3)	$	168	$	(104)	$	64
Retained earnings	3		9,623		104		9,727

Consolidated Statements of Comprehensive Income

	Three Months Ended March 31,
	2021		2020
(in millions)	Accounting Change Impact		Previously Reported		Accounting Change Impact		Recast Amounts
Other noninterest expenses	$	(5)	$	25	$	(8)	$	17
Provision (benefit) for income taxes	2		(21)		2		(19)
Net income (loss)	3		(65)		6		(59)
Earnings (losses) per common share
Basic	$	0.03	$	(0.46)	$	0.04	$	(0.42)
Diluted	$	0.02	$	(0.46)	$	0.04	$	(0.42)

5

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

Consolidated Statements of Cash Flows

	Three Months Ended March 31,
	2021		2020
(in millions)	Accounting Change Impact		Previously Reported		Accounting Change Impact		Recast Amounts
Net (loss) income	$	3	$	(65)	$	6	$	(59)
(Benefit) provision for deferred income taxes	2		(73)		2		(71)
Net periodic defined benefit credit	(5)		(5)		(8)		(13)

NOTE 2 – 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.

Investment securities available-for-sale, derivatives, deferred compensation plans and equity securities with readily determinable fair values (primarily money market mutual funds) 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.

Refer to Note 1 to the consolidated financial statements in the Corporation's Annual Report on Form 10-K for the year ended December 31, 2020 for further information about the fair value hierarchy, descriptions 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.

6

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

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 March 31, 2021 and December 31, 2020.

(in millions)	Total		Level 1		Level 2		Level 3
March 31, 2021
Deferred compensation plan assets	$	108	$	108	$	—	$	—
Equity securities	54		54		—		—
Investment securities available-for-sale:
U.S. Treasury and other U.S. government agency securities	4,613		4,613		—		—
Residential mortgage-backed securities (a)	10,982		—		10,982		—
Total investment securities available-for-sale	15,595		4,613		10,982		—
Derivative assets:
Interest rate contracts	340		—		316		24
Energy contracts	269		—		269		—
Foreign exchange contracts	12		—		12		—
Total derivative assets	621		—		597		24
Total assets at fair value	$	16,378	$	4,775	$	11,579	$	24
Derivative liabilities:
Interest rate contracts	$	65	$	—	$	65	$	—
Energy contracts	265		—		265		—
Foreign exchange contracts	10		—		10		—
Total derivative liabilities	340		—		340		—
Deferred compensation plan liabilities	108		108		—		—
Total liabilities at fair value	$	448	$	108	$	340	$	—
December 31, 2020
Deferred compensation plan assets	$	107	$	107	$	—	$	—
Equity securities	60		60		—		—
Investment securities available-for-sale:
U.S. Treasury and other U.S. government agency securities	4,658		4,658		—		—
Residential mortgage-backed securities (a)	10,370		—		10,370		—
Total investment securities available-for-sale	15,028		4,658		10,370		—
Derivative assets:
Interest rate contracts	531		—		492		39
Energy contracts	151		—		151		—
Foreign exchange contracts	18		—		18		—
Total derivative assets	700		—		661		39
Total assets at fair value	$	15,895	$	4,825	$	11,031	$	39
Derivative liabilities:
Interest rate contracts	$	61	$	—	$	61	$	—
Energy contracts	149		—		149		—
Foreign exchange contracts	19		—		19		—
Total derivative liabilities	229		—		229		—
Deferred compensation plan liabilities	107		107		—		—
Total liabilities at fair value	$	336	$	107	$	229	$	—

(a)Issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.

    There were no transfers of assets or liabilities recorded at fair value on a recurring basis into or out of Level 3 fair value measurements during each of the three-month periods ended March 31, 2021 and 2020.

7

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

The following table summarizes the changes in Level 3 assets and liabilities measured at fair value on a recurring basis for the three-month periods ended March 31, 2021 and 2020.

			Net Realized/Unrealized Gains (Losses) (Pretax) Recorded in Earnings (a)
	Balance at Beginning of Period								Balance at End of Period
							Sales
(in millions)			Realized		Unrealized
Three Months Ended March 31, 2021
Derivative assets:
Interest rate contracts	$	39	$	—	$	(15)	$	—	$	24
Three Months Ended March 31, 2020
Derivative assets:
Interest rate contracts	$	22	$	—	$	21	$	—	$	43

(a)Realized and unrealized gains and losses due to changes in fair value are recorded in other noninterest income on the Consolidated Statements of Comprehensive Income.

Assets and Liabilities Recorded at Fair Value on a Nonrecurring Basis

The Corporation may be required 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, and were recognized at fair value since it was less than cost at the end of the period.

The following table presents assets recorded at fair value on a nonrecurring basis at March 31, 2021 and December 31, 2020. No liabilities were recorded at fair value on a nonrecurring basis at March 31, 2021 and December 31, 2020.

(in millions)	Level 3
March 31, 2021
Loans:
Commercial	$	125
Commercial mortgage	12
Total loans	137
Other real estate	8
Total assets at fair value	$	145
December 31, 2020
Loans:
Commercial	$	134
Commercial mortgage	16
Total assets at fair value	$	150

Level 3 assets recorded at fair value on a nonrecurring basis at March 31, 2021 and December 31, 2020 included both nonaccrual loans and TDRs for which a specific allowance was established based on the fair value of collateral. The unobservable inputs were the additional adjustments applied by management to the appraised values to reflect such factors as non-current appraisals and revisions to estimated time to sell. These adjustments are determined based on qualitative judgments made by management on a case-by-case basis and are not quantifiable inputs, although they are used in the determination of fair value.

Estimated Fair Values of Financial Instruments Not Recorded at Fair Value 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.

8

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

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:

	Carrying Amount		Estimated Fair Value
(in millions)			Total		Level 1		Level 2		Level 3
March 31, 2021
Assets
Cash and due from banks	$	1,064	$	1,064	$	1,064	$	—	$	—
Interest-bearing deposits with banks	13,807		13,807		13,807		—		—
Loans held-for-sale	14		14		—		14		—
Total loans, net of allowance for loan losses (a)	49,805		48,880		—		—		48,880
Customers’ liability on acceptances outstanding	13		13		13		—		—
Restricted equity investments	92		92		92		—		—
Nonmarketable equity securities (b)	7		9
Liabilities
Demand deposits (noninterest-bearing)	38,822		38,822		—		38,822		—
Interest-bearing deposits	32,844		32,844		—		32,844		—
Customer certificates of deposit	2,141		2,140		—		2,140		—
Total deposits	73,807		73,806		—		73,806		—
Acceptances outstanding	13		13		13		—		—
Medium- and long-term debt	2,852		2,919		—		2,919		—
Credit-related financial instruments	(50)		(50)		—		—		(50)
December 31, 2020
Assets
Cash and due from banks	$	1,031	$	1,031	$	1,031	$	—	$	—
Interest-bearing deposits with banks	14,736		14,736		14,736		—		—
Loans held-for-sale	5		5		—		5		—
Total loans, net of allowance for loan losses (a)	51,343		50,601		—		—		50,601
Customers’ liability on acceptances outstanding	1		1		1		—		—
Restricted equity investments	207		207		207		—		—
Nonmarketable equity securities (b)	5		9
Liabilities
Demand deposits (noninterest-bearing)	39,420		39,420		—		39,420		—
Interest-bearing deposits	31,316		31,316		—		31,316		—
Customer certificates of deposit	2,133		2,133		—		2,133		—
Total deposits	72,869		72,869		—		72,869		—
Acceptances outstanding	1		1		1		—		—
Medium- and long-term debt	5,728		5,790		—		5,790		—
Credit-related financial instruments	(68)		(68)		—		—		(68)

(a)Included $137 million and $150 million of loans recorded at fair value on a nonrecurring basis at March 31, 2021 and December 31, 2020, respectively.

(b)Certain investments that are measured at fair value using the net asset value have not been classified in the fair value hierarchy. The fair value amounts presented in the table are intended to permit reconciliation of the fair value hierarchy to the amounts presented in the Consolidated Balance Sheets.

9

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

NOTE 3 - INVESTMENT SECURITIES

A summary of the Corporation’s investment securities follows:

(in millions)	Amortized Cost		Gross Unrealized Gains		Gross Unrealized Losses		Fair Value
March 31, 2021
Investment securities available-for-sale:
U.S. Treasury and other U.S. government agency securities	$	4,578	$	59	$	24	$	4,613
Residential mortgage-backed securities (a)	10,924		178		120		10,982
Total investment securities available-for-sale	$	15,502	$	237	$	144	$	15,595
December 31, 2020
Investment securities available-for-sale:
U.S. Treasury and other U.S. government agency securities	$	4,583	$	76	$	1	$	4,658
Residential mortgage-backed securities (a)	10,169		203		2		10,370
Total investment securities available-for-sale	$	14,752	$	279	$	3	$	15,028

(a)Issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.

A summary of the Corporation’s investment securities in an unrealized loss position as of March 31, 2021 and December 31, 2020 follows:

	Temporarily Impaired
	Less than 12 Months				12 Months or more				Total
(in millions)	Fair Value		Unrealized Losses		Fair Value		Unrealized Losses		Fair Value		Unrealized Losses
March 31, 2021
U.S. Treasury and other U.S. government agency securities	$	1,834	$	24	$	—	$	—	$	1,834	$	24
Residential mortgage-backed securities (a)	3,577		120		—		—		3,577		120
Total temporarily impaired securities	$	5,411	$	144	$	—	$	—	$	5,411	$	144
December 31, 2020
U.S. Treasury and other U.S. government agency securities	$	1,119	$	1	$	—	$	—	$	1,119	$	1
Residential mortgage-backed securities (a)	952		2		—		—		952		2
Total temporarily impaired securities	$	2,071	$	3	$	—	$	—	$	2,071	$	3

(a)Issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.

Unrealized losses resulted from changes in market interest rates and liquidity. The Corporation’s portfolio is comprised of securities issued or guaranteed by the U.S. government or government-sponsored enterprises. As such, it is expected that the securities would not be settled at a price less than the amortized cost of the investments. Further, the Corporation does not intend to sell the investments, and it is not more likely than not that it will be required to sell the investments before recovery of amortized costs. At March 31, 2021, the Corporation had 138 securities in an unrealized loss

position with no allowance for credit losses, comprised of 19 U.S. Treasury securities and 119 residential mortgage-backed

securities.

Interest receivable on investment securities totaled $19 million at March 31, 2021 and $18 million at December 31, 2020 and was included in accrued income and other assets on the Consolidated Balance Sheets.

Sales, calls and write-downs of investment securities available-for-sale resulted in the following losses recorded in net securities losses on the Consolidated Statements of Comprehensive Income, computed based on the adjusted cost of the specific security.

	Three Months Ended March 31,
(in millions)	2021		2020
Securities losses	$	—	$	(1)
Net securities losses	$	—	$	(1)

10

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

The following table summarizes the amortized cost and fair values of debt securities by contractual maturity. Securities with multiple maturity dates are classified in the period of final maturity. Expected maturities will differ from contractual maturities because borrowers may have the right to call or prepay obligations with or without call or prepayment penalties.

(in millions)
March 31, 2021	Amortized Cost		Fair Value
Contractual maturity
Within one year	$	1,617	$	1,634
After one year through five years	3,177		3,208
After five years through ten years	570		587
After ten years	10,138		10,166
Total investment securities	$	15,502	$	15,595

Included in the contractual maturity distribution in the table above were residential mortgage-backed securities with a total amortized cost of $10.9 billion and a fair value of $11.0 billion. The actual cash flows of mortgage-backed securities may differ as borrowers of the underlying loans may exercise prepayment options.

At March 31, 2021, investment securities with a carrying value of $4.7 billion were pledged where permitted or required by law, including $4.0 billion pledged to the Federal Home Loan Bank (FHLB) as collateral for potential future borrowings of approximately $3.9 billion and $648 million to secure $485 million of liabilities, primarily public and other deposits of state and local government agencies as well as derivative instruments. For information on FHLB borrowings, refer to Note 7.

11

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

NOTE 4 – CREDIT QUALITY AND ALLOWANCE FOR CREDIT LOSSES

The following table presents an aging analysis of the amortized cost basis of loans.

	Loans Past Due and Still Accruing
(in millions)	30-59 Days		60-89  Days		90 Days or More		Total		Nonaccrual Loans		Current Loans (a)		Total  Loans
March 31, 2021
Business loans:
Commercial	$	103	$	57	$	17	$	177	$	230	$	30,479	$	30,886
Real estate construction:
Commercial Real Estate business line (b)	—		—		—		—		—		3,810		3,810
Other business lines (c)	9		8		2		19		1		414		434
Total real estate construction	9		8		2		19		1		4,224		4,244
Commercial mortgage:
Commercial Real Estate business line (b)	12		1		—		13		3		2,295		2,311
Other business lines (c)	40		25		21		86		31		7,565		7,682
Total commercial mortgage	52		26		21		99		34		9,860		9,993
Lease financing	14		—		1		15		1		561		577
International	—		2		—		2		—		988		990
Total business loans	178		93		41		312		266		46,112		46,690
Retail loans:
Residential mortgage	8		4		—		12		33		1,754		1,799
Consumer:
Home equity	5		4		—		9		15		1,546		1,570
Other consumer	10		—		19		29		—		494		523
Total consumer	15		4		19		38		15		2,040		2,093
Total retail loans	23		8		19		50		48		3,794		3,892
Total loans	$	201	$	101	$	60	$	362	$	314	$	49,906	$	50,582
December 31, 2020
Business loans:
Commercial	$	62	$	115	$	33	$	210	$	252	$	32,291	$	32,753
Real estate construction:
Commercial Real Estate business line (b)	31		—		—		31		—		3,626		3,657
Other business lines (c)	9		—		—		9		1		415		425
Total real estate construction	40		—		—		40		1		4,041		4,082
Commercial mortgage:
Commercial Real Estate business line (b)	51		1		—		52		3		2,218		2,273
Other business lines (c)	48		40		5		93		26		7,520		7,639
Total commercial mortgage	99		41		5		145		29		9,738		9,912
Lease financing	14		—		1		15		1		578		594
International	—		—		—		—		—		926		926
Total business loans	215		156		39		410		283		47,574		48,267
Retail loans:
Residential mortgage	11		4		—		15		47		1,768		1,830
Consumer:
Home equity	7		1		—		8		17		1,563		1,588
Other consumer	10		—		6		16		—		590		606
Total consumer	17		1		6		24		17		2,153		2,194
Total retail loans	28		5		6		39		64		3,921		4,024
Total loans	$	243	$	161	$	45	$	449	$	347	$	51,495	$	52,291

(a)Includes $87 million and $141 million of loans with deferred payments not considered past due in accordance with the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) at March 31, 2021 and December 31, 2020, respectively.

(b)Primarily loans to real estate developers.

(c)Primarily loans secured by owner-occupied real estate.

12

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

The following table presents loans by credit quality indicator (CQI) and vintage year. CQI is based on internal risk ratings assigned to each business loan at the time of approval and subjected to subsequent reviews, generally at least annually, and to pools of retail loans with similar risk characteristics. Vintage year is the year of origination or major modification.

	March 31, 2021
	Vintage Year
(in millions)	2021			2020			2019		2018		2017		Prior		Revolvers		Revolvers Converted to Term		Total
Business loans:
Commercial:
Pass (a)	$	1,632	(b)	$	5,073	(b)	$	2,191	$	1,445	$	944	$	1,061	$	16,601	$	16	$	28,963
Criticized (c)	30			41			217		173		86		211		1,163		2		1,923
Total commercial	1,662			5,114			2,408		1,618		1,030		1,272		17,764		18		30,886
Real estate construction
Pass (a)	44			604			1,206		1,142		571		426		183		—		4,176
Criticized (c)	—			3			29		17		8		9		2		—		68
Total real estate construction	44			607			1,235		1,159		579		435		185		—		4,244
Commercial mortgage
Pass (a)	398			2,107			1,587		1,161		1,062		2,858		399		—		9,572
Criticized (c)	3			31			63		43		33		232		16		—		421
Total commercial mortgage	401			2,138			1,650		1,204		1,095		3,090		415		—		9,993
Lease financing
Pass (a)	28			104			115		61		47		186		—		—		541
Criticized (c)	—			3			19		11		2		1		—		—		36
Total lease financing	28			107			134		72		49		187		—		—		577
International
Pass (a)	137			155			159		85		10		66		316		—		928
Criticized (c)	—			14			8		17		4		8		11		—		62
Total international	137			169			167		102		14		74		327		—		990
Total business loans	2,272			8,135			5,594		4,155		2,767		5,058		18,691		18		46,690
Retail loans:
Residential mortgage
Pass (a)	97			631			213		108		162		555		—		—		1,766
Criticized (c)	2			1			2		2		7		19		—		—		33
Total residential mortgage	99			632			215		110		169		574		—		—		1,799
Consumer:
Home equity
Pass (a)	—			—			—		—		—		16		1,474		58		1,548
Criticized (c)	—			—			—		—		—		—		16		6		22
Total home equity	—			—			—		—		—		16		1,490		64		1,570
Other consumer
Pass (a)	15			107			19		12		2		36		316		—		507
Criticized (c)	—			—			—		1		—		7		8		—		16
Total other consumer	15			107			19		13		2		43		324		—		523
Total consumer	15			107			19		13		2		59		1,814		64		2,093
Total retail loans	114			739			234		123		171		633		1,814		64		3,892
Total loans	$	2,386		$	8,874		$	5,828	$	4,278	$	2,938	$	5,691	$	20,505	$	82	$	50,582
Table continues on the following page.

13

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

	December 31, 2020
	Vintage Year
	2020			2019		2018		2017		2016		Prior		Revolvers		Revolvers Converted to Term		Total
Business loans:
Commercial:
Pass (a)	$	5,991	(b)	$	2,316	$	1,563	$	1,051	$	429	$	755	$	18,416	$	17	$	30,538
Criticized (c)	30			281		191		116		64		166		1,365		2		2,215
Total commercial	6,021			2,597		1,754		1,167		493		921		19,781		19		32,753
Real estate construction:
Pass (a)	433			1,080		1,244		631		335		141		171		—		4,035
Criticized (c)	3			28		5		8		—		1		2		—		47
Total real estate construction	436			1,108		1,249		639		335		142		173		—		4,082
Commercial mortgage:
Pass (a)	2,053			1,559		1,146		1,120		818		2,272		431		—		9,399
Criticized (c)	47			130		42		45		41		193		15		—		513
Total commercial mortgage	2,100			1,689		1,188		1,165		859		2,465		446		—		9,912
Lease financing
Pass (a)	109			122		71		50		14		201		—		—		567
Criticized (c)	2			17		5		2		1		—		—		—		27
Total lease financing	111			139		76		52		15		201		—		—		594
International
Pass (a)	274			161		103		11		3		64		245		—		861
Criticized (c)	13			8		18		4		7		2		13		—		65
Total international	287			169		121		15		10		66		258		—		926
Total business loans	8,955			5,702		4,388		3,038		1,712		3,795		20,658		19		48,267
Retail loans:
Residential mortgage
Pass (a)	639			230		119		197		196		398		—		—		1,779
Criticized (c)	7			2		2		6		2		32		—		—		51
Total residential mortgage	646			232		121		203		198		430		—		—		1,830
Consumer:
Home equity
Pass (a)	—			—		—		—		—		15		1,489		63		1,567
Criticized (c)	—			—		—		—		—		1		13		7		21
Total home equity	—			—		—		—		—		16		1,502		70		1,588
Other consumer
Pass (a)	113			23		12		2		3		41		404		—		598
Criticized (c)	—			—		2		—		—		—		6		—		8
Total other consumer	113			23		14		2		3		41		410		—		606
Total consumer	113			23		14		2		3		57		1,912		70		2,194
Total retail loans	759			255		135		205		201		487		1,912		70		4,024
Total loans	$	9,714		$	5,957	$	4,523	$	3,243	$	1,913	$	4,282	$	22,570	$	89	$	52,291

(a)Includes all loans not included in the categories of special mention, substandard or nonaccrual.

(b)Includes Small Business Administration Paycheck Protection Program (PPP) loans of $925 million and $2.9 billion in 2021 and 2020, respectively, at March 31, 2021, and PPP loans of $3.5 billion in 2020 at December 31, 2020.

(c)Includes loans with an internal rating of special mention, substandard loans for which the accrual of interest has not been discontinued and nonaccrual loans. Special mention loans have potential credit weaknesses that deserve management’s close attention, such as loans to borrowers who may be experiencing financial difficulties that may result in deterioration of repayment prospects from the borrower at some future date. Accruing substandard loans have a well-defined weakness, or weaknesses, such as loans to borrowers who may be experiencing losses from operations or inadequate liquidity of a degree and duration that jeopardizes the orderly repayment of the loan. Substandard loans are also distinguished by the distinct possibility of loss in the future if these weaknesses are not corrected. Nonaccrual loans are loans for which the accrual of interest has been discontinued. For further information regarding nonaccrual loans, refer to the Nonperforming Assets subheading in Note 1 - Basis of Presentation and Accounting Policies on page F-59 in the Corporation's 2020 Annual Report. These categories are generally consistent with the "special mention" and "substandard" categories as defined by regulatory authorities. A minority of nonaccrual loans are consistent with the "doubtful" category.

Loan interest receivable totaled $142 million and $141 million at March 31, 2021 and December 31, 2020, respectively, and was included in accrued income and other assets on the Consolidated Balance Sheets.

14

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

Allowance for Credit Losses

The following table details the changes in the allowance for credit losses.

	2021									2020
(in millions)	Business Loans			Retail Loans			Total			Business Loans			Retail Loans			Total
Three Months Ended March 31
Balance at beginning of period:
Allowance for loan losses	$	895		$	53		$	948		$	601		$	36		$	637
Allowance for credit losses on lending-related commitments	35			9			44			28			3			31
Allowance for credit losses	930			62			992			629			39			668
Cumulative effect of change in accounting principle	—			—			—			(42)			25			(17)
Loan charge-offs	(15)			(1)			(16)			(87)			(2)			(89)
Recoveries on loans previously charged-off	12			1			13			5			—			5
Net loan charge-offs	(3)			—			(3)			(82)			(2)			(84)
Provision for credit losses:
Provision for loan losses	(183)			15			(168)			384			(4)			380
Provision for credit losses on lending-related commitments	(13)			(1)			(14)			24			7			31
Provision for credit losses	(196)			14			(182)			408			3			411
Balance at end of period:
Allowance for loan losses	709			68			777			861			55			916
Allowance for credit losses on lending-related commitments	22			8			30			52			10			62
Allowance for credit losses	$	731		$	76		$	807		$	913		$	65		$	978
Allowance for loan losses as a percentage of total loans	1.52		%	1.74		%	1.54		%	1.75		%	1.35		%	1.71		%
Allowance for loan losses as a percentage of total loans excluding PPP loans	1.65			n/a			1.66			n/a			n/a			n/a
Allowance for credit losses as a percentage of total loans	1.57			1.94			1.59			1.85			1.57			1.83
Allowance for credit losses as a percentage of total loans excluding PPP loans	1.70			n/a			1.72			n/a			n/a			n/a

n/a - not applicable

15

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

Nonaccrual Loans

The following table presents additional information regarding nonaccrual loans. No interest income was recognized on nonaccrual loans for the three-month periods ended March 31, 2021 and 2020.

(in millions)	Nonaccrual Loans with No Related Allowance		Nonaccrual Loans with Related Allowance		Total Nonaccrual Loans
March 31, 2021
Business loans:
Commercial	$	50	$	180	$	230
Real estate construction:
Other business lines (a)	—		1		1
Commercial mortgage:
Commercial Real Estate business line (b)	1		2		3
Other business lines (a)	7		24		31
Total commercial mortgage	8		26		34
Lease financing	—		1		1
Total business loans	58		208		266
Retail loans:
Residential mortgage	33		—		33
Consumer:
Home equity	15		—		15
Total retail loans	48		—		48
Total nonaccrual loans	$	106	$	208	$	314
December 31, 2020
Business loans:
Commercial	$	57	$	195	$	252
Real estate construction:
Other business lines (a)	—		1		1
Commercial mortgage:
Commercial Real Estate business line (b)	1		2		3
Other business lines (a)	5		21		26
Total commercial mortgage	6		23		29
Lease financing	—		1		1
Total business loans	63		220		283
Retail loans:
Residential mortgage	47		—		47
Consumer:
Home equity	17		—		17
Total retail loans	64		—		64
Total nonaccrual loans	$	127	$	220	$	347

(a)Primarily loans secured by owner-occupied real estate.

(b)Primarily loans to real estate developers.

Foreclosed Properties

Foreclosed properties totaled $8 million at both March 31, 2021 and December 31, 2020. There were no retail loans secured by residential real estate properties in process of foreclosure included in nonaccrual loans at March 31, 2021 and December 31, 2020.

16

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

Troubled Debt Restructurings

The following table details the amortized cost basis at March 31, 2021 and 2020 of loans considered to be TDRs that were restructured during the three-month periods ended March 31, 2021 and 2020, by type of modification. In cases of loans with more than one type of modification, the loans were categorized based on the most significant modification.

	Principal Deferrals (a)
(in millions)	2021		2020
Three Months Ended March 31,
Commercial	$	—	$	22
Commercial mortgage:
Other business lines (b)	—		2
Total loans	$	—	$	24

(a)Primarily represents loan balances where terms were extended by more than an insignificant time period, typically more than 180 days, at or above contractual interest rates. Also includes commercial loans restructured in bankruptcy. In accordance with the provisions of the CARES Act, balances exclude $71 million, primarily retail loans, with terms extended by more than an insignificant time period.

(b)Primarily loans secured by owner-occupied real estate.

The Corporation charges interest on principal balances outstanding during deferral periods. Additionally, none of the modifications involved forgiveness of principal. There were no commitments to lend additional funds to borrowers whose terms have been modified in TDRs at March 31, 2021 and December 31, 2020. On an ongoing basis, the Corporation monitors the performance of modified loans to their restructured terms. The allowance for loan losses continues to be reassessed on the basis of an individual evaluation of the loan.

For principal deferrals, incremental deterioration in the credit quality of the loan, represented by a downgrade in the risk rating of the loan, for example, due to missed interest payments or a reduction of collateral value, is considered a subsequent default. For interest rate reductions, a subsequent payment default is defined in terms of delinquency, when a principal or interest payment is 90 days past due. Of the TDRs modified during the twelve-month periods ended March 31, 2021 and 2020, there were no subsequent defaults of principal deferrals or interest rate reductions in the three-month period ended March 31, 2021, compared to $10 million of principal deferrals and no interest rate reductions in the comparable period in 2020.

NOTE 5 - DERIVATIVE AND CREDIT-RELATED FINANCIAL INSTRUMENTS

In the normal course of business, the Corporation enters into various transactions involving derivative and credit-related financial instruments to manage exposure to fluctuations in interest rate, foreign currency and other market risks and to meet the financing needs of customers (customer-initiated derivatives). These financial instruments involve, to varying degrees, elements of market and credit risk. Market and credit risk are included in the determination of fair value.

Market risk is the potential loss that may result from movements in interest rates, foreign currency exchange rates or energy commodity prices that cause an unfavorable change in the value of a financial instrument. The Corporation manages this risk by establishing monetary exposure limits and monitoring compliance with those limits. Market risk inherent in interest rate and energy contracts entered into on behalf of customers is mitigated by taking offsetting positions, except in those circumstances when the amount, tenor and/or contract rate level results in negligible economic risk, whereby the cost of purchasing an offsetting contract is not economically justifiable. The Corporation mitigates most of the inherent market risk in foreign exchange contracts entered into on behalf of customers by taking offsetting positions and manages the remainder through individual foreign currency position limits and aggregate value-at-risk limits. These limits are established annually and positions are monitored quarterly. Market risk inherent in derivative instruments held or issued for risk management purposes is typically offset by changes in the fair value of the assets or liabilities being hedged.

Credit risk is the possible loss that may occur in the event of nonperformance by the counterparty to a financial instrument. The Corporation attempts to minimize credit risk arising from customer-initiated derivatives by evaluating the creditworthiness of each customer, adhering to the same credit approval process used for traditional lending activities and obtaining collateral as deemed necessary. Derivatives with dealer counterparties are either cleared through a clearinghouse or settled directly with a single counterparty. For derivatives settled directly with dealer counterparties, the Corporation utilizes counterparty risk limits and monitoring procedures as well as master netting arrangements and bilateral collateral agreements to facilitate the management of credit risk. Master netting arrangements effectively reduce credit valuation adjustments by permitting settlement of positive and negative positions and offset cash collateral held with the same counterparty on a net basis. Bilateral collateral agreements require daily exchange of cash or highly rated securities issued by the U.S. Treasury or other U.S. government entities to collateralize amounts due to either party. At March 31, 2021, counterparties with bilateral

17

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

collateral agreements deposited $11 million of cash with the Corporation to secure the fair value of contracts in an unrealized gain position, and the Corporation had pledged $29 million of marketable investment securities and posted $256 million of cash as collateral for contracts in an unrealized loss position. For those counterparties not covered under bilateral collateral agreements, collateral is obtained, if deemed necessary, based on the results of management’s credit evaluation of the counterparty. Collateral varies, but may include cash, investment securities, accounts receivable, equipment or real estate. Included in the fair value of derivative instruments are credit valuation adjustments reflecting counterparty credit risk. 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. There were no derivative instruments with credit-risk-related contingent features that were in a liability position at March 31, 2021.

Derivative Instruments

Derivative instruments utilized by the Corporation are negotiated over-the-counter and primarily include swaps, caps and floors, forward contracts and options, each of which may relate to interest rates, energy commodity prices or foreign currency exchange rates. Swaps are agreements in which two parties periodically exchange cash payments based on specified indices applied to a specified notional amount until a stated maturity. Caps and floors are agreements which entitle the buyer to receive cash payments based on the difference between a specified reference rate or price and an agreed strike rate or price, applied to a specified notional amount until a stated maturity. Forward contracts are over-the-counter agreements to buy or sell an asset at a specified future date and price. Options are similar to forward contracts except the purchaser has the right, but not the obligation, to buy or sell the asset during a specified period or at a specified future date.

Over-the-counter contracts are tailored to meet the needs of the counterparties involved and, therefore, contain a greater degree of credit risk and liquidity risk than exchange-traded contracts, which have standardized terms and readily available price information. The Corporation reduces exposure to market and liquidity risks from over-the-counter derivative instruments entered into for risk management purposes, and transactions entered into to mitigate the market risk associated with customer-initiated transactions, by taking offsetting positions with investment grade domestic and foreign financial institutions and subjecting counterparties to credit approvals, limits and collateral monitoring procedures similar to those used in making other extensions of credit. In addition, certain derivative contracts executed bilaterally with a dealer counterparty in the over-the-counter market are cleared through a clearinghouse, whereby the clearinghouse becomes the counterparty to the transaction.

18

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

The following table presents the composition of the Corporation’s derivative instruments held or issued for risk management purposes or in connection with customer-initiated and other activities at March 31, 2021 and December 31, 2020.

	March 31, 2021						December 31, 2020
			Fair Value						Fair Value
(in millions)	Notional/ Contract Amount (a)		Gross Derivative Assets		Gross Derivative Liabilities		Notional/ Contract Amount (a)		Gross Derivative Assets		Gross Derivative Liabilities
Risk management purposes
Derivatives designated as hedging instruments
Interest rate contracts:
Swaps - fair value - receive fixed/pay floating	$	2,650	$	—	$	—	$	2,650	$	—	$	—
Swaps - cash flow - receive fixed/pay floating	5,550		—		—		5,550		—		—
Derivatives used as economic hedges
Foreign exchange contracts:
Spot, forwards and swaps	390		1		1		442		1		4
Total risk management purposes	8,590		1		1		8,642		1		4
Customer-initiated and other activities
Interest rate contracts:
Caps and floors written	909		—		2		869		—		—
Caps and floors purchased	909		2		—		869		—		—
Swaps	19,693		338		63		19,783		531		61
Total interest rate contracts	21,511		340		65		21,521		531		61
Energy contracts:
Caps and floors written	665		1		60		503		1		33
Caps and floors purchased	665		60		1		503		33		1
Swaps	2,873		208		204		2,115		117		115
Total energy contracts	4,203		269		265		3,121		151		149
Foreign exchange contracts:
Spot, forwards, options and swaps	1,429		11		9		1,901		17		15
Total customer-initiated and other activities	27,143		620		339		26,543		699		225
Total gross derivatives	$	35,733	$	621	$	340	$	35,185	$	700	$	229
Amounts offset in the Consolidated Balance Sheets:
Netting adjustment - Offsetting derivative assets/liabilities			(59)		(59)				(83)		(83)
Netting adjustment - Cash collateral received/posted			(2)		(227)				(17)		(48)
Net derivatives included in the Consolidated Balance Sheets (b)			560		54				600		98
Amounts not offset in the Consolidated Balance Sheets:
Marketable securities pledged under bilateral collateral agreements			—		(26)				—		(42)
Net derivatives after deducting amounts not offset in the Consolidated Balance Sheets			$	560	$	28			$	600	$	56

(a)Notional or contractual amounts, which represent the extent of involvement in the derivatives market, are used to determine the contractual cash flows required in accordance with the terms of the agreement. These amounts are typically not exchanged, significantly exceed amounts subject to credit or market risk and are not reflected in the Consolidated Balance Sheets.

(b)Net derivative assets are included in accrued income and other assets and net derivative liabilities are included in accrued expenses and other liabilities on the Consolidated Balance Sheets. Included in the fair value of net derivative assets and net derivative liabilities are credit valuation adjustments reflecting counterparty credit risk and credit risk of the Corporation. The fair value of net derivative assets included credit valuation adjustments for counterparty credit risk of $16 million and $27 million at March 31, 2021 and December 31, 2020, respectively.

19

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

Risk Management

The Corporation's derivative instruments used for managing interest rate risk include cash flow hedging strategies that convert variable-rate loans to fixed rates and fair value hedging strategies that convert fixed-rate long-term debt to variable rates. Interest and fees on loans included $24 million and $3 million of cash flow hedge income for the three-month periods ended March 31, 2021 and 2020, respectively.

The following table details the effects of fair value hedging on the Consolidated Statements of Comprehensive Income.

	Interest on Medium- and Long-Term Debt
	Three Months Ended March 31,
(in millions)	2021		2020
Total interest on medium- and long-term debt (a)	$	9	$	40
Fair value hedging relationships:
Interest rate contracts:
Hedged items	25		30
Derivatives designated as hedging instruments	(17)		(6)

(a) Includes the effects of hedging.

    For information on accumulated net gains on cash flow hedges, refer to Note 8.

    The following table summarizes the expected weighted average remaining maturity of the notional amount of risk management interest rate swaps, the carrying amount of the related hedged items and the weighted average interest rates associated with amounts expected to be received or paid on interest rate swap agreements as of March 31, 2021 and December 31, 2020.

Cash flow swaps - receive fixed/pay floating rate on variable-rate loans

(dollar amounts in millions)	March 31, 2021			December 31, 2020
Derivative notional amount	$	5,550		$	5,550
Weighted average:
Remaining maturity (in years)	2.0			2.3
Receive rate	1.87		%	1.87		%
Pay rate (a)	0.12			0.15

(a)Variable rates paid on receive fixed swaps designated as cash flow hedges are based on one-month LIBOR rates in effect at March 31, 2021 and December 31, 2020.

Fair value swaps - receive fixed/pay floating rate on medium- and long-term debt

(dollar amounts in millions)	March 31, 2021			December 31, 2020
Derivative notional amount	$	2,650		$	2,650
Carrying value of hedged items (a)	2,852			2,928
Weighted average:
Remaining maturity (in years)	4.4			4.6
Receive rate	3.68		%	3.68		%
Pay rate (b)	1.10			1.16

(a)Included $202 million and $279 million of cumulative hedging adjustments at March 31, 2021 and December 31, 2020, respectively, which included $5 million and $6 million, respectively, of hedging adjustment on a discontinued hedging relationship.

(b)Variable rates paid on receive fixed swaps designated as fair value hedges are based on one- and six-month LIBOR rates in effect at March 31, 2021 and December 31, 2020.

Customer-Initiated and Other

The Corporation enters into derivative transactions at the request of customers and generally takes offsetting positions with dealer counterparties to mitigate the inherent market risk. Income primarily results from the spread between the customer derivative and the offsetting dealer position.

For customer-initiated foreign exchange contracts where offsetting positions have not been taken, the Corporation manages the remaining inherent market risk through individual foreign currency position limits and aggregate value-at-risk limits. These limits are established annually and reviewed quarterly. For those customer-initiated derivative contracts which

20

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

were not offset or where the Corporation holds a position within the limits described above, the Corporation did not recognize any gains or losses for both the three-month periods ended March 31, 2021 and 2020.

Fair values of customer-initiated and other derivative instruments represent the net unrealized gains or losses on such contracts and are recorded on the Consolidated Balance Sheets. Changes in fair value are recognized on the Consolidated Statements of Comprehensive Income. The net gains recognized in income on customer-initiated derivative instruments, net of the impact of offsetting positions included in derivative income, were as follows:

	Three Months Ended March 31,
(in millions)	2021		2020
Interest rate contracts	$	15	$	8
Energy contracts	4		1
Foreign exchange contracts	11		11
Total derivative income	$	30	$	20

Credit-Related Financial Instruments

The Corporation issues off-balance sheet financial instruments in connection with commercial and consumer lending activities. The Corporation’s credit risk associated with these instruments is represented by the contractual amounts indicated in the following table.

(in millions)	March 31, 2021		December 31, 2020
Unused commitments to extend credit:
Commercial and other	$	24,598	$	23,443
Bankcard, revolving check credit and home equity loan commitments	3,322		3,297
Total unused commitments to extend credit	$	27,920	$	26,740
Standby letters of credit	$	3,278	$	3,273
Commercial letters of credit	40		30

The Corporation maintains an allowance to cover current expected credit losses inherent in lending-related commitments, including unused commitments to extend credit, letters of credit and financial guarantees. The allowance for credit losses on lending-related commitments, included in accrued expenses and other liabilities on the Consolidated Balance Sheets, was $30 million and $44 million at March 31, 2021 and December 31, 2020, respectively.

Unused Commitments to Extend Credit

Commitments to extend credit are legally binding agreements to lend to a customer, provided there is no violation of any condition established in the contract. These commitments generally have fixed expiration dates or other termination clauses and may require payment of a fee. Since many commitments expire without being drawn upon, the total contractual amount of commitments does not necessarily represent future cash requirements of the Corporation. Commercial and other unused commitments are primarily variable rate commitments. The allowance for credit losses on lending-related commitments included $25 million at March 31, 2021 and $37 million at December 31, 2020 for expected credit losses inherent in the Corporation’s unused commitments to extend credit.

Standby and Commercial Letters of Credit

Standby letters of credit represent conditional obligations of the Corporation which guarantee the performance of a customer to a third party. Standby letters of credit are primarily issued to support public and private borrowing arrangements, including commercial paper, bond financing and similar transactions. Commercial letters of credit are issued to finance foreign or domestic trade transactions. These contracts expire in decreasing amounts through the year 2028. The Corporation may enter into participation arrangements with third parties that effectively reduce the maximum amount of future payments which may be required under standby and commercial letters of credit. There were $3.3 billion standby and commercial letters of credit outstanding at both March 31, 2021 and December 31, 2020, of which these risk participations covered $149 million and $150 million, respectively.

The carrying value of the Corporation’s standby and commercial letters of credit, included in accrued expenses and other liabilities on the Consolidated Balance Sheets, totaled $25 million at March 31, 2021, including $20 million in deferred fees and $5 million in the allowance for credit losses on lending-related commitments. At December 31, 2020, the comparable amounts were $31 million, $24 million and $7 million, respectively.

The following table presents a summary of criticized standby and commercial letters of credit at March 31, 2021 and December 31, 2020. The Corporation's criticized list is generally consistent with the Special Mention, Substandard and

21

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

Doubtful categories defined by regulatory authorities. The Corporation manages credit risk through underwriting, periodically reviewing and approving its credit exposures using Board committee approved credit policies and guidelines.

(dollar amounts in millions)	March 31, 2021			December 31, 2020
Total criticized standby and commercial letters of credit	$	54		$	73
As a percentage of total outstanding standby and commercial letters of credit	1.6		%	2.2		%

Other Credit-Related Financial Instruments

The Corporation enters into credit risk participation agreements, under which the Corporation assumes credit exposure associated with a borrower’s performance related to certain interest rate derivative contracts. The Corporation is not a party to the interest rate derivative contracts and only enters into these credit risk participation agreements in instances in which the Corporation is also a party to the related loan participation agreements for such borrowers. The Corporation manages its credit risk on the credit risk participation agreements by monitoring the creditworthiness of the borrowers, which is based on the normal credit review process as if the Corporation had entered into the derivative instruments directly with the borrowers. The notional amount of such credit risk participation agreements reflects the pro-rata share of the derivative instrument, consistent with its share of the related participated loan. As of March 31, 2021 and December 31, 2020, the total notional amount of the credit risk participation agreements was approximately $1.0 billion and $1.1 billion, respectively, and the fair value was $1 million at March 31, 2021 and $3 million at December 31, 2020. The maximum estimated exposure to these agreements, as measured by projecting a maximum value of the guaranteed derivative instruments, assuming 100 percent default by all obligors on the maximum values, was $40 million and $62 million at March 31, 2021 and December 31, 2020, respectively. In the event of default, the lead bank has the ability to liquidate the assets of the borrower, in which case the lead bank would be required to return a percentage of the recouped assets to the participating banks. As of March 31, 2021, the weighted average remaining maturity of outstanding credit risk participation agreements was 4.4 years.

NOTE 6 - VARIABLE INTEREST ENTITIES (VIEs)

The Corporation evaluates its interest in certain entities to determine if these entities meet the definition of a VIE and whether the Corporation is the primary beneficiary and should consolidate the entity based on the variable interests it held both at inception and when there is a change in circumstances that requires a reconsideration.

The Corporation holds ownership interests in funds in the form of limited partnerships or limited liability companies (LLCs) investing in affordable housing projects that qualify for the low-income housing tax credit (LIHTC). The Corporation also directly invests in limited partnerships and LLCs which invest in community development projects, which generate similar tax credits to investors (other tax credit entities). As an investor, the Corporation obtains income tax credits and deductions from the operating losses of these tax credit entities. These tax credit entities meet the definition of a VIE; however, the Corporation is not the primary beneficiary of the entities, as the general partner or the managing member has both the power to direct the activities that most significantly impact the economic performance of the entities and the obligation to absorb losses or the right to receive benefits that could be significant to the entities.

The Corporation accounts for its interests in LIHTC entities using the proportional amortization method. Ownership interests in other tax credit entities are accounted for under either the cost or equity method. Exposure to loss as a result of the Corporation's involvement in LIHTC entities and other tax credit entities at March 31, 2021 was limited to $458 million and $12 million, respectively.

Investment balances, including all legally binding commitments to fund future investments, are included in accrued income and other assets on the Consolidated Balance Sheets. A liability is recognized in accrued expenses and other liabilities on the Consolidated Balance Sheets for all legally binding unfunded commitments to fund tax credit entities ($173 million at March 31, 2021). Amortization and other write-downs of LIHTC investments are presented on a net basis as a component of the provision for income taxes on the Consolidated Statements of Comprehensive Income, while amortization and write-downs of other tax credit investments are recorded in other noninterest income. The income tax credits and deductions are recorded as a reduction of income tax expense and a reduction of federal income taxes payable.

The Corporation provided no financial or other support that was not contractually required to any of the above VIEs during the three months ended March 31, 2021 and 2020.

22

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

The following table summarizes the impact of these tax credit entities on the Corporation’s Consolidated Statements of Comprehensive Income.

	Three Months Ended March 31,
(in millions)	2021		2020
Provision for income taxes:
Amortization of LIHTC investments	$	17	$	17
Low income housing tax credits	(16)		(16)
Other tax benefits related to tax credit entities	(4)		(4)
Total provision for income taxes	$	(3)	$	(3)

For further information on the Corporation’s consolidation policy, see Note 1 to the consolidated financial statements in the Corporation's 2020 Annual Report.

NOTE 7 - MEDIUM- AND LONG-TERM DEBT

Medium- and long-term debt is summarized as follows:

(in millions)	March 31, 2021		December 31, 2020
Parent company
Subordinated notes:
3.80% subordinated notes due 2026 (a)	$	270	$	280
Medium- and long-term notes:
3.70% notes due 2023 (a)	898		905
4.00% notes due 2029 (a)	597		633
Total medium- and long-term notes	1,495		1,538
Total parent company	1,765		1,818
Subsidiaries
Subordinated notes:
4.00% subordinated notes due 2025 (a)	371		380
7.875% subordinated notes due 2026 (a)	199		207
Total subordinated notes	570		587
Medium- and long-term notes:
2.50% notes due 2024 (a)	517		523
Total medium- and long-term notes	517		523
FHLB advances:
Floating-rate based on FHLB auction rate due 2026	—		2,800
Total FHLB advances	—		2,800
Total subsidiaries	1,087		3,910
Total medium- and long-term debt	$	2,852	$	5,728

(a)The fixed interest rates on these notes have been swapped to a variable rate and designated in a hedging relationship. Accordingly, carrying value has been adjusted to reflect the change in the fair value of the debt as a result of changes in the benchmark rate.

    Subordinated notes with remaining maturities greater than one year qualify as Tier 2 capital.

    Comerica Bank (the Bank), a wholly-owned subsidiary of the Corporation, is a member of the FHLB, which provides short-and long-term funding to its members through advances collateralized by real estate-related assets. The interest rates on the FHLB advances resets between four and eight weeks, based on the FHLB auction rate. Each note may be prepaid in full, without penalty, at each scheduled reset date. The Bank held no outstanding long-term advances at March 31, 2021. Borrowing capacity is contingent on the amount of collateral available to be pledged to the FHLB. At March 31, 2021, $18.6 billion of real estate-related loans and $4.0 billion of investment securities were pledged to the FHLB as collateral with capacity for potential future borrowings of approximately $13.9 billion.

    Unamortized debt issuance costs deducted from the carrying amount of medium- and long-term debt totaled $9 million at March 31, 2021 and $10 million at December 31, 2020.

23

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

NOTE 8 - ACCUMULATED OTHER COMPREHENSIVE (LOSS) INCOME

The following table presents a reconciliation of the changes in the components of accumulated other comprehensive (loss) income and details the components of other comprehensive (loss) income for the three months ended March 31, 2021 and 2020, including the amount of income tax expense (benefit) allocated to each component of other comprehensive (loss) income.

	Three Months Ended March 31,
(in millions)	2021		2020
Accumulated net unrealized gains on investment securities:
Balance at beginning of period, net of tax	$	211	$	65
Net unrealized holding (losses) gains arising during the period	(183)		323
Less: (Benefit) provision for income taxes	(43)		76
Change in net unrealized gains on investment securities, net of tax	(140)		247
Balance at end of period, net of tax	$	71	$	312
Accumulated net gains on cash flow hedges:
Balance at beginning of period, net of tax	$	155	$	34
Net cash flow hedge (losses) gains arising during the period	(18)		205
Less: (Benefit) provision for income taxes	(4)		48
Change in net cash flow hedge (losses) gains arising during the period, net of tax	(14)		157
Less:
Net cash flow hedge gains included in interest and fees on loans	24		3
Less: Provision for income taxes	6		1
Reclassification adjustment for net cash flow hedge gains included in net income, net of tax	18		2
Change in net cash flow hedge (losses) gains, net of tax	(32)		155
Balance at end of period, net of tax (a)	$	123	$	189
Accumulated defined benefit pension and other postretirement plans adjustment:
Balance at beginning of period, net of tax (b)	$	(302)	$	(415)
Actuarial loss arising during the period (b)	—		(3)
Less: Benefit for income taxes (b)	—		(1)
Net defined benefit pension and other postretirement plans adjustment arising during the period, net of tax (b)	—		(2)
Amounts recognized in other noninterest expenses:
Amortization of actuarial net loss (b)	10		11
Amortization of prior service credit	(6)		(7)
Total amounts recognized in other noninterest expenses (b)	4		4
Less: Provision for income taxes (b)	1		1
Adjustment for amounts recognized as components of net periodic benefit cost during the period, net of tax (b)	3		3
Change in defined benefit pension and other postretirement plans adjustment, net of tax (b)	3		1
Balance at end of period, net of tax (b)	$	(299)	$	(414)
Total accumulated other comprehensive (loss) income at end of period, net of tax (b)	$	(105)	$	87

(a)The Corporation expects to reclassify $67 million of gains, net of tax, from accumulated other comprehensive income to earnings over the next twelve months if interest yield curves and notional amounts remain at March 31, 2021 levels.

(b)Balances at beginning of period, net of tax and changes for the three months ended March 31, 2020 have been recast to reflect the retrospective application of the Corporation's election to change the accounting method for certain components of the qualified defined benefit pension plan as of January 1, 2021. Refer to Note 1 for further information.

24

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

NOTE 9 - NET INCOME (LOSS) PER COMMON SHARE

Basic and diluted net income (loss) per common share are presented in the following table.

	Three Months Ended March 31,
(in millions, except per share data)	2021		2020
Basic and diluted
Net income (loss)	$	350	$	(59)
Less:
Income allocated to participating securities	1		—
Preferred stock dividends	6		—
Net income (loss) attributable to common shares	$	343	$	(59)
Basic average common shares	140		141
Basic net income (loss) per common share	$	2.46	$	(0.42)
Basic average common shares	140		141
Dilutive common stock equivalents:
Net effect of the assumed exercise of stock awards	1		—
Diluted average common shares	141		141
Diluted net income (loss) per common share	$	2.43	$	(0.42)

The following average shares related to outstanding options to purchase shares of common stock were not included in the computation of diluted net income (loss) per common share because the exercise price was greater than the average market price of common shares for the period.

	Three Months Ended March 31,
(average outstanding options in thousands)	2021	2020
Average outstanding options	782	1,210
Range of exercise prices	67.53 - 95.25	56.79 - 95.25

Due to the net loss attributable to common shares reported for the three months ended March 31, 2020, stock awards representing 2.6 million shares of common stock were excluded from the computation of diluted net loss per share, as their inclusion would have been anti-dilutive.

25

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

NOTE 10 - EMPLOYEE BENEFIT PLANS

Net periodic defined benefit cost (credit) is comprised of service cost and other components of net benefit cost (credit). Service cost is included in salaries and benefits expense and other components of net benefit cost (credit) are included in other noninterest expenses on the Consolidated Statements of Comprehensive Income. For further information on the Corporation's employee benefit plans, refer to Note 17 to the consolidated financial statements in the Corporation's 2020 Annual Report.

The components of net periodic benefit cost (credit) for the Corporation's qualified pension plan, non-qualified pension plan and postretirement benefit plan are as follows.

Qualified Defined Benefit Pension Plan	Three Months Ended March 31,
(in millions)	2021		2020 (a)
Service cost	$	10	$	8
Other components of net benefit credit:
Interest cost	15		18
Expected return on plan assets	(50)		(46)
Amortization of prior service credit	(5)		(5)
Amortization of net loss	7		9
Total other components of net benefit credit	(33)		(24)
Net periodic defined benefit credit	$	(23)	$	(16)

(a)Expected return on plan assets increased $3 million and amortization of net loss was reduced by $5 million to reflect the retrospective application of the Corporation's election to change the accounting method for certain components of the qualified defined benefit pension plan as of January 1, 2021, resulting in an increase of $8 million to total other components of net benefit credit. Refer to Note 1 for further information.

Non-Qualified Defined Benefit Pension Plan	Three Months Ended March 31,
(in millions)	2021		2020
Service cost	$	—	$	1
Other components of net benefit cost:
Interest cost	2		2
Amortization of prior service credit	(1)		(2)
Amortization of net loss	3		2
Total other components of net benefit cost	4		2
Net periodic defined benefit cost	$	4	$	3

Postretirement Benefit Plan	Three Months Ended March 31,
(in millions)	2021		2020
Other components of net benefit credit:
Expected return on plan assets	$	(1)	$	—
Net periodic defined benefit credit	$	(1)	$	—

NOTE 11 - INCOME TAXES AND TAX-RELATED ITEMS

At March 31, 2021, net unrecognized tax benefits were $20 million, compared to $19 million at December 31, 2020. The Corporation anticipates that it is reasonably possible that final settlement of federal and state tax issues will result in a change in net unrecognized tax benefits of $6 million within the next twelve months. Included in accrued expenses and other liabilities on the Consolidated Balance Sheets was a liability for tax-related interest and penalties of $6 million at both March 31, 2021 and December 31, 2020.

Net deferred tax assets were $15 million at March 31, 2021, compared to $4 million at December 31, 2020, primarily driven by decreases to deferred tax liabilities related to unrealized losses on investment securities available-for-sale as well as net hedging gains that were partially offset by decreases to deferred tax assets related to the allowance for loan losses and increases to deferred tax liabilities related to defined benefit plans. These were partially offset by increases to deferred tax assets related to defined benefit plan components of OCI. Included in deferred tax assets at both March 31, 2021 and December 31, 2020 were $3 million of state net operating loss carryforwards, which expire between 2021 and 2030. The Corporation believes that it is more likely than not that the benefit from certain of these state net operating loss carryforwards will not be realized and, accordingly, maintained a valuation allowance of $3 million at both March 31, 2021 and December 31, 2020. The determination regarding valuation allowance was based on evidence of loss carryback capacity, projected future

26

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

reversals of existing taxable temporary differences to absorb the deferred tax assets and assumptions made regarding future events.

In the ordinary course of business, the Corporation enters into certain transactions that have tax consequences. From time to time, the Internal Revenue Service (IRS) or other tax jurisdictions may review and/or challenge specific interpretive tax positions taken by the Corporation with respect to those transactions. The Corporation believes its tax returns were filed based upon applicable statutes, regulations and case law in effect at the time of the transactions. The IRS or other tax jurisdictions, an administrative authority or a court, if presented with the transactions, could disagree with the Corporation’s interpretation of the tax law.

Based on current knowledge and probability assessment of various potential outcomes, the Corporation believes that current tax reserves are adequate, and the amount of any potential incremental liability arising is not expected to have a material adverse effect on the Corporation’s consolidated financial condition or results of operations. Probabilities and outcomes are reviewed as events unfold, and adjustments to the reserves are made when necessary.

NOTE 12 - CONTINGENT LIABILITIES

Legal Proceedings

As previously reported in the Corporation's Form 10-K for the year ended December 31, 2020, the Bank is appealing a court's decision in Butte Local Development v. Masters Group v. Comerica Bank, for lender liability. Management believes that current reserves related to this case are adequate in the event of an adverse outcome.

The Corporation and certain of its subsidiaries are subject to various other pending or threatened legal proceedings arising out of the normal course of business or operations. The Corporation believes it has meritorious defenses to the claims asserted against it in its other currently outstanding legal proceedings and, with respect to such legal proceedings, intends to continue to defend itself vigorously, litigating or settling cases according to management’s judgment as to what is in the best interests of the Corporation and its shareholders. Settlement may result from the Corporation's determination that it may be more prudent financially to settle, rather than litigate, and should not be regarded as an admission of liability. On at least a quarterly basis, the Corporation assesses its potential liabilities and contingencies in connection with outstanding legal proceedings utilizing the latest information available. On a case-by-case basis, reserves are established for those legal claims for which it is probable that a loss will be incurred either as a result of a settlement or judgment, and the amount of such loss can be reasonably estimated. The actual costs of resolving these claims may be substantially higher or lower than the amounts reserved. Based on current knowledge, and after consultation with legal counsel, management believes current reserves are adequate, and the amount of any incremental liability arising from these matters is not expected to have a material adverse effect on the Corporation’s consolidated financial condition, results of operations or cash flows. Legal fees of $2 million were included in other noninterest expenses on the Consolidated Statements of Comprehensive Income for both the three-month periods ended March 31, 2021 and 2020, respectively.

For matters where a loss is not probable, the Corporation has not established legal reserves. The Corporation believes the estimate of the aggregate range of reasonably possible losses, in excess of reserves established, for all legal proceedings in which it is involved is from zero to approximately $94 million at March 31, 2021. This estimated aggregate range of reasonably possible losses is based upon currently available information for those proceedings in which the Corporation is involved, taking into account the Corporation’s best estimate of such losses for those cases for which such estimate can be made. For certain cases, the Corporation does not believe that an estimate can currently be made. The Corporation’s estimate involves significant judgment, given the varying stages of the proceedings (including the fact many are currently in preliminary stages), the existence in certain proceedings of multiple defendants (including the Corporation) whose share of liability has yet to be determined, the numerous yet-unresolved issues in many of the proceedings (including issues regarding class certification and the scope of many of the claims) and the attendant uncertainty of the various potential outcomes of such proceedings. Accordingly, the Corporation’s estimate will change from time to time, and actual losses may be more or less than the current estimate.

In the event of unexpected future developments, it is possible the ultimate resolution of these matters, if unfavorable, may be material to the Corporation's consolidated financial condition, results of operations or cash flows.

For information regarding income tax contingencies, refer to Note 11.

27

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

NOTE 13 - STRATEGIC LINES OF BUSINESS AND MARKETS

The Corporation has strategically aligned its operations into three major business segments: the Commercial Bank, the Retail Bank and Wealth Management. These business segments are differentiated based on the type of customer and the related products and services provided. In addition to the three major business segments, the Finance Division is also reported as a segment. Business segment results are produced by the Corporation’s internal management accounting system. This system measures financial results based on the internal business unit structure of the Corporation. The performance of the business segments is not comparable with the Corporation's consolidated results and is not necessarily comparable with similar information for any other financial institution. Additionally, because of the interrelationships of the various segments, the information presented is not indicative of how the segments would perform if they operated as independent entities. The management accounting system assigns balance sheet and income statement items to each business segment using certain methodologies, which are regularly reviewed and refined. From time to time, the Corporation may make reclassifications among the segments to more appropriately reflect management's current view of the segments, and methodologies may be modified as the management accounting system is enhanced and changes occur in the organizational structure and/or product lines. For comparability purposes, amounts in all periods are based on business unit structure and methodologies in effect at March 31, 2021.

The following discussion provides information about the activities of each business segment. A discussion of the financial results and the factors impacting performance can be found in "Business Segments" in the "Strategic Lines of Business and Markets" section of the financial review.

The Commercial Bank meets the needs of small and middle market businesses, multinational corporations and governmental entities by offering various products and services including commercial loans and lines of credit, deposits, cash management, capital market products, international trade finance, letters of credit, foreign exchange management services and loan syndication services.

The Retail Bank includes a full range of personal financial services, consisting of consumer lending, consumer deposit gathering and mortgage loan origination. This business segment offers a variety of consumer products including deposit accounts, installment loans, credit cards, student loans, home equity lines of credit and residential mortgage loans. In addition, this business segment offers a subset of commercial products and services to micro-businesses whose primary contact is through the branch network.

Wealth Management offers products and services consisting of fiduciary services, private banking, retirement services, investment management and advisory services, investment banking and brokerage services. This business segment also offers the sale of annuity products, as well as life, disability and long-term care insurance products.

The Finance segment includes the Corporation’s securities portfolio and asset and liability management activities. This segment is responsible for managing the Corporation’s funding, liquidity and capital needs, performing interest sensitivity analysis and executing various strategies to manage the Corporation’s exposure to liquidity, interest rate risk and foreign exchange risk.

The Other category includes the income and expense impact of equity and cash, tax benefits not assigned to specific business segments, charges of an unusual or infrequent nature that are not reflective of the normal operations of the business segments and miscellaneous other expenses of a corporate nature.

For further information on the methodologies which form the basis for these results refer to Note 22 to the consolidated financial statements in the Corporation's 2020 Annual Report.

28

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

Business segment financial results are as follows:

	Commercial Bank			Retail Bank			Wealth Management			Finance		Other		Total
(dollar amounts in millions)
Three Months Ended March 31, 2021
Earnings summary:
Net interest income (expense)	$	382		$	133		$	42		$	(117)	$	3	$	443
Provision for credit losses	(177)			6			(12)			—		1		(182)
Noninterest income	159			28			67			12		4		270
Noninterest expenses	215			149			76			—		7		447
Provision (benefit) for income taxes	113			—			10			(25)		—		98
Net income (loss)	$	390		$	6		$	35		$	(80)	$	(1)	$	350
Net credit-related charge-offs	$	2		$	1		$	—		$	—	$	—	$	3
Selected average balances:
Assets	$	44,448		$	3,463		$	5,162		$	16,959	$	14,527	$	84,559
Loans	42,904			2,620			5,059			—		6		50,589
Deposits	41,102			24,322			4,826			985		157		71,392
Statistical data:
Return on average assets (a)	3.56		%	0.11		%	2.72		%	n/m		n/m		1.68		%
Efficiency ratio (b)	39.66			91.68			69.84			n/m		n/m		62.55
Three Months Ended March 31, 2020
Earnings summary:
Net interest income (expense)	$	380		$	125		$	41		$	(44)	$	11	$	513
Provision for credit losses	396			3			12			—		—		411
Noninterest income	127			28			70			14		(2)		237
Noninterest expenses (c)	192			145			70			—		10		417
(Benefit) provision for income taxes (c)	(19)			1			6			(8)		1		(19)
Net (loss) income (c)	$	(62)		$	4		$	23		$	(22)	$	(2)	$	(59)
Net credit-related charge-offs	$	83		$	1		$	—		$	—	$	—	$	84
Selected average balances:
Assets	$	44,254		$	2,864		$	5,078		$	14,285	$	6,784	$	73,265
Loans	42,593			2,075			4,936			—		—		49,604
Deposits	30,230			21,195			4,025			1,136		182		56,768
Statistical data:
Return on average assets (a) (c)	(0.56)		%	0.07		%	1.81		%	n/m		n/m		(0.32)		%
Efficiency ratio (b) (c)	37.95			94.07			62.68			n/m		n/m		55.58

(a)Return on average assets is calculated based on the greater of average assets or average liabilities and attributed equity.

(b)Noninterest expenses as a percentage of the sum of net interest income and noninterest income excluding net losses from securities and a derivative contract tied to the conversion rate of Visa Class B shares.

(c)See Defined Benefit Pension and Other Postretirement Costs in Note 1.

n/m – not meaningful

The Corporation operates in three primary markets - Texas, California and Michigan, as well as in Arizona and Florida, with select businesses operating in several other states and in Canada and Mexico. The Corporation produces market segment results for the Corporation’s three primary geographic markets as well as Other Markets. Other Markets includes Florida, Arizona, the International Finance division and businesses with a national perspective. The Finance & Other category includes the Finance segment and the Other category as previously described. Market segment results are provided as supplemental information to the business segment results and may not meet all operating segment criteria as set forth in GAAP. For comparability purposes, amounts in all periods are based on market segments and methodologies in effect at March 31, 2021.

A discussion of the financial results and the factors impacting performance can be found in the section entitled "Market Segments" in the "Strategic Lines of Business and Markets" section of the financial review.

29

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

Market segment financial results are as follows:

	Michigan			California			Texas			Other Markets			Finance & Other		Total
(dollar amounts in millions)
Three Months Ended March 31, 2021
Earnings summary:
Net interest income (expense)	$	154		$	172		$	114		$	117		$	(114)	$	443
Provision for credit losses	(28)			(54)			(86)			(15)			1		(182)
Noninterest income	66			48			36			104			16		270
Noninterest expenses	135			104			88			113			7		447
Provision (benefit) for income taxes	22			40			31			30			(25)		98
Net income (loss)	$	91		$	130		$	117		$	93		$	(81)	$	350
Net credit-related charge-offs	$	—		$	1		$	2		$	—		$	—	$	3
Selected average balances:
Assets	$	12,916		$	18,143		$	10,668		$	11,348		$	31,484	$	84,559
Loans	12,247			17,946			10,161			10,231			4		50,589
Deposits	25,683			19,968			10,783			13,816			1,142		71,392
Statistical data:
Return on average assets (a)	1.40		%	2.51		%	3.88		%	2.54		%	n/m		1.68		%
Efficiency ratio (b)	60.86			47.09			58.85			51.18			n/m		62.55
Three Months Ended March 31, 2020
Earnings summary:
Net interest income (expense)	$	163		$	176		$	115		$	92		$	(33)	$	513
Provision for credit losses	24			46			290			51			—		411
Noninterest income	72			33			30			90			12		237
Noninterest expenses (c)	137			93			83			94			10		417
Provision (benefit) for income taxes (c)	16			17			(50)			5			(7)		(19)
Net income (loss) (c)	$	58		$	53		$	(178)		$	32		$	(24)	$	(59)
Net credit-related charge-offs	$	3		$	8		$	70		$	3		$	—	$	84
Selected average balances:
Assets	$	12,895		$	18,007		$	11,154		$	10,140		$	21,069	$	73,265
Loans	12,191			17,742			10,566			9,105			—		49,604
Deposits	20,748			16,627			9,204			8,871			1,318		56,768
Statistical data:
Return on average assets (a) (c)	1.10		%	1.19		%	(6.47)		%	1.27		%	n/m		(0.32)		%
Efficiency ratio (b) (c)	57.92			44.60			57.38			51.69			n/m		55.58

(a)Return on average assets is calculated based on the greater of average assets or average liabilities and attributed equity.

(b)Noninterest expenses as a percentage of the sum of net interest income and noninterest income excluding net losses from securities and a derivative contract tied to the conversion rate of Visa Class B shares.

(c)See Defined Benefit Pension and Other Postretirement Costs in Note 1.

n/m – not meaningful.

30

Notes to Consolidated Financial Statements (unaudited)

Comerica Incorporated and Subsidiaries

NOTE 14 - REVENUE FROM CONTRACTS WITH CUSTOMERS

Revenue from contracts with customers comprises the noninterest income earned by the Corporation in exchange for services provided to customers. The following table presents the composition of revenue from contracts with customers, segregated from other sources of noninterest income, by business segment.

	Commercial Bank		Retail Bank		Wealth Management		Finance & Other		Total
(in millions)
Three Months Ended March 31, 2021
Revenue from contracts with customers:
Card fees	$	60	$	10	$	1	$	—	$	71
Fiduciary income	—		—		53		—		53
Service charges on deposit accounts	34		13		1		—		48
Commercial loan servicing fees (a)	4		—		—		—		4
Brokerage fees	—		—		4		—		4
Other noninterest income (b)	5		4		5		—		14
Total revenue from contracts with customers	103		27		64		—		194
Other sources of noninterest income	56		1		3		16		76
Total noninterest income	$	159	$	28	$	67	$	16	$	270
Three Months Ended March 31, 2020
Revenue from contracts with customers:
Card fees	$	49	$	9	$	1	$	—	$	59
Fiduciary income	—		—		54		—		54
Service charges on deposit accounts	32		16		1		—		49
Commercial loan servicing fees (a)	4		—		—		—		4
Brokerage fees	—		—		7		—		7
Other noninterest income (b)	4		3		5		—		12
Total revenue from contracts with customers	89		28		68		—		185
Other sources of noninterest income	38		—		2		12		52
Total noninterest income	$	127	$	28	$	70	$	12	$	237

(a)Included in commercial lending fees on the Consolidated Statements of Comprehensive Income.

(b)Excludes derivative, warrant and other miscellaneous income.

    Adjustments to revenue during the three-month periods ended March 31, 2021 and 2020 for refunds or credits relating to prior periods were not significant.

    Revenue from contracts with customers did not generate significant contract assets and liabilities.

31

ITEM 2. Management's Discussion and Analysis of Financial Condition and Results of Operations

FORWARD-LOOKING STATEMENTS

This report includes forward-looking statements as defined in the Private Securities Litigation Reform Act of 1995. In addition, the Corporation may make other written and oral communications from time to time that contain such statements. All statements regarding the Corporation's expected financial position, strategies and growth prospects and general economic conditions expected to exist in the future are forward-looking statements. The words, "anticipates," "believes," "contemplates," "feels," "expects," "estimates," "seeks," "strives," "plans," "intends," "outlook," "forecast," "position," "target," "mission," "assume," "achievable," "potential," "strategy," "goal," "aspiration," "opportunity," "initiative," "outcome," "continue," "remain," "maintain," "on track," "trend," "objective," "looks forward," "projects," "models," and variations of such words and similar expressions, or future or conditional verbs such as "will," "would," "should," "could," "might," "can," "may" or similar expressions, as they relate to the Corporation or its management, are intended to identify forward-looking statements. These forward-looking statements are predicated on the beliefs and assumptions of the Corporation's management based on information known to the Corporation's management as of the date of this report and do not purport to speak as of any other date. Forward-looking statements may include descriptions of plans and objectives of the Corporation's management for future or past operations, products or services and forecasts of the Corporation's revenue, earnings or other measures of economic performance, including statements of profitability, business segments and subsidiaries as well as estimates of credit trends and global stability. Such statements reflect the view of the Corporation's management as of this date with respect to future events and are subject to risks and uncertainties. Should one or more of these risks materialize or should underlying beliefs or assumptions prove incorrect, the Corporation's actual results could differ materially from those discussed. Factors that could cause or contribute to such differences include credit risks (unfavorable developments concerning credit quality; declines or other changes in the businesses or industries of the Corporation's customers, in particular the energy industry; and changes in customer behavior); market risks (changes in monetary and fiscal policies; fluctuations in interest rates and their impact on deposit pricing; and transitions away from LIBOR towards new interest rate benchmarks); liquidity risks (the Corporation's ability to maintain adequate sources of funding and liquidity; reductions in the Corporation's credit rating; and the interdependence of financial service companies); technology risks (cybersecurity risks and heightened legislative and regulatory focus on cybersecurity and data privacy); operational risks (operational, systems or infrastructure failures; reliance on other companies to provide certain key components of business infrastructure; the impact of legal and regulatory proceedings or determinations; losses due to fraud; and controls and procedures failures); compliance risks (changes in regulation or oversight; the effects of stringent capital requirements; and the impacts of future legislative, administrative or judicial changes to tax regulations); strategic risks (damage to the Corporation's reputation; the Corporation's ability to utilize technology to efficiently and effectively develop, market and deliver new products and services; competitive product and pricing pressures among financial institutions within the Corporation's markets; the implementation of the Corporation's strategies and business initiatives; management's ability to maintain and expand customer relationships; management's ability to retain key officers and employees; and any future strategic acquisitions or divestitures); and other general risks (impacts from the COVID-19 global pandemic; changes in general economic, political or industry conditions; the effectiveness of methods of reducing risk exposures; the effects of catastrophic events; changes in accounting standards and the critical nature of the Corporation's accounting policies; and the volatility of the Corporation's stock price). The Corporation cautions that the foregoing list of factors is not all-inclusive. For discussion of factors that may cause actual results to differ from expectations, please refer to our filings with the Securities and Exchange Commission. In particular, please refer to “Item 1A. Risk Factors” beginning on page 13 of the Corporation's Annual Report on Form 10-K for the year ended December 31, 2020. Forward-looking statements speak only as of the date they are made. The Corporation does not undertake to update forward-looking statements to reflect facts, circumstances, assumptions or events that occur after the date the forward-looking statements are made. For any forward-looking statements made in this report or in any documents, the Corporation claims the protection of the safe harbor for forward-looking statements contained in the Private Securities Litigation Reform Act of 1995.

32

RESULTS OF OPERATIONS

Net income for the three months ended March 31, 2021 was $350 million compared to a net loss of $59 million for the three months ended March 31, 2020, which was driven by lower provision for credit losses resulting from an improved economic outlook and strong credit performance. Results for the three months ended March 31, 2021 were also impacted by lower net interest income, reflecting a decline in short-term interest rates, as well as an increase in noninterest expenses, partially offset by higher noninterest income. The provision for income taxes increased $117 million to $98 million due to the increase in pre-tax income.

Net income per diluted common share for the three months ended March 31, 2021 was $2.43 compared to a net loss per diluted common share of $0.42 for the same period in the prior year.

Pension Plan Accounting Change

Effective January 1, 2021, the Corporation elected to change the accounting methodology for determining market-related value of plan assets (MRVA) to a more preferable method for certain classes of assets in the qualified defined benefit pension plan. The classes of assets impacted by the new accounting methodology are fixed income securities and private placement assets held in the portfolio, which are primarily designed to match the duration and interest rate exposure of the Corporation's long-term pension commitments to mitigate against the volatility of interest rates. Under the previous policy, MRVA was calculated based on a five-year average fair value. The new accounting policy recognizes changes in fair value in the year they occur and better aligns the timing of recognition of interest rate impacts to pension assets and liabilities, reducing earnings volatility.

As a result of the policy change, the defined benefit plan benefit is expected to be $79 million in 2021, an increase of $18 million from the estimated benefit under the previous policy. The impact of the change for the three months ended March 31, 2021 was an increase to the pension benefit reduction to noninterest expenses of $5 million and a corresponding increase to net income of $3 million. The change in accounting methodology is applied retrospectively to all prior periods presented in the consolidated financial statements. Discussion of results of operations is based on recast results. See Note 1 to the consolidated financial statements for further information and impacts of the change in accounting policy.

33

Three Months Ended March 31, 2021 compared to Three Months Ended March 31, 2020

Analysis of Net Interest Income

	Three Months Ended
	March 31, 2021						March 31, 2020
(dollar amounts in millions)	Average Balance		Interest		Average Rate		Average Balance		Interest		Average Rate
Commercial loans (a)	$	30,968	$	254	3.33	%	$	30,697	$	314	4.11	%
Real estate construction loans	4,137		34		3.37		3,564		43		4.85
Commercial mortgage loans	9,952		70		2.85		9,638		101		4.21
Lease financing (b)	592		(12)		(8.44)		582		5		3.63
International loans	962		8		3.17		1,004		11		4.48
Residential mortgage loans	1,809		14		3.13		1,855		17		3.67
Consumer loans	2,169		18		3.40		2,264		26		4.60
Total loans (c)	50,589		386		3.09		49,604		517		4.19
Mortgage-backed securities (d)	10,257		51		2.03		9,514		57		2.42
U.S. Treasury securities (e)	4,637		18		1.58		2,817		17		2.48
Total investment securities	14,894		69		1.89		12,331		74		2.43
Interest-bearing deposits with banks	12,869		4		0.10		5,407		18		1.34
Other short-term investments	171		—		0.28		154		—		1.09
Total earning assets	78,523		459		2.37		67,496		609		3.64
Cash and due from banks	970						838
Allowance for loan losses	(915)						(693)
Accrued income and other assets	5,981						5,624
Total assets	$	84,559					$	73,265
Money market and interest-bearing checking deposits	$	29,012	6		0.08		$	24,654	45		0.73
Savings deposits	2,800		—		0.02		2,202		—		0.06
Customer certificates of deposit	2,155		1		0.24		2,999		11		1.42
Other time deposits	—		—		—		70		—		2.00
Foreign office time deposits	64		—		0.09		82		—		1.30
Total interest-bearing deposits	34,031		7		0.08		30,007		56		0.76
Short-term borrowings	3		—		0.05		157		—		0.82
Medium- and long-term debt	3,609		9		0.99		7,324		40		2.15
Total interest-bearing sources	37,643		16		0.17		37,488		96		1.03
Noninterest-bearing deposits	37,361						26,761
Accrued expenses and other liabilities	1,415						1,578
Shareholders’ equity	8,140						7,438
Total liabilities and shareholders’ equity	$	84,559					$	73,265
Net interest income/rate spread			$	443	2.20				$	513	2.61
Impact of net noninterest-bearing sources of funds					0.09						0.45
Net interest margin (as a percentage of average earning assets)					2.29	%					3.06	%

(a)Includes Paycheck Protection Program (PPP) loans with average balance of $3.6 billion, interest income of $31 million and an average yield of 3.47% for the three months ended March 31, 2021.

(b)The three months ended March 31, 2021 includes residual value adjustments totaling $17 million.

(c)Nonaccrual loans are included in average balances reported and in the calculation of average rates.

(d)Average balances included $157 million and $105 million of unrealized gains and losses for the three months ended March 31, 2021 and 2020, respectively; yields calculated gross of these unrealized gains and losses.

(e)Average balances included $56 million and $72 million of unrealized gains and losses for the three months ended March 31, 2021 and 2020, respectively; yields calculated gross of these unrealized gains and losses.

34

Rate/Volume Analysis

	Three Months Ended
	March 31, 2021/March 31, 2020
(in millions)	Decrease Due to Rate		Increase (Decrease) Due to Volume (a)		Net Decrease
Interest Income:
Loans	$	(139)	$	8	$	(131)
Investment securities	(16)		11		(5)
Interest-bearing deposits with banks	(16)		2		(14)
Total interest income	(171)		21		(150)
Interest Expense:
Interest-bearing deposits	(50)		1		(49)
Medium- and long-term debt	(23)		(8)		(31)
Total interest expense	(73)		(7)		(80)
Net interest income	$	(98)	$	28	$	(70)

(a)Rate/volume variances are allocated to variances due to volume.

Net interest income was $443 million for the three months ended March 31, 2021, a decrease of $70 million compared to $513 million for the three months ended March 31, 2020. Net interest margin was 2.29 percent for the three months ended March 31, 2021, a decline of 77 basis points from 3.06 percent for the three months ended March 31, 2020, reflecting the impact of lower interest rates. Average earning assets increased $11.0 billion, primarily due to increases of $7.5 billion in interest-bearing deposits with banks and $3.6 billion in PPP loans. Average interest-bearing funding sources increased $155 million, reflecting a $4.0 billion increase in interest-bearing deposits, partially offset by a $3.7 billion decrease in medium- and long-term debt and a smaller decrease in short-term borrowings.

Provision for Credit Losses

    The provision for credit losses, which includes the provision for loan losses and the provision for credit losses on lending-related commitments, was a benefit of $182 million for the three months ended March 31, 2021, compared to an expense of $411 million for the three months ended March 31, 2020. Net loan charge-offs decreased $81 million to $3 million, or 3 basis points of average total loans for the three months ended March 31, 2021, compared to $84 million, or 68 basis points of average total loans for the three months ended March 31, 2020. Energy net charge-offs decreased $68 million to a net recovery of $1 million for the three months ended March 31, 2021.

    An analysis of the allowance for credit losses and a summary of nonperforming assets are presented under the "Credit Risk" subheading in the "Risk Management" section of this financial review.

35

Noninterest Income

	Three Months Ended March 31,
(in millions)	2021		2020
Card fees	$	71	$	59
Fiduciary income	53		54
Service charges on deposit accounts	48		49
Derivative income (a)	30		20
Commercial lending fees	18		17
Bank-owned life insurance	11		12
Letter of credit fees	10		9
Brokerage fees	4		7
Net securities losses	—		(1)
Other noninterest income (a)(b)	25		11
Total noninterest income	$	270	$	237

(a)Beginning with the first quarter 2021, the Corporation reported customer derivative income, previously a component of other noninterest income, and foreign exchange income as a combined item captioned by derivative income on the Consolidated Statements of Comprehensive Income. Prior periods have been adjusted to conform to this presentation and the changes in presentation do not impact total noninterest income.

(b)The table below provides further details on certain categories included in other noninterest income.

    Noninterest income increased $33 million to $270 million for the three months ended March 31, 2021, including an increase in card fees as a result of higher activity related to stimulus payments and higher derivative income primarily from favorable valuation adjustments, partially offset by a decrease in brokerage fees due to lower money market funds fee revenue. Noninterest income was also impacted by increases in deferred compensation asset returns (offset in noninterest expenses) and principal investing and warrants, included in other noninterest income and detailed below.

    The following table presents certain categories included in other noninterest income on the Consolidated Statements of Comprehensive Income.

	Three Months Ended March 31,
(in millions)	2021		2020
Income from principal investing and warrants	$	6	$	—
Investment banking fees	4		3
Deferred compensation asset returns (a)	3		(3)
Securities trading income	2		2
All other noninterest income	10		9
Other noninterest income	$	25	$	11

(a)    Compensation deferred by the Corporation's officers and directors is invested based on investment selections of the officers and directors. Income earned on these assets is reported in other noninterest income and the offsetting change in deferred compensation plan liabilities is reported in salaries and benefits expense.

Noninterest Expenses

	Three Months Ended March 31,
(in millions)	2021		2020
Salaries and benefits expense	$	282	$	242
Outside processing fee expense	64		57
Occupancy expense	39		37
Software expense	39		37
Equipment expense	12		12
Advertising expense	6		7
FDIC insurance expense	6		8
Other noninterest expenses (a)	(1)		17
Total noninterest expenses (a)	$	447	$	417

(a)    The three months ended March 31, 2020 has been recast to reflect the retrospective application of the Corporation's election to change the accounting method for certain components of expense related to the defined pension plan, resulting in a decrease of $8 million from the previously reported balances See Note 1 to the consolidated financial statements for further information and impacts of the change in accounting policy.

Noninterest expenses increased $30 million to $447 million, primarily reflecting increases in salaries and benefits and outside processing fee expenses, partially offset by decreases in operational losses and non-salary pension expense (both components of other noninterest expense). The increase in salaries and benefits expense was mostly a result of lower accrued expenses in the first quarter 2020 for performance-related compensation, including stock-based compensation, due to the expected impact to performance of the COVID-19 pandemic, as well as an increase in deferred compensation expense (offset in

36

other noninterest income). The increase in outside processing fee expense was primarily due to volume-driven increases in government card processing expense tied to card fee revenues.

OUTLOOK

This outlook is based on management expectations for continued improvement in economic conditions.

	Second Quarter 2021 Compared to First Quarter 2021	Trends for Second Half of 2021
Average loans	•Average loans (excluding PPP) reflect growth in several businesses, including Middle Market, offset by declines in Mortgage Banker Finance, National Dealer Services and Energy. In addition, decline in PPP loans due to forgiveness process.	•Solid average loan growth in nearly all business lines (excluding PPP), more than offset by forgiveness of the bulk of PPP loans.
Average deposits	•Average deposits to remain strong, benefiting from latest stimulus.	•Average deposits begin to wane as customers put cash to use.
Net interest income	•Increase in net interest income as lease residual adjustment ($17 million in first quarter) does not repeat. All other factors offset each other.	•Net interest income reflects higher loan volume (excluding PPP loans) offset by lower securities yields. In addition, PPP volume and accelerated fees decline.
Credit quality	•Strong credit quality continues, with provision reflecting economic conditions.	•Allowance moving towards pre-pandemic level.
Noninterest income	•Decrease in noninterest income as first quarter levels of derivatives, warrants and deferred compensation asset returns not expected to repeat, partly offset by increase in card, fiduciary and syndication fees.	•Noninterest income includes increases in service charges on deposit accounts, fiduciary income and commercial loan fees, partly offset by lower card fees from decreased stimulus activity.
Noninterest expenses	•Stable noninterest expenses reflect lower salaries and benefits (annual stock-based compensation and deferred compensation asset returns not expected to repeat, as well as seasonally lower payroll taxes partly offset by merit increases and one additional day in the second quarter) offset by increase in outside processing as well as seasonal increases in occupancy and advertising.	•Continued expense discipline offsets increase in technology investment. In addition, increases due to seasonal factors and revenue-related expenses.
Tax rate	•Income tax expense for full-year 2021 to be between 22 and 23 percent of pre-tax income, excluding discrete items.
Capital	•Resume share purchases; CET1 target of approximately 10 percent.

37

STRATEGIC LINES OF BUSINESS AND MARKETS

The Corporation has strategically aligned its operations into three major business segments: the Commercial Bank, the Retail Bank and Wealth Management. These business segments are differentiated based on the type of customer and the related products and services provided. In addition to the three major business segments, the Finance Division is also reported as a segment. The Other category includes items not directly associated with the business segments or the Finance segment. The performance of the business segments is not comparable with the Corporation's consolidated results and is not necessarily comparable with similar information for any other financial institution. Additionally, because of the interrelationships of the various segments, the information presented is not indicative of how the segments would perform if they operated as independent entities. Market segment results are also provided for the Corporation's three primary geographic markets: Michigan, California and Texas. In addition to the three primary geographic markets, Other Markets is also reported as a market segment. Note 13 to the consolidated financial statements describes the business activities of each business segment and presents financial results of the business and market segments for the three-month periods ended March 31, 2021 and 2020.

The Corporation's management accounting system assigns balance sheet and income statement items to each segment using certain methodologies, which are regularly reviewed and refined. These methodologies may be modified as the management accounting system is enhanced and changes occur in the organizational structure and/or product lines. Note 22 to the consolidated financial statements in the Corporation's 2020 Annual Report describes the Corporation's segment reporting methodology.

Net interest income for each segment reflects the interest income generated by earning assets less interest expense on interest-bearing liabilities plus the net impact from associated internal funds transfer pricing (FTP). The FTP methodology allocates credits to each business segment for deposits and other funds provided as well as charges for loans and other assets being funded. FTP crediting rates on deposits and other funds provided reflect the long-term value of deposits and other funding sources based on their implied maturities. Due to the longer-term nature of implied maturities, FTP crediting rates are generally less volatile than changes in interest rates observed in the market. FTP charge rates for funding loans and other assets reflect a matched cost of funds based on the pricing and duration characteristics of the assets. As a result of applying matched funding, interest revenue for each segment resulting from loans and other assets is generally not impacted by changes in interest rates. Therefore, net interest income for each segment primarily reflects the volume of loans and other earning assets at the spread over the matched cost of funds, as well as the volume of deposits at the associated FTP crediting rates. Due to the impact of lower interest rates, business segments, particularly those focused on generating deposits, were impacted by lower FTP crediting rates on deposits in the three months ended March 31, 2021 compared to the same period in the prior year. Similarly, FTP charges for funding loans decreased in the three months ended March 31, 2021, compared to the same period in the prior year.

Business Segments

The following sections present a summary of the performance of each of the Corporation's business segments for the three months ended March 31, 2021 compared to the same period in the prior year. The three months ended March 31, 2020 has been recast to reflect the retrospective application of the Corporation's election to change the accounting method for certain components of expense related to the defined pension plan. Further information about the change in accounting methodology is presented in Note 1 to the consolidated financial statements.

Commercial Bank

	Three Months Ended						Percent Change
(dollar amounts in millions)	March 31, 2021		March 31, 2020		Change
Earnings summary:
Net interest income	$	382	$	380	$	2	—	%
Provision for credit losses	(177)		396		(573)		n/m
Noninterest income	159		127		32		26
Noninterest expenses	215		192		23		11
Provision (benefit) for income taxes	113		(19)		132		n/m
Net income (loss)	$	390	$	(62)	$	452	n/m
Net credit-related charge-offs	$	2	$	83	$	(81)	(97)	%
Selected average balances:
Loans	$	42,904	$	42,593	$	311	1	%
Deposits	41,102		30,230		10,872		36

n/m - not meaningful

38

Average loans were relatively stable. The 2021 period included average PPP loans totaling $2.7 billion. Average deposits increased $10.9 billion, reflecting increases in all deposit categories with the exception of time deposits. The Commercial Bank's net income increased $452 million from a net loss of $62 million. Net interest income was stable, while the provision for credit losses decreased $573 million to a benefit of $177 million, reflecting improvements in the economic forecast and in the Energy portfolio as well as strong credit performance. Net credit-related charge-offs decreased $81 million, primarily due to a reduction in Energy net charge-offs. Noninterest income increased $32 million, primarily reflecting increases in card fees, derivative income and warrant income. Noninterest expenses increased $23 million, primarily reflecting increases in salaries and benefits expense, corporate overhead and outside processing fee expense, partially offset by decreases in operational losses and travel expenses.

Retail Bank

	Three Months Ended						Percent Change
(dollar amounts in millions)	March 31, 2021		March 31, 2020		Change
Earnings summary:
Net interest income	$	133	$	125	$	8	7	%
Provision for credit losses	6		3		3		63
Noninterest income	28		28		—		(1)
Noninterest expenses	149		145		4		2
Provision for income taxes	—		1		(1)		(83)
Net income	$	6	$	4	$	2	77%
Net credit-related charge-offs	$	1	$	1	$	—	—
Selected average balances:
Loans	$	2,620	$	2,075	$	545	26	%
Deposits	24,322		21,195		3,127		15

Average loans increased $545 million due to loans to small businesses, including PPP loans. Average deposits increased $3.1 billion, including increases in all deposit categories with the exception of time deposits. The Retail Bank's net income increased $2 million, which included an $8 million increase in net interest income, primarily due to an increase in average loans, and a $3 million increase in provision for credit losses. Noninterest income was stable, while noninterest expenses increased $4 million, primarily due to increases in corporate overhead and occupancy expenses, offset by decreases in operational losses.

Wealth Management

	Three Months Ended						Percent Change
(dollar amounts in millions)	March 31, 2021		March 31, 2020		Change
Earnings summary:
Net interest income	$	42	$	41	$	1	2	%
Provision for credit losses	(12)		12		(24)		n/m
Noninterest income	67		70		(3)		(5)
Noninterest expenses	76		70		6		9
Provision for income taxes	10		6		4		56
Net income	$	35	$	23	$	12	53	%
Selected average balances:
Loans	$	5,059	$	4,936	$	123	2	%
Deposits	4,826		4,025		801		20

n/m - not meaningful

    Average loans remained relatively stable. Average deposits increased $801 million, reflecting increases in all deposit categories with the exception of time deposits. Wealth Management's net income increased $12 million, which included stable net interest income and a $24 million decrease in provision for credit losses to a benefit of $12 million due to an improving economic outlook. Noninterest income decreased $3 million, while noninterest expenses increased $6 million, primarily reflecting an increase in corporate overhead.

Market Segments

The following sections present a summary of the performance of each of the Corporation's market segments for the three months ended March 31, 2021 compared to the same period in the prior year. The three months ended March 31, 2020 has been recast to reflect the retrospective application of the Corporation's election to change the accounting method for certain

39

components of expense related to the defined pension plan. Further information about the change in accounting methodology is presented in Note 1 to the consolidated financial statements.

Michigan

	Three Months Ended						Percent Change
(dollar amounts in millions)	March 31, 2021		March 31, 2020		Change
Earnings summary:
Net interest income	$	154	$	163	$	(9)	(5)	%
Provision for credit losses	(28)		24		(52)		n/m
Noninterest income	66		72		(6)		(8)
Noninterest expenses	135		137		(2)		(1)
Provision for income taxes	22		16		6		40
Net income	$	91	$	58	$	33	57	%
Net credit-related charge-offs	$	—	$	3	$	(3)	n/m
Selected average balances:
Loans	$	12,247	$	12,191	$	56	—	%
Deposits	25,683		20,748		4,935		24

n/m - not meaningful

Average loans were stable at $12.2 billion, while average deposits increased $4.9 billion, reflecting increases in all deposit categories with the exception of personal time deposits. The Michigan market's net income increased $33 million to $91 million. Net interest income decreased $9 million, primarily due to lower interest income from deposits (FTP basis), while the provision for credit losses decreased $52 million to a benefit of $28 million, primarily due to decreases in general Middle Market, Corporate Banking and Business Banking. Noninterest income decreased $6 million, primarily due to decreases in service charges on deposits accounts and fiduciary income, while noninterest expenses were stable.

California

	Three Months Ended						Percent Change
(dollar amounts in millions)	March 31, 2021		March 31, 2020		Change
Earnings summary:
Net interest income	$	172	$	176	$	(4)	(3)	%
Provision for credit losses	(54)		46		(100)		n/m
Noninterest income	48		33		15		47
Noninterest expenses	104		93		11		11
Provision for income taxes	40		17		23		n/m
Net income	$	130	$	53	$	77	n/m
Net credit-related charge-offs	$	1	$	8	$	(7)	(92)	%
Selected average balances:
Loans	$	17,946	$	17,742	$	204	1	%
Deposits	19,968		16,627		3,341		20

n/m - not meaningful

Average loans increased $204 million to $17.9 billion, while average deposits increased $3.3 billion, including increases in all deposit categories with the exception of time deposits. The California market's net income increased $77 million to $130 million. Net interest income was stable, while the provision for credit losses decreased $100 million to a benefit of $54 million, primarily reflecting decreases in general Middle Market, Corporate Banking and Technology and Life Sciences. Net credit-related charge-offs decreased $7 million, mainly due to a decrease in Technology and Life Sciences. Noninterest income increased $15 million, mostly from derivative income and warrant income. Noninterest expenses increased $11 million, including increases in salaries and benefits and corporate overhead.

40

Texas

	Three Months Ended						Percent Change
(dollar amounts in millions)	March 31, 2021		March 31, 2020		Change
Earnings summary:
Net interest income	$	114	$	115	$	(1)	(1)	%
Provision for credit losses	(86)		290		(376)		n/m
Noninterest income	36		30		6		17
Noninterest expenses	88		83		5		5
Provision (benefit) for income taxes	31		(50)		81		n/m
Net income (loss)	$	117	$	(178)	$	295	n/m
Net credit-related charge-offs	$	2	$	70	$	(68)	(96)	%
Selected average balances:
Loans	$	10,161	$	10,566	$	(405)	(4)	%
Deposits	10,783		9,204		1,579		17

n/m - not meaningful

Average loans were relatively stable, while average deposits increased $1.6 billion, reflecting increases in all deposit categories with the exception of time deposits. The Texas market's net income increased $295 million to $117 million, which included stable net interest income. The provision for credit losses decreased $376 million to a benefit of $86 million and net credit-related charge-offs decreased $68 million, both primarily reflecting decreases in Energy. Noninterest income increased $6 million, primarily reflecting increased derivative income. Noninterest expenses increased $5 million, primarily due to higher corporate overhead and salaries and benefits expense, partially offset by lower operational losses.

Other Markets

	Three Months Ended						Percent Change
(dollar amounts in millions)	March 31, 2021		March 31, 2020		Change
Earnings summary:
Net interest income	$	117	$	92	$	25	27	%
Provision for credit losses	(15)		51		(66)		n/m
Noninterest income	104		90		14		15
Noninterest expenses	113		94		19		20
Provision for income taxes	30		5		25		n/m
Net income	$	93	$	32	$	61	n/m
Net credit-related recoveries	$	—	$	3	$	(3)	(98)	%
Selected average balances:
Loans	$	10,231	$	9,105	$	1,126	12	%
Deposits	13,816		8,871		4,945		56

n/m - not meaningful

Average loans increased $1.1 billion, primarily due to an increase in Mortgage Banker Finance, while average deposits increased $4.9 billion, including increases in all deposit categories with the exception of time deposits. Other Markets' net income increased $61 million to $93 million. Net interest income increased $25 million primarily due to growth in average loans, while the provision for credit losses decreased $66 million to a benefit of $15 million, primarily reflecting decreases in Technology and Life Sciences and Corporate Banking. Noninterest income increased $14 million, mostly from an increase in card fees. Noninterest expenses increased $19 million, primarily reflecting increases in outside processing fees and salaries and benefits expense as well as smaller increases in other categories.

41

Finance & Other

	Three Months Ended						Percent Change
(dollar amounts in millions)	March 31, 2021		March 31, 2020		Change
Earnings summary:
Net interest expense	$	(114)	$	(33)	$	(81)	n/m
Provision for credit losses	1		—		1		n/m
Noninterest income	16		12		4		35	%
Noninterest expenses	7		10		(3)		(29)
Benefit for income taxes	(25)		(7)		(18)		n/m
Net loss	$	(81)	$	(24)	$	(57)	n/m
Selected average balances:
Loans	$	4	$	—	$	4	n/m
Deposits	1,142		1,318		(176)		(13)	%

n/m - not meaningful

Net loss for the Finance & Other category increased $57 million to $81 million. Net interest expense increased $81 million, primarily reflecting a decrease in net FTP revenue as a result of lower rates charged to the business segments under the Corporation's internal FTP methodology. Noninterest income increased $4 million, primarily driven by an increase in securities trading income. Noninterest expenses decreased $3 million, mainly due to a decrease in operational losses.

The following table lists the Corporation's banking centers by geographic market segment.

	March 31,
	2021	2020
Michigan	190	192
Texas	123	123
California	96	96
Other Markets	25	25
Total	434	436

42

FINANCIAL CONDITION

First Quarter 2021 Compared to Fourth Quarter 2020

Period-End Balances

Total assets decreased $1.8 billion to $86.3 billion, driven by a decrease of $1.7 billion in loans, which included declines in National Dealer Services and Mortgage Banker Finance. PPP loans increased $304 million to $3.8 billion, reflecting $925 million in second round funding, partially offset by first round repayments of $621 million, primarily through the forgiveness process.

Total liabilities decreased $1.9 billion to $78.1 billion, primarily reflecting decreases of $2.9 billion in medium- and long-term debt, due to the repayment of $2.8 billion in floating-rate Federal Home Loan Bank (FHLB) advances during the first quarter, and $598 million in noninterest-bearing deposits, partially offset by an increase of $1.5 billion in interest-bearing deposits. The decrease in noninterest-bearing deposits included a $1.8 billion decrease in National Card Services primarily due to the timing of deposits by the U.S. Treasury, which typically fund a government card program on the first day of each month. The January funding was received a day early, in the fourth quarter of 2020, due to the New Year's holiday, leading to a timing difference between periods. The increase in interest-bearing deposits primarily reflected increases in Middle Market and Retail Banking.

Average Balances

Total assets decreased $769 million to $84.6 billion due to an $816 million decrease in loans. The following table provides information about the change in the Corporation's average loan portfolio by loan type and geographic market.

	Three Months Ended						Percent Change
(dollar amounts in millions)	March 31, 2021		December 31, 2020		Change
By Loan Type:
Commercial loans (a)	$	30,968	$	31,713	$	(745)	(2	%)
Real estate construction loans	4,137		4,157		(20)		—
Commercial mortgage loans	9,952		9,938		14		—
Lease financing	592		600		(8)		(1)
International loans	962		918		44		5
Residential mortgage loans	1,809		1,908		(99)		(5)
Consumer loans	2,169		2,171		(2)		—
Total loans	$	50,589	$	51,405	$	(816)	(2	%)
Loans By Geographic Market:
Michigan	$	12,247	$	12,225	$	22	—	%
California	17,946		18,030		(84)		—
Texas	10,161		10,583		(422)		(4)
Other Markets and Finance	10,235		10,567		(332)		(3)
Total loans	$	50,589	$	51,405	$	(816)	(2	%)

(a)Includes PPP loans of $3.6 billion and $3.7 billion for the three months ended March 31, 2021 and December 31, 2020, respectively.

The decrease in loans was driven by declines in Mortgage Banker Finance, Energy and National Dealer Services, partially offset by an increase in Equity Funds Services. The decrease in Mortgage Banker Finance resulted from lower purchase volumes compared to the high balances recorded during the fourth quarter of 2020. Energy declined due to higher oil prices resulting in improved cash flow and capital markets activity, while National Dealer Services continues to be impacted by supply chain issues impacting production. The growth in Equity Funds Services resulted from strong fund formation activity. PPP loans decreased $137 million to $3.6 billion, as average forgiven balances outpaced average newly originated balances during the quarter.

Total liabilities decreased $1.0 billion to $76.4 billion, reflecting a decrease of $2.1 billion in medium- and long-term debt due to the repayment of $2.8 billion in floating-rate FHLB advances during the first quarter, partially offset by increases of $603 million and $546 million in noninterest-bearing and interest-bearing deposits, respectively. The deposit growth was driven by a $993 million increase in consumer deposits primarily due to additional government stimulus payments and seasonality, as well as customers continuing to conserve cash.

43

Capital

The following table presents a summary of changes in total shareholders' equity for the three months ended March 31, 2021.

(in millions)
Balance at January 1, 2021			$	8,050
Net income			350
Cash dividends declared on common stock			(95)
Cash dividends declared on preferred stock			(6)
Purchase of common stock			(3)
Other comprehensive loss:
Investment securities	$	(140)
Cash flow hedges	(32)
Defined benefit and other postretirement plans	3
Total other comprehensive loss			(169)
Issuance of common stock under employee stock plans			3
Share-based compensation			22
Balance at March 31, 2021			$	8,152

The following table summarizes the Corporation's repurchase activity during the three months ended March 31, 2021.

(shares in thousands)	Total Number of Shares Purchased as  Part of Publicly Announced Repurchase Plans or Programs	Remaining Share Repurchase Authorization (a)	Total Number of Shares Purchased (b)	Average Price Paid Per  Share
January 2021	—	4,870	47	$	60.50
February 2021	—	4,870	8	66.62
March 2021	—	4,870	—	—
Total first quarter 2021	—	4,870	55	$	61.39

(a)Maximum number of shares that may be repurchased under the publicly announced plans or programs.

(b)Includes approximately 55,000 shares purchased pursuant to deferred compensation plans and shares purchased from employees to pay for taxes related to restricted stock vesting under the terms of an employee share-based compensation plan during the three months ended March 31, 2021. These transactions are not considered part of the Corporation's repurchase program.

The Corporation did not make any share repurchases under the share repurchase program during the first quarter of 2021 due to the uncertain path of the economic recovery. With more confidence in the economic outlook, and an estimated CET1 ratio of more than 11 percent, which is well above its target of approximately 10 percent, the Corporation is resuming repurchases in the second quarter of 2021. On April 27, 2021, the Corporation entered into an Accelerated Share Repurchase transaction (ASR) to repurchase up to $400 million of common shares in the second quarter of 2021 to help facilitate the repurchase. The timing and actual amount of additional share repurchases are subject to various factors, including the Corporation's earnings generation, capital needs to fund future loan growth and market conditions. To authorize the Corporation's share repurchases, including the ASR, on April 27, 2021 the Corporation's Board of Directors approved the authorization to repurchase up to an additional 10 million shares of its outstanding common stock. Since the inception of the share repurchase program in 2010, a total of 97.2 million shares have been authorized for repurchase. There is no expiration date for the share repurchase program.

Upon resumption of the share repurchase activity, the Corporation continues to target a common equity Tier 1 capital ratio of approximately 10 percent with continued active capital management. At March 31, 2021, the Corporation's estimated CET1 capital ratio was 11.09 percent. In 2020, the Corporation elected regulatory relief to defer the impact of adopting the CECL model for measuring credit losses on regulatory capital. At March 31, 2021, $26 million, or a cumulative 4-basis-point benefit to the estimated capital ratios, was deferred.

44

    The following table presents the minimum ratios required.

Common equity tier 1 capital to risk-weighted assets	4.5	%
Tier 1 capital to risk-weighted assets	6.0
Total capital to risk-weighted assets	8.0
Capital conservation buffer (a)	2.5
Tier 1 capital to adjusted average assets (leverage ratio)	4.0

(a)In addition to the minimum risk-based capital requirements, the Corporation is required to maintain a minimum capital conservation buffer, in the form of common equity, in order to avoid restrictions on capital distributions and discretionary bonuses.

The Corporation's capital ratios exceeded minimum regulatory requirements as follows:

	March 31, 2021				December 31, 2020
(dollar amounts in millions)	Capital/Assets		Ratio		Capital/Assets		Ratio
Common equity tier 1 (a), (b)	$	7,236	11.09	%	$	6,919	10.34	%
Tier 1 risk-based (a), (b)	7,630		11.70		7,313		10.93
Total risk-based (a)	9,097		13.94		8,833		13.20
Leverage (a)	7,630		9.08		7,313		8.63
Common shareholders' equity	7,758		8.99		7,656		8.69
Tangible common equity (b)	7,109		8.30		7,020		8.02
Risk-weighted assets (a)	65,237				66,931

(a)    March 31, 2021 capital, risk-weighted assets and ratios are estimated.

(b)    See Supplemental Financial Data section for reconciliations of non-GAAP financial measures and regulatory ratios.

RISK MANAGEMENT

The following updated information should be read in conjunction with the "Risk Management" section on pages F-22 through F-38 in the Corporation's 2020 Annual Report.

Credit Risk

Allowance for Credit Losses

The allowance for credit losses includes both the allowance for loan losses and the allowance for credit losses on lending-related commitments. As a percentage of total loans, the allowance for credit losses was 1.59 percent at March 31, 2021, compared to 1.90 percent at December 31, 2020. Excluding $3.8 billion in PPP loans, which are guaranteed by the Small Business Administration, the allowance for credit losses was 1.72 percent of total loans at March 31, 2021, compared to 2.03% at December 31, 2020. The allowance for credit losses covered 2.6 times and 2.8 times total nonperforming loans at March 31, 2021 and December 31, 2020, respectively.

The allowance for credit losses decreased $185 million to $807 million at March 31, 2021, primarily reflecting a sustained recovery by the U.S. economy from the COVID-19 pandemic and impacts of mitigating actions by the U.S. government. In addition to the $900 billion relief package approved in December 2020, Congress passed an additional $1.9 trillion of stimulus in March 2021 as part of the American Rescue Plan Act of 2021 in March 2021. While there continues to be uncertainty, the positive progress of the vaccine rollout and associated opening of the broader economy contributed to the improved economic outlook and increase in energy prices.

These factors shaped the 2-year reasonable and supportable forecast used by the Corporation in its CECL estimate at March 31, 2021. The U.S. economy is expected to grow this year at a faster pace than previously expected, primarily due to the additional stimulus package approved in the first quarter, normalizing into historical growth rates in the second half of the forecast period. Forecasts for other key economic variables, including the unemployment rate and oil prices, are generally in line with GDP projections. Interest rates remain low, reflecting the Federal Reserve's expectation that rates will remain at current levels in the near-to mid-term, while corporate bond rates reflect stabilizing default risk. The following table summarizes the forecasts for the economic variables most impactful to the allowance for credit losses estimate at March 31, 2021.

45

Economic Variable	Base Forecast
Real Gross Domestic Product (GDP) growth	Growth peaks at 7 percent in third quarter 2021, normalizing into a long-term growth rate of 2 percent by second quarter 2022.
Unemployment rate	Current levels gradually decrease to 4 percent by the end of the forecast period.
Corporate BBB bond to 10-year Treasury bond spreads	Spreads gradually increasing from current levels to 1.6 percent by the end of the forecast period.
Oil Prices	Prices remain near $55 per barrel throughout the forecast period.

Due to the high level of uncertainty regarding significant assumptions, such as the ultimate impact of the global pandemic, the Corporation evaluated a range of economic scenarios, including more benign and more severe economic forecasts. In the more severe scenario, real GDP is expected to contract in 2021, gradually improving to 3 percent by third quarter 2022. Other key economic variables follow a similar pattern of an uneven, lagged recovery. Selecting the more severe forecast would result in an increase in the quantitative calculation of allowance for credit losses by approximately $312 million as of March 31, 2021. However, factoring in model overlays and qualitative adjustments could result in a materially different estimate under a more severe scenario.

Allowance for Loan Losses

The allowance for loan losses represents management’s estimates of current expected credit losses in the Corporation’s loan portfolio. Pools of loans with similar risk characteristics are collectively evaluated, while loans that no longer share risk characteristics with loan pools are evaluated individually.

Collective loss estimates are determined by applying reserve factors, designed to estimate current expected credit losses, to amortized cost balances over the remaining contractual life of the collectively evaluated portfolio. Loans with similar risk characteristics are aggregated into homogeneous pools. The allowance for loan losses also includes qualitative adjustments to bring the allowance to the level management believes is appropriate based on factors that have not otherwise been fully accounted for, including adjustments for foresight risk, input imprecisions and model imprecision. Credit losses for loans that no longer share risk characteristics with the loan pools are estimated on an individual basis. Individual credit loss estimates are typically performed for nonaccrual loans and modified loans classified as troubled debt restructurings (TDRs) and are based on one of several methods, including the estimated fair value of the underlying collateral, observable market value of similar debt or the present value of expected cash flows.    

As a percentage of total loans, the allowance for loan losses was 1.54 percent at March 31, 2021, compared to 1.81 percent at December 31, 2020. Excluding PPP loans, the allowance for loan losses was 1.66 percent of total loans at March 31, 2021, compared to 1.94% at December 31, 2020. Nonperforming loans were 0.63 percent of total loans at March 31, 2021, compared to 0.67 percent at December 31, 2020, and the allowance for loan losses covered 2.5 times and 2.7 times total nonperforming loans at March 31, 2021 and December 31, 2020, respectively.

Allowance for Credit Losses on Lending-Related Commitments

    The allowance for credit losses on lending-related commitments estimates current expected credit losses on collective pools of letters of credit and unused commitments to extend credit based on reserve factors, determined in a manner similar to business loans, multiplied by a probability of draw estimate based on historical experience and credit risk, applied to commitment amounts. The allowance for credit losses on lending-related commitments totaled $30 million and $44 million at March 31, 2021 and December 31, 2020, respectively.

    For additional information regarding the allowance for credit losses, refer to the "Critical Accounting Policies" section and pages F-57 through F-59 in Note 1 to the consolidated financial statements of the Corporation's 2020 Annual Report.

Nonperforming Assets

Nonperforming assets include loans on nonaccrual status, TDRs which have been renegotiated to less than the original contractual rates (reduced-rate loans) and foreclosed assets. TDRs include performing and nonperforming loans, with nonperforming TDRs on either nonaccrual or reduced-rate status. In accordance with the provisions of the CARES Act, the Corporation elected not to consider qualifying COVID-19-related modifications, primarily deferrals, as TDRs and does not designate such loans as past due or nonaccrual. For additional information regarding the Corporation's accounting policies for the CARES Act, refer to page F-56 in Note 1 to the consolidated financial statements of the Corporation's 2020 Annual Report.

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The following table presents a summary of nonperforming assets and past due loans.

(dollar amounts in millions)	March 31, 2021			December 31, 2020
Nonaccrual loans:
Business loans:
Commercial	$	230		$	252
Real estate construction	1			1
Commercial mortgage	34			29
Lease financing	1			1
Total nonaccrual business loans	266			283
Retail loans:
Residential mortgage	33			47
Consumer:
Home equity	15			17
Total nonaccrual retail loans	48			64
Total nonaccrual loans	314			347
Reduced-rate loans	2			3
Total nonperforming loans	316			350
Foreclosed property	8			8
Other repossessed assets	1			1
Total nonperforming assets	$	325		$	359
Nonperforming loans as a percentage of total loans	0.63		%	0.67		%
Nonperforming assets as a percentage of total loans and foreclosed property	0.64			0.69
Allowance for credit losses as a multiple of total nonperforming loans	2.6x			2.8x
Loans past due 90 days or more and still accruing	$	60		$	45

Nonperforming assets decreased $34 million to $325 million at March 31, 2021, from $359 million at December 31, 2020. The decrease in nonperforming assets primarily reflected a $21 million decrease in nonperforming Energy loans, which are a component of commercial loans.

As of March 31, 2021, COVID-19-related payment deferrals totaled $87 million, or 0.17 percent of total loans, representing approximately 100 obligors and consisting of 79 percent retail loans, primarily residential mortgages, and 21 percent commercial loans. Initial deferrals have expired and new requests have been nominal as customers continue to adjust to the new environment, resulting in a $54 million decrease in deferrals since fourth quarter 2020. Loans with COVID-19-related deferred payments on a third deferral, primarily residential mortgages, totaled $71 million at March 31, 2021 and would generally be considered TDRs if not for the provisions in the CARES Act.

The following table presents a summary of TDRs at March 31, 2021 and December 31, 2020.

(in millions)	March 31, 2021		December 31, 2020
Nonperforming TDRs:
Nonaccrual TDRs	$	29	$	33
Reduced-rate TDRs	2		3
Total nonperforming TDRs	31		36
Performing TDRs (a)	40		41
Total TDRs	$	71	$	77

(a)TDRs that do not include a reduction in the original contractual interest rate which are performing in accordance with their modified terms.

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The following table presents a summary of changes in nonaccrual loans.

	Three Months Ended
(in millions)	March 31, 2021		December 31, 2020
Balance at beginning of period	$	347	$	322
Loans transferred to nonaccrual (a)	61		88
Nonaccrual loan gross charge-offs	(16)		(39)
Loans transferred to accrual status (a)	(17)		(3)
Nonaccrual loans sold	(25)		—
Payments/other (b)	(36)		(21)
Balance at end of period	$	314	$	347

(a)Based on an analysis of nonaccrual loans with book balances greater than $2 million.

(b)Includes net changes related to nonaccrual loans with balances less than or equal to $2 million, payments on nonaccrual loans with book balances greater than $2 million and transfers of nonaccrual loans to foreclosed property.

There were three borrowers with a balance greater than $2 million, totaling $61 million, transferred to nonaccrual status in first quarter 2021, compared to seven borrowers totaling $88 million in fourth quarter 2020. For further information about the composition of loans transferred to nonaccrual during the current period, refer to the nonaccrual information by industry category table below.

The following table presents the composition of nonaccrual loans by balance and the related number of borrowers at March 31, 2021 and December 31, 2020.

	March 31, 2021			December 31, 2020
(dollar amounts in millions)	Number of Borrowers	Balance		Number of Borrowers	Balance
Under $2 million	661	$	88	682	$	83
$2 million - $5 million	14	40		20	61
$5 million - $10 million	9	70		9	73
$10 million - $25 million	5	82		7	94
Greater than $25 million	1	34		1	36
Total	690	$	314	719	$	347

The following table presents a summary of nonaccrual loans at March 31, 2021 and loans transferred to nonaccrual and net loan charge-offs (recoveries) for the three months ended March 31, 2021, based on North American Industry Classification System (NAICS) categories.

	March 31, 2021				Three Months Ended March 31, 2021
(dollar amounts in millions)	Nonaccrual Loans				Loans Transferred to Nonaccrual (a)				Net Loan Charge-Offs (Recoveries)
Industry Category
Mining, Quarrying and Oil & Gas Extraction	$	93	30	%	$	28	47	%	$	(1)	(36)	%
Transportation & Warehousing	34		11		—		—		—		—
Manufacturing	33		11		—		—		2		61
Residential Mortgage	33		10		—		—		—		—
Wholesale Trade	28		9		—		—		—		—
Services	18		6		3		4		1		20
Real Estate & Home Builders	15		5		—		—		(1)		(11)
Information & Communication	14		4		—		—		—		—
Arts, Entertainment & Recreation	9		3		—		—		—		—
Retail Trade	4		1		—		—		—		—
Health Care & Social Assistance	3		1		—		—		(1)		(27)
Contractors	3		1		—		—		(1)		(41)
Utilities	—		—		30		49		5		149
Other (b)	27		8		—		—		(1)		(15)
Total	$	314	100	%	$	61	100	%	$	3	100	%

(a)Based on an analysis of nonaccrual loans with book balances greater than $2 million.

(b)Consumer, excluding residential mortgage and certain personal purpose nonaccrual loans and net charge-offs, are included in the Other category.

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Loans past due 90 days or more and still accruing interest generally represent loans that are well collateralized and in the process of collection. Loans past due 90 days or more increased $15 million to $60 million at March 31, 2021, compared to $45 million at December 31, 2020. Loans past due 30-89 days decreased $102 million to $302 million at March 31, 2021, compared to $404 million at December 31, 2020. Loans past due 30 days or more and still accruing interest as a percentage of total loans were 0.72 percent and 0.86 percent at March 31, 2021 and December 31, 2020, respectively. An aging analysis of loans included in Note 4 to the consolidated financial statements provides further information about the balances comprising past due loans.

The following table presents a summary of total criticized loans. The Corporation's criticized list is consistent with the Special Mention, Substandard and Doubtful categories defined by regulatory authorities. Criticized loans with balances of $2 million or more on nonaccrual status or loans with balances of $1 million or more whose terms have been modified in a TDR are individually subjected to quarterly credit quality reviews, and the Corporation may establish specific allowances for such loans. A table of loans by credit quality indicator included in Note 4 to the consolidated financial statements provides further information about the balances comprising total criticized loans.

(dollar amounts in millions)	March 31, 2021			December 31, 2020
Total criticized loans	$	2,581		$	2,947
As a percentage of total loans	5.1		%	5.6		%

The $366 million decrease in criticized loans during the three months ended March 31, 2021 included decreases of $207 million in Energy and $155 million in general Middle Market.

Concentrations of Credit Risk

Concentrations of credit risk may exist when a number of borrowers are engaged in similar activities, or activities in the same geographic region, and have similar economic characteristics that would cause them to be similarly impacted by changes in economic or other conditions. The Corporation has concentrations of credit risk with the commercial real estate and automotive industries. All other industry concentrations, as defined by management, individually represented less than 10 percent of total loans at March 31, 2021.

Commercial Real Estate Lending

The following table summarizes the Corporation's commercial real estate loan portfolio by loan category.

	March 31, 2021						December 31, 2020
(in millions)	Commercial Real Estate business line (a)		Other (b)		Total		Commercial Real Estate business line (a)		Other (b)		Total
Real estate construction loans	$	3,810	$	434	$	4,244	$	3,657	$	425	$	4,082
Commercial mortgage loans	2,311		7,682		9,993		2,273		7,639		9,912
Total commercial real estate	$	6,121	$	8,116	$	14,237	$	5,930	$	8,064	$	13,994

(a)Primarily loans to real estate developers.

(b)Primarily loans secured by owner-occupied real estate.

The Corporation limits risk inherent in its commercial real estate lending activities by monitoring borrowers directly involved in the commercial real estate markets and adhering to conservative policies on loan-to-value ratios for such loans. Commercial real estate loans, consisting of real estate construction and commercial mortgage loans, totaled $14.2 billion at March 31, 2021. Of the total, $6.1 billion, or 43 percent, were to borrowers in the Commercial Real Estate business line, which includes loans to real estate developers, an increase of $191 million compared to December 31, 2020. Commercial real estate loans in other business lines totaled $8.1 billion, or 57 percent, at March 31, 2021. These loans consisted primarily of owner-occupied commercial mortgages, which bear credit characteristics similar to non-commercial real estate business loans.

The real estate construction loan portfolio primarily contains loans made to long-tenured customers with satisfactory completion experience. Criticized real estate construction loans in the Commercial Real Estate business line totaled $29 million and $27 million at March 31, 2021 and December 31, 2020, respectively. In other business lines, criticized real estate construction loans totaled $39 million at March 31, 2021, compared to $20 million at December 31, 2020. There were no real estate construction loan charge-offs in either of the three-month periods ended March 31, 2021 and 2020.

Commercial mortgage loans are loans where the primary collateral is a lien on any real property and are primarily loans secured by owner-occupied real estate. Real property is generally considered primary collateral if the value of that collateral represents more than 50 percent of the commitment at loan approval. Loans in the commercial mortgage portfolio generally mature within three to five years. Criticized commercial mortgage loans in the Commercial Real Estate business line totaled $71 million and $73 million at March 31, 2021 and December 31, 2020, respectively. In other business lines, $350 million and $440 million of commercial mortgage loans were criticized at March 31, 2021 and December 31, 2020,

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respectively. There were no commercial mortgage loan net charge-offs for the three months ended March 31, 2021, compared to net recoveries of $2 million for the same period in 2020.

Automotive Lending - Dealer

The following table presents a summary of dealer loans.

	March 31, 2021				December 31, 2020
(in millions)	Loans Outstanding		Percent of Total Loans		Loans Outstanding		Percent of Total Loans
Dealer:
Floor plan	$	1,506			$	2,344
Other	3,245				3,348
Total dealer	$	4,751	9.4	%	$	5,692	10.9	%

Substantially all dealer loans are in the National Dealer Services business line and primarily include floor plan financing and other loans to automotive dealerships. Floor plan loans, included in commercial loans in the Consolidated Balance Sheets, totaled $1.5 billion at March 31, 2021, a decrease of $838 million compared to $2.3 billion at December 31, 2020 due to an imbalance in supply and demand impacted by a shortage in microchips used in automotive production. At March 31, 2021 and December 31, 2020, other loans to automotive dealers in the National Dealer Services business line totaled $3.2 billion and $3.3 billion, respectively, including $2.0 billion of owner-occupied commercial real estate mortgage loans at both March 31, 2021 and December 31, 2020.

There were no nonaccrual dealer loans at both March 31, 2021 and December 31, 2020. Additionally, there were no net charge-offs of dealer loans in the three months ended March 31, 2021, compared to $1 million in the three months ended March 31, 2020.

Automotive Lending- Production

The following table presents a summary of loans to borrowers involved with automotive production.

	March 31, 2021				December 31, 2020
(in millions)	Loans Outstanding (a)		Percent of Total Loans		Loans Outstanding (a)		Percent of Total Loans
Production:
Domestic	$	796			$	791
Foreign	306				302
Total production	$	1,102	2.2	%	$	1,093	2.1	%

(a)Excludes PPP loans.

Loans to borrowers involved with automotive production, primarily Tier 1 and Tier 2 suppliers, totaled $1.1 billion at both March 31, 2021 and December 31, 2020. These borrowers have faced, and could face in the future, financial difficulties due to disruptions in auto production as well as their supply chains and logistics operations as a result of the COVID-19 pandemic. As such, management continued to monitor this portfolio and allocated reserves for this portfolio at March 31, 2021 were relatively stable.

Nonaccrual loans to borrowers involved with automotive production totaled $8 million at March 31, 2021 and $7 million at December 31, 2020. Criticized automotive production loans were 21 percent of the automotive production portfolio at March 31, 2021, compared to 24 percent at December 31, 2020. There were no automotive production loan net charge-offs in both of the three months ended March 31, 2021 and 2020.

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Residential Real Estate Lending

At March 31, 2021, residential real estate loans represented 7 percent of total loans. The following table summarizes the Corporation's residential mortgage and home equity loan portfolios by geographic market.

	March 31, 2021								December 31, 2020
(dollar amounts in millions)	Residential Mortgage Loans		% of Total		Home Equity Loans		% of Total		Residential Mortgage Loans		% of Total		Home Equity Loans		% of Total
Geographic market:
Michigan	$	425	23	%	$	516	33	%	$	428	23	%	$	540	34	%
California	894		50		662		42		927		51		655		41
Texas	264		15		328		21		254		14		328		21
Other Markets	216		12		64		4		221		12		65		4
Total	$	1,799	100	%	$	1,570	100	%	$	1,830	100	%	$	1,588	100	%

Residential real estate loans, which consist of traditional residential mortgages and home equity loans and lines of credit, totaled $3.4 billion at March 31, 2021. The residential real estate portfolio is principally located within the Corporation's primary geographic markets. Substantially all residential real estate loans past due 90 days or more are placed on nonaccrual status, and substantially all junior lien home equity loans that are current or less than 90 days past due are placed on nonaccrual status if full collection of the senior position is in doubt. At no later than 180 days past due, such loans are charged off to current appraised values less costs to sell.

Residential mortgages totaled $1.8 billion at March 31, 2021, and were primarily larger, variable-rate mortgages originated and retained for certain private banking relationship customers. Of the $1.8 billion of residential mortgage loans outstanding, $33 million were on nonaccrual status at March 31, 2021. The home equity portfolio totaled $1.6 billion at March 31, 2021, of which $1.5 billion was outstanding under primarily variable-rate, interest-only home equity lines of credit, $64 million were in amortizing status and $16 million were closed-end home equity loans. Of the $1.6 billion of home equity loans outstanding, $15 million were on nonaccrual status at March 31, 2021. A majority of the home equity portfolio was secured by junior liens at March 31, 2021. 

Energy Lending

The Corporation has a portfolio of Energy loans that are included entirely in commercial loans in the Consolidated Balance Sheets. Customers in the Corporation's Energy business line (approximately 120 relationships) are engaged in three segments of the oil and gas business: exploration and production (E&P), midstream and energy services. E&P generally includes such activities as searching for potential oil and gas fields, drilling exploratory wells and operating active wells. Commitments to E&P borrowers are generally subject to semi-annual borrowing base re-determinations based on a variety of factors including updated prices (reflecting market and competitive conditions), energy reserve levels and the impact of hedging. The midstream sector is generally involved in the transportation, storage and marketing of crude and/or refined oil and gas products. The Corporation's energy services customers provide products and services primarily to the E&P segment.

The following table summarizes information about loans in the Corporation's Energy business line.

	March 31, 2021										December 31, 2020
(dollar amounts in millions)	Outstandings				Nonaccrual			Criticized (a)			Outstandings				Nonaccrual			Criticized (a)
Exploration and production (E&P)	$	1,077	79	%	$	93		$	346		$	1,295	81	%	$	114		$	527
Midstream	270		20		—			32			261		16		—			56
Services	19		1		—			11			44		3		—			13
Total Energy business line	$	1,366	100	%	$	93		$	389		$	1,600	100	%	$	114		$	596
As a percentage of total Energy loans					7		%	28		%					7		%	37		%

(a)    Includes nonaccrual loans.

Loans in the Energy business line totaled $1.4 billion, or 3 percent of total loans, at March 31, 2021, a decrease of $234 million. Total exposure, including unused commitments to extend credit and letters of credit, was $3.0 billion (a utilization rate of 46 percent) and $3.1 billion at March 31, 2021 and December 31, 2020, respectively.

Net credit-related Energy recoveries were $1 million in first quarter 2021, compared to net charge-offs of $67 million for the same period in 2020. Nonaccrual Energy loans decreased $21 million to $93 million at March 31, 2021, compared to December 31, 2020. Criticized Energy loans decreased $207 million to $389 million, or 15 percent of total criticized loans, at March 31, 2021.

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Leveraged Loans

Certain loans in the Corporation's commercial portfolio are considered leveraged transactions. These loans are typically used for mergers, acquisitions, business recapitalizations, refinancing and equity buyouts. To help mitigate the risk associated with these loans, the Corporation focuses on middle market companies with highly capable management teams, strong sponsors and solid track records of financial performance. Industries prone to cyclical downturns and acquisitions with a high degree of integration risk are generally avoided. Other considerations include the sufficiency of collateral, the level of balance sheet leverage and the adequacy of financial covenants. During the underwriting process, cash flows are stress-tested to evaluate the borrowers' abilities to handle economic downturns and an increase in interest rates.

The FDIC defines higher-risk commercial and industrial (HR C&I) loans for assessment purposes as loans generally with leverage of four times total debt to earnings before interest, taxes and depreciation (EBITDA) as well as three times senior debt to EBITDA, excluding certain collateralized loans.

The following table summarizes information about HR C&I loans.

(in millions)	March 31, 2021		December 31, 2020
Outstandings	$	2,497	$	2,441
Criticized	404		418
Net loan charge-offs	2021		2020
Three Months Ended March 31,	$	1	$	8

Other Sectors Most at Risk due to Economic Stress Resulting from COVID-19 Impacts

    As the economy recovers, aided by additional stimulus packages and positive momentum in the vaccine rollout, the Corporation has continued to monitor the lingering impacts of the pandemic on its customers. In addition to the energy, automotive production and leveraged loan portfolios, the Corporation considers the following sectors of its loan portfolio to be most vulnerable to financial risks from business disruptions caused by the pandemic spread mitigation efforts. For further discussion, see Item 1.A "Risk Factors" on page 13 of the Corporation's 2020 Annual Report.

	March 31, 2021
Sector based on NAICS category (dollar amounts in millions)	Loans (a)		Percent of Total Loans		Percent Criticized (b)		Percent Nonaccrual (c)
Retail Commercial Real Estate (d)	$	843	1.6	%	4.6	%	—	%
Hotels	528		1.0		12.4		1.8
Arts/Recreation	237		0.5		34.1		4.4
Retail Goods and Services	230		0.5		15.2		0.1
All other impacted sectors (e)	989		2.0		11.4		1.2
Total	$	2,827	5.6	%	11.8	%	1.1	%

(a)Excludes PPP loans.

(b)Sector criticized loans as a percentage of sector total loans.

(c)Sector nonaccrual loans as a percentage of sector total loans.

(d)Loans in the retail commercial real estate sector are primarily included in the Corporation's commercial real estate portfolio.

(e)Includes airlines, restaurants and bars, childcare, coffee shops, cruise lines, education, gasoline and convenience stores, religious organizations, senior living, freight, as well as travel arrangements.

Market and Liquidity Risk

Market risk represents the risk of loss due to adverse movement in prices, including interest rates, foreign exchange rates, commodity prices and equity prices. Liquidity risk represents the risk that the Corporation does not have sufficient access to funds to maintain its normal operations at all times, or does not have the ability to raise or borrow funds at a reasonable cost at all times.

The Asset and Liability Policy Committee (ALCO) of the Corporation establishes and monitors compliance with the policies and risk limits pertaining to market and liquidity risk management activities. ALCO meets regularly to discuss and review market and liquidity risk management strategies and consists of executive and senior management from various areas of the Corporation, including treasury, finance, economics, lending, deposit gathering and risk management. Corporate Treasury mitigates market and liquidity risk under the direction of ALCO through the actions it takes to manage the Corporation's market, liquidity and capital positions.

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In addition to assessing liquidity risk on a consolidated basis, Corporate Treasury also monitors the parent company's liquidity and has established limits for the minimum number of months into the future in which the parent company can meet existing and forecasted obligations without the support of additional dividends from subsidiaries. ALCO's liquidity policy requires the parent company to maintain sufficient liquidity to meet expected capital and debt obligations with a target of 24 months but no less than 18 months.

Corporate Treasury and the Enterprise Risk Division support ALCO in measuring, monitoring and managing interest rate risk as well as all other market risks. Key activities encompass: (i) providing information and analyses of the Corporation's balance sheet structure and measurement of interest rate and all other market risks; (ii) monitoring and reporting of the Corporation's positions relative to established policy limits and guidelines; (iii) developing and presenting analyses and strategies to adjust risk positions; (iv) reviewing and presenting policies and authorizations for approval; and (v) monitoring of industry trends and analytical tools to be used in the management of interest rate and all other market and liquidity risks.

Interest Rate Risk

Net interest income is the primary source of revenue for the Corporation. Interest rate risk arises in the normal course of business due to differences in the repricing and cash flow characteristics of assets and liabilities, primarily through the Corporation's core business activities of extending loans and acquiring deposits. The Corporation's balance sheet is predominantly characterized by floating-rate loans funded by core deposits. Including the impact of interest rate swaps converting floating-rate loans to fixed, the Corporation's loan composition at March 31, 2021 was 55 percent 30-day LIBOR, 7 percent other LIBOR (primarily 60-and 90-day), 11 percent prime and 27 percent fixed rate. Additionally, 25 percent of loans had non-zero interest rate floors protecting against future rate declines. The composition of the loan portfolio creates sensitivity to interest rate movements due to the imbalance between the faster repricing of the floating-rate loan portfolio versus deposit products. In addition, the growth and/or contraction in the Corporation's loans and deposits may lead to changes in sensitivity to interest rate movements in the absence of mitigating actions. Examples of such actions are purchasing fixed-rate investment securities, which provide liquidity to the balance sheet and act to mitigate the inherent interest sensitivity, as well as hedging with interest rate swaps and options. Other mitigating factors include interest rate floors on a portion of the loan portfolio. The Corporation actively manages its exposure to interest rate risk with the principal objective of optimizing net interest income and the economic value of equity while operating within acceptable limits established for interest rate risk and maintaining adequate levels of funding and liquidity.

Since no single measurement system satisfies all management objectives, a combination of techniques is used to manage interest rate risk. These techniques examine the impact of interest rate risk on net interest income and the economic value of equity under a variety of alternative scenarios, including changes in the level, slope and shape of the yield curve utilizing multiple simulation analyses. Simulation analyses produce only estimates of net interest income as the assumptions used are inherently uncertain. Actual results may differ from simulated results due to many factors, including, but not limited to, the timing, magnitude and frequency of changes in interest rates, market conditions, regulatory impacts and management strategies.

Sensitivity of Net Interest Income to Changes in Interest Rates

The analysis of the impact of changes in interest rates on net interest income under various interest rate scenarios is management's principal risk management technique. Management models a base-case net interest income under an unchanged interest rate environment. Existing derivative instruments entered into for risk management purposes as of the balance sheet dates are included in the analysis, but no additional hedging is forecasted. At March 31, 2021, these derivative instruments comprise interest rate swaps that convert $2.7 billion of fixed-rate medium- and long-term debt to variable rates through fair value hedges and convert $5.6 billion of variable-rate loans to fixed rates through cash flow hedges. Additionally, included in this analysis are $12.7 billion of loans that were subject to an average interest rate floor of 0.8 percent at March 31, 2021. This base-case net interest income is then compared against interest rate scenarios in which short-term rates rise or decline 100 basis points (with a floor of zero percent) in a linear, non-parallel fashion from the base case over 12 months, resulting in an average change of 50 basis points over the period while long-term rates increase or decrease to a lesser degree.

Each scenario includes assumptions such as loan growth, investment security prepayment levels, depositor behavior, yield curve changes, loan and deposit pricing, and overall balance sheet mix and growth which are in line with historical patterns. However, in this low rate environment, depositors have maintained a higher level of liquidity and their historical behavior may be less indicative of future trends. As a result, the rising rate scenario reflects a greater decrease in deposits than we have experienced historically as rates rise. Changes in actual economic activity may result in a materially different interest rate environment as well as a balance sheet structure that is different from the changes management included in its simulation analysis.

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The table below, as of March 31, 2021 and December 31, 2020, displays the estimated impact on net interest income during the next 12 months by relating the base case scenario results to those from the rising and declining rate scenarios described above.

	Estimated Annual Change
	March 31, 2021					December 31, 2020
(dollar amounts in millions)	Amount		%			Amount		%
Change in Interest Rates:					Change in Interest Rates:
Rising 100 basis points	$	156	9	%	Rising 100 basis points	$	161	9	%
Declining to zero percent	(31)		(2)		Declining to zero percent	(34)		(2)

Sensitivity to declining interest rates remained steady from December 31, 2020 to March 31, 2021 due to offsetting changes in balance sheet composition, as well as limited remaining downward movement in rates before hitting zero percent floors. Sensitivity to rising interest rates remained relatively constant due to continued fixed-rate PPP lending, growth of floating rate loans with floors as well as a slightly larger securities portfolio offsetting higher deposit volumes.

Sensitivity of Economic Value of Equity to Changes in Interest Rates

In addition to the simulation analysis on net interest income, an economic value of equity analysis provides an alternative view of the interest rate risk position. The economic value of equity is the difference between the estimate of the economic value of the Corporation's financial assets, liabilities and off-balance sheet instruments, derived through discounting cash flows based on actual rates at the end of the period, and the estimated economic value after applying the estimated impact of rate movements. The Corporation primarily monitors the percentage change on the base-case economic value of equity. The economic value of equity analysis is based on an immediate parallel 100 basis point shock with a floor of zero percent.

The table below, as of March 31, 2021 and December 31, 2020, displays the estimated impact on the economic value of equity from the interest rate scenario described above.

	March 31, 2021					December 31, 2020
(dollar amounts in millions)	Amount		%			Amount		%
Change in Interest Rates:					Change in Interest Rates:
Rising 100 basis points	$	1,335	11	%	Rising 100 basis points	$	1,793	18	%
Declining to zero percent	(516)		(4)		Declining to zero percent	(551)		(6)

The sensitivity of the economic value of equity to rising rates decreased from December 31, 2020 to March 31, 2021 due to duration extension in the securities portfolio and expected shorter deposit lives. Sensitivity to declining rates decreased slightly due to the changes in balance sheet composition and is limited by the assumption of a zero percent rate floor.

LIBOR Transition

On July 27, 2017, the United Kingdom’s Financial Conduct Authority, which regulates LIBOR, publicly announced that it intends to stop persuading or compelling banks to submit LIBOR rates after 2021. The Corporation has substantial exposure to LIBOR-based products, including loans, securities, derivatives and hedges, and is preparing for a transition from LIBOR toward alternative rates. Execution activities to begin incorporating fallback language in legacy LIBOR-based commercial loans started in the fourth quarter 2020. By the end of first quarter 2021, the Corporation completed initial systems readiness activities to support new Secured Overnight Financing Rate (SOFR) origination. The Corporation has also signed the new ISDA protocols and is operationally ready to issue new SOFR-based Swaps. Communications and learning activities to support customers and colleagues are ongoing. The Corporation's enterprise transition milestones are closely aligned with recommendations from the Alternative Reference Rates Committee for both best practices and recommended objectives. The Corporation will continue to align with industry and regulatory guidelines regarding the cessation of LIBOR as well as monitor market developments for transitioning to alternative reference rates. For a discussion of the various risks facing the Corporation in relation to the transition away from LIBOR, see the market risk discussion within “Item 1A. Risk Factors” beginning on page 13 of the Corporation's Annual Report on Form 10-K for the year ended December 31, 2020.

Wholesale Funding

The Corporation may access the purchased funds market when necessary, which includes a variety of funding sources. Capacity for incremental purchased funds at March 31, 2021 included short-term FHLB advances, the ability to purchase federal funds, sell securities under agreements to repurchase as well as issue deposits through brokers. Purchased funds decreased to $30 million at March 31, 2021 compared to $66 million at December 31, 2020.

At March 31, 2021, the Bank had pledged loans totaling $18.9 billion which provided for up to $15.2 billion of available collateralized borrowing with the Federal Reserve Bank (FRB).

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The Bank is a member of the FHLB of Dallas, Texas, which provides short- and long-term funding to its members through advances collateralized by real estate-related assets. Actual borrowing capacity is contingent on the amount of collateral available to be pledged to the FHLB. At March 31, 2021, $18.6 billion of real estate-related loans and $4.0 billion of investment securities were pledged to the FHLB as collateral for potential future borrowings. The Corporation had capacity for potential future borrowings of approximately $13.9 billion.

In April 2021, the Bank terminated a $15.0 billion note program, under which the Bank had the ability to issue up to $13.5 billion of debt at March 31, 2021. Outstanding notes issued under the program were unaffected by the termination.

The Corporation maintains a shelf registration statement with the Securities and Exchange Commission from which it may issue debt and/or equity securities.

The ability of the Corporation and the Bank to raise funds at competitive rates may be impacted by rating agencies' views of the credit quality, liquidity, capital and earnings of the Corporation and the Bank. As of March 31, 2021, the three major rating agencies had assigned the ratings below to long-term senior unsecured obligations of the Corporation and the Bank. A security rating is not a recommendation to buy, sell, or hold securities and may be subject to revision or withdrawal at any time by the assigning rating agency. Each rating should be evaluated independently of any other rating.

	Comerica Incorporated		Comerica Bank
March 31, 2021	Rating	Outlook	Rating	Outlook
Standard and Poor’s	BBB+	Negative	A-	Negative
Moody’s Investors Service	A3	Stable	A3	Stable
Fitch Ratings	A-	Stable	A-	Stable

The Corporation satisfies liquidity needs with either liquid assets or various funding sources. Liquid assets totaled $26.0 billion and $25.9 billion at March 31, 2021 and December 31, 2020, respectively. Liquid assets include cash and due from banks, federal funds sold, interest-bearing deposits with banks, other short-term investments and unencumbered investment securities.

The Corporation performs monthly liquidity stress testing to evaluate its ability to meet funding needs in hypothetical stressed environments. Such environments cover a series of broad events, distinguished in terms of duration and severity. The evaluation as of March 31, 2021 projected sufficient sources of liquidity were available under each series of events.

Total liquidity sources, comprised of liquid assets and remaining borrowing capacity with the FRB and the FHLB, totaled $55.0 billion at March 31, 2021. On a stand-alone basis, the Corporation had liquid assets of $1.5 billion on an unconsolidated basis at March 31, 2021.

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CRITICAL ACCOUNTING POLICIES

The Corporation’s consolidated financial statements are prepared based on the application of accounting policies, the most significant of which are described in Note 1 to the consolidated financial statements included in the Corporation's 2020 Annual Report. These policies require numerous estimates and strategic or economic assumptions, which may prove inaccurate or subject to variations. Changes in underlying factors, assumptions or estimates could have a material impact on the Corporation’s future financial condition and results of operations. At December 31, 2020, the most critical of these significant accounting policies were the policies related to the allowance for credit losses, fair value measurement, goodwill, pension plan accounting and income taxes. These policies were reviewed with the Audit Committee of the Corporation’s Board of Directors and are discussed more fully on pages F-39 through F-43 in the Corporation's 2020 Annual Report. As of the date of this report, there have been no significant changes to the Corporation's critical accounting policies or estimates, except for the MRVA methodology change described in Results of Operations and Note 1 to the consolidated financial statements.

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SUPPLEMENTAL FINANCIAL DATA

The Corporation believes non-GAAP measures are meaningful because they reflect adjustments commonly made by management, investors, regulators and analysts to evaluate the adequacy of common equity and our performance trends. Tangible common equity is used by the Corporation to measure the quality of capital and the return relative to balance sheet risk.

Common equity tier 1 capital ratio removes preferred stock from the Tier 1 capital ratio as defined by and calculated in conformity with bank regulations. The tangible common equity ratio removes the effect of intangible assets from capital and total assets. Tangible common equity per share of common stock removes the effect of intangible assets from common shareholders' equity per share of common stock.

The following table provides a reconciliation of non-GAAP financial measures and regulatory ratios used in this financial review with financial measures defined by GAAP.

(dollar amounts in millions)	March 31, 2021			December 31, 2020
Common Equity Tier 1 Capital (a):
Tier 1 capital	$	7,630		$	7,313
Less:
Fixed-rate reset non-cumulative perpetual preferred stock	394			394
Common equity tier 1 capital	$	7,236		$	6,919
Risk-weighted assets	$	65,237		$	66,931
Tier 1 capital ratio	11.70		%	10.93		%
Common equity tier 1 capital ratio	11.09			10.34
Tangible Common Equity Ratio:
Total shareholders' equity	$	8,152		$	8,050
Less:
Fixed-rate reset non-cumulative perpetual preferred stock	394			394
Common shareholders' equity	$	7,758		$	7,656
Less:
Goodwill	635			635
Other intangible assets (b)	14			1
Tangible common equity	$	7,109		$	7,020
Total assets	$	86,291		$	88,129
Less:
Goodwill	635			635
Other intangible assets (b)	14			1
Tangible assets	$	85,642		$	87,493
Common equity ratio	8.99		%	8.69		%
Tangible common equity ratio	8.30			8.02
Tangible Common Equity per Share of Common Stock:
Common shareholders' equity	$	7,758		$	7,656
Tangible common equity	7,109			7,020
Shares of common stock outstanding (in millions)	140			139
Common shareholders' equity per share of common stock	$	55.58		$	55.01
Tangible common equity per share of common stock	50.93			50.43

(a)March 31, 2021 ratios are estimated. Ratios reflect deferral of CECL model impact as calculated per regulatory guidance.

(b)In first quarter 2021, the Corporation acquired an intangible asset of $13 million to be amortized over a period of 10 years.

57

ITEM 3. Quantitative and Qualitative Disclosures about Market Risk

Quantitative and qualitative disclosures for the current period can be found in the "Market and Liquidity Risk" section of "Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations."

ITEM 4. Controls and Procedures

(a)Evaluation of Disclosure Controls and Procedures. The Corporation maintains a set of disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended (the "Exchange Act")) that are designed to ensure that information required to be disclosed by the Corporation in the reports that it files or submits under the Exchange Act is recorded, processed, summarized and reported within the time periods specified in the Securities and Exchange Commission's rules and forms, and that such information is accumulated and communicated to the Corporation's management, including the Corporation's Chief Executive Officer and Chief Financial Officer, as appropriate, to allow timely decisions regarding required disclosure. Management has evaluated, with the participation of the Corporation's Chief Executive Officer and Chief Financial Officer, the effectiveness of the Corporation's disclosure controls and procedures as of the end of the period covered by this quarterly report (the "Evaluation Date"). Based on the evaluation, the Corporation's Chief Executive Officer and Chief Financial Officer have concluded that, as of the Evaluation Date, the Corporation's disclosure controls and procedures are effective.

(b)Changes in Internal Control Over Financial Reporting. During the period to which this report relates, there have not been any changes in the Corporation's internal control over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act) that have materially affected, or that are reasonably likely to materially affect, such controls.

PART II. OTHER INFORMATION

ITEM 1. Legal Proceedings

For information regarding the Corporation's legal proceedings, see "Part I. Item 1. Note 12 – Contingent Liabilities," which is incorporated herein by reference.

ITEM 1A. Risk Factors

    There has been no material change in the Corporation’s risk factors as previously disclosed in our Form 10-K for the fiscal year ended December 31, 2020 in response to Part I, Item 1A. of such Form 10-K. Such risk factors are incorporated herein by reference.     

ITEM 2. Unregistered Sales of Equity Securities and Use of Proceeds

For information regarding the Corporation's purchase of equity securities, see "Part I. Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations – Capital," which is incorporated herein by reference.

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ITEM 6. Exhibits

Exhibit No.	Description
3.1	Restated Certificate of Incorporation of Comerica Incorporated (filed as Exhibit 3.2 to Registrant's Current Report on Form 8-K dated August 4, 2010, and incorporated herein by reference).
3.2	Certificate of Amendment to Restated Certificate of Incorporation of Comerica Incorporated (filed as Exhibit 3.2 to Registrant's Quarterly Report on Form 10-Q for the quarter ended March 31, 2011, and incorporated herein by reference).
3.3	Amended and Restated Bylaws of Comerica Incorporated (filed as Exhibit 3.3 to Registrant's Current Report on Form 8-K dated November 3, 2020, and incorporated herein by reference).
3.4	Certificate of Designations of 5.625% Fixed-Rate Reset Non-Cumulative Perpetual Preferred Stock, Series A, dated May 26, 2020, of Comerica Incorporated (including the form of 5.625% Fixed-Rate Reset Non-Cumulative Perpetual Preferred Stock, Series A Certificate of Comerica Incorporated attached as Exhibit A thereto) (filed as Exhibit 3.1 to Registrant's Current Report on Form 8-K dated May 26, 2020, and incorporated herein by reference).
4	[In accordance with Regulation S-K Item No. 601(b)(4)(iii), the Registrant is not filing copies of instruments defining the rights of holders of long-term debt because none of those instruments authorizes debt in excess of 10% of the total assets of the registrant and its subsidiaries on a consolidated basis. The Registrant hereby agrees to furnish a copy of any such instrument to the SEC upon request.]
10.1†	Comerica Incorporated Amended and Restated 2018 Long-Term Incentive Plan.
10.1G†	Form of Standard Comerica Incorporated Senior Executive Long-Term Performance Restricted Stock Unit Award Agreement under the Comerica Incorporated 2018 Long-Term Incentive Plan (2020 version) (filed as Exhibit 10.1G to Registrant's Annual Report on Form 10-K for the year ended December 31, 2020, and incorporated herein by reference).
10.1K†	Form of Standard Comerica Incorporated Restricted Stock Unit Agreement (2021 three-year non-cliff vesting) under the Comerica Incorporated 2018 Long-Term Incentive Plan.
18.1	Preferability Letter from Independent Registered Public Accounting Firm.
31.1	Chairman, President and CEO Rule 13a-14(a)/15d-14(a) Certification of Periodic Report (pursuant to Section 302 of the Sarbanes-Oxley Act of 2002).
31.2	Executive Vice President and CFO Rule 13a-14(a)/15d-14(a) Certification of Periodic Report (pursuant to Section 302 of the Sarbanes-Oxley Act of 2002).
32	Section 1350 Certification of Periodic Report (pursuant to Section 906 of the Sarbanes-Oxley Act of 2002).
101	Financial statements from Quarterly Report on Form 10-Q of the Registrant for the quarter ended March 31, 2021, formatted in Inline XBRL: (i) the Consolidated Balance Sheets (unaudited), (ii) the Consolidated Statements of Comprehensive Income (unaudited), (iii) the Consolidated Statements of Changes in Shareholders' Equity (unaudited), (iv) the Consolidated Statements of Cash Flows (unaudited) and (v) the Notes to Consolidated Financial Statements (unaudited).
104	The cover page from the Registrant's Quarterly Report on Form 10-Q for the quarter ended March 31, 2021, formatted in Inline XBRL (included in Exhibit 101).
†	Management contract or compensatory plan or arrangement.

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SIGNATURE

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned thereunto duly authorized.

COMERICA INCORPORATED

(Registrant)

/s/ Mauricio A. Ortiz

Mauricio A. Ortiz

Senior Vice President and

Chief Accounting Officer and

Duly Authorized Officer

Date: April 28, 2021

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EX-10.1K

Exhibit 10.1K

COMERICA INCORPORATED

RESTRICTED STOCK UNIT AWARD AGREEMENT (2 & 3 YEAR VEST)

THIS AGREEMENT (this “Agreement”) between Comerica Incorporated (the “Company”) and XXXXXX (the “Participant”) is effective as of XXXXXX (the “Effective Date”). Any undefined terms appearing herein as defined terms shall have the same meaning as they do in the Comerica Incorporated 2018 Long-Term Incentive Plan, as amended and/or restated from time to time, or any successor plan thereto (the “Plan”). The Company shall provide a copy of the Plan to the Participant upon request.

WITNESSETH:

1.Award of Restricted Stock Units. Pursuant to the provisions of the Plan, the Company hereby awards the Participant, subject to the terms and conditions of the Plan (incorporated herein by reference), and subject further to the terms and conditions in this Agreement, XXXXXX restricted stock units (“RSUs”) (the “Award”). Each RSU shall represent an unfunded, unsecured right for the Participant to receive one (1) Share, as described in this Agreement.

2.Ownership Rights. The Participant shall have no voting or other ownership rights in the Company arising from the Award of RSUs under this Agreement prior to the delivery of Shares upon the vesting and settlement of RSUs underlying the Award.

3.Dividend Equivalents. If cash dividends are declared by the Board on the Common Stock on or after the Effective Date and prior to the Settlement Date (as defined below), cash dividend equivalents (the “Dividend Equivalents”) shall accrue on the Shares underlying RSUs, whether such RSUs are vested or unvested, which Dividend Equivalents shall be subject to vesting and forfeiture on the same terms and conditions as the underlying RSUs. Such Dividend Equivalents shall be in an amount of cash per RSU equal to the cash dividend paid with respect to each outstanding Share and shall be credited on the declaration date applicable to Shares. The Dividend Equivalents accrued prior to each Settlement Date shall be paid to the Participant with respect to all vested RSUs as soon as administratively feasible (and in no event more than forty-five (45) days) following each Settlement Date. The Dividend Equivalents accrued on Shares underlying RSUs that do not vest and are forfeited shall be forfeited for no consideration on the date such RSU is forfeited.

4.Vesting of Award.

a.General. Except as otherwise provided in the Plan and this Agreement, 50% of the RSUs covered by the Award shall vest on each of the second and third anniversaries of the Effective Date (or, if such date is not a business day, the business day immediately preceding such date) (each, a “Vesting Date”), subject to the Participant’s continued employment by the Company or one of its Affiliates through the applicable Vesting Date. Any RSU representing a fraction of a Share that would otherwise vest on any date shall be rounded down to the next lowest whole number, with any such fraction added to the portion of the Award that vests and becomes free of restrictions on the next Vesting Date.

b.Death or Disability. In the event of the Participant’s Termination of Service due to death or Disability, prior to the final Vesting Date, any RSUs covered by the Award that are unvested shall immediately and fully vest effective as of the date of the Participant’s Termination of Service.

c.Change in Control. To the extent a Replacement Award is provided pursuant to Section 10(c) of the Plan, upon a Termination of Service of the Participant by the Company other than for Cause or by the Participant for Good Reason (as defined below), in each case, prior to the final Vesting Date and within twenty-four (24) months following a Change in Control, any RSUs covered by the Award that are unvested shall immediately and fully vest effective as of the date of the Participant’s Termination of Service. If a Replacement Award is not provided in respect of the Award, the vesting provisions set forth in Section 10(b) of the Plan shall apply.

Notwithstanding any provision of the Plan or any other agreement to the contrary, for purposes of this Agreement, the term “Good Reason” means the occurrence of any of the following without the Participant’s consent: (i) a material reduction in the Participant’s annual base salary or target short-term

Restricted Stock Unit Award Agreement (Special Version) Page 2 of 5

incentive compensation opportunity, in each case, from that in effect immediately prior to the Change in Control; or (ii) a mandatory relocation of the Participant’s principal location of employment to a location that is more than fifty (50) miles from his or her principal employment location immediately prior to the Change in Control and increases the distance between the Participant’s home and principal employment location. In order to invoke a termination for Good Reason, the Participant shall provide written notice to the Company of the existence of one or more of the conditions described in clauses (i) or (ii) within ninety (90) days following the Participant’s knowledge of the initial existence of such condition or conditions, and the Company shall have thirty (30) days following receipt of such written notice (the “Cure Period”) during which it may cure the condition, if curable. If the Company fails to cure the condition constituting Good Reason during the Cure Period, the Participant must terminate employment, if at all, within one (1) year following the end of the Cure Period in order for such termination to constitute a termination for Good Reason. The Participant’s mental or physical incapacity following the occurrence of an event described above in clauses (i) or (ii) shall not affect the Participant’s ability to terminate employment for Good Reason.

d.All Other Terminations. Except as provided in this Section 4, if the Participant’s Termination of Service occurs prior to the final Vesting Date, any RSUs covered by the Award that are unvested shall be forfeited for no consideration effective immediately as of the date of Termination of Service, unless the Committee determines otherwise.

5.Special Vesting and Forfeiture Terms.

a.Forfeiture Resulting from Acts Occurring During the Grant Year. Notwithstanding any other provision of this Agreement, if it shall be determined at any time subsequent to the Effective Date and prior to each respective Settlement Date (or, in the case of a termination due to death or Disability, the date of Termination of Service) that the Participant has, during the calendar year in which the Effective Date occurs (the “Grant Year”), (i) failed to comply with Company policies and procedures, including the Code of Business Conduct and Ethics or the Senior Financial Officer Code of Ethics (if applicable), (ii) violated any law or regulation, (iii) engaged in negligent or willful misconduct, (iv) engaged in activity resulting in a significant or material Sarbanes-Oxley control deficiency, or (v) demonstrated poor risk management or lack of judgment in discharge of Company duties, and such failure, violation, misconduct, activity or behavior (1) demonstrates an inadequate sensitivity to the inherent risks of Participant’s business line or functional area, and (2) results in, or is reasonably likely to result in, a material adverse impact (whether financial or reputational) on the Company or Participant’s business line or functional area, all or part of the Award granted under this Agreement that has not yet become vested at the time of such determination may be cancelled and forfeited. “Inadequate sensitivity” to risk is demonstrated by imprudent activities that subject the Company to risk outcomes in future periods, including risks that may not be apparent at the time the activities are undertaken.

b.Forfeiture of Award for Acts Occurring in Years Other Than the Grant Year. Notwithstanding any other provisions of this Agreement, if the Participant receives one or more equity awards in any calendar years other than the Grant Year (an “Other Grant Year”) pursuant to an Award Agreement that contains a clause substantially similar to Section 5(a) above, and it shall be determined that Participant, as a result of risk-related behavior, should be subject to the forfeiture of all or part of any such award granted in such Other Grant Year in accordance with the terms of such clause, then the unvested portion of the Award granted under this Agreement shall be subject to forfeiture to the extent necessary to equal the Unsatisfied Forfeiture Value (as defined below). The term “Unsatisfied Forfeiture Value” shall mean the value (as determined by the Committee in its absolute discretion) of any portion of the Award determined by the Committee to be subject to forfeiture with respect to the Other Grant Year (without regard to whether or not some portion thereof has already vested) that has in fact vested prior to such determination by the Committee. All or a portion of the RSUs granted under this Agreement that have not yet become vested shall be subject to forfeiture in order to satisfy as much as possible of the Unsatisfied Forfeiture Value, and the valuation of the Award for such purpose shall be determined in the absolute discretion of the Committee.

6.Settlement. Once vested, the Award shall be settled as follows:

Restricted Stock Unit Award Agreement (Cliff) Page 3 of 5

a.In General. Subject to the terms of the Plan and this Agreement, the vested portion of the Award shall be settled in Common Stock as soon as reasonably practicable (and in no event more than forty-five (45) days) following each date on which the Award vests (each date of settlement, a “Settlement Date”). On each Settlement Date, the Company shall issue to the Participant (or, in the case of the Participant’s death, to the Participant’s designated beneficiary pursuant to Section 13(f) of the Plan, as applicable or, in the case of the Participant’s Disability, to the Participant’s guardian or legal representative, if applicable and if permissible under applicable law) a number of whole Shares equal to the number of RSUs that are vested but unsettled as of immediately prior to the applicable Settlement Date (the “Settlement Shares”). Nothing herein shall preclude the Company from settling the RSUs upon a Section 409A CIC, if they are not replaced by a Replacement Award, to the extent such settlement is effectuated in accordance with Treas. Regs. § 1.409A-3(j)(4)(ix)(B).

b.Termination of Rights. Upon the issuance of the Settlement Shares in settlement of the vested RSUs, such portion of the Award shall be settled in full and the Participant (or his or her designated beneficiary pursuant to Section 13(f) of the Plan, in the case of death) shall have no further rights with respect to such portion of the Award, other than with respect to the payment of the Dividend Equivalents accrued with respect to such vested RSUs.

7.Withholding. The Participant authorizes the Company to withhold from his or her compensation, including RSUs subject to the Award and the Settlement Shares issuable hereunder, to satisfy any income and employment tax withholding obligations in connection with the Award. No later than the date as of which an amount first becomes includible in the gross income of the Participant for Federal income tax purposes with respect to any Settlement Shares subject to the Award, the Participant shall pay to the Company, or make arrangements satisfactory to the Company regarding the payment of, all Federal, state and local income and employment taxes that are required by applicable laws and regulations to be withheld with respect to such amount. The Participant agrees that the Company may delay delivery of the Settlement Shares until proper payment of such taxes has been made by the Participant. If required pursuant to the Company’s policy as applied to the Participant or elected by the Participant, to the extent permitted by law, tax withholding obligations in respect of the Award shall be satisfied by authorizing the Company to withhold (provided the amount withheld does not exceed the maximum statutory tax rate in the Participant’s applicable tax jurisdiction or such lesser amount as is necessary to avoid adverse accounting treatment for the Company) from the Settlement Shares otherwise issuable to the individual pursuant to the settlement of the Award, a number of Shares having a Fair Market Value, as of the date the obligation to withhold such taxes arises, which will satisfy the amount of the withholding tax obligation. Further, unless determined otherwise by the Committee, the Participant may satisfy such obligations under this Section 7 by any other method authorized under Section 13(d) of the Plan.

8.Section 409A of the Code.

a.The Award is intended to qualify for the “short-term deferral” exception under Section 409A of the Code. To the extent that the Award is construed to be nonqualified deferred compensation subject to Section 409A of the Code, the Company shall use its reasonable efforts to operate, administer, construe and interpret this Agreement in a manner that minimizes adverse tax consequences to the Participant and is consistent with the requirements of Section 409A of the Code. Each payment of compensation under this Agreement shall be treated as a separate payment of compensation. In no event may the Participant, directly or indirectly, designate the calendar year of any payment or distribution under this Agreement. Notwithstanding any other provision of the Plan or this Agreement to the contrary, if the Participant is a “specified employee” within the meaning of Section 409A of the Code (as determined in accordance with the methodology established by the Company), amounts that constitute “nonqualified deferred compensation” subject to Section 409A of the Code that would otherwise be payable by reason of the Participant's Termination of Service during the six (6)-month period immediately following such Termination of Service shall instead be paid or provided on the first business day following the date that is six (6) months following the Participant’s Termination of Service. If the Participant dies following the Termination of Service and prior to the payment of any amounts delayed on account of Section 409A of the Code, such amounts shall be paid to the designated beneficiary of the Participant pursuant to Section 13(f) of the Plan within forty-five (45) days following the date of the Participant's death.

Restricted Stock Unit Award Agreement (Cliff) Page 4 of 5

b.This Agreement shall be subject to amendment, with or without advance notice to the Participant, and on a prospective or retroactive basis, including, but not limited to, amendment in a manner that adversely affects the rights of the Participant, to the extent necessary to effect compliance with Section 409A of the Code. Notwithstanding anything contained in this Agreement or the Plan, the Company shall have no liability whatsoever for or in respect of any decision to take action to attempt to comply with Section 409A of the Code, any omission to take such action or for the failure of any such action taken by the Company to so comply.

9.Cancellation of Award. The Committee has the right to cancel for no consideration all or any portion of the Award in accordance with Section 2(d) of the Plan if the Committee determines in good faith that the Participant has done any of the following: (i) been convicted of, or plead guilty or nolo contendere to, a charge of commission of a felony under federal law or the law of the state in which such action occurred; (ii) committed fraud; (iii) embezzled; (iv) disclosed confidential information or trade secrets; (v) was terminated for Cause; (vi) engaged in any activity in competition with the business of the Company or any Subsidiary or Affiliate of the Company; or (vii) engaged in conduct that adversely affected the Company.

The Delegate shall have the power and authority to suspend the vesting of or the right to receive the Settlement Shares in respect of all or any portion of the Award if the Delegate makes in good faith the determination described in the preceding sentence. Any such suspension of an Award shall remain in effect until the suspension shall be presented to and acted on by the Committee at its next meeting. This Section 9 shall have no application following a Change in Control.

10.Compliance with Laws and Regulations. The Award and the obligation of the Company to deliver the Settlement Shares subject to the Award are subject to compliance with all applicable laws, rules and regulations, to receipt of any approvals by any government or regulatory agency as may be required, and to any determinations the Company may make regarding the application of all such laws, rules and regulations.

11.Binding Nature of Plan. The Award is subject to the Plan. The Participant agrees to be bound by all terms and provisions of the Plan and related administrative rules and procedures, including, without limitation, terms and provisions and administrative rules and procedures adopted and/or modified after the granting of the Award. If any provisions hereof are inconsistent with those of the Plan, the provisions of the Plan shall control, except to the extent expressly modified herein pursuant to authority granted under the Plan.

12.Notices. Any notice to the Company under this Agreement shall be in writing to the following address or facsimile number: Human Resources - Total Rewards, Comerica Incorporated, 1717 Main Street, MC 6515, Dallas, TX 75201; Facsimile Number: 214-462-4430. The Company shall address any notice to the Participant to his or her current address according to the Company’s personnel files. All written notices provided in accordance with this Section 12 shall be deemed to be given when (a) delivered to the appropriate address(es) by hand or by a nationally recognized overnight courier service (costs prepaid); (b) sent by facsimile to the appropriate facsimile number, with confirmation by telephone of transmission receipt; or (c) received by the addressee, if sent by U.S. mail to the appropriate address or by Company inter-office mail to the appropriate mail code. Either party may designate in writing some other address or facsimile number for notice under this Agreement.

13.Force and Effect. The various provisions of this Agreement are severable in their entirety. Any judicial or legal determination of invalidity or unenforceability of any one provision shall have no effect on the continuing force and effect of the remaining provisions.

14.Successors. This Agreement shall be binding upon and inure to the benefit of the successors of the respective parties.

15.No Right to Continued Employment. Nothing in the Plan or this Agreement shall confer on the Participant any right to continue in the employment of the Company or its Affiliates for any given period or on any specified terms nor in any way affect the Company’s or its Affiliates’ right to terminate the Participant’s employment without prior notice at any time for any reason or for no reason.

16.Voluntary Participation. Participation in the Plan is voluntary. The value of the Award is an extraordinary item of compensation outside the scope of the Participant’s employment contract, if any. As such, the Award is not

Restricted Stock Unit Award Agreement (Cliff) Page 5 of 5

part of normal or expected compensation for purposes of calculating any severance, resignation, redundancy, end of service payments, bonuses, long-service awards, pension or retirement benefits or similar payments.

17.Recoupment. In addition to the cancellation provisions of Sections 5 and 9, RSUs granted pursuant to this Agreement shall be subject to the terms of the recoupment (clawback) policy adopted by the Company as in effect from time to time, as well as any recoupment/forfeiture provisions required by law and applicable to the Company or its subsidiaries; provided, however, unless prohibited by applicable law, the Company’s recoupment (clawback) policy shall have no application to the Award following a Change in Control.

IN WITNESS WHEREOF, this Agreement has been executed by an appropriate officer of Comerica Incorporated and accepted by the Participant, both as of the day and year first above written.

COMERICA INCORPORATED

By:________________________

Name:

Title:

EX-10.1

Exhibit 10.1

COMERICA INCORPORATEDAMENDED AND RESTATED 2018 LONG-TERM INCENTIVE PLAN

SECTION 1.Purpose; Definitions

The purpose of this Plan is to give the Company a competitive advantage in attracting, retaining and motivating officers, employees, non-employee directors and/or consultants and to provide the Company and its Subsidiaries and Affiliates with a stock plan providing incentives for future performance of services directly linked to the profitability of the Company’s businesses and increases in Company shareholder value.

For purposes of this Plan, the following terms are defined as set forth below, and certain other terms used herein have the definitions given to them in the first place in which they are used:

(a)“Affiliate” means a company or other entity controlled by, controlling or under common control with the Company.

(b)“Applicable Exchange” means the New York Stock Exchange or such other securities exchange as may at the applicable time be the principal market for the Common Stock.

(c)“Award” means a Stock Option, Stock Appreciation Right, Restricted Stock, Restricted Stock Unit, Other Stock-Based Award or Cash Award granted pursuant to the terms of this Plan.

(d)“Award Agreement” means a written or electronic document or agreement setting forth the terms and conditions of a specific Award.

(e)“Board” means the board of directors of the Company.

(f)“Business Combination”has the meaning set forth in Section 10(e)(iii).

(g)“Cash Award” means an Award granted under Section 8 of the Plan.

(h)“Cause” means, unless otherwise provided in an Award Agreement, (i) “Cause” as defined in any Individual Agreement (unless expressly provided otherwise in such Individual Agreement) to which a Participant is a party as in effect as of immediately prior to the date of the Termination of Service that occurs on or after a Change in Control, or (ii) if there is no Individual Agreement, if it does not define Cause or if a Change in Control has not occurred prior to the date of Termination of Service: (A) conviction of, or plea of guilty or nolo contendere by, the Participant for committing a felony under federal law or the law of the state in which such action occurred, (B) willful and deliberate failure on the part of the Participant in the performance of his or her employment duties in any material respect, (C) dishonesty in the course of fulfilling the Participant’s employment duties, (D) a material violation of the Company’s ethics and

compliance program or (E) prior to a Change in Control, such other events as shall be determined by the Committee. Notwithstanding the general rule of Section 2(c), following a Change in Control, any determination by the Committee as to whether “Cause” exists shall be subject to de novo review.

(i)“Change in Control” has the meaning set forth in Section 10(e).

(j)“Code” means the Internal Revenue Code of 1986, as amended from time to time, and any successor thereto, the Treasury Regulations thereunder and other relevant interpretive guidance issued by the Internal Revenue Service or the Treasury Department. Reference to any specific section of the Code shall be deemed to include such regulations and guidance, as well as any successor provision of the Code.

(k)“Committee” means the Committee referred to in Section 2.

(l)“Common Stock” means common stock, $5.00 par value per share, of the Company.

(m)“Company” means Comerica Incorporated, a Delaware corporation, or its successor.

(n)“Corporate Transaction”has the meaning set forth in Section 3(e).

(o)“Delegate” has the meaning set forth in Section 2(d).

(p)“Disability” means, unless otherwise provided in an Award Agreement, permanent and total disability as determined under the Company’s Long-Term Disability Plan applicable to the Participant; provided that, in any case, for an Award that is subject to Section 409A of the Code, “Disability” means “disability” as defined in Section 409(a)(2)(C) of the Code.

(q)“Disaffiliation” means a Subsidiary’s or an Affiliate’s ceasing to be a Subsidiary or Affiliate for any reason (including as a result of a public offering, or a spinoff or sale by the Company, of the stock of the Subsidiary or Affiliate) or a sale of a division of the Company and its Affiliates.

(r)“Effective Date”has the meaning set forth in Section 12(a).

(s)“Eligible Individuals” means officers, employees, non-employee directors and consultants of the Company or any of its Subsidiaries or Affiliates, and prospective officers, employees, non-employee directors and consultants who have accepted offers of employment or consultancy from the Company or its Subsidiaries or Affiliates.

(t)“Exchange Act” means the Securities Exchange Act of 1934, as amended from time to time, and any successor thereto.

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(u)“Fair Market Value” means, except as otherwise determined by the Committee, the closing price of a Share on the Applicable Exchange on the date of measurement or, if Shares were not traded on the Applicable Exchange on such measurement date, then on the most recent prior date on which Shares were traded on the Applicable Exchange, as reported by such source as the Committee may select. If there is no regular public trading market for such Common Stock, the Fair Market Value of the Common Stock shall be determined by the Committee in good faith and, to the extent applicable, such determination shall be made in a manner that satisfies Section 409A and Section 422(c)(1) of the Code.

(v)“Full-Value Award” means any Award other than a Stock Option, Stock Appreciation Right or Cash Award.

(w)“Good Reason” means, unless otherwise provided in an Award Agreement, (i) “Good Reason” as defined in any Individual Agreement (unless expressly provided otherwise in such Individual Agreement) to which the Participant is a party as in effect as of immediately prior to the date of the Termination of Service that occurs on or after a Change in Control, or (ii) if there is no such Individual Agreement or if it does not define Good Reason, the occurrence of any of the following without a Participant’s consent: (A) a material reduction in the Participant’s annual base salary or target short-term incentive compensation opportunity, in each case, from that in effect immediately prior to the Change in Control; or (B) a mandatory relocation of the Participant’s principal location of employment to a location that is more than fifty (50) miles from his or her principal employment location immediately prior to the Change in Control and increases the distance between such Participant’s home and principal employment location. In order to invoke a termination for Good Reason, the Participant shall provide written notice to the Company of the existence of one or more of the conditions described in clauses (A) through (B) within ninety (90) days following the Participant’s knowledge of the initial existence of such condition or conditions, and the Company shall have thirty (30) days following receipt of such written notice (the “Cure Period”) during which it may cure the condition, if curable. If the Company fails to cure the condition constituting Good Reason during the Cure Period, the Participant must terminate employment, if at all, within one (1) year following the end of the Cure Period in order for such termination to constitute a termination for Good Reason. The Participant’s mental or physical incapacity following the occurrence of an event described above in clauses (A) through (B) shall not affect the Participant’s ability to terminate employment for Good Reason.

(x)“Grant Date” means (i) the date on which the Committee by resolution selects an Eligible Individual to receive a grant of an Award and determines the number of Shares, or the formula for earning a number of Shares, to be subject to such Award or the cash amount subject to such Award, or (ii) such later date as the Committee shall provide in such resolution.

(y)“Incentive Stock Option” means any Stock Option designated in the applicable Award Agreement as an “incentive stock option” within the meaning of Section 422 of the Code, and that in fact so qualifies.

(z)“Incumbent Board”has the meaning set forth in Section 10(e)(ii).

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(aa)“Indemnified Person” has the meaning set forth in Section 13(k).

(bb)“Individual Agreement” means, solely with respect to periods on or after a Change in Control, a change in control, severance or salary continuation agreement between a Participant and the Company or one of its Subsidiaries or Affiliates, which, for the avoidance of doubt, does not include any arrangement providing for similar benefits under a plan or policy.

(cc)“Nonqualified Stock Option” means any Stock Option that is not an Incentive Stock Option.

(dd)“Other Stock-Based Award” means Awards granted to a Participant under Section 9 of this Plan.

(ee)“Outstanding Company Common Stock”has the meaning set forth in Section 10(e)(i).

(ff)“Outstanding Company Voting Securities”has the meaning set forth in Section 10(e)(i).

(gg)“Participant” means an Eligible Individual to whom an Award is or has been granted.

(hh)“Performance Goals” means the performance goals established by the Committee in connection with the grant of an Award. Such goals shall be based on the attainment of specified levels of one or more of the following measures: (a) earnings per share (including variations thereof, such as diluted earnings per share, earnings per common share or diluted earnings per common share), (b) return measures (including, but not limited to, return on assets, average assets, equity, common equity or sales or shareholder payout ratio), (c) income measures (before or after taxes, including, but not limited to, net income, net interest income and noninterest income), (d) cash flow (including, but not limited to, operating cash flow and free cash flow), (e) cash flow return on investments, which equals net cash flows divided by owner’s equity, (f) earnings before or after taxes, interest, depreciation and/or amortization, (g) internal rate of return or increase in net present value, (h) revenue measures (including, but not limited to, gross revenues and pre-provision net revenue), (i) gross margins, (j) expenses (including expense efficiency ratios and other expense measures), (k) strategic plan development and implementation, (l) capital levels, (m) loan growth, (n) stock price (including, but not limited to, growth measures and total stockholder return), (o) sustainability measures (including, but not limited to, the measures set forth in Comerica’s Sustainability report, such as percentage reduction in paper consumption, water use, greenhouse gas emissions and/or landfill waste), (p) asset quality, (q) net interest margin, (r) deposit growth, (s) cost control, (t) liquidity, (u) objective customer service measures or indices, (v) customer satisfaction reports and (w) any other objective or subjective measures determined by the Committee, in each case with respect to the Company or any one or more Subsidiaries, divisions, business units or business segments thereof, or individual performance, either in absolute terms or relative to the performance of one or more other companies (including an index covering multiple companies). Without limiting the

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generality of the foregoing, in measuring the achievement of the Performance Goals, the Committee may make such adjustments as it determines to be appropriate, including for items that are unusual in nature or occur infrequently, the impact of charges for restructurings, discontinued operations, force majeure events (such as a natural disaster, severe weather event, act of war,terrorist attack, pandemic or other similar event), the effect of accounting or tax changes and other items.

(ii)“Person”has the meaning set forth in Section 10(e)(i).

(jj)“Plan” means the Comerica Incorporated Amended and Restated 2018 Long-Term Incentive Plan, as set forth herein and as hereinafter amended from time to time.

(kk)“Prior Plans” means the Comerica Incorporated 2006 Amended and Restated Long-Term Incentive Plan, as amended to date, and the 2015 Comerica Incorporated Incentive Plan for Non-Employee Directors, as amended to date.

(ll)“Replaced Award” has the meaning set forth in Section 10(b).

(mm)“Replacement Award” has the meaning set forth in Section 10(b).

(nn)“Restricted Stock” means an Award granted under Section 6.

(oo)“Restricted Stock Unit” has the meaning set forth in Section 7(a).

(pp)“Retirement” means, as it pertains to officers and employees, except as otherwise provided by the Committee, retirement from active employment with the Company or any Affiliate on or after age 65 or after attainment of both age 55 and at least ten (10) years of service with the Company or its Affiliates (as reflected in the Company’s records).

(qq)“Section 16(b)”has the meaning set forth in Section 2(g).

(rr)“Section 409A CIC” has the meaning set forth in Section 10(a).

(ss)“Separation from Service” has the meaning set forth in Section 1(yy).

(tt)“Share” means a share of Common Stock.

(uu)“Stock Appreciation Right” means an Award granted under Section 5(b).

(vv)“Stock Option” means an Award granted under Section 5(a).

(ww)“Subsidiary” means any corporation, partnership, joint venture, limited liability company or other entity during any period in which at least a 50% voting or profits interest is owned, directly or indirectly, by the Company or any successor to the Company.

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(xx)“Term” means the maximum period during which a Stock Option or Stock Appreciation Right may remain outstanding, subject to earlier termination upon Termination of Service or otherwise, as specified in the applicable Award Agreement.

(yy)“Termination of Service” means the termination of the applicable Participant’s employment with, or performance of services for, the Company and any of its Subsidiaries or Affiliates. Unless otherwise determined by the Committee, (i) if a Participant’s employment with the Company and its Affiliates terminates but such Participant continues to provide services to the Company and its Affiliates in a non-employee capacity, such change in status shall not be deemed a Termination of Service, and (ii) a Participant employed by, or performing services for, a Subsidiary or an Affiliate or a division of the Company and its Affiliates shall also be deemed to incur a Termination of Service if, as a result of a Disaffiliation, such Subsidiary, Affiliate or division ceases to be a Subsidiary, Affiliate or division, as the case may be, and the Participant does not immediately thereafter become an employee of, or service provider for, the Company or any Subsidiary or Affiliate. Temporary absences from employment because of illness, vacation or leave of absence and transfers among the Company and its Subsidiaries and Affiliates shall not be considered Terminations of Service. Notwithstanding the foregoing provisions of this definition, with respect to any Award that constitutes a “nonqualified deferred compensation plan” subject to Section 409A of the Code, a Participant shall not be considered to have experienced a “Termination of Service” unless the Participant has experienced a “separation from service” within the meaning of Section 409A of the Code (a “Separation from Service”).

SECTION 2.Administration

(a)Committee. This Plan shall be administered by the Board directly, or if the Board elects, by the Governance, Compensation and Nominating Committee or such other committee of the Board as the Board may from time to time designate, which committee shall be composed of not less than two directors, and shall be appointed by and serve at the pleasure of the Board. All references in this Plan to the “Committee” refer to the Board as a whole, unless a separate committee has been designated or authorized consistent with the foregoing.

Subject to the terms and conditions of this Plan, the Committee shall have absolute authority:

(i)To select the Eligible Individuals to whom Awards may from time to time be granted;

(ii)To determine whether and to what extent Incentive Stock Options, Nonqualified Stock Options, Stock Appreciation Rights, Restricted Stock, Restricted Stock Units, Other Stock-Based Awards and Cash Awards or any combination thereof are to be granted hereunder;

(iii)To determine the number of Shares to be covered by each Award granted hereunder or the amount of any Cash Award;

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(iv)To approve the form of any Award Agreement and determine the terms and conditions of any Award granted hereunder, including, but not limited to, the exercise price (subject to Section 5(c)) or any vesting condition, restriction or limitation (which may be related to the performance of the Participant, the Company or any Subsidiary or Affiliate);

(v)To modify, amend or adjust the terms and conditions (including, but not limited to, Performance Goals) of any Award (subject to Section 5(c) and Section 5(d)), at any time or from time to time, including, without limitation, in order to comply with tax and securities laws and to comply with changes of law and accounting standards;

(vi)To determine to what extent and under what circumstances Common Stock or cash payable with respect to an Award shall be deferred, either automatically or at the election of a Participant;

(vii)To determine under what circumstances an Award may be settled in cash, Shares, other property or a combination of the foregoing;

(viii)To adopt, alter and repeal such administrative rules, guidelines and practices governing this Plan as it shall from time to time deem advisable;

(ix)To establish any “blackout” period that the Committee in its sole discretion deems necessary or advisable;

(x)To interpret the terms and provisions of this Plan and any Award issued under this Plan (and any Award Agreement relating thereto);

(xi)To decide all other matters that must be determined in connection with an Award; and

(xii)To otherwise administer this Plan.

(b)Procedures.

(i)The Committee may act only by a majority of its members then in office, except that the Committee may, except to the extent prohibited by applicable law or the listing standards of the Applicable Exchange and, subject to Section 2(g), allocate all or any portion of its responsibilities and powers to any one or more of its members and may delegate all or any part of its responsibilities and powers to any officer or officers selected by it. Any such allocation or delegation may be revoked by the Committee at any time.

(ii)Any authority granted to the Committee may be exercised by the full Board. To the extent that any permitted action taken by the Board conflicts with action taken by the Committee, the Board action shall control.

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(c)Discretion of Committee. Subject to Section 1(h), any determination made by the Committee or pursuant to delegated authority under the provisions of this Plan with respect to any Award shall be made in the sole discretion of the Committee or such delegate at the time of the grant of the Award or, unless in contravention of any express term of this Plan, at any time thereafter. All decisions made by the Committee or any appropriately delegated officer pursuant to the provisions of this Plan shall be final, binding and conclusive on all persons, including the Company, Participants and Eligible Individuals.

(d)Cancellation or Suspension. Subject to Section 5(c), the Committee may cancel all or any portion of any Award, whether or not vested or deferred, as set forth below. Upon cancellation, the Participant shall forfeit the Award and any benefits attributable to such canceled Award or portion thereof. The Committee may cancel an Award if, in its sole discretion, the Committee determines in good faith that the Participant has done any of the following: (i) been convicted of, or plead guilty or nolo contendere to, a charge of commission of a felony under federal law or the law of the state in which such action occurred; (ii) committed fraud; (iii) embezzled; (iv) disclosed confidential information or trade secrets; (v) was terminated for Cause; (vi) engaged in any activity in competition with the business of the Company or any Subsidiary or Affiliate of the Company; or (vii) engaged in conduct that adversely affected the Company. The Executive Vice President — Chief Human Resources Officer, or such other officer designated from time to time by the Committee (the “Delegate”), shall have the power and authority to suspend all or any portion of any Award if the Delegate makes in good faith the determination described in the preceding sentence. Any such suspension of an Award shall remain in effect until the suspension shall be presented to and acted on by the Committee at its next meeting. This Section 2(d) shall have no application following a Change in Control.

(e)Award Agreements. The terms and conditions of each Award, as determined by the Committee, shall be set forth in a written (or electronic) Award Agreement, which shall be delivered to the Participant receiving such Award upon, or as promptly as is reasonably practicable following, the grant of such Award. The effectiveness of an Award shall be subject to the Participant’s acceptance of the applicable Award Agreement within the time period specified in the Award Agreement, unless otherwise provided in the Award Agreement. Award Agreements may be amended only in accordance with Section 12(d) hereof.

(f)Minimum Vesting Period. Except for Awards granted with respect to a maximum of 5% of the Shares authorized in the first sentence of Section 3(a), Award Agreements shall not provide for a designated vesting period of less than one (1) year.

(g)Section 16(b). The provisions of this Plan are intended to ensure that no transaction under this Plan is subject to (and all such transactions will be exempt from) the short-swing profit recovery rules of Section 16(b) of the Exchange Act (“Section 16(b)”). Accordingly, the composition of the Committee shall be subject to such limitations as the Board deems appropriate to permit transactions pursuant to this Plan to be exempt (pursuant to Rule 16b-3 promulgated under the Exchange Act) from Section 16(b), and no delegation of authority by the

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Committee shall be permitted if such delegation would cause any such transaction to be subject to (and not exempt from) Section 16(b).

SECTION 3.Common Stock Subject to Plan

(a)Authorized Shares. The maximum number of Shares that may be issued pursuant to Awards granted under this Plan shall be 7,720,000 Shares. Shares subject to an Award under this Plan may be authorized and unissued Shares, treasury Shares or Shares purchased in the open market or otherwise, at the sole discretion of the Committee.

(b)Prior Plans. On and after the Effective Date, no new awards may be granted under the Prior Plans, it being understood that (i) awards outstanding under the Prior Plans as of the Effective Date shall remain in full force and effect under the applicable Prior Plan according to their respective terms, and (ii) to the extent that any such award is forfeited, terminates, expires or lapses without being exercised (to the extent applicable), or is settled for cash, the Shares subject to such award not delivered as a result thereof, including any Shares that are unearned under performance awards taking into account the maximum possible payout, shall again be available for Awards under this Plan.

(c)Individual Limits. No Participant, other than a non-employee director, may be granted (i) Stock Appreciation Rights and Stock Options covering in excess of 1,000,000 Shares during any calendar year, (ii) Full-Value Awards covering in excess of 500,000 Shares during any calendar year or (iii) Cash Awards in excess of $10,000,000 during any calendar year. No Participant who is a non-employee director of the Company may be granted during any calendar year Awards covering Shares with a grant date fair value in excess of $500,000.

(d)Rules for Calculating Shares Issued. To the extent that any Award is forfeited, terminates, expires or lapses instead of being exercised, or any Award is settled for cash, the Shares subject to such Awards shall not be counted as Shares issued under this Plan. If tax withholding obligations relating to any Full-Value Award are satisfied by delivering Shares (either actually or through a signed document affirming the Participant’s ownership and delivery of such Shares) or the Company withholding Shares relating to such Award, the net number of Shares subject to the Award after payment of the tax withholding obligations shall be deemed to have been granted for purposes of the first sentence of Section 3(a). If the exercise price and/or tax withholding obligations relating to any Stock Option or Stock Appreciation Right are satisfied by delivering Shares (either actually or through a signed document affirming the Participant’s ownership and delivery of such Shares) or the Company withholding Shares relating to such Stock Option or Stock Appreciation Right, the gross number of Shares subject to the Stock Option or Stock Appreciation Right shall nonetheless be deemed to have been issued under this Plan.

(e)Adjustment Provisions.

(i)In the event of a merger, consolidation, acquisition of property or shares, stock rights offering, liquidation, disposition for consideration of the Company’s direct or indirect

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ownership of a Subsidiary or Affiliate (including by reason of a Disaffiliation),or similar event affecting the Company or any of its Subsidiaries (each, a “Corporate Transaction”), the Committee or the Board may in its discretion make such substitutions or adjustments as it deems appropriate and equitable to (A) the aggregate number and kind of Shares or other securities reserved for issuance and delivery under this Plan, (B) the maximum limitations on Awards in respect of Shares set forth in Section 3(c) applicable to the grants to individuals, (C) the number and kind of Shares or other securities subject to outstanding Awards, (D) financial goals or results underlying or relevant to a Performance Goal and (E) the exercise price of outstanding Awards.

(ii)In the event of a stock dividend, stock split, reverse stock split, reorganization, share combination or recapitalization or similar event affecting the capital structure of the Company, or a Disaffiliation, separation or spinoff, in each case without consideration, or other extraordinary dividend of cash or other property to the Company’s shareholders, the Committee or the Board shall make such substitutions or adjustments as it deems appropriate and equitable to (A) the aggregate number and kind of Shares or other securities reserved for issuance and delivery under this Plan, (B) the maximum limitation limitations on Awards in respect of Shares set forth in Section 3(c) applicable to the grants to individuals, (C) the number and kind of Shares or other securities subject to outstanding Awards, (D) financial goals or results underlying or relevant to a Performance Goal, and (E) the exercise price of outstanding Awards.

(iii)In the case of Corporate Transactions, such adjustments may include:(A) the cancellation of outstanding Awards in exchange for payments of cash, property or a combination thereof having an aggregate value equal to the value of such Awards, as determined by the Committee or the Board in its sole discretion (it being understood that in the case of a Corporate Transaction with respect to which shareholders of Common Stock receive consideration other than publicly traded equity securities of the ultimate surviving entity, any such determination by the Committee that the value of a Stock Option or Stock Appreciation Right shall for this purpose be deemed to equal the excess, if any, of the value of the consideration being paid for each Share pursuant to such Corporate Transaction over the exercise price of such Stock Option or Stock Appreciation Right shall conclusively be deemed valid); (B) the substitution of other property (including cash or other securities of the Company and securities of entities other than the Company) for the Shares subject to outstanding Awards; and (C) in connection with any Disaffiliation, arranging for the assumption of Awards, or replacement of Awards with new awards based on other property or other securities (including other securities of the Company and securities of entities other than the Company), by the affected Subsidiary, Affiliate or division or by the entity that controls such Subsidiary, Affiliate, or division following such Disaffiliation (as well as any corresponding adjustments to Awards that remain based upon Company securities).

(iv)Any adjustments made pursuant to this Section 3(e) to Awards that are considered “nonqualified deferred compensation” subject to Section 409A of the Code shall be made in compliance with the requirements of Section 409A of the Code, and any adjustments made pursuant to Section 3(e) to Awards that are not considered “nonqualified deferred

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compensation” subject to Section 409A of the Code shall be made in such a manner as to ensure that, after such adjustments, either (A) the Awards continue not to be subject to Section 409A of the Code or (B) there does not result in the imposition of any penalty taxes under Section 409A of the Code in respect of such Awards.

(v)Any adjustment under this Section 3(e) need not be the same for all Participants.

SECTION 4.Eligibility

Awards may be granted under this Plan to Eligible Individuals; provided, however, that Incentive Stock Options may be granted only to employees of the Company and its subsidiaries or parent corporation (within the meaning of Section 424(f) of the Code).

SECTION 5.Stock Options and Stock Appreciation Rights

(a)Stock Options. Stock Options may be granted alone or in addition to other Awards granted under this Plan and may be of two types: Incentive Stock Options and Nonqualified Stock Options. The Award Agreement for a Stock Option shall indicate whether the Stock Option is intended to be an Incentive Stock Option or a Nonqualified Stock Option.

(b)Stock Appreciation Rights. Upon the exercise of a Stock Appreciation Right, the Participant shall be entitled to receive an amount in cash, or Shares in value equal to the product of (i) the excess of the Fair Market Value of one (1) Share over the exercise price of the applicable Stock Appreciation Right, multiplied by (ii) the number of Shares in respect of which the Stock Appreciation Right has been exercised. The applicable Award Agreement shall specify whether such payment is to be made in cash or Shares, or shall reserve to the Committee or the Participant the right to make that determination prior to or upon the exercise of the Stock Appreciation Right.

(c)Exercise Price; Prohibition on Repricing. The exercise price per Share subject to a Stock Option or Stock Appreciation Right shall be determined by the Committee and set forth in the applicable Award Agreement, and shall not be less than the Fair Market Value of a Share on the applicable Grant Date. In no event may any Stock Option or Stock Appreciation Right granted under this Plan be amended, other than pursuant to Section 3(e), to decrease the exercise price thereof, be cancelled in exchange for other Awards or in conjunction with the grant of any new Stock Option or Stock Appreciation Right with a lower exercise price, or otherwise be subject to any action that would be treated, under the Applicable Exchange listing standards or for accounting purposes, as a “repricing” of such Stock Option or Stock Appreciation Right, unless such amendment, cancellation, or action is approved by the Company’s shareholders. Further, except as provided in Section 3(e) hereof, the Committee may not, without prior approval of the Company’s shareholders, seek to effect any repricing of any previously granted “underwater” Stock Option or Stock Appreciation Right by repurchasing the underwater Stock Option or Stock Appreciation Right with cash. A Stock Option or Stock Appreciation Right shall be deemed to be “underwater” at any time when the Fair Market Value of the Shares covered by such Stock

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Option or Stock Appreciation Right is less than the exercise price of the Stock Option or Stock Appreciation Right.

(d)Term. The Term of each Stock Option and each Stock Appreciation Right shall be fixed by the Committee, but no Stock Option or Stock Appreciation Right shall be exercisable more than ten (10) years after its Grant Date.

(e)Exercisability. Except as otherwise provided herein, Stock Options and Stock Appreciation Rights shall be exercisable at such time or times and subject to such terms and conditions as shall be determined by the Committee.

(f)Method of Exercise. Subject to the provisions of this Section 5, Stock Options and Stock Appreciation Rights may be exercised, in whole or in part, at any time during the Term thereof, in accordance with the methods and procedures established by the Committee in the Award Agreement or otherwise.

(g)Delivery; Rights of Shareholders. A Participant shall not be entitled to delivery of Shares pursuant to the exercise of a Stock Option or Stock Appreciation Right until the exercise price therefor has been fully paid and applicable taxes have been withheld. Except as otherwise provided in Section 5(k), a Participant shall have all of the rights of a shareholder of the Company holding the number of Shares deliverable pursuant to such Stock Option or Stock Appreciation Right (including, if applicable, the right to vote the applicable Shares), when the Participant (i) has given proper notice of exercise, (ii) if requested, has given the representation described in Section 13(a) and (iii) in the case of a Stock Option, has paid in full for such Shares.

(h)Nontransferability of Stock Options and Stock Appreciation Rights. No Stock Option or Stock Appreciation Right shall be transferable by a Participant other than, for no value or consideration, (i) by will or by the laws of descent and distribution, or (ii) upon the Participant’s death, to a designated beneficiary pursuant to Section 13(f) hereof. Any Stock Option or Stock Appreciation Right shall be exercisable, subject to the terms of this Plan, only by the Participant, the guardian or legal representative of the Participant, or any person to whom such Stock Option is transferred pursuant to this Section 5(h), it being understood that the term “holder” and “Participant” include such guardian, legal representative and other transferee; provided, however, that the term “Termination of Service” shall continue to refer to the Termination of Service of the original Participant.

(i)Termination of Service. The effect of a Participant’s Termination of Service on any Stock Option or Stock Appreciation Right then held by the Participant shall be set forth in the applicable Award Agreement or any other document approved by the Committee and applicable to such Stock Option or Stock Appreciation Right. In no event shall a Stock Option or Stock Appreciation Right be exercisable after the expiration of its Term.

(j)Additional Rules for Incentive Stock Options. Notwithstanding any other provision of this Plan to the contrary, no Stock Option that is intended to qualify as an Incentive Stock Option may be granted to any Eligible Individual who at the time of such grant owns stock

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possessing more than 10% of the total combined voting power of all classes of stock of the Company or of any Subsidiary, unless at the time such Stock Option is granted the exercise price is at least 110% of the Fair Market Value of a Share and such Stock Option by its terms is not exercisable after the expiration of five (5) years from the date such Stock Option is granted. In addition, the aggregate Fair Market Value of the Common Stock (determined at the time a Stock Option for the Common Stock is granted) for which Incentive Stock Options are exercisable for the first time by a Participant during any calendar year, under all of the incentive stock option plans of the Company and of any Subsidiary, may not exceed $100,000. To the extent a Stock Option that by its terms was intended to be an Incentive Stock Option exceeds this $100,000 limit, the portion of the Stock Option in excess of such limit shall be treated as a Nonqualified Stock Option.

(k)Dividends and Dividend Equivalents. Dividends (whether paid in cash or Shares) and dividend equivalents may not be paid or accrued on Stock Options or Stock Appreciation Rights; provided that Stock Options and Stock Appreciation Rights may be adjusted under certain circumstances in accordance with the terms of Section 3(e).

SECTION 6.Restricted Stock

(a)Administration. Shares of Restricted Stock are actual Shares issued to a Participant and may be awarded either alone or in addition to other Awards granted under this Plan. The Committee shall determine the Eligible Individuals to whom and the time or times at which grants of Restricted Stock will be awarded, the number of Shares to be awarded to any Eligible Individual, the conditions for vesting, the time or times within which such Awards may be subject to forfeiture and any other terms and conditions of the Awards, in addition to those contained in Section 6(c).

(b)Book Entry Registration or Certificated Shares. Shares of Restricted Stock shall be evidenced in such manner as the Committee may deem appropriate, including book-entry registration or issuance of one or more stock certificates. If any certificate is issued in respect of Shares of Restricted Stock, such certificate shall be registered in the name of the Participant and shall bear an appropriate legend referring to the terms, conditions and restrictions applicable to such Award, substantially in the following form:

The transferability of this certificate and the shares of stock represented hereby are subject to the terms and conditions (including forfeiture) of the Comerica Incorporated Amended and Restated 2018 Long-Term Incentive Plan and an Award Agreement. Copies of such Plan and Agreement are on file at the offices of Comerica Incorporated, 1717 Main Street, Dallas, Texas 75201.

The Committee may require that the certificates evidencing such Shares be held in custody by the Company until the restrictions thereon shall have lapsed and that, as a condition of any

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Award of Restricted Stock, the applicable Participant shall have delivered a stock power, endorsed in blank, relating to the Common Stock covered by such Award.

(c)Terms and Conditions. Shares of Restricted Stock shall be subject to the following terms and conditions and such other terms and conditions as are set forth in the applicable Award Agreement (including the vesting or forfeiture provisions applicable upon a Termination of Service):

(i)The Committee shall, prior to or at the time of grant, condition (A) the vesting of an Award of Restricted Stock upon the continued service of the applicable Participant, or (B) the grant or vesting of an Award of Restricted Stock upon the attainment of Performance Goals or the attainment of Performance Goals and the continued service of the applicable Participant. The conditions for grant or vesting and the other provisions of Awards of Restricted Stock (including any applicable Performance Goals) need not be the same with respect to each recipient.

(ii)Subject to the provisions of this Plan and the applicable Award Agreement, during the period, if any, set by the Committee, commencing with the date of such Awards of Restricted Stock for which such vesting restrictions apply, and until the expiration of such period, the Participant shall not be permitted to sell, assign, transfer, pledge or otherwise encumber Shares of Restricted Stock.

(d)Rights of a Shareholder. Except as provided in this Section 6 and the applicable Award Agreement, the applicable Participant shall have, with respect to the Shares of Restricted Stock, all of the rights of a shareholder of the Company holding the class or series of Common Stock that is the subject of the Restricted Stock, including, if applicable, the right to vote the Shares and the right to receive any dividends; provided, however, that (A) cash dividends on the class or series of Common Stock that is the subject of the Restricted Stock shall be held subject to the vesting of the underlying Restricted Stock and (B) subject to Section 13(e), dividends payable in Common Stock shall be paid in the form of Restricted Stock of the same class as the Common Stock with which such dividend was paid and shall be held subject to the vesting of the underlying Restricted Stock.

(e)Termination of Service. The effect of a Participant’s Termination of Service on any Share of Restricted Stock then held by the Participant shall be set forth in the applicable Award Agreement or any other document approved by the Committee and applicable to such Share of Restricted Stock.

SECTION 7.Restricted Stock Units

(a)Nature of Awards. Restricted stock units and deferred share rights (together, “Restricted Stock Units”) are Awards denominated in Shares that will be settled, subject to the terms and conditions of the Restricted Stock Units, in a specified number of Shares or an amount of cash equal to the Fair Market Value of a specified number of Shares.

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(b)Terms and Conditions. Restricted Stock Units shall be subject to the following terms and conditions and such other terms and conditions as are set forth in the applicable Award Agreement (including the vesting or forfeiture provisions applicable upon a Termination of Service):

(i)The Committee shall, prior to or at the time of grant, condition (A) the vesting of Restricted Stock Units upon the continued service of the applicable Participant or (B) the grant or vesting of Restricted Stock Units upon the attainment of Performance Goals or the attainment of Performance Goals and the continued service of the applicable Participant. The conditions for grant or vesting and the other provisions of Restricted Stock Units (including any applicable Performance Goals) need not be the same with respect to each recipient. An Award of Restricted Stock Units shall be settled as and when the Restricted Stock Units vest, at a later time specified by the Committee in the applicable Award Agreement, or, if the Committee so permits, in accordance with an election of the Participant.

(ii)Subject to the provisions of this Plan and the applicable Award Agreement, prior to the delivery of Shares in settlement of Restricted Stock Units, the Participant shall not be permitted to sell, assign, transfer, pledge or otherwise encumber Restricted Stock Units.

(iii)The Award Agreement for Restricted Stock Units shall specify whether, to what extent and on what terms and conditions the applicable Participant shall be entitled to receive payments of cash, Common Stock or other property corresponding to the dividends payable on the Common Stock (subject to Section 13(e) below).

(c)Rights of a Shareholder. A Participant to whom Restricted Stock Units are awarded shall have no rights as a shareholder with respect to the Shares represented by the Restricted Stock Units unless and until Shares are actually delivered to the participant in settlement thereof. The Award Agreement shall set forth any rights applicable to an Award of Restricted Stock Units to adjustment to reflect the deemed reinvestment in additional Restricted Stock Units of the dividends that would be paid and distributions that would be made with respect to the Award of Restricted Stock Units as if it consisted of actual Shares, subject to Section 13(e).

(d)Termination of Service. The effect of a Participant’s Termination of Service on any Restricted Stock Unit then held by the Participant shall be set forth in the applicable Award Agreement or any other document approved by the Committee and applicable to such Restricted Stock Unit.

SECTION 8.Cash Award

The Committee may grant awards to Eligible Individuals that are denominated and payable in cash in such amounts and subject to such terms and conditions consistent with the terms of this Plan as the Committee shall determine. With respect to a Cash Award subject to Performance Goals, the Performance Goals to be achieved during any performance period and

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the length of the performance period shall be determined by the Committee upon the grant of such Cash Award. The conditions for grant or vesting and the other provisions of a Cash Award (including any applicable Performance Goals) need not be the same with respect to each recipient.

SECTION 9.Other Stock-Based Awards

The Committee may grant equity-based or equity-related awards not otherwise described herein in such amounts and subject to such terms and conditions consistent with the terms of this Plan as the Committee shall determine. Without limiting the generality of the preceding sentence, each such Other Stock-Based Award may (a) involve the transfer of actual Shares to Participants, either at the time of grant or thereafter, or payment in cash or otherwise of amounts based on the value of Shares, (b) be subject to performance-based and/or service-based conditions, (c) be in the form of phantom stock, restricted stock, restricted stock units, performance shares, deferred share units or share-denominated performance units, or other awards denominated in, or with a value determined by reference to, a number of Shares that is specified at the time of the grant of such Award, and (d) be designed to comply with applicable laws of jurisdictions other than the United States.

SECTION 10.Change-in-Control Provisions

(a)General. The provisions of this Section 10 shall, subject to Section 3(e), apply notwithstanding any other provision of this Plan to the contrary, except to the extent the Committee specifically provides otherwise in an Award Agreement.

(b)Impact of Change in Control. Upon the occurrence of a Change in Control, unless otherwise provided in the applicable Award Agreement: (i) all then-outstanding Stock Options and Stock Appreciation Rights shall become fully vested and exercisable, and all Full-Value Awards (other than performance-based Awards) and all Cash Awards (other than performance-based Cash Awards) shall vest in full, be free of restrictions and be deemed to be earned and payable in an amount equal to the full value of such Award, except in each case to the extent that another Award meeting the requirements of Section 10(c) (any award meeting the requirements of Section 10(c), a “Replacement Award”) is provided to the Participant pursuant to Section 3(e) to replace such Award (any award intended to be replaced by a Replacement Award, a “Replaced Award”), and (ii) any performance-based Full Value Award or Cash Award that is not replaced by a Replacement Award shall be deemed to be earned and payable in an amount equal to the full value of such performance-based Award (with all applicable Performance Goals deemed achieved at the greater of (x) the applicable target level and (y) the level of achievement as determined by the Committee not later than the date of the Change in Control, taking into account performance through the latest date preceding the Change in Control as to which performance can, as a practical matter, be determined (but not later than the end of the applicable performance period)).

(c)Replacement Awards. An Award shall meet the conditions of this Section 10(c) (and hence qualify as a Replacement Award) if: (i) it is of the same type as the Replaced Award (except that for any Replaced Award that is performance-based, the Replacement Award shall be

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subject solely to time-based vesting for the remainder of the applicable performance period (or such shorter period as determined by the Committee) and the applicable Performance Goals shall be deemed to be achieved at the greater of (x) the applicable target level and (y) the level of achievement as determined by the Committee, taking into account performance through the latest date preceding the Change in Control as to which performance can, as a practical matter, be determined (but not later than the end of the applicable performance period)); (ii) it has a value equal to the value of the Replaced Award as of the date of the Change in Control, as determined by the Committee in its sole discretion consistent with Section 3(e); (iii) the underlying Replaced Award was an equity-based award, it relates to publicly traded equity securities of the Company or the entity surviving the Company following the Change in Control; (iv) it contains terms relating to time-based vesting (including with respect to a Termination of Service) that are substantially identical to those of the Replaced Award; and (v) its other terms and conditions are not less favorable to the Participant than the terms and conditions of the Replaced Award (including the provisions that would apply in the event of a subsequent Change in Control) as of the date of the Change in Control. Without limiting the generality of the foregoing, a Replacement Award may take the form of a continuation of the applicable Replaced Award if the requirements of the preceding sentence are satisfied. If a Replacement Award is granted, the Replaced Award shall not vest upon the Change in Control. The determination whether the conditions of this Section 10(c) are satisfied shall be made by the Committee, as constituted immediately before the Change in Control, in its sole discretion.

(d)Termination of Service. Notwithstanding any other provision of this Plan to the contrary and unless otherwise determined by the Committee and set forth in the applicable Award Agreement, upon a Termination of Service of a Participant by the Company other than for Cause or by the Participant for Good Reason within twenty-four (24) months following a Change in Control (or such longer period as specified in the applicable Award Agreement), (i) all Replacement Awards held by such Participant shall vest in full and be free of restrictions and (ii) unless otherwise provided in the applicable Award Agreement, notwithstanding any other provision of this Plan to the contrary, any Stock Option or Stock Appreciation Right held by the Participant as of the date of the Change in Control that remains outstanding as of the date of such Termination of Service may thereafter be exercised until the expiration of the stated full Term of such Nonqualified Stock Option or Stock Appreciation Right.

(e)Definition of Change in Control. For purposes of this Plan, a “Change in Control” shall mean the happening of any of the following events:

(i)An acquisition by any individual, entity or group (within the meaning of Section 13(d)(3) or 14(d)(2) of the Exchange Act) (a “Person”) of beneficial ownership (within the meaning of Rule 13d-3 promulgated under the Exchange Act) of 30% or more of either (1) the then-outstanding shares of common stock of the Company (the “Outstanding Company Common Stock”) or (2) the combined voting power of the then‑outstanding voting securities of the Company entitled to vote generally in the election of directors (the “Outstanding Company Voting Securities”); provided, however, that for purposes of this subsection (i), the following acquisitions shall not constitute a

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Change in Control: (1) any acquisition directly from the Company, (2) any acquisition by the Company, (3) any acquisition by any employee benefit plan (or related trust) sponsored or maintained by the Company or any entity controlled by the Company or (4) any acquisition by any entity pursuant to a transaction that complies with clauses (1), (2) and (3) of subsection (iii) of this Section 10(e); or

(ii)A change in the composition of the Board such that the individuals who, as of the Effective Date, constitute the Board (the “Incumbent Board”) cease for any reason to constitute at least a majority of the Board; provided, however, that, for purposes of this Section 10(e), any individual who becomes a member of the Board subsequent to the Effective Date whose election, or nomination for election by the Company’s shareholders, was approved by a vote of at least a majority of those individuals who are members of the Board and who were also members of the Incumbent Board (or deemed to be such pursuant to this proviso) shall be considered as though such individual were a member of the Incumbent Board; provided further, that any such individual whose initial assumption of office occurs as a result of either an actual or threatened election contest with respect to the election or removal of directors or other actual or threatened solicitation of proxies or consents by or on behalf of a Person other than the Board shall not be considered as a member of the Incumbent Board; or

(iii)The consummation of a reorganization, merger, statutory share exchange or consolidation or similar transaction involving the Company or any of its Subsidiaries or sale or other disposition of all or substantially all of the assets of the Company, or the acquisition of assets or securities of another entity by the Company or any of its subsidiaries (a “Business Combination”), in each case, unless, following such Business Combination, (1) all or substantially all of the individuals and entities who were the beneficial owners, respectively, of the Outstanding Company Common Stock and Outstanding Company Voting Securities immediately prior to such Business Combination beneficially own, directly or indirectly, more than 50% of, respectively, the then-outstanding shares of common stock (or, for a noncorporate entity, equivalent securities) and the combined voting power of the then-outstanding voting securities entitled to vote generally in the election of directors (or, for a noncorporate entity, equivalent securities), as the case may be, of the entity resulting from such Business Combination (including an entity that, as a result of such transaction, owns the Company or all or substantially all of the Company’s assets either directly or through one or more subsidiaries) in substantially the same proportions as their ownership, immediately prior to such Business Combination of the Outstanding Company Common Stock and Outstanding Company Voting Securities, as the case may be, (2) no Person (excluding any entity resulting from such Business Combination or any employee benefit plan (or related trust) of the Company or such entity resulting from such Business Combination) beneficially owns, directly or indirectly, 30% or more of, respectively, the then‑outstanding shares of common stock (or, for a noncorporate entity, equivalent securities) of the entity resulting from such Business Combination or the combined voting power of the then‑outstanding voting securities of such entity except to the extent

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that such ownership existed prior to the Business Combination and (3) at least a majority of the members of the board of directors (or, for a noncorporate entity, equivalent body or committee) of the entity resulting from such Business Combination were members of the Board at the time of the execution of the initial agreement, or of the action of the Board, providing for such Business Combination; or

(iv)The approval by the shareholders of the Company of a complete liquidation or dissolution of the Company.

Notwithstanding any other provision of this Plan, any Award Agreement or any Individual Agreement, for any Award that constitutes nonqualified deferred compensation within the meaning of Section 409A of the Code, a Change in Control shall not constitute a settlement or distribution event with respect to such Award, or an event that otherwise changes the timing of settlement or distribution of such Award, unless the Change in Control also constitutes an event described in Section 409A(a)(2)(v) of the Code and the regulations promulgated thereunder (a “Section 409A CIC”); provided, however, that whether or not a Change in Control is a Section 409A CIC, such Change in Control shall result in the accelerated vesting of such Award to the extent provided by the Award Agreement, this Plan, any Individual Agreement or otherwise by the Committee.

SECTION 11.Section 409A

    This Plan and the Awards granted hereunder are intended to comply with the requirements of Section 409A of the Code or an exemption or exclusion therefrom and, with respect to amounts that are subject to Section 409A of the Code, it is intended that this Plan be administered and interpreted in all respects in accordance with Section 409A of the Code. Each payment under any Award that constitutes nonqualified deferred compensation subject to Section 409A of the Code shall be treated as a separate payment for purposes of Section 409A of the Code. In no event may a Participant, directly or indirectly, designate the calendar year of any payment to be made under any Award that constitutes nonqualified deferred compensation subject to Section 409A of the Code. Notwithstanding any other provision of this Plan or any Award Agreement to the contrary, if a Participant is a “specified employee” within the meaning of Section 409A of the Code (as determined in accordance with the methodology established by the Company), amounts that constitute “nonqualified deferred compensation” subject to Section 409A of the Code that would otherwise be payable by reason of a Participant’s Separation from Service during the six (6)-month period immediately following such Separation from Service shall instead be paid or provided on the first business day following the date that is six (6) months following the Participant’s Separation from Service. If the Participant dies following the Separation from Service and prior to the payment of any amounts delayed on account of Section 409A of the Code, such amounts shall be paid to the designated beneficiary of the Participant pursuant to Section 13(f) hereof within thirty (30) days following the date of the Participant’s death.

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SECTION 12.Term, Amendment and Termination

(a)Effectiveness. The Comerica Incorporated 2018 Long-Term Incentive Plan was originally approved by the Committee and adopted by the Board on February 27, 2018, and became effective on April 24, 2018, the date of approval by the Company’s shareholders (such original version of the Plan, the “Prior 2018 Plan”). This Plan (the Comerica Incorporated Amended and Restated 2018 Long-Term Incentive Plan) was approved by the Committee and adopted by the Board on February 23, 2021, subject to and contingent upon approval by the Company’s shareholders. This Plan will be effective as of the date of such approval by the Company’s shareholders (the “Effective Date”). For the avoidance of doubt, if this Plan is not approved, the Prior 2018 Plan shall continue in effect.

(b)Termination. This Plan will terminate on the tenth (10th) anniversary of the Effective Date. Awards outstanding as of such date shall not be affected or impaired by the termination of this Plan.

(c)Amendment of Plan. The Board or the Committee may amend, alter or discontinue this Plan, but no amendment, alteration or discontinuation shall be made that would materially impair the rights of the Participant with respect to a previously granted Award without such Participant’s consent, except such an amendment made to comply with applicable law, including Section 409A of the Code, Applicable Exchange listing standards or accounting rules. In addition, no amendment shall be made without the approval of the Company’s shareholders to the extent such approval is required by applicable law or the listing standards of the Applicable Exchange.

(d)Amendment of Awards. Subject to Section 5(c), the Committee may unilaterally amend the terms of any Award theretofore granted, but no such amendment shall, without the Participant’s consent, materially impair the rights of any Participant with respect to an Award, except such an amendment made to cause this Plan or Award to comply with applicable law, Applicable Exchange listing standards or accounting rules.

SECTION 13.General Provisions

(a)Conditions for Issuance. The Committee may require each person purchasing or receiving Shares pursuant to an Award to represent to and agree with the Company in writing that such person is acquiring the Shares without a view to the distribution thereof. The certificates for such Shares may include any legend that the Committee deems appropriate to reflect any restrictions on transfer. Notwithstanding any other provision of this Plan or agreements made pursuant thereto, the Company shall not be required to issue or deliver any Shares (whether in certificated or book-entry form) under this Plan prior to fulfillment of all of the following conditions: (i) listing or approval for listing upon notice of issuance, of such Shares on the Applicable Exchange; (ii) any registration or other qualification of such Shares of the Company under any state or federal law or regulation, or the maintaining in effect of any such registration or other qualification that the Committee shall, in its absolute discretion upon the advice of counsel, deem necessary or advisable; and (iii) obtaining any other consent, approval or permit from any

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state or federal governmental agency that the Committee shall, in its absolute discretion, determine to be necessary or advisable.

(b)Additional Compensation Arrangements. Nothing contained in this Plan shall prevent the Company or any Subsidiary or Affiliate from adopting other or additional compensation arrangements for its employees or directors.

(c)No Contract of Employment. This Plan shall not constitute a contract of employment, and adoption of this Plan shall not confer upon any employee any right to continued employment, nor shall it interfere in any way with the right of the Company or any Subsidiary or Affiliate to terminate the employment of any employee at any time.

(d)Required Taxes. No later than the date as of which an amount first becomes includible in the gross income of a Participant for federal, state, local or foreign income or employment or other tax purposes with respect to any Award under this Plan, such Participant shall pay to the Company, or make arrangements satisfactory to the Company regarding the payment of, any federal, state, local or foreign taxes of any kind required by law to be withheld with respect to such amount. Unless otherwise determined by the Company, withholding obligations may be settled with Common Stock, including Common Stock that is part of the Award that gives rise to the withholding requirement, having a Fair Market Value on the date of withholding equal to the amount to be withheld for tax purposes, all in accordance with such procedures as the Committee establishes. The obligations of the Company under this Plan shall be conditional on such payment or arrangements, and the Company and its Affiliates shall, to the extent permitted by law, have the right to deduct any such taxes from any payment otherwise due to such Participant. The Committee may establish such procedures as it deems appropriate, including making irrevocable elections, for the settlement of withholding obligations with Common Stock.

(e)Limitation on Dividend Reinvestment and Dividend Equivalents. Reinvestment of dividends in additional Restricted Stock at the time of any dividend payment, and the payment of Shares with respect to dividends to Participants holding Awards of Restricted Stock Units, shall only be permissible if sufficient Shares are available under Section 3 for such reinvestment or payment (taking into account then-outstanding Awards). If sufficient Shares are not available for such reinvestment or payment, such reinvestment or payment shall be made in the form of a grant of Restricted Stock Units equal in number to the Shares that would have been obtained by such payment or reinvestment, the terms of which Restricted Stock Units shall provide for settlement in cash and for dividend equivalent reinvestment in further Restricted Stock Units on the terms contemplated by this Section 13(e). Any dividends or dividend equivalents credited with respect to any Award will be subject to the same time and/or performance-based vesting conditions applicable to such Award and shall, if vested, be delivered or paid at the same time as such Award.

(f)Designation of Death Beneficiary. The Committee shall establish such procedures as it deems appropriate for a Participant to designate a beneficiary to whom any amounts payable

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in the event of such Participant’s death are to be paid or by whom any rights of such Participant after such Participant’s death may be exercised.

(g)Governing Law and Interpretation.This Plan and all Awards made and actions taken hereunder shall be governed by and construed in accordance with the laws of the State of Delaware, without reference to principles of conflict of laws. The captions of this Plan are not part of the provisions hereof and shall have no force or effect. Whenever the words “include,” “includes” or “including” are used in this Plan, they shall be deemed to be followed by the words “but not limited to” and the word “or” shall be understood to mean “and/or” where the context so requires.

(h)Nontransferability. Except as otherwise provided in Section 5(h), or as determined by the Committee, Awards under this Plan are not transferable except by will or by laws of descent and distribution, in each case, for no value or consideration.

(i)Clawback Policy. Awards granted pursuant to this Plan shall be subject to the terms of the recoupment (clawback) policy adopted by the Company as in effect from time to time, as well as any recoupment/forfeiture provisions required by law and applicable to the Company or its subsidiaries; provided, however, unless prohibited by applicable law, the Company’s recoupment (clawback) policy shall have no application to the Award (or the Shares, or payments received in respect of an Award) following a Change in Control.

(j)Whistleblowing. Nothing contained in this Plan prohibits a Participant from (i) reporting possible violations of federal law or regulations, including any possible securities laws violations, to any government agency or entity, (ii) making any other disclosures that are protected under the whistleblower provisions of federal law or regulations or (iii) otherwise fully participating in any federal whistleblower programs, including but not limited to any such programs managed by the U.S. Securities and Exchange Commission.

(k)Indemnification. No member of the Board or the Committee or any designated officer, Delegate or employee (each, an “Indemnified Person”) shall have any liability to any person (including, without limitation, any Participant) for any action, failure to act, determination or interpretation made in good faith with respect to this Plan or any Award granted hereunder. The Company shall indemnify an Indemnified Person for all costs and expenses and, to the fullest extent permitted by applicable law and the Company’s governing documents, any liability incurred in connection with defending against, responding to, negotiating for the settlement of or otherwise dealing with any claim, cause of action or dispute of any kind arising in connection with the administration of this Plan and the Awards granted hereunder.

(l)Unfunded Status of Plan. It is intended that this Plan constitute an “unfunded” plan. Neither the Company nor the Committee shall have any obligation to segregate assets or establish a trust or other arrangements to meet the obligations created under the Plan. Any liability of the Company to any Participant with respect to an Award shall be based solely upon contractual obligation created by the Plan and the Award Agreement. No such obligation shall be deemed to be secured by any pledge or encumbrance on the property of the Company.

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EX-18.1

Exhibit 18.1

April 28, 2021

Board of Directors

Comerica Incorporated

1717 Main Street, MC 6404

Dallas, Texas 75204

Ladies and Gentlemen:

Note 1 of the Notes to the Consolidated Financial Statements of Comerica Incorporated (the Company) included in its Quarterly Report on Form 10-Q for the three-month period ended March 31, 2021, describes changes in the Company’s method of accounting for determining the expected returns on the fixed income securities and private placement assets held within the plan assets of the qualified defined benefit plan. The changes in the method of computing expected returns on fixed income securities and private placement assets is from a method that utilizes a calculated value of fixed income securities and private placement assets and includes changes in the fair values of the fixed income securities and private placement assets over a period of five years to a method that includes the actual fair values of fixed income securities and private placement assets. There are no authoritative criteria for determining a “preferable” method of accounting for calculating the expected returns on plan assets based on the particular circumstances; however, we conclude that such a change in method of accounting is to an acceptable alternative method which, based on your business judgment to make this change and for the stated reason, is preferable in your circumstances. We have not conducted an audit in accordance with the standards of the Public Company Accounting Oversight Board (United States) of any financial statements of the Company as of any date or for any period subsequent to December 31, 2020, and therefore we do not express any opinion on any financial statements of the Company subsequent to that date.

Very truly yours,

/s/ Ernst & Young LLP

Dallas, Texas

EX-31.1

Exhibit 31.1

Chairman, President and CEO Rule 13a-14(a)/15d-14(a) Certification of Periodic Report (pursuant to Section 302 of the Sarbanes-Oxley Act of 2002)

CERTIFICATION OF PERIODIC REPORT

PURSUANT TO SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002

I, Curtis C. Farmer, certify that:

1.I have reviewed this report on Form 10-Q for the quarterly period ended March 31, 2021 of Comerica Incorporated (the “Registrant”);

2.Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations and cash flows of the Registrant as of, and for, the periods presented in this report;

4.The Registrant's other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15(d)-15(f)) for the Registrant and have:

(a)Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the Registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

(b)Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

(c)Evaluated the effectiveness of the Registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

(d)Disclosed in this report any change in the Registrant's internal control over financial reporting that occurred during the Registrant's most recent fiscal quarter (the Registrant's fourth fiscal quarter in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the Registrant's internal control over financial reporting; and

5.The Registrant's other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the Registrant's auditors and the audit committee of the Registrant's board of directors (or persons performing the equivalent functions):

(a)All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the Registrant's ability to record, process, summarize and report financial information; and

(b)Any fraud, whether or not material, that involves management or other employees who have a significant role in the Registrant's internal control over financial reporting.

Date:	April 28, 2021	/s/ Curtis C. Farmer
		Curtis C. Farmer
		Chairman, President and Chief Executive Officer

EX-31.2

Exhibit 31.2

Executive Vice President and CFO Rule 13a-14(a)/15d-14(a) Certification of Periodic Report (pursuant to Section 302 of the Sarbanes-Oxley Act of 2002)

CERTIFICATION OF PERIODIC REPORT

PURSUANT TO SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002

I, James J. Herzog, certify that:

1.I have reviewed this report on Form 10-Q for the quarterly period ended March 31, 2021 of Comerica Incorporated (the “Registrant”);

2.Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations and cash flows of the Registrant as of, and for, the periods presented in this report;

4.The Registrant's other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15(d)-15(f)) for the Registrant and have:

(a)Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the Registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

(b)Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

(c)Evaluated the effectiveness of the Registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

(d)Disclosed in this report any change in the Registrant's internal control over financial reporting that occurred during the Registrant's most recent fiscal quarter (the Registrant's fourth fiscal quarter in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the Registrant's internal control over financial reporting; and

5.The Registrant's other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the Registrant's auditors and the audit committee of the Registrant's board of directors (or persons performing the equivalent functions):

(a)All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the Registrant's ability to record, process, summarize and report financial information; and

(b)Any fraud, whether or not material, that involves management or other employees who have a significant role in the Registrant's internal control over financial reporting.

Date:	April 28, 2021	/s/ James J. Herzog
		James J. Herzog
		Executive Vice President and Chief Financial Officer

EX-32

Exhibit 32

Section 1350 Certification of Periodic Report (pursuant to Section 906 of the Sarbanes-Oxley Act of 2002)

CERTIFICATION OF PERIODIC REPORT

PURSUANT TO SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002

The undersigned, Curtis C. Farmer, Chairman, President and Chief Executive Officer, and James J. Herzog, Executive Vice President and Chief Financial Officer, of Comerica Incorporated (the “Company”), certify, pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, 18 U.S.C. Section 1350, that:

(1)the Quarterly Report on Form 10-Q of the Company for the quarterly period ended March 31, 2021 (the “Report”) fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m or 78o(d)); and

(2)the information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company.

Dated:	April 28, 2021	/s/ Curtis C. Farmer
		Curtis C. Farmer
		Chairman, President and Chief Executive Officer
		/s/ James J. Herzog
		James J. Herzog
		Executive Vice President and Chief Financial Officer

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Document And Entity Information - shares	3 Months Ended
	Mar. 31, 2021	Apr. 26, 2021
Document And Entity Information [Abstract]
Document Quarterly Report	true
Title of 12(b) Security	Common Stock, $5 par value
Entity Incorporation, State or Country Code	DE
Entity Tax Identification Number	38-1998421
Document Type	10-Q
Document Period End Date	Mar. 31, 2021
Amendment Flag	false
Entity Registrant Name	Comerica Incorporated
Entity Central Index Key	0000028412
Current Fiscal Year End Date	--12-31
Document Fiscal Year Focus	2021
Document Fiscal Period Focus	Q1
Entity Filer Category	Large Accelerated Filer
Entity Common Stock, Shares Outstanding		139,612,779
Entity File Number	1-10706
Entity Shell Company	false
Entity Emerging Growth Company	false
Entity Small Business	false
Entity Current Reporting Status	Yes
Entity Interactive Data Current	Yes
Entity Address, Address Line One	1717 Main Street, MC 6404
Entity Address, City or Town	Dallas
Entity Address, State or Province	TX
Entity Address, Postal Zip Code	75201
City Area Code	(214)
Local Phone Number	462-6831
Document Transition Report	false
Trading Symbol	CMA
Security Exchange Name	NYSE

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Consolidated Balance Sheets - USD ($) $ in Millions	Mar. 31, 2021		Dec. 31, 2020
ASSETS
Cash and due from banks	$ 1,064		$ 1,031
Interest-bearing deposits with banks	13,807		14,736
Other short-term investments	176		172
Investment securities available-for-sale	15,595		15,028
Commercial loans	30,886		32,753
Real estate construction loans	4,244		4,082
Commercial mortgage loans	9,993		9,912
Lease financing	577		594
International loans	990		926
Residential mortgage loans	1,799		1,830
Consumer loans	2,093		2,194
Total loans	50,582		52,291
Less allowance for loan losses	(777)		(948)
Net loans	49,805		51,343
Premises and equipment	456		459
Accrued income and other assets	5,388		5,360
Total assets	86,291		88,129
LIABILITIES AND SHAREHOLDERS' EQUITY
Noninterest-bearing deposits	38,822		39,420
Money market and interest-bearing checking deposits	29,880		28,540
Savings deposits	2,934		2,710
Customer certificates of deposit	2,141		2,133
Foreign office time deposits	30		66
Total interest-bearing deposits	34,985		33,449
Total deposits	73,807		72,869
Accrued expenses and other liabilities	1,480		1,482
Medium- and long-term debt	2,852		5,728
Total liabilities	78,139		80,079
Fixed rate reset non-cumulative perpetual preferred stock, series A, no par value, $100,000 liquidation preference per share: Authorized - 4,000 shares, Issued - 4,000 shares at 3/31/2021 and 12/31/2020	394		394
Common stock - $5 par value: Authorized - 325,000,000 shares; Issued - 228,164,824 shares	1,141		1,141
Capital surplus	2,183		2,185
Accumulated other comprehensive (loss) income	(105)	[1]	64
Retained earnings	9,975		9,727
Less cost of common stock in treasury - 89,579,635 shares at 3/31/21 and 88,997,430 shares at 12/31/20	(5,436)		(5,461)
Total shareholders' equity	8,152		8,050
Total liabilities and shareholders' equity	$ 86,291		$ 88,129

[1] Balances at beginning of period, net of tax and changes for the three months ended March 31, 2020 have been recast to reflect the retrospective application of the Corporation's election to change the accounting method for certain components of the qualified defined benefit pension plan as of January 1, 2021. Refer to Note 1 for further information.

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Consolidated Balance Sheets (Parenthetical) - $ / shares	Mar. 31, 2021	Dec. 31, 2020
Statement of Financial Position [Abstract]
Preferred Stock, No Par Value	$ 0
Preferred Stock, Shares Authorized	4,000
Preferred Stock, Shares Issued	4,000
Common stock, par value	$ 5	$ 5
Common stock, authorized shares	325,000,000	325,000,000
Common stock, issued shares	228,164,824	228,164,824
Shares in treasury	88,579,635	88,997,430

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Consolidated Statements Of Comprehensive Income - USD ($) $ in Millions		3 Months Ended
		Mar. 31, 2021	Mar. 31, 2020
INTEREST INCOME
Interest and fees on loans		$ 386	$ 517
Interest on investment securities		69	74
Interest on short-term investments		4	18
Total interest income		459	609
INTEREST EXPENSE
Interest on deposits		7	56
Interest on medium- and long-term debt	[1]	9	40
Total interest expense		16	96
Net interest income		443	513
Provision for credit losses		(182)	411
Net interest income after provision for credit losses		625	102
NONINTEREST INCOME
Card fees		71	59
Fiduciary income		53	54
Service charges on deposit accounts		48	49
Derivative income		30	20
Commercial lending fees		18	17
Bank-owned life insurance		11	12
Letter of credit fees		10	9
Brokerage fees		4	7
Net securities losses		0	(1)
Other noninterest income		25	11
Total noninterest income		270	237
NONINTEREST EXPENSES
Salaries and benefits expense		282	242
Outside processing fee expense		64	57
Occupancy expense		39	37
Software expense		39	37
Equipment expense		12	12
Advertising expense		6	7
FDIC insurance expense		6	8
Other noninterest expenses		(1)	17
Total noninterest expenses		447	417	[2]
Income (loss) before income taxes		448	(78)
Provision (benefit) for income taxes		98	(19)	[2]
Net income (loss)		350	(59)	[2]
Less income allocated to participating securities		1	0
Preferred stock dividends		6	0
Net income (loss) attributable to common shares		$ 343	$ (59)
Basic earnings (losses) per common share		$ 2.46	$ (0.42)
Diluted earnings (losses) per common share		$ 2.43	$ (0.42)
Comprehensive income		$ 181	$ 344
Cash dividends declared on common stock		$ 95	$ 94
Cash dividends declared per common share		$ 0.68	$ 0.68

[1] Includes the effects of hedging.

[2] See Defined Benefit Pension and Other Postretirement Costs in Note 1.

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Consolidated Statements Of Changes In Shareholders' Equity - USD ($) shares in Millions, $ in Millions	Total		Preferred Stock	Common Stock	Capital Surplus	Accumulated Other Comprehensive Income (Loss)	Retained Earnings	Treasury Stock
BALANCE (in shares) at Dec. 31, 2019				142.1
BALANCE at Dec. 31, 2019	$ 7,327			$ 1,141	$ 2,174	$ (316)	$ 9,619	$ (5,291)
Net income (loss)	(59)	[1]					(59)
Cumulative effect of change in accounting principle	13						13
Other comprehensive income (loss), net of tax	403					403
Cash dividends declared on common stock	(94)						(94)
Purchase of common stock	(195)							(195)
Purchase of common stock (in shares)				(3.4)
Net issuance of common stock under employee stock plans	(1)				(14)		(3)	16
Net issuance of common stock under employee stock plans (in shares)				0.3
Share-based compensation	8				8
BALANCE at Mar. 31, 2020	7,402			$ 1,141	2,168	87	9,476	(5,470)
BALANCE (in shares) at Mar. 31, 2020				139.0
BALANCE (in shares) at Dec. 31, 2020				139.2
BALANCE at Dec. 31, 2020	8,050		$ 394	$ 1,141	2,185	64	9,727	(5,461)
Net income (loss)	350						350
Other comprehensive income (loss), net of tax	(169)					(169)
Cash dividends declared on common stock	(95)						(95)
Cash dividends declared on preferred stock	(6)						(6)
Purchase of common stock	(3)							(3)
Purchase of common stock (in shares)				(0.1)
Net issuance of common stock under employee stock plans	3				(24)		(1)	28
Net issuance of common stock under employee stock plans (in shares)				0.5
Share-based compensation	22				22
BALANCE at Mar. 31, 2021	$ 8,152		$ 394	$ 1,141	$ 2,183	$ (105)	$ 9,975	$ (5,436)
BALANCE (in shares) at Mar. 31, 2021				139.6

[1] See Defined Benefit Pension and Other Postretirement Costs in Note 1.

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Consolidated Statements Of Changes In Shareholders' Equity (Parenthetical) - $ / shares	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020
Statement of Stockholders' Equity [Abstract]
Cash dividends declared on stock, per common share	$ 0.68	$ 0.68

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Consolidated Statements Of Cash Flows - USD ($) $ in Millions	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020
OPERATING ACTIVITIES
Net income (loss)	$ 350	$ (59)	[1]
Adjustments to reconcile net income (loss) to net cash provided by operating activities:
Provision for credit losses	(182)	411
Provision (benefit) for deferred income taxes	39	(71)
Depreciation and amortization	25	26
Net periodic defined benefit credit	(20)	(13)
Share-based compensation expense	22	8
Net amortization of securities	8	1
Net securities losses	0	1
Net change in accrued income receivable	(5)	8
Net change in accrued expenses payable	26	(12)
Other, net	(104)	399
Net cash provided by operating activities	159	699
INVESTING ACTIVITIES
Maturities and redemptions of investments securities available-for-sale	992	598
Purchases of investment securities available-for-sale	(1,750)	(920)
Net change in loans	1,685	(3,174)
Net increase in premises and equipment	(18)	(15)
Purchases of Federal Home Loan Bank stock	0	(31)
Redemptions of Federal Home Loan Bank stock	115	0
Proceeds from bank-owned life insurance settlements	5	8
Other, net	(21)	0
Net cash provided by (used in) investing activities	1,008	(3,534)
FINANCING ACTIVITIES
Net change in deposits	824	(29)
Net change in short-term borrowings	0	2,192
Maturities and redemptions of medium- and long-term debt	(2,800)	0
Preferred stock cash dividends paid	(6)	0
Repurchases of common stock	(8)	(199)
Cash dividends paid on common stock	(95)	(95)
Issuances of common stock under employee stock plans	10	3
Other, net	12	0
Net cash (used in) provided by financing activities	(2,063)	1,872
Net decrease in cash and cash equivalents	(896)	(963)
Cash and cash equivalents at beginning of period	15,767	5,818
Cash and cash equivalents at end of period	14,871	4,855
Interest paid	20	102
Income taxes paid	$ 1	$ 3

[1] See Defined Benefit Pension and Other Postretirement Costs in Note 1.

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Basis of Presentation and Accounting Policies

3 Months Ended

Mar. 31, 2021

Accounting Policies [Abstract]

Basis of Presentation and Accounting Policies

BASIS OF PRESENTATION AND ACCOUNTING POLICIES

Organization

The accompanying unaudited consolidated financial statements were prepared in accordance with United States (U.S.) generally accepted accounting principles (GAAP) for interim financial information and with the instructions to Form 10-Q and Article 10 of Regulation S-X. Accordingly, the statements do not include all of the information and footnotes required by GAAP for complete financial statements. In the opinion of management, all adjustments (consisting of normal recurring accruals) considered necessary for a fair presentation were included. The results of operations for the three months ended March 31, 2021 are not necessarily indicative of the results that may be expected for the year ending December 31, 2021. Certain items in prior periods were reclassified to conform to the current presentation. For further information, refer to the consolidated financial statements and footnotes thereto included in the Annual Report of Comerica Incorporated and Subsidiaries (the Corporation) on Form 10-K for the year ended December 31, 2020.

Defined Benefit Pension and Other Postretirement Costs

Effective January 1, 2021, the Corporation elected to change the accounting methodology for determining the market-related value of assets (MRVA) for certain classes of assets in the qualified defined benefit pension plan. The MRVA is used to calculate the Corporation's expected return on plan assets, a component of defined pension benefit cost (credit). These classes are currently comprised of the fixed income securities and private placement assets held in the portfolio, utilized by the Corporation to mitigate the impacts to financial results from changes in fair value of the pension liability. Previously, MRVA was measured using a historical five-year average fair value. Under the new methodology, the Corporation calculates MRVA using fair value of plan assets. Although both methods are permitted under U.S. GAAP, the Corporation believes the new policy is preferable for these classes of assets as it results in more timely recognition of the performance of pension assets in the results from operations.

The change in accounting methodology is applied retrospectively to all prior periods presented in the consolidated financial statements. The impact of the change to the qualified defined benefit plan on the Corporation's consolidated financial statements is as follows:

Consolidated Balance Sheets

	March 31, 2021		December 31, 2020
(in millions)	Accounting Change Impact		Previously Reported		Accounting Change Impact		Recast Amounts
Accumulated other comprehensive income (loss)	$	(3)	$	168	$	(104)	$	64
Retained earnings	3		9,623		104		9,727

Consolidated Statements of Comprehensive Income

	Three Months Ended March 31,
	2021		2020
(in millions)	Accounting Change Impact		Previously Reported		Accounting Change Impact		Recast Amounts
Other noninterest expenses	$	(5)	$	25	$	(8)	$	17
Provision (benefit) for income taxes	2		(21)		2		(19)
Net income (loss)	3		(65)		6		(59)
Earnings (losses) per common share
Basic	$	0.03	$	(0.46)	$	0.04	$	(0.42)
Diluted	$	0.02	$	(0.46)	$	0.04	$	(0.42)

Consolidated Statements of Cash Flows

	Three Months Ended March 31,
	2021		2020
(in millions)	Accounting Change Impact		Previously Reported		Accounting Change Impact		Recast Amounts
Net (loss) income	$	3	$	(65)	$	6	$	(59)
(Benefit) provision for deferred income taxes	2		(73)		2		(71)
Net periodic defined benefit credit	(5)		(5)		(8)		(13)

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Fair Value Measurements

3 Months Ended

Mar. 31, 2021

Fair Value Disclosures [Abstract]

Fair Value Measurements

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.

Investment securities available-for-sale, derivatives, deferred compensation plans and equity securities with readily determinable fair values (primarily money market mutual funds) 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.

Refer to Note 1 to the consolidated financial statements in the Corporation's Annual Report on Form 10-K for the year ended December 31, 2020 for further information about the fair value hierarchy, descriptions 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.

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 March 31, 2021 and December 31, 2020.

(in millions)	Total		Level 1		Level 2		Level 3
March 31, 2021
Deferred compensation plan assets	$	108	$	108	$	—	$	—
Equity securities	54		54		—		—
Investment securities available-for-sale:
U.S. Treasury and other U.S. government agency securities	4,613		4,613		—		—
Residential mortgage-backed securities (a)	10,982		—		10,982		—
Total investment securities available-for-sale	15,595		4,613		10,982		—
Derivative assets:
Interest rate contracts	340		—		316		24
Energy contracts	269		—		269		—
Foreign exchange contracts	12		—		12		—
Total derivative assets	621		—		597		24
Total assets at fair value	$	16,378	$	4,775	$	11,579	$	24
Derivative liabilities:
Interest rate contracts	$	65	$	—	$	65	$	—
Energy contracts	265		—		265		—
Foreign exchange contracts	10		—		10		—
Total derivative liabilities	340		—		340		—
Deferred compensation plan liabilities	108		108		—		—
Total liabilities at fair value	$	448	$	108	$	340	$	—
December 31, 2020
Deferred compensation plan assets	$	107	$	107	$	—	$	—
Equity securities	60		60		—		—
Investment securities available-for-sale:
U.S. Treasury and other U.S. government agency securities	4,658		4,658		—		—
Residential mortgage-backed securities (a)	10,370		—		10,370		—
Total investment securities available-for-sale	15,028		4,658		10,370		—
Derivative assets:
Interest rate contracts	531		—		492		39
Energy contracts	151		—		151		—
Foreign exchange contracts	18		—		18		—
Total derivative assets	700		—		661		39
Total assets at fair value	$	15,895	$	4,825	$	11,031	$	39
Derivative liabilities:
Interest rate contracts	$	61	$	—	$	61	$	—
Energy contracts	149		—		149		—
Foreign exchange contracts	19		—		19		—
Total derivative liabilities	229		—		229		—
Deferred compensation plan liabilities	107		107		—		—
Total liabilities at fair value	$	336	$	107	$	229	$	—

(a)Issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.

    There were no transfers of assets or liabilities recorded at fair value on a recurring basis into or out of Level 3 fair value measurements during each of the three-month periods ended March 31, 2021 and 2020.

The following table summarizes the changes in Level 3 assets and liabilities measured at fair value on a recurring basis for the three-month periods ended March 31, 2021 and 2020.

			Net Realized/Unrealized Gains (Losses) (Pretax) Recorded in Earnings (a)
	Balance at Beginning of Period								Balance at End of Period
							Sales
(in millions)			Realized		Unrealized
Three Months Ended March 31, 2021
Derivative assets:
Interest rate contracts	$	39	$	—	$	(15)	$	—	$	24
Three Months Ended March 31, 2020
Derivative assets:
Interest rate contracts	$	22	$	—	$	21	$	—	$	43

(a)Realized and unrealized gains and losses due to changes in fair value are recorded in other noninterest income on the Consolidated Statements of Comprehensive Income.

Assets and Liabilities Recorded at Fair Value on a Nonrecurring Basis

The Corporation may be required 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, and were recognized at fair value since it was less than cost at the end of the period.

The following table presents assets recorded at fair value on a nonrecurring basis at March 31, 2021 and December 31, 2020. No liabilities were recorded at fair value on a nonrecurring basis at March 31, 2021 and December 31, 2020.

(in millions)	Level 3
March 31, 2021
Loans:
Commercial	$	125
Commercial mortgage	12
Total loans	137
Other real estate	8
Total assets at fair value	$	145
December 31, 2020
Loans:
Commercial	$	134
Commercial mortgage	16
Total assets at fair value	$	150

Level 3 assets recorded at fair value on a nonrecurring basis at March 31, 2021 and December 31, 2020 included both nonaccrual loans and TDRs for which a specific allowance was established based on the fair value of collateral. The unobservable inputs were the additional adjustments applied by management to the appraised values to reflect such factors as non-current appraisals and revisions to estimated time to sell. These adjustments are determined based on qualitative judgments made by management on a case-by-case basis and are not quantifiable inputs, although they are used in the determination of fair value.

Estimated Fair Values of Financial Instruments Not Recorded at Fair Value 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:

	Carrying Amount		Estimated Fair Value
(in millions)			Total		Level 1		Level 2		Level 3
March 31, 2021
Assets
Cash and due from banks	$	1,064	$	1,064	$	1,064	$	—	$	—
Interest-bearing deposits with banks	13,807		13,807		13,807		—		—
Loans held-for-sale	14		14		—		14		—
Total loans, net of allowance for loan losses (a)	49,805		48,880		—		—		48,880
Customers’ liability on acceptances outstanding	13		13		13		—		—
Restricted equity investments	92		92		92		—		—
Nonmarketable equity securities (b)	7		9
Liabilities
Demand deposits (noninterest-bearing)	38,822		38,822		—		38,822		—
Interest-bearing deposits	32,844		32,844		—		32,844		—
Customer certificates of deposit	2,141		2,140		—		2,140		—
Total deposits	73,807		73,806		—		73,806		—
Acceptances outstanding	13		13		13		—		—
Medium- and long-term debt	2,852		2,919		—		2,919		—
Credit-related financial instruments	(50)		(50)		—		—		(50)
December 31, 2020
Assets
Cash and due from banks	$	1,031	$	1,031	$	1,031	$	—	$	—
Interest-bearing deposits with banks	14,736		14,736		14,736		—		—
Loans held-for-sale	5		5		—		5		—
Total loans, net of allowance for loan losses (a)	51,343		50,601		—		—		50,601
Customers’ liability on acceptances outstanding	1		1		1		—		—
Restricted equity investments	207		207		207		—		—
Nonmarketable equity securities (b)	5		9
Liabilities
Demand deposits (noninterest-bearing)	39,420		39,420		—		39,420		—
Interest-bearing deposits	31,316		31,316		—		31,316		—
Customer certificates of deposit	2,133		2,133		—		2,133		—
Total deposits	72,869		72,869		—		72,869		—
Acceptances outstanding	1		1		1		—		—
Medium- and long-term debt	5,728		5,790		—		5,790		—
Credit-related financial instruments	(68)		(68)		—		—		(68)

(a)Included $137 million and $150 million of loans recorded at fair value on a nonrecurring basis at March 31, 2021 and December 31, 2020, respectively.

(b)Certain investments that are measured at fair value using the net asset value have not been classified in the fair value hierarchy. The fair value amounts presented in the table are intended to permit reconciliation of the fair value hierarchy to the amounts presented in the Consolidated Balance Sheets.

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Investment Securities

3 Months Ended

Mar. 31, 2021

Investments, Debt and Equity Securities [Abstract]

Investment Securities

INVESTMENT SECURITIES

A summary of the Corporation’s investment securities follows:

(in millions)	Amortized Cost		Gross Unrealized Gains		Gross Unrealized Losses		Fair Value
March 31, 2021
Investment securities available-for-sale:
U.S. Treasury and other U.S. government agency securities	$	4,578	$	59	$	24	$	4,613
Residential mortgage-backed securities (a)	10,924		178		120		10,982
Total investment securities available-for-sale	$	15,502	$	237	$	144	$	15,595
December 31, 2020
Investment securities available-for-sale:
U.S. Treasury and other U.S. government agency securities	$	4,583	$	76	$	1	$	4,658
Residential mortgage-backed securities (a)	10,169		203		2		10,370
Total investment securities available-for-sale	$	14,752	$	279	$	3	$	15,028

(a)Issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.

A summary of the Corporation’s investment securities in an unrealized loss position as of March 31, 2021 and December 31, 2020 follows:

	Temporarily Impaired
	Less than 12 Months				12 Months or more				Total
(in millions)	Fair Value		Unrealized Losses		Fair Value		Unrealized Losses		Fair Value		Unrealized Losses
March 31, 2021
U.S. Treasury and other U.S. government agency securities	$	1,834	$	24	$	—	$	—	$	1,834	$	24
Residential mortgage-backed securities (a)	3,577		120		—		—		3,577		120
Total temporarily impaired securities	$	5,411	$	144	$	—	$	—	$	5,411	$	144
December 31, 2020
U.S. Treasury and other U.S. government agency securities	$	1,119	$	1	$	—	$	—	$	1,119	$	1
Residential mortgage-backed securities (a)	952		2		—		—		952		2
Total temporarily impaired securities	$	2,071	$	3	$	—	$	—	$	2,071	$	3

(a)Issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.

Unrealized losses resulted from changes in market interest rates and liquidity. The Corporation’s portfolio is comprised of securities issued or guaranteed by the U.S. government or government-sponsored enterprises. As such, it is expected that the securities would not be settled at a price less than the amortized cost of the investments. Further, the Corporation does not intend to sell the investments, and it is not more likely than not that it will be required to sell the investments before recovery of amortized costs. At March 31, 2021, the Corporation had 138 securities in an unrealized loss

position with no allowance for credit losses, comprised of 19 U.S. Treasury securities and 119 residential mortgage-backed

securities.

Interest receivable on investment securities totaled $19 million at March 31, 2021 and $18 million at December 31, 2020 and was included in accrued income and other assets on the Consolidated Balance Sheets.

Sales, calls and write-downs of investment securities available-for-sale resulted in the following losses recorded in net securities losses on the Consolidated Statements of Comprehensive Income, computed based on the adjusted cost of the specific security.

	Three Months Ended March 31,
(in millions)	2021		2020
Securities losses	$	—	$	(1)
Net securities losses	$	—	$	(1)

The following table summarizes the amortized cost and fair values of debt securities by contractual maturity. Securities with multiple maturity dates are classified in the period of final maturity. Expected maturities will differ from contractual maturities because borrowers may have the right to call or prepay obligations with or without call or prepayment penalties.

(in millions)
March 31, 2021	Amortized Cost		Fair Value
Contractual maturity
Within one year	$	1,617	$	1,634
After one year through five years	3,177		3,208
After five years through ten years	570		587
After ten years	10,138		10,166
Total investment securities	$	15,502	$	15,595

Included in the contractual maturity distribution in the table above were residential mortgage-backed securities with a total amortized cost of $10.9 billion and a fair value of $11.0 billion. The actual cash flows of mortgage-backed securities may differ as borrowers of the underlying loans may exercise prepayment options.

At March 31, 2021, investment securities with a carrying value of $4.7 billion were pledged where permitted or required by law, including $4.0 billion pledged to the Federal Home Loan Bank (FHLB) as collateral for potential future borrowings of approximately $3.9 billion and $648 million to secure $485 million of liabilities, primarily public and other deposits of state and local government agencies as well as derivative instruments. For information on FHLB borrowings, refer to Note 7.

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Credit Quality And Allowance For Credit Losses

3 Months Ended

Mar. 31, 2021

Credit Quality And Allowance For Credit Losses [Abstract]

Credit Quality And Allowance For Credit Losses

CREDIT QUALITY AND ALLOWANCE FOR CREDIT LOSSES

The following table presents an aging analysis of the amortized cost basis of loans.

	Loans Past Due and Still Accruing
(in millions)	30-59 Days		60-89  Days		90 Days or More		Total		Nonaccrual Loans		Current Loans (a)		Total  Loans
March 31, 2021
Business loans:
Commercial	$	103	$	57	$	17	$	177	$	230	$	30,479	$	30,886
Real estate construction:
Commercial Real Estate business line (b)	—		—		—		—		—		3,810		3,810
Other business lines (c)	9		8		2		19		1		414		434
Total real estate construction	9		8		2		19		1		4,224		4,244
Commercial mortgage:
Commercial Real Estate business line (b)	12		1		—		13		3		2,295		2,311
Other business lines (c)	40		25		21		86		31		7,565		7,682
Total commercial mortgage	52		26		21		99		34		9,860		9,993
Lease financing	14		—		1		15		1		561		577
International	—		2		—		2		—		988		990
Total business loans	178		93		41		312		266		46,112		46,690
Retail loans:
Residential mortgage	8		4		—		12		33		1,754		1,799
Consumer:
Home equity	5		4		—		9		15		1,546		1,570
Other consumer	10		—		19		29		—		494		523
Total consumer	15		4		19		38		15		2,040		2,093
Total retail loans	23		8		19		50		48		3,794		3,892
Total loans	$	201	$	101	$	60	$	362	$	314	$	49,906	$	50,582
December 31, 2020
Business loans:
Commercial	$	62	$	115	$	33	$	210	$	252	$	32,291	$	32,753
Real estate construction:
Commercial Real Estate business line (b)	31		—		—		31		—		3,626		3,657
Other business lines (c)	9		—		—		9		1		415		425
Total real estate construction	40		—		—		40		1		4,041		4,082
Commercial mortgage:
Commercial Real Estate business line (b)	51		1		—		52		3		2,218		2,273
Other business lines (c)	48		40		5		93		26		7,520		7,639
Total commercial mortgage	99		41		5		145		29		9,738		9,912
Lease financing	14		—		1		15		1		578		594
International	—		—		—		—		—		926		926
Total business loans	215		156		39		410		283		47,574		48,267
Retail loans:
Residential mortgage	11		4		—		15		47		1,768		1,830
Consumer:
Home equity	7		1		—		8		17		1,563		1,588
Other consumer	10		—		6		16		—		590		606
Total consumer	17		1		6		24		17		2,153		2,194
Total retail loans	28		5		6		39		64		3,921		4,024
Total loans	$	243	$	161	$	45	$	449	$	347	$	51,495	$	52,291

(a)Includes $87 million and $141 million of loans with deferred payments not considered past due in accordance with the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) at March 31, 2021 and December 31, 2020, respectively.

(b)Primarily loans to real estate developers.

(c)Primarily loans secured by owner-occupied real estate.

The following table presents loans by credit quality indicator (CQI) and vintage year. CQI is based on internal risk ratings assigned to each business loan at the time of approval and subjected to subsequent reviews, generally at least annually, and to pools of retail loans with similar risk characteristics. Vintage year is the year of origination or major modification.

	March 31, 2021
	Vintage Year
(in millions)	2021			2020			2019		2018		2017		Prior		Revolvers		Revolvers Converted to Term		Total
Business loans:
Commercial:
Pass (a)	$	1,632	(b)	$	5,073	(b)	$	2,191	$	1,445	$	944	$	1,061	$	16,601	$	16	$	28,963
Criticized (c)	30			41			217		173		86		211		1,163		2		1,923
Total commercial	1,662			5,114			2,408		1,618		1,030		1,272		17,764		18		30,886
Real estate construction
Pass (a)	44			604			1,206		1,142		571		426		183		—		4,176
Criticized (c)	—			3			29		17		8		9		2		—		68
Total real estate construction	44			607			1,235		1,159		579		435		185		—		4,244
Commercial mortgage
Pass (a)	398			2,107			1,587		1,161		1,062		2,858		399		—		9,572
Criticized (c)	3			31			63		43		33		232		16		—		421
Total commercial mortgage	401			2,138			1,650		1,204		1,095		3,090		415		—		9,993
Lease financing
Pass (a)	28			104			115		61		47		186		—		—		541
Criticized (c)	—			3			19		11		2		1		—		—		36
Total lease financing	28			107			134		72		49		187		—		—		577
International
Pass (a)	137			155			159		85		10		66		316		—		928
Criticized (c)	—			14			8		17		4		8		11		—		62
Total international	137			169			167		102		14		74		327		—		990
Total business loans	2,272			8,135			5,594		4,155		2,767		5,058		18,691		18		46,690
Retail loans:
Residential mortgage
Pass (a)	97			631			213		108		162		555		—		—		1,766
Criticized (c)	2			1			2		2		7		19		—		—		33
Total residential mortgage	99			632			215		110		169		574		—		—		1,799
Consumer:
Home equity
Pass (a)	—			—			—		—		—		16		1,474		58		1,548
Criticized (c)	—			—			—		—		—		—		16		6		22
Total home equity	—			—			—		—		—		16		1,490		64		1,570
Other consumer
Pass (a)	15			107			19		12		2		36		316		—		507
Criticized (c)	—			—			—		1		—		7		8		—		16
Total other consumer	15			107			19		13		2		43		324		—		523
Total consumer	15			107			19		13		2		59		1,814		64		2,093
Total retail loans	114			739			234		123		171		633		1,814		64		3,892
Total loans	$	2,386		$	8,874		$	5,828	$	4,278	$	2,938	$	5,691	$	20,505	$	82	$	50,582
Table continues on the following page.

	December 31, 2020
	Vintage Year
	2020			2019		2018		2017		2016		Prior		Revolvers		Revolvers Converted to Term		Total
Business loans:
Commercial:
Pass (a)	$	5,991	(b)	$	2,316	$	1,563	$	1,051	$	429	$	755	$	18,416	$	17	$	30,538
Criticized (c)	30			281		191		116		64		166		1,365		2		2,215
Total commercial	6,021			2,597		1,754		1,167		493		921		19,781		19		32,753
Real estate construction:
Pass (a)	433			1,080		1,244		631		335		141		171		—		4,035
Criticized (c)	3			28		5		8		—		1		2		—		47
Total real estate construction	436			1,108		1,249		639		335		142		173		—		4,082
Commercial mortgage:
Pass (a)	2,053			1,559		1,146		1,120		818		2,272		431		—		9,399
Criticized (c)	47			130		42		45		41		193		15		—		513
Total commercial mortgage	2,100			1,689		1,188		1,165		859		2,465		446		—		9,912
Lease financing
Pass (a)	109			122		71		50		14		201		—		—		567
Criticized (c)	2			17		5		2		1		—		—		—		27
Total lease financing	111			139		76		52		15		201		—		—		594
International
Pass (a)	274			161		103		11		3		64		245		—		861
Criticized (c)	13			8		18		4		7		2		13		—		65
Total international	287			169		121		15		10		66		258		—		926
Total business loans	8,955			5,702		4,388		3,038		1,712		3,795		20,658		19		48,267
Retail loans:
Residential mortgage
Pass (a)	639			230		119		197		196		398		—		—		1,779
Criticized (c)	7			2		2		6		2		32		—		—		51
Total residential mortgage	646			232		121		203		198		430		—		—		1,830
Consumer:
Home equity
Pass (a)	—			—		—		—		—		15		1,489		63		1,567
Criticized (c)	—			—		—		—		—		1		13		7		21
Total home equity	—			—		—		—		—		16		1,502		70		1,588
Other consumer
Pass (a)	113			23		12		2		3		41		404		—		598
Criticized (c)	—			—		2		—		—		—		6		—		8
Total other consumer	113			23		14		2		3		41		410		—		606
Total consumer	113			23		14		2		3		57		1,912		70		2,194
Total retail loans	759			255		135		205		201		487		1,912		70		4,024
Total loans	$	9,714		$	5,957	$	4,523	$	3,243	$	1,913	$	4,282	$	22,570	$	89	$	52,291

(a)Includes all loans not included in the categories of special mention, substandard or nonaccrual.

(b)Includes Small Business Administration Paycheck Protection Program (PPP) loans of $925 million and $2.9 billion in 2021 and 2020, respectively, at March 31, 2021, and PPP loans of $3.5 billion in 2020 at December 31, 2020.

(c)Includes loans with an internal rating of special mention, substandard loans for which the accrual of interest has not been discontinued and nonaccrual loans. Special mention loans have potential credit weaknesses that deserve management’s close attention, such as loans to borrowers who may be experiencing financial difficulties that may result in deterioration of repayment prospects from the borrower at some future date. Accruing substandard loans have a well-defined weakness, or weaknesses, such as loans to borrowers who may be experiencing losses from operations or inadequate liquidity of a degree and duration that jeopardizes the orderly repayment of the loan. Substandard loans are also distinguished by the distinct possibility of loss in the future if these weaknesses are not corrected. Nonaccrual loans are loans for which the accrual of interest has been discontinued. For further information regarding nonaccrual loans, refer to the Nonperforming Assets subheading in Note 1 - Basis of Presentation and Accounting Policies on page F-59 in the Corporation's 2020 Annual Report. These categories are generally consistent with the "special mention" and "substandard" categories as defined by regulatory authorities. A minority of nonaccrual loans are consistent with the "doubtful" category.

Loan interest receivable totaled $142 million and $141 million at March 31, 2021 and December 31, 2020, respectively, and was included in accrued income and other assets on the Consolidated Balance Sheets.

Allowance for Credit Losses

The following table details the changes in the allowance for credit losses.

	2021									2020
(in millions)	Business Loans			Retail Loans			Total			Business Loans			Retail Loans			Total
Three Months Ended March 31
Balance at beginning of period:
Allowance for loan losses	$	895		$	53		$	948		$	601		$	36		$	637
Allowance for credit losses on lending-related commitments	35			9			44			28			3			31
Allowance for credit losses	930			62			992			629			39			668
Cumulative effect of change in accounting principle	—			—			—			(42)			25			(17)
Loan charge-offs	(15)			(1)			(16)			(87)			(2)			(89)
Recoveries on loans previously charged-off	12			1			13			5			—			5
Net loan charge-offs	(3)			—			(3)			(82)			(2)			(84)
Provision for credit losses:
Provision for loan losses	(183)			15			(168)			384			(4)			380
Provision for credit losses on lending-related commitments	(13)			(1)			(14)			24			7			31
Provision for credit losses	(196)			14			(182)			408			3			411
Balance at end of period:
Allowance for loan losses	709			68			777			861			55			916
Allowance for credit losses on lending-related commitments	22			8			30			52			10			62
Allowance for credit losses	$	731		$	76		$	807		$	913		$	65		$	978
Allowance for loan losses as a percentage of total loans	1.52		%	1.74		%	1.54		%	1.75		%	1.35		%	1.71		%
Allowance for loan losses as a percentage of total loans excluding PPP loans	1.65			n/a			1.66			n/a			n/a			n/a
Allowance for credit losses as a percentage of total loans	1.57			1.94			1.59			1.85			1.57			1.83
Allowance for credit losses as a percentage of total loans excluding PPP loans	1.70			n/a			1.72			n/a			n/a			n/a

n/a - not applicable

Nonaccrual Loans

The following table presents additional information regarding nonaccrual loans. No interest income was recognized on nonaccrual loans for the three-month periods ended March 31, 2021 and 2020.

(in millions)	Nonaccrual Loans with No Related Allowance		Nonaccrual Loans with Related Allowance		Total Nonaccrual Loans
March 31, 2021
Business loans:
Commercial	$	50	$	180	$	230
Real estate construction:
Other business lines (a)	—		1		1
Commercial mortgage:
Commercial Real Estate business line (b)	1		2		3
Other business lines (a)	7		24		31
Total commercial mortgage	8		26		34
Lease financing	—		1		1
Total business loans	58		208		266
Retail loans:
Residential mortgage	33		—		33
Consumer:
Home equity	15		—		15
Total retail loans	48		—		48
Total nonaccrual loans	$	106	$	208	$	314
December 31, 2020
Business loans:
Commercial	$	57	$	195	$	252
Real estate construction:
Other business lines (a)	—		1		1
Commercial mortgage:
Commercial Real Estate business line (b)	1		2		3
Other business lines (a)	5		21		26
Total commercial mortgage	6		23		29
Lease financing	—		1		1
Total business loans	63		220		283
Retail loans:
Residential mortgage	47		—		47
Consumer:
Home equity	17		—		17
Total retail loans	64		—		64
Total nonaccrual loans	$	127	$	220	$	347

(a)Primarily loans secured by owner-occupied real estate.

(b)Primarily loans to real estate developers.

Foreclosed Properties

Foreclosed properties totaled $8 million at both March 31, 2021 and December 31, 2020. There were no retail loans secured by residential real estate properties in process of foreclosure included in nonaccrual loans at March 31, 2021 and December 31, 2020.

Troubled Debt Restructurings

The following table details the amortized cost basis at March 31, 2021 and 2020 of loans considered to be TDRs that were restructured during the three-month periods ended March 31, 2021 and 2020, by type of modification. In cases of loans with more than one type of modification, the loans were categorized based on the most significant modification.

	Principal Deferrals (a)
(in millions)	2021		2020
Three Months Ended March 31,
Commercial	$	—	$	22
Commercial mortgage:
Other business lines (b)	—		2
Total loans	$	—	$	24

(a)Primarily represents loan balances where terms were extended by more than an insignificant time period, typically more than 180 days, at or above contractual interest rates. Also includes commercial loans restructured in bankruptcy. In accordance with the provisions of the CARES Act, balances exclude $71 million, primarily retail loans, with terms extended by more than an insignificant time period.

(b)Primarily loans secured by owner-occupied real estate.

The Corporation charges interest on principal balances outstanding during deferral periods. Additionally, none of the modifications involved forgiveness of principal. There were no commitments to lend additional funds to borrowers whose terms have been modified in TDRs at March 31, 2021 and December 31, 2020. On an ongoing basis, the Corporation monitors the performance of modified loans to their restructured terms. The allowance for loan losses continues to be reassessed on the basis of an individual evaluation of the loan.

For principal deferrals, incremental deterioration in the credit quality of the loan, represented by a downgrade in the risk rating of the loan, for example, due to missed interest payments or a reduction of collateral value, is considered a subsequent default. For interest rate reductions, a subsequent payment default is defined in terms of delinquency, when a principal or interest payment is 90 days past due. Of the TDRs modified during the twelve-month periods ended March 31, 2021 and 2020, there were no subsequent defaults of principal deferrals or interest rate reductions in the three-month period ended March 31, 2021, compared to $10 million of principal deferrals and no interest rate reductions in the comparable period in 2020.

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Derivative And Credit-Related Financial Instruments

3 Months Ended

Mar. 31, 2021

Derivative Instruments and Hedging Activities Disclosure [Abstract]

Derivative And Credit-Related Financial Instruments

DERIVATIVE AND CREDIT-RELATED FINANCIAL INSTRUMENTS

In the normal course of business, the Corporation enters into various transactions involving derivative and credit-related financial instruments to manage exposure to fluctuations in interest rate, foreign currency and other market risks and to meet the financing needs of customers (customer-initiated derivatives). These financial instruments involve, to varying degrees, elements of market and credit risk. Market and credit risk are included in the determination of fair value.

Market risk is the potential loss that may result from movements in interest rates, foreign currency exchange rates or energy commodity prices that cause an unfavorable change in the value of a financial instrument. The Corporation manages this risk by establishing monetary exposure limits and monitoring compliance with those limits. Market risk inherent in interest rate and energy contracts entered into on behalf of customers is mitigated by taking offsetting positions, except in those circumstances when the amount, tenor and/or contract rate level results in negligible economic risk, whereby the cost of purchasing an offsetting contract is not economically justifiable. The Corporation mitigates most of the inherent market risk in foreign exchange contracts entered into on behalf of customers by taking offsetting positions and manages the remainder through individual foreign currency position limits and aggregate value-at-risk limits. These limits are established annually and positions are monitored quarterly. Market risk inherent in derivative instruments held or issued for risk management purposes is typically offset by changes in the fair value of the assets or liabilities being hedged.

Credit risk is the possible loss that may occur in the event of nonperformance by the counterparty to a financial instrument. The Corporation attempts to minimize credit risk arising from customer-initiated derivatives by evaluating the creditworthiness of each customer, adhering to the same credit approval process used for traditional lending activities and obtaining collateral as deemed necessary. Derivatives with dealer counterparties are either cleared through a clearinghouse or settled directly with a single counterparty. For derivatives settled directly with dealer counterparties, the Corporation utilizes counterparty risk limits and monitoring procedures as well as master netting arrangements and bilateral collateral agreements to facilitate the management of credit risk. Master netting arrangements effectively reduce credit valuation adjustments by permitting settlement of positive and negative positions and offset cash collateral held with the same counterparty on a net basis. Bilateral collateral agreements require daily exchange of cash or highly rated securities issued by the U.S. Treasury or other U.S. government entities to collateralize amounts due to either party. At March 31, 2021, counterparties with bilateral

collateral agreements deposited $11 million of cash with the Corporation to secure the fair value of contracts in an unrealized gain position, and the Corporation had pledged $29 million of marketable investment securities and posted $256 million of cash as collateral for contracts in an unrealized loss position. For those counterparties not covered under bilateral collateral agreements, collateral is obtained, if deemed necessary, based on the results of management’s credit evaluation of the counterparty. Collateral varies, but may include cash, investment securities, accounts receivable, equipment or real estate. Included in the fair value of derivative instruments are credit valuation adjustments reflecting counterparty credit risk. 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. There were no derivative instruments with credit-risk-related contingent features that were in a liability position at March 31, 2021.

Derivative Instruments

Derivative instruments utilized by the Corporation are negotiated over-the-counter and primarily include swaps, caps and floors, forward contracts and options, each of which may relate to interest rates, energy commodity prices or foreign currency exchange rates. Swaps are agreements in which two parties periodically exchange cash payments based on specified indices applied to a specified notional amount until a stated maturity. Caps and floors are agreements which entitle the buyer to receive cash payments based on the difference between a specified reference rate or price and an agreed strike rate or price, applied to a specified notional amount until a stated maturity. Forward contracts are over-the-counter agreements to buy or sell an asset at a specified future date and price. Options are similar to forward contracts except the purchaser has the right, but not the obligation, to buy or sell the asset during a specified period or at a specified future date.

Over-the-counter contracts are tailored to meet the needs of the counterparties involved and, therefore, contain a greater degree of credit risk and liquidity risk than exchange-traded contracts, which have standardized terms and readily available price information. The Corporation reduces exposure to market and liquidity risks from over-the-counter derivative instruments entered into for risk management purposes, and transactions entered into to mitigate the market risk associated with customer-initiated transactions, by taking offsetting positions with investment grade domestic and foreign financial institutions and subjecting counterparties to credit approvals, limits and collateral monitoring procedures similar to those used in making other extensions of credit. In addition, certain derivative contracts executed bilaterally with a dealer counterparty in the over-the-counter market are cleared through a clearinghouse, whereby the clearinghouse becomes the counterparty to the transaction.

The following table presents the composition of the Corporation’s derivative instruments held or issued for risk management purposes or in connection with customer-initiated and other activities at March 31, 2021 and December 31, 2020.

	March 31, 2021						December 31, 2020
			Fair Value						Fair Value
(in millions)	Notional/ Contract Amount (a)		Gross Derivative Assets		Gross Derivative Liabilities		Notional/ Contract Amount (a)		Gross Derivative Assets		Gross Derivative Liabilities
Risk management purposes
Derivatives designated as hedging instruments
Interest rate contracts:
Swaps - fair value - receive fixed/pay floating	$	2,650	$	—	$	—	$	2,650	$	—	$	—
Swaps - cash flow - receive fixed/pay floating	5,550		—		—		5,550		—		—
Derivatives used as economic hedges
Foreign exchange contracts:
Spot, forwards and swaps	390		1		1		442		1		4
Total risk management purposes	8,590		1		1		8,642		1		4
Customer-initiated and other activities
Interest rate contracts:
Caps and floors written	909		—		2		869		—		—
Caps and floors purchased	909		2		—		869		—		—
Swaps	19,693		338		63		19,783		531		61
Total interest rate contracts	21,511		340		65		21,521		531		61
Energy contracts:
Caps and floors written	665		1		60		503		1		33
Caps and floors purchased	665		60		1		503		33		1
Swaps	2,873		208		204		2,115		117		115
Total energy contracts	4,203		269		265		3,121		151		149
Foreign exchange contracts:
Spot, forwards, options and swaps	1,429		11		9		1,901		17		15
Total customer-initiated and other activities	27,143		620		339		26,543		699		225
Total gross derivatives	$	35,733	$	621	$	340	$	35,185	$	700	$	229
Amounts offset in the Consolidated Balance Sheets:
Netting adjustment - Offsetting derivative assets/liabilities			(59)		(59)				(83)		(83)
Netting adjustment - Cash collateral received/posted			(2)		(227)				(17)		(48)
Net derivatives included in the Consolidated Balance Sheets (b)			560		54				600		98
Amounts not offset in the Consolidated Balance Sheets:
Marketable securities pledged under bilateral collateral agreements			—		(26)				—		(42)
Net derivatives after deducting amounts not offset in the Consolidated Balance Sheets			$	560	$	28			$	600	$	56

(a)Notional or contractual amounts, which represent the extent of involvement in the derivatives market, are used to determine the contractual cash flows required in accordance with the terms of the agreement. These amounts are typically not exchanged, significantly exceed amounts subject to credit or market risk and are not reflected in the Consolidated Balance Sheets.

(b)Net derivative assets are included in accrued income and other assets and net derivative liabilities are included in accrued expenses and other liabilities on the Consolidated Balance Sheets. Included in the fair value of net derivative assets and net derivative liabilities are credit valuation adjustments reflecting counterparty credit risk and credit risk of the Corporation. The fair value of net derivative assets included credit valuation adjustments for counterparty credit risk of $16 million and $27 million at March 31, 2021 and December 31, 2020, respectively.

Risk Management

The Corporation's derivative instruments used for managing interest rate risk include cash flow hedging strategies that convert variable-rate loans to fixed rates and fair value hedging strategies that convert fixed-rate long-term debt to variable rates. Interest and fees on loans included $24 million and $3 million of cash flow hedge income for the three-month periods ended March 31, 2021 and 2020, respectively.

The following table details the effects of fair value hedging on the Consolidated Statements of Comprehensive Income.

	Interest on Medium- and Long-Term Debt
	Three Months Ended March 31,
(in millions)	2021		2020
Total interest on medium- and long-term debt (a)	$	9	$	40
Fair value hedging relationships:
Interest rate contracts:
Hedged items	25		30
Derivatives designated as hedging instruments	(17)		(6)

(a) Includes the effects of hedging.

    For information on accumulated net gains on cash flow hedges, refer to Note 8.

    The following table summarizes the expected weighted average remaining maturity of the notional amount of risk management interest rate swaps, the carrying amount of the related hedged items and the weighted average interest rates associated with amounts expected to be received or paid on interest rate swap agreements as of March 31, 2021 and December 31, 2020.

Cash flow swaps - receive fixed/pay floating rate on variable-rate loans

(dollar amounts in millions)	March 31, 2021			December 31, 2020
Derivative notional amount	$	5,550		$	5,550
Weighted average:
Remaining maturity (in years)	2.0			2.3
Receive rate	1.87		%	1.87		%
Pay rate (a)	0.12			0.15

(a)Variable rates paid on receive fixed swaps designated as cash flow hedges are based on one-month LIBOR rates in effect at March 31, 2021 and December 31, 2020.

Fair value swaps - receive fixed/pay floating rate on medium- and long-term debt

(dollar amounts in millions)	March 31, 2021			December 31, 2020
Derivative notional amount	$	2,650		$	2,650
Carrying value of hedged items (a)	2,852			2,928
Weighted average:
Remaining maturity (in years)	4.4			4.6
Receive rate	3.68		%	3.68		%
Pay rate (b)	1.10			1.16

(a)Included $202 million and $279 million of cumulative hedging adjustments at March 31, 2021 and December 31, 2020, respectively, which included $5 million and $6 million, respectively, of hedging adjustment on a discontinued hedging relationship.

(b)Variable rates paid on receive fixed swaps designated as fair value hedges are based on one- and six-month LIBOR rates in effect at March 31, 2021 and December 31, 2020.

Customer-Initiated and Other

The Corporation enters into derivative transactions at the request of customers and generally takes offsetting positions with dealer counterparties to mitigate the inherent market risk. Income primarily results from the spread between the customer derivative and the offsetting dealer position.

For customer-initiated foreign exchange contracts where offsetting positions have not been taken, the Corporation manages the remaining inherent market risk through individual foreign currency position limits and aggregate value-at-risk limits. These limits are established annually and reviewed quarterly. For those customer-initiated derivative contracts which

were not offset or where the Corporation holds a position within the limits described above, the Corporation did not recognize any gains or losses for both the three-month periods ended March 31, 2021 and 2020.

Fair values of customer-initiated and other derivative instruments represent the net unrealized gains or losses on such contracts and are recorded on the Consolidated Balance Sheets. Changes in fair value are recognized on the Consolidated Statements of Comprehensive Income. The net gains recognized in income on customer-initiated derivative instruments, net of the impact of offsetting positions included in derivative income, were as follows:

	Three Months Ended March 31,
(in millions)	2021		2020
Interest rate contracts	$	15	$	8
Energy contracts	4		1
Foreign exchange contracts	11		11
Total derivative income	$	30	$	20

Credit-Related Financial Instruments

The Corporation issues off-balance sheet financial instruments in connection with commercial and consumer lending activities. The Corporation’s credit risk associated with these instruments is represented by the contractual amounts indicated in the following table.

(in millions)	March 31, 2021		December 31, 2020
Unused commitments to extend credit:
Commercial and other	$	24,598	$	23,443
Bankcard, revolving check credit and home equity loan commitments	3,322		3,297
Total unused commitments to extend credit	$	27,920	$	26,740
Standby letters of credit	$	3,278	$	3,273
Commercial letters of credit	40		30

The Corporation maintains an allowance to cover current expected credit losses inherent in lending-related commitments, including unused commitments to extend credit, letters of credit and financial guarantees. The allowance for credit losses on lending-related commitments, included in accrued expenses and other liabilities on the Consolidated Balance Sheets, was $30 million and $44 million at March 31, 2021 and December 31, 2020, respectively.

Unused Commitments to Extend Credit

Commitments to extend credit are legally binding agreements to lend to a customer, provided there is no violation of any condition established in the contract. These commitments generally have fixed expiration dates or other termination clauses and may require payment of a fee. Since many commitments expire without being drawn upon, the total contractual amount of commitments does not necessarily represent future cash requirements of the Corporation. Commercial and other unused commitments are primarily variable rate commitments. The allowance for credit losses on lending-related commitments included $25 million at March 31, 2021 and $37 million at December 31, 2020 for expected credit losses inherent in the Corporation’s unused commitments to extend credit.

Standby and Commercial Letters of Credit

Standby letters of credit represent conditional obligations of the Corporation which guarantee the performance of a customer to a third party. Standby letters of credit are primarily issued to support public and private borrowing arrangements, including commercial paper, bond financing and similar transactions. Commercial letters of credit are issued to finance foreign or domestic trade transactions. These contracts expire in decreasing amounts through the year 2028. The Corporation may enter into participation arrangements with third parties that effectively reduce the maximum amount of future payments which may be required under standby and commercial letters of credit. There were $3.3 billion standby and commercial letters of credit outstanding at both March 31, 2021 and December 31, 2020, of which these risk participations covered $149 million and $150 million, respectively.

The carrying value of the Corporation’s standby and commercial letters of credit, included in accrued expenses and other liabilities on the Consolidated Balance Sheets, totaled $25 million at March 31, 2021, including $20 million in deferred fees and $5 million in the allowance for credit losses on lending-related commitments. At December 31, 2020, the comparable amounts were $31 million, $24 million and $7 million, respectively.

The following table presents a summary of criticized standby and commercial letters of credit at March 31, 2021 and December 31, 2020. The Corporation's criticized list is generally consistent with the Special Mention, Substandard and

Doubtful categories defined by regulatory authorities. The Corporation manages credit risk through underwriting, periodically reviewing and approving its credit exposures using Board committee approved credit policies and guidelines.

(dollar amounts in millions)	March 31, 2021			December 31, 2020
Total criticized standby and commercial letters of credit	$	54		$	73
As a percentage of total outstanding standby and commercial letters of credit	1.6		%	2.2		%

Other Credit-Related Financial Instruments

The Corporation enters into credit risk participation agreements, under which the Corporation assumes credit exposure associated with a borrower’s performance related to certain interest rate derivative contracts. The Corporation is not a party to the interest rate derivative contracts and only enters into these credit risk participation agreements in instances in which the Corporation is also a party to the related loan participation agreements for such borrowers. The Corporation manages its credit risk on the credit risk participation agreements by monitoring the creditworthiness of the borrowers, which is based on the normal credit review process as if the Corporation had entered into the derivative instruments directly with the borrowers. The notional amount of such credit risk participation agreements reflects the pro-rata share of the derivative instrument, consistent with its share of the related participated loan. As of March 31, 2021 and December 31, 2020, the total notional amount of the credit risk participation agreements was approximately $1.0 billion and $1.1 billion, respectively, and the fair value was $1 million at March 31, 2021 and $3 million at December 31, 2020. The maximum estimated exposure to these agreements, as measured by projecting a maximum value of the guaranteed derivative instruments, assuming 100 percent default by all obligors on the maximum values, was $40 million and $62 million at March 31, 2021 and December 31, 2020, respectively. In the event of default, the lead bank has the ability to liquidate the assets of the borrower, in which case the lead bank would be required to return a percentage of the recouped assets to the participating banks. As of March 31, 2021, the weighted average remaining maturity of outstanding credit risk participation agreements was 4.4 years.

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Variable Interest Entities (VIEs)

3 Months Ended

Mar. 31, 2021

Variable Interest Entity, Not Primary Beneficiary, Disclosures [Abstract]

Variable Interest Entities (VIEs)

VARIABLE INTEREST ENTITIES (VIEs)

The Corporation evaluates its interest in certain entities to determine if these entities meet the definition of a VIE and whether the Corporation is the primary beneficiary and should consolidate the entity based on the variable interests it held both at inception and when there is a change in circumstances that requires a reconsideration.

The Corporation holds ownership interests in funds in the form of limited partnerships or limited liability companies (LLCs) investing in affordable housing projects that qualify for the low-income housing tax credit (LIHTC). The Corporation also directly invests in limited partnerships and LLCs which invest in community development projects, which generate similar tax credits to investors (other tax credit entities). As an investor, the Corporation obtains income tax credits and deductions from the operating losses of these tax credit entities. These tax credit entities meet the definition of a VIE; however, the Corporation is not the primary beneficiary of the entities, as the general partner or the managing member has both the power to direct the activities that most significantly impact the economic performance of the entities and the obligation to absorb losses or the right to receive benefits that could be significant to the entities.

The Corporation accounts for its interests in LIHTC entities using the proportional amortization method. Ownership interests in other tax credit entities are accounted for under either the cost or equity method. Exposure to loss as a result of the Corporation's involvement in LIHTC entities and other tax credit entities at March 31, 2021 was limited to $458 million and $12 million, respectively.

Investment balances, including all legally binding commitments to fund future investments, are included in accrued income and other assets on the Consolidated Balance Sheets. A liability is recognized in accrued expenses and other liabilities on the Consolidated Balance Sheets for all legally binding unfunded commitments to fund tax credit entities ($173 million at March 31, 2021). Amortization and other write-downs of LIHTC investments are presented on a net basis as a component of the provision for income taxes on the Consolidated Statements of Comprehensive Income, while amortization and write-downs of other tax credit investments are recorded in other noninterest income. The income tax credits and deductions are recorded as a reduction of income tax expense and a reduction of federal income taxes payable.

The Corporation provided no financial or other support that was not contractually required to any of the above VIEs during the three months ended March 31, 2021 and 2020.

The following table summarizes the impact of these tax credit entities on the Corporation’s Consolidated Statements of Comprehensive Income.

	Three Months Ended March 31,
(in millions)	2021		2020
Provision for income taxes:
Amortization of LIHTC investments	$	17	$	17
Low income housing tax credits	(16)		(16)
Other tax benefits related to tax credit entities	(4)		(4)
Total provision for income taxes	$	(3)	$	(3)

For further information on the Corporation’s consolidation policy, see Note 1 to the consolidated financial statements in the Corporation's 2020 Annual Report.

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Medium- And Long-Term Debt

3 Months Ended

Mar. 31, 2021

Debt Disclosure [Abstract]

Medium- And Long-Term Debt

MEDIUM- AND LONG-TERM DEBT

Medium- and long-term debt is summarized as follows:

(in millions)	March 31, 2021		December 31, 2020
Parent company
Subordinated notes:
3.80% subordinated notes due 2026 (a)	$	270	$	280
Medium- and long-term notes:
3.70% notes due 2023 (a)	898		905
4.00% notes due 2029 (a)	597		633
Total medium- and long-term notes	1,495		1,538
Total parent company	1,765		1,818
Subsidiaries
Subordinated notes:
4.00% subordinated notes due 2025 (a)	371		380
7.875% subordinated notes due 2026 (a)	199		207
Total subordinated notes	570		587
Medium- and long-term notes:
2.50% notes due 2024 (a)	517		523
Total medium- and long-term notes	517		523
FHLB advances:
Floating-rate based on FHLB auction rate due 2026	—		2,800
Total FHLB advances	—		2,800
Total subsidiaries	1,087		3,910
Total medium- and long-term debt	$	2,852	$	5,728

(a)The fixed interest rates on these notes have been swapped to a variable rate and designated in a hedging relationship. Accordingly, carrying value has been adjusted to reflect the change in the fair value of the debt as a result of changes in the benchmark rate.

    Subordinated notes with remaining maturities greater than one year qualify as Tier 2 capital.

    Comerica Bank (the Bank), a wholly-owned subsidiary of the Corporation, is a member of the FHLB, which provides short-and long-term funding to its members through advances collateralized by real estate-related assets. The interest rates on the FHLB advances resets between four and eight weeks, based on the FHLB auction rate. Each note may be prepaid in full, without penalty, at each scheduled reset date. The Bank held no outstanding long-term advances at March 31, 2021. Borrowing capacity is contingent on the amount of collateral available to be pledged to the FHLB. At March 31, 2021, $18.6 billion of real estate-related loans and $4.0 billion of investment securities were pledged to the FHLB as collateral with capacity for potential future borrowings of approximately $13.9 billion.

    Unamortized debt issuance costs deducted from the carrying amount of medium- and long-term debt totaled $9 million at March 31, 2021 and $10 million at December 31, 2020.

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Accumulated Other Comprehensive Income (Loss)

3 Months Ended

Mar. 31, 2021

Accumulated Other Comprehensive Income (Loss), Net of Tax [Abstract]

Accumulated Other Comprehensive Loss

ACCUMULATED OTHER COMPREHENSIVE (LOSS) INCOME

The following table presents a reconciliation of the changes in the components of accumulated other comprehensive (loss) income and details the components of other comprehensive (loss) income for the three months ended March 31, 2021 and 2020, including the amount of income tax expense (benefit) allocated to each component of other comprehensive (loss) income.

	Three Months Ended March 31,
(in millions)	2021		2020
Accumulated net unrealized gains on investment securities:
Balance at beginning of period, net of tax	$	211	$	65
Net unrealized holding (losses) gains arising during the period	(183)		323
Less: (Benefit) provision for income taxes	(43)		76
Change in net unrealized gains on investment securities, net of tax	(140)		247
Balance at end of period, net of tax	$	71	$	312
Accumulated net gains on cash flow hedges:
Balance at beginning of period, net of tax	$	155	$	34
Net cash flow hedge (losses) gains arising during the period	(18)		205
Less: (Benefit) provision for income taxes	(4)		48
Change in net cash flow hedge (losses) gains arising during the period, net of tax	(14)		157
Less:
Net cash flow hedge gains included in interest and fees on loans	24		3
Less: Provision for income taxes	6		1
Reclassification adjustment for net cash flow hedge gains included in net income, net of tax	18		2
Change in net cash flow hedge (losses) gains, net of tax	(32)		155
Balance at end of period, net of tax (a)	$	123	$	189
Accumulated defined benefit pension and other postretirement plans adjustment:
Balance at beginning of period, net of tax (b)	$	(302)	$	(415)
Actuarial loss arising during the period (b)	—		(3)
Less: Benefit for income taxes (b)	—		(1)
Net defined benefit pension and other postretirement plans adjustment arising during the period, net of tax (b)	—		(2)
Amounts recognized in other noninterest expenses:
Amortization of actuarial net loss (b)	10		11
Amortization of prior service credit	(6)		(7)
Total amounts recognized in other noninterest expenses (b)	4		4
Less: Provision for income taxes (b)	1		1
Adjustment for amounts recognized as components of net periodic benefit cost during the period, net of tax (b)	3		3
Change in defined benefit pension and other postretirement plans adjustment, net of tax (b)	3		1
Balance at end of period, net of tax (b)	$	(299)	$	(414)
Total accumulated other comprehensive (loss) income at end of period, net of tax (b)	$	(105)	$	87

(a)The Corporation expects to reclassify $67 million of gains, net of tax, from accumulated other comprehensive income to earnings over the next twelve months if interest yield curves and notional amounts remain at March 31, 2021 levels.

(b)Balances at beginning of period, net of tax and changes for the three months ended March 31, 2020 have been recast to reflect the retrospective application of the Corporation's election to change the accounting method for certain components of the qualified defined benefit pension plan as of January 1, 2021. Refer to Note 1 for further information.

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Net Income (Loss) Per Common Share

3 Months Ended

Mar. 31, 2021

Earnings Per Share [Abstract]

Net Income (Loss) Per Common Share

NET INCOME (LOSS) PER COMMON SHARE

Basic and diluted net income (loss) per common share are presented in the following table.

	Three Months Ended March 31,
(in millions, except per share data)	2021		2020
Basic and diluted
Net income (loss)	$	350	$	(59)
Less:
Income allocated to participating securities	1		—
Preferred stock dividends	6		—
Net income (loss) attributable to common shares	$	343	$	(59)
Basic average common shares	140		141
Basic net income (loss) per common share	$	2.46	$	(0.42)
Basic average common shares	140		141
Dilutive common stock equivalents:
Net effect of the assumed exercise of stock awards	1		—
Diluted average common shares	141		141
Diluted net income (loss) per common share	$	2.43	$	(0.42)

The following average shares related to outstanding options to purchase shares of common stock were not included in the computation of diluted net income (loss) per common share because the exercise price was greater than the average market price of common shares for the period.

	Three Months Ended March 31,
(average outstanding options in thousands)	2021	2020
Average outstanding options	782	1,210
Range of exercise prices	67.53 - 95.25	56.79 - 95.25

Due to the net loss attributable to common shares reported for the three months ended March 31, 2020, stock awards representing 2.6 million shares of common stock were excluded from the computation of diluted net loss per share, as their inclusion would have been anti-dilutive.

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Employee Benefit Plans

3 Months Ended

Mar. 31, 2021

Defined Benefit Plans and Other Postretirement Benefit Plans Disclosures [Abstract]

Employee Benefit Plans

EMPLOYEE BENEFIT PLANS

Net periodic defined benefit cost (credit) is comprised of service cost and other components of net benefit cost (credit). Service cost is included in salaries and benefits expense and other components of net benefit cost (credit) are included in other noninterest expenses on the Consolidated Statements of Comprehensive Income. For further information on the Corporation's employee benefit plans, refer to Note 17 to the consolidated financial statements in the Corporation's 2020 Annual Report.

The components of net periodic benefit cost (credit) for the Corporation's qualified pension plan, non-qualified pension plan and postretirement benefit plan are as follows.

Qualified Defined Benefit Pension Plan	Three Months Ended March 31,
(in millions)	2021		2020 (a)
Service cost	$	10	$	8
Other components of net benefit credit:
Interest cost	15		18
Expected return on plan assets	(50)		(46)
Amortization of prior service credit	(5)		(5)
Amortization of net loss	7		9
Total other components of net benefit credit	(33)		(24)
Net periodic defined benefit credit	$	(23)	$	(16)

(a)Expected return on plan assets increased $3 million and amortization of net loss was reduced by $5 million to reflect the retrospective application of the Corporation's election to change the accounting method for certain components of the qualified defined benefit pension plan as of January 1, 2021, resulting in an increase of $8 million to total other components of net benefit credit. Refer to Note 1 for further information.

Non-Qualified Defined Benefit Pension Plan	Three Months Ended March 31,
(in millions)	2021		2020
Service cost	$	—	$	1
Other components of net benefit cost:
Interest cost	2		2
Amortization of prior service credit	(1)		(2)
Amortization of net loss	3		2
Total other components of net benefit cost	4		2
Net periodic defined benefit cost	$	4	$	3

Postretirement Benefit Plan	Three Months Ended March 31,
(in millions)	2021		2020
Other components of net benefit credit:
Expected return on plan assets	$	(1)	$	—
Net periodic defined benefit credit	$	(1)	$	—

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Income Taxes And Tax-Related Items

3 Months Ended

Mar. 31, 2021

Income Tax Disclosure [Abstract]

Income Taxes and Tax-Related Items

INCOME TAXES AND TAX-RELATED ITEMS

At March 31, 2021, net unrecognized tax benefits were $20 million, compared to $19 million at December 31, 2020. The Corporation anticipates that it is reasonably possible that final settlement of federal and state tax issues will result in a change in net unrecognized tax benefits of $6 million within the next twelve months. Included in accrued expenses and other liabilities on the Consolidated Balance Sheets was a liability for tax-related interest and penalties of $6 million at both March 31, 2021 and December 31, 2020.

Net deferred tax assets were $15 million at March 31, 2021, compared to $4 million at December 31, 2020, primarily driven by decreases to deferred tax liabilities related to unrealized losses on investment securities available-for-sale as well as net hedging gains that were partially offset by decreases to deferred tax assets related to the allowance for loan losses and increases to deferred tax liabilities related to defined benefit plans. These were partially offset by increases to deferred tax assets related to defined benefit plan components of OCI. Included in deferred tax assets at both March 31, 2021 and December 31, 2020 were $3 million of state net operating loss carryforwards, which expire between 2021 and 2030. The Corporation believes that it is more likely than not that the benefit from certain of these state net operating loss carryforwards will not be realized and, accordingly, maintained a valuation allowance of $3 million at both March 31, 2021 and December 31, 2020. The determination regarding valuation allowance was based on evidence of loss carryback capacity, projected future

reversals of existing taxable temporary differences to absorb the deferred tax assets and assumptions made regarding future events.

In the ordinary course of business, the Corporation enters into certain transactions that have tax consequences. From time to time, the Internal Revenue Service (IRS) or other tax jurisdictions may review and/or challenge specific interpretive tax positions taken by the Corporation with respect to those transactions. The Corporation believes its tax returns were filed based upon applicable statutes, regulations and case law in effect at the time of the transactions. The IRS or other tax jurisdictions, an administrative authority or a court, if presented with the transactions, could disagree with the Corporation’s interpretation of the tax law.

Based on current knowledge and probability assessment of various potential outcomes, the Corporation believes that current tax reserves are adequate, and the amount of any potential incremental liability arising is not expected to have a material adverse effect on the Corporation’s consolidated financial condition or results of operations. Probabilities and outcomes are reviewed as events unfold, and adjustments to the reserves are made when necessary.

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Contingent Liabilities

3 Months Ended

Mar. 31, 2021

Commitments and Contingencies Disclosure [Abstract]

Contingent Liabilities

CONTINGENT LIABILITIES

Legal Proceedings

As previously reported in the Corporation's Form 10-K for the year ended December 31, 2020, the Bank is appealing a court's decision in Butte Local Development v. Masters Group v. Comerica Bank, for lender liability. Management believes that current reserves related to this case are adequate in the event of an adverse outcome.

The Corporation and certain of its subsidiaries are subject to various other pending or threatened legal proceedings arising out of the normal course of business or operations. The Corporation believes it has meritorious defenses to the claims asserted against it in its other currently outstanding legal proceedings and, with respect to such legal proceedings, intends to continue to defend itself vigorously, litigating or settling cases according to management’s judgment as to what is in the best interests of the Corporation and its shareholders. Settlement may result from the Corporation's determination that it may be more prudent financially to settle, rather than litigate, and should not be regarded as an admission of liability. On at least a quarterly basis, the Corporation assesses its potential liabilities and contingencies in connection with outstanding legal proceedings utilizing the latest information available. On a case-by-case basis, reserves are established for those legal claims for which it is probable that a loss will be incurred either as a result of a settlement or judgment, and the amount of such loss can be reasonably estimated. The actual costs of resolving these claims may be substantially higher or lower than the amounts reserved. Based on current knowledge, and after consultation with legal counsel, management believes current reserves are adequate, and the amount of any incremental liability arising from these matters is not expected to have a material adverse effect on the Corporation’s consolidated financial condition, results of operations or cash flows. Legal fees of $2 million were included in other noninterest expenses on the Consolidated Statements of Comprehensive Income for both the three-month periods ended March 31, 2021 and 2020, respectively.

For matters where a loss is not probable, the Corporation has not established legal reserves. The Corporation believes the estimate of the aggregate range of reasonably possible losses, in excess of reserves established, for all legal proceedings in which it is involved is from zero to approximately $94 million at March 31, 2021. This estimated aggregate range of reasonably possible losses is based upon currently available information for those proceedings in which the Corporation is involved, taking into account the Corporation’s best estimate of such losses for those cases for which such estimate can be made. For certain cases, the Corporation does not believe that an estimate can currently be made. The Corporation’s estimate involves significant judgment, given the varying stages of the proceedings (including the fact many are currently in preliminary stages), the existence in certain proceedings of multiple defendants (including the Corporation) whose share of liability has yet to be determined, the numerous yet-unresolved issues in many of the proceedings (including issues regarding class certification and the scope of many of the claims) and the attendant uncertainty of the various potential outcomes of such proceedings. Accordingly, the Corporation’s estimate will change from time to time, and actual losses may be more or less than the current estimate.

In the event of unexpected future developments, it is possible the ultimate resolution of these matters, if unfavorable, may be material to the Corporation's consolidated financial condition, results of operations or cash flows.

For information regarding income tax contingencies, refer to Note 11.

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Strategic Lines of Business and Markets

3 Months Ended

Mar. 31, 2021

Segment Reporting [Abstract]

Business Segment Information

STRATEGIC LINES OF BUSINESS AND MARKETS

The Corporation has strategically aligned its operations into three major business segments: the Commercial Bank, the Retail Bank and Wealth Management. These business segments are differentiated based on the type of customer and the related products and services provided. In addition to the three major business segments, the Finance Division is also reported as a segment. Business segment results are produced by the Corporation’s internal management accounting system. This system measures financial results based on the internal business unit structure of the Corporation. The performance of the business segments is not comparable with the Corporation's consolidated results and is not necessarily comparable with similar information for any other financial institution. Additionally, because of the interrelationships of the various segments, the information presented is not indicative of how the segments would perform if they operated as independent entities. The management accounting system assigns balance sheet and income statement items to each business segment using certain methodologies, which are regularly reviewed and refined. From time to time, the Corporation may make reclassifications among the segments to more appropriately reflect management's current view of the segments, and methodologies may be modified as the management accounting system is enhanced and changes occur in the organizational structure and/or product lines. For comparability purposes, amounts in all periods are based on business unit structure and methodologies in effect at March 31, 2021.

The following discussion provides information about the activities of each business segment. A discussion of the financial results and the factors impacting performance can be found in "Business Segments" in the "Strategic Lines of Business and Markets" section of the financial review.

The Commercial Bank meets the needs of small and middle market businesses, multinational corporations and governmental entities by offering various products and services including commercial loans and lines of credit, deposits, cash management, capital market products, international trade finance, letters of credit, foreign exchange management services and loan syndication services.

The Retail Bank includes a full range of personal financial services, consisting of consumer lending, consumer deposit gathering and mortgage loan origination. This business segment offers a variety of consumer products including deposit accounts, installment loans, credit cards, student loans, home equity lines of credit and residential mortgage loans. In addition, this business segment offers a subset of commercial products and services to micro-businesses whose primary contact is through the branch network.

Wealth Management offers products and services consisting of fiduciary services, private banking, retirement services, investment management and advisory services, investment banking and brokerage services. This business segment also offers the sale of annuity products, as well as life, disability and long-term care insurance products.

The Finance segment includes the Corporation’s securities portfolio and asset and liability management activities. This segment is responsible for managing the Corporation’s funding, liquidity and capital needs, performing interest sensitivity analysis and executing various strategies to manage the Corporation’s exposure to liquidity, interest rate risk and foreign exchange risk.

The Other category includes the income and expense impact of equity and cash, tax benefits not assigned to specific business segments, charges of an unusual or infrequent nature that are not reflective of the normal operations of the business segments and miscellaneous other expenses of a corporate nature.

For further information on the methodologies which form the basis for these results refer to Note 22 to the consolidated financial statements in the Corporation's 2020 Annual Report.

Business segment financial results are as follows:

	Commercial Bank			Retail Bank			Wealth Management			Finance		Other		Total
(dollar amounts in millions)
Three Months Ended March 31, 2021
Earnings summary:
Net interest income (expense)	$	382		$	133		$	42		$	(117)	$	3	$	443
Provision for credit losses	(177)			6			(12)			—		1		(182)
Noninterest income	159			28			67			12		4		270
Noninterest expenses	215			149			76			—		7		447
Provision (benefit) for income taxes	113			—			10			(25)		—		98
Net income (loss)	$	390		$	6		$	35		$	(80)	$	(1)	$	350
Net credit-related charge-offs	$	2		$	1		$	—		$	—	$	—	$	3
Selected average balances:
Assets	$	44,448		$	3,463		$	5,162		$	16,959	$	14,527	$	84,559
Loans	42,904			2,620			5,059			—		6		50,589
Deposits	41,102			24,322			4,826			985		157		71,392
Statistical data:
Return on average assets (a)	3.56		%	0.11		%	2.72		%	n/m		n/m		1.68		%
Efficiency ratio (b)	39.66			91.68			69.84			n/m		n/m		62.55
Three Months Ended March 31, 2020
Earnings summary:
Net interest income (expense)	$	380		$	125		$	41		$	(44)	$	11	$	513
Provision for credit losses	396			3			12			—		—		411
Noninterest income	127			28			70			14		(2)		237
Noninterest expenses (c)	192			145			70			—		10		417
(Benefit) provision for income taxes (c)	(19)			1			6			(8)		1		(19)
Net (loss) income (c)	$	(62)		$	4		$	23		$	(22)	$	(2)	$	(59)
Net credit-related charge-offs	$	83		$	1		$	—		$	—	$	—	$	84
Selected average balances:
Assets	$	44,254		$	2,864		$	5,078		$	14,285	$	6,784	$	73,265
Loans	42,593			2,075			4,936			—		—		49,604
Deposits	30,230			21,195			4,025			1,136		182		56,768
Statistical data:
Return on average assets (a) (c)	(0.56)		%	0.07		%	1.81		%	n/m		n/m		(0.32)		%
Efficiency ratio (b) (c)	37.95			94.07			62.68			n/m		n/m		55.58

(a)Return on average assets is calculated based on the greater of average assets or average liabilities and attributed equity.

(b)Noninterest expenses as a percentage of the sum of net interest income and noninterest income excluding net losses from securities and a derivative contract tied to the conversion rate of Visa Class B shares.

(c)See Defined Benefit Pension and Other Postretirement Costs in Note 1.

n/m – not meaningful

The Corporation operates in three primary markets - Texas, California and Michigan, as well as in Arizona and Florida, with select businesses operating in several other states and in Canada and Mexico. The Corporation produces market segment results for the Corporation’s three primary geographic markets as well as Other Markets. Other Markets includes Florida, Arizona, the International Finance division and businesses with a national perspective. The Finance & Other category includes the Finance segment and the Other category as previously described. Market segment results are provided as supplemental information to the business segment results and may not meet all operating segment criteria as set forth in GAAP. For comparability purposes, amounts in all periods are based on market segments and methodologies in effect at March 31, 2021.

A discussion of the financial results and the factors impacting performance can be found in the section entitled "Market Segments" in the "Strategic Lines of Business and Markets" section of the financial review.

Market segment financial results are as follows:

	Michigan			California			Texas			Other Markets			Finance & Other		Total
(dollar amounts in millions)
Three Months Ended March 31, 2021
Earnings summary:
Net interest income (expense)	$	154		$	172		$	114		$	117		$	(114)	$	443
Provision for credit losses	(28)			(54)			(86)			(15)			1		(182)
Noninterest income	66			48			36			104			16		270
Noninterest expenses	135			104			88			113			7		447
Provision (benefit) for income taxes	22			40			31			30			(25)		98
Net income (loss)	$	91		$	130		$	117		$	93		$	(81)	$	350
Net credit-related charge-offs	$	—		$	1		$	2		$	—		$	—	$	3
Selected average balances:
Assets	$	12,916		$	18,143		$	10,668		$	11,348		$	31,484	$	84,559
Loans	12,247			17,946			10,161			10,231			4		50,589
Deposits	25,683			19,968			10,783			13,816			1,142		71,392
Statistical data:
Return on average assets (a)	1.40		%	2.51		%	3.88		%	2.54		%	n/m		1.68		%
Efficiency ratio (b)	60.86			47.09			58.85			51.18			n/m		62.55
Three Months Ended March 31, 2020
Earnings summary:
Net interest income (expense)	$	163		$	176		$	115		$	92		$	(33)	$	513
Provision for credit losses	24			46			290			51			—		411
Noninterest income	72			33			30			90			12		237
Noninterest expenses (c)	137			93			83			94			10		417
Provision (benefit) for income taxes (c)	16			17			(50)			5			(7)		(19)
Net income (loss) (c)	$	58		$	53		$	(178)		$	32		$	(24)	$	(59)
Net credit-related charge-offs	$	3		$	8		$	70		$	3		$	—	$	84
Selected average balances:
Assets	$	12,895		$	18,007		$	11,154		$	10,140		$	21,069	$	73,265
Loans	12,191			17,742			10,566			9,105			—		49,604
Deposits	20,748			16,627			9,204			8,871			1,318		56,768
Statistical data:
Return on average assets (a) (c)	1.10		%	1.19		%	(6.47)		%	1.27		%	n/m		(0.32)		%
Efficiency ratio (b) (c)	57.92			44.60			57.38			51.69			n/m		55.58

(a)Return on average assets is calculated based on the greater of average assets or average liabilities and attributed equity.

(b)Noninterest expenses as a percentage of the sum of net interest income and noninterest income excluding net losses from securities and a derivative contract tied to the conversion rate of Visa Class B shares.

(c)See Defined Benefit Pension and Other Postretirement Costs in Note 1.

n/m – not meaningful.

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Revenue from Contracts with Customers

3 Months Ended

Mar. 31, 2021

Revenue from Contract with Customer [Abstract]

Revenue from Contracts with Customers

REVENUE FROM CONTRACTS WITH CUSTOMERS

Revenue from contracts with customers comprises the noninterest income earned by the Corporation in exchange for services provided to customers. The following table presents the composition of revenue from contracts with customers, segregated from other sources of noninterest income, by business segment.

	Commercial Bank		Retail Bank		Wealth Management		Finance & Other		Total
(in millions)
Three Months Ended March 31, 2021
Revenue from contracts with customers:
Card fees	$	60	$	10	$	1	$	—	$	71
Fiduciary income	—		—		53		—		53
Service charges on deposit accounts	34		13		1		—		48
Commercial loan servicing fees (a)	4		—		—		—		4
Brokerage fees	—		—		4		—		4
Other noninterest income (b)	5		4		5		—		14
Total revenue from contracts with customers	103		27		64		—		194
Other sources of noninterest income	56		1		3		16		76
Total noninterest income	$	159	$	28	$	67	$	16	$	270
Three Months Ended March 31, 2020
Revenue from contracts with customers:
Card fees	$	49	$	9	$	1	$	—	$	59
Fiduciary income	—		—		54		—		54
Service charges on deposit accounts	32		16		1		—		49
Commercial loan servicing fees (a)	4		—		—		—		4
Brokerage fees	—		—		7		—		7
Other noninterest income (b)	4		3		5		—		12
Total revenue from contracts with customers	89		28		68		—		185
Other sources of noninterest income	38		—		2		12		52
Total noninterest income	$	127	$	28	$	70	$	12	$	237

(a)Included in commercial lending fees on the Consolidated Statements of Comprehensive Income.

(b)Excludes derivative, warrant and other miscellaneous income.

    Adjustments to revenue during the three-month periods ended March 31, 2021 and 2020 for refunds or credits relating to prior periods were not significant.

    Revenue from contracts with customers did not generate significant contract assets and liabilities.

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Basis of Presentation and Accounting Policies Basis of Presentation and Accounting Policies (Policies)

3 Months Ended

Mar. 31, 2021

Accounting Policies [Abstract]

Defined Benefit Pension and Other Postretirement Costs

Defined Benefit Pension and Other Postretirement Costs

Effective January 1, 2021, the Corporation elected to change the accounting methodology for determining the market-related value of assets (MRVA) for certain classes of assets in the qualified defined benefit pension plan. The MRVA is used to calculate the Corporation's expected return on plan assets, a component of defined pension benefit cost (credit). These classes are currently comprised of the fixed income securities and private placement assets held in the portfolio, utilized by the Corporation to mitigate the impacts to financial results from changes in fair value of the pension liability. Previously, MRVA was measured using a historical five-year average fair value. Under the new methodology, the Corporation calculates MRVA using fair value of plan assets. Although both methods are permitted under U.S. GAAP, the Corporation believes the new policy is preferable for these classes of assets as it results in more timely recognition of the performance of pension assets in the results from operations.

The change in accounting methodology is applied retrospectively to all prior periods presented in the consolidated financial statements. The impact of the change to the qualified defined benefit plan on the Corporation's consolidated financial statements is as follows:

Consolidated Balance Sheets

	March 31, 2021		December 31, 2020
(in millions)	Accounting Change Impact		Previously Reported		Accounting Change Impact		Recast Amounts
Accumulated other comprehensive income (loss)	$	(3)	$	168	$	(104)	$	64
Retained earnings	3		9,623		104		9,727

Consolidated Statements of Comprehensive Income

	Three Months Ended March 31,
	2021		2020
(in millions)	Accounting Change Impact		Previously Reported		Accounting Change Impact		Recast Amounts
Other noninterest expenses	$	(5)	$	25	$	(8)	$	17
Provision (benefit) for income taxes	2		(21)		2		(19)
Net income (loss)	3		(65)		6		(59)
Earnings (losses) per common share
Basic	$	0.03	$	(0.46)	$	0.04	$	(0.42)
Diluted	$	0.02	$	(0.46)	$	0.04	$	(0.42)

Consolidated Statements of Cash Flows

	Three Months Ended March 31,
	2021		2020
(in millions)	Accounting Change Impact		Previously Reported		Accounting Change Impact		Recast Amounts
Net (loss) income	$	3	$	(65)	$	6	$	(59)
(Benefit) provision for deferred income taxes	2		(73)		2		(71)
Net periodic defined benefit credit	(5)		(5)		(8)		(13)

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Basis of Presentation and Accounting Policies Basis of Presentation and Accounting Policies (Tables)

3 Months Ended

Mar. 31, 2021

Accounting Policies [Abstract]

Schedule of Consolidated Balance Sheets with Change in Accounting Principle

	March 31, 2021		December 31, 2020
(in millions)	Accounting Change Impact		Previously Reported		Accounting Change Impact		Recast Amounts
Accumulated other comprehensive income (loss)	$	(3)	$	168	$	(104)	$	64
Retained earnings	3		9,623		104		9,727

Schedule of Consolidated Statements of Comprehensive Income with Change in Accounting Principle

	Three Months Ended March 31,
	2021		2020
(in millions)	Accounting Change Impact		Previously Reported		Accounting Change Impact		Recast Amounts
Other noninterest expenses	$	(5)	$	25	$	(8)	$	17
Provision (benefit) for income taxes	2		(21)		2		(19)
Net income (loss)	3		(65)		6		(59)
Earnings (losses) per common share
Basic	$	0.03	$	(0.46)	$	0.04	$	(0.42)
Diluted	$	0.02	$	(0.46)	$	0.04	$	(0.42)

Schedule of Consolidated Statements of Cash Flows with Change in Accounting Principle

	Three Months Ended March 31,
	2021		2020
(in millions)	Accounting Change Impact		Previously Reported		Accounting Change Impact		Recast Amounts
Net (loss) income	$	3	$	(65)	$	6	$	(59)
(Benefit) provision for deferred income taxes	2		(73)		2		(71)
Net periodic defined benefit credit	(5)		(5)		(8)		(13)

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Fair Value Measurements (Tables)

3 Months Ended

Mar. 31, 2021

Fair Value Disclosures [Abstract]

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 March 31, 2021 and December 31, 2020.

(in millions)	Total		Level 1		Level 2		Level 3
March 31, 2021
Deferred compensation plan assets	$	108	$	108	$	—	$	—
Equity securities	54		54		—		—
Investment securities available-for-sale:
U.S. Treasury and other U.S. government agency securities	4,613		4,613		—		—
Residential mortgage-backed securities (a)	10,982		—		10,982		—
Total investment securities available-for-sale	15,595		4,613		10,982		—
Derivative assets:
Interest rate contracts	340		—		316		24
Energy contracts	269		—		269		—
Foreign exchange contracts	12		—		12		—
Total derivative assets	621		—		597		24
Total assets at fair value	$	16,378	$	4,775	$	11,579	$	24
Derivative liabilities:
Interest rate contracts	$	65	$	—	$	65	$	—
Energy contracts	265		—		265		—
Foreign exchange contracts	10		—		10		—
Total derivative liabilities	340		—		340		—
Deferred compensation plan liabilities	108		108		—		—
Total liabilities at fair value	$	448	$	108	$	340	$	—
December 31, 2020
Deferred compensation plan assets	$	107	$	107	$	—	$	—
Equity securities	60		60		—		—
Investment securities available-for-sale:
U.S. Treasury and other U.S. government agency securities	4,658		4,658		—		—
Residential mortgage-backed securities (a)	10,370		—		10,370		—
Total investment securities available-for-sale	15,028		4,658		10,370		—
Derivative assets:
Interest rate contracts	531		—		492		39
Energy contracts	151		—		151		—
Foreign exchange contracts	18		—		18		—
Total derivative assets	700		—		661		39
Total assets at fair value	$	15,895	$	4,825	$	11,031	$	39
Derivative liabilities:
Interest rate contracts	$	61	$	—	$	61	$	—
Energy contracts	149		—		149		—
Foreign exchange contracts	19		—		19		—
Total derivative liabilities	229		—		229		—
Deferred compensation plan liabilities	107		107		—		—
Total liabilities at fair value	$	336	$	107	$	229	$	—

(a)Issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.

Changes In Level 3 Assets And Liabilities Measured At Fair Value On A Recurring Basis

The following table summarizes the changes in Level 3 assets and liabilities measured at fair value on a recurring basis for the three-month periods ended March 31, 2021 and 2020.

			Net Realized/Unrealized Gains (Losses) (Pretax) Recorded in Earnings (a)
	Balance at Beginning of Period								Balance at End of Period
							Sales
(in millions)			Realized		Unrealized
Three Months Ended March 31, 2021
Derivative assets:
Interest rate contracts	$	39	$	—	$	(15)	$	—	$	24
Three Months Ended March 31, 2020
Derivative assets:
Interest rate contracts	$	22	$	—	$	21	$	—	$	43

(a)Realized and unrealized gains and losses due to changes in fair value are recorded in other noninterest income on the Consolidated Statements of Comprehensive Income.

Assets And Liabilities Recorded At Fair Value On A Nonrecurring Basis

The following table presents assets recorded at fair value on a nonrecurring basis at March 31, 2021 and December 31, 2020. No liabilities were recorded at fair value on a nonrecurring basis at March 31, 2021 and December 31, 2020.

(in millions)	Level 3
March 31, 2021
Loans:
Commercial	$	125
Commercial mortgage	12
Total loans	137
Other real estate	8
Total assets at fair value	$	145
December 31, 2020
Loans:
Commercial	$	134
Commercial mortgage	16
Total assets at fair value	$	150

Estimated Fair Values Of Financial Instruments Not Recorded At Fair Value In Their Entirety On A Recurring Basis

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:

	Carrying Amount		Estimated Fair Value
(in millions)			Total		Level 1		Level 2		Level 3
March 31, 2021
Assets
Cash and due from banks	$	1,064	$	1,064	$	1,064	$	—	$	—
Interest-bearing deposits with banks	13,807		13,807		13,807		—		—
Loans held-for-sale	14		14		—		14		—
Total loans, net of allowance for loan losses (a)	49,805		48,880		—		—		48,880
Customers’ liability on acceptances outstanding	13		13		13		—		—
Restricted equity investments	92		92		92		—		—
Nonmarketable equity securities (b)	7		9
Liabilities
Demand deposits (noninterest-bearing)	38,822		38,822		—		38,822		—
Interest-bearing deposits	32,844		32,844		—		32,844		—
Customer certificates of deposit	2,141		2,140		—		2,140		—
Total deposits	73,807		73,806		—		73,806		—
Acceptances outstanding	13		13		13		—		—
Medium- and long-term debt	2,852		2,919		—		2,919		—
Credit-related financial instruments	(50)		(50)		—		—		(50)
December 31, 2020
Assets
Cash and due from banks	$	1,031	$	1,031	$	1,031	$	—	$	—
Interest-bearing deposits with banks	14,736		14,736		14,736		—		—
Loans held-for-sale	5		5		—		5		—
Total loans, net of allowance for loan losses (a)	51,343		50,601		—		—		50,601
Customers’ liability on acceptances outstanding	1		1		1		—		—
Restricted equity investments	207		207		207		—		—
Nonmarketable equity securities (b)	5		9
Liabilities
Demand deposits (noninterest-bearing)	39,420		39,420		—		39,420		—
Interest-bearing deposits	31,316		31,316		—		31,316		—
Customer certificates of deposit	2,133		2,133		—		2,133		—
Total deposits	72,869		72,869		—		72,869		—
Acceptances outstanding	1		1		1		—		—
Medium- and long-term debt	5,728		5,790		—		5,790		—
Credit-related financial instruments	(68)		(68)		—		—		(68)

(a)Included $137 million and $150 million of loans recorded at fair value on a nonrecurring basis at March 31, 2021 and December 31, 2020, respectively.

(b)Certain investments that are measured at fair value using the net asset value have not been classified in the fair value hierarchy. The fair value amounts presented in the table are intended to permit reconciliation of the fair value hierarchy to the amounts presented in the Consolidated Balance Sheets.

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Investment Securities (Tables)

3 Months Ended

Mar. 31, 2021

Investments, Debt and Equity Securities [Abstract]

Summary Of Investment Securities

A summary of the Corporation’s investment securities follows:

(in millions)	Amortized Cost		Gross Unrealized Gains		Gross Unrealized Losses		Fair Value
March 31, 2021
Investment securities available-for-sale:
U.S. Treasury and other U.S. government agency securities	$	4,578	$	59	$	24	$	4,613
Residential mortgage-backed securities (a)	10,924		178		120		10,982
Total investment securities available-for-sale	$	15,502	$	237	$	144	$	15,595
December 31, 2020
Investment securities available-for-sale:
U.S. Treasury and other U.S. government agency securities	$	4,583	$	76	$	1	$	4,658
Residential mortgage-backed securities (a)	10,169		203		2		10,370
Total investment securities available-for-sale	$	14,752	$	279	$	3	$	15,028

(a)Issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.

Summary Of Investment Securities In Unrealized Loss Positions

A summary of the Corporation’s investment securities in an unrealized loss position as of March 31, 2021 and December 31, 2020 follows:

	Temporarily Impaired
	Less than 12 Months				12 Months or more				Total
(in millions)	Fair Value		Unrealized Losses		Fair Value		Unrealized Losses		Fair Value		Unrealized Losses
March 31, 2021
U.S. Treasury and other U.S. government agency securities	$	1,834	$	24	$	—	$	—	$	1,834	$	24
Residential mortgage-backed securities (a)	3,577		120		—		—		3,577		120
Total temporarily impaired securities	$	5,411	$	144	$	—	$	—	$	5,411	$	144
December 31, 2020
U.S. Treasury and other U.S. government agency securities	$	1,119	$	1	$	—	$	—	$	1,119	$	1
Residential mortgage-backed securities (a)	952		2		—		—		952		2
Total temporarily impaired securities	$	2,071	$	3	$	—	$	—	$	2,071	$	3

(a)Issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.

Summary of Net Securities Gains (Losses)

Sales, calls and write-downs of investment securities available-for-sale resulted in the following losses recorded in net securities losses on the Consolidated Statements of Comprehensive Income, computed based on the adjusted cost of the specific security.

	Three Months Ended March 31,
(in millions)	2021		2020
Securities losses	$	—	$	(1)
Net securities losses	$	—	$	(1)

Contractual Maturity Distribution Of Debt Securities

The following table summarizes the amortized cost and fair values of debt securities by contractual maturity. Securities with multiple maturity dates are classified in the period of final maturity. Expected maturities will differ from contractual maturities because borrowers may have the right to call or prepay obligations with or without call or prepayment penalties.

(in millions)
March 31, 2021	Amortized Cost		Fair Value
Contractual maturity
Within one year	$	1,617	$	1,634
After one year through five years	3,177		3,208
After five years through ten years	570		587
After ten years	10,138		10,166
Total investment securities	$	15,502	$	15,595

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Credit Quality And Allowance For Credit Losses (Tables)

3 Months Ended

Mar. 31, 2021

Credit Quality And Allowance For Credit Losses [Abstract]

Aging Analysis Of Loans

The following table presents an aging analysis of the amortized cost basis of loans.

	Loans Past Due and Still Accruing
(in millions)	30-59 Days		60-89  Days		90 Days or More		Total		Nonaccrual Loans		Current Loans (a)		Total  Loans
March 31, 2021
Business loans:
Commercial	$	103	$	57	$	17	$	177	$	230	$	30,479	$	30,886
Real estate construction:
Commercial Real Estate business line (b)	—		—		—		—		—		3,810		3,810
Other business lines (c)	9		8		2		19		1		414		434
Total real estate construction	9		8		2		19		1		4,224		4,244
Commercial mortgage:
Commercial Real Estate business line (b)	12		1		—		13		3		2,295		2,311
Other business lines (c)	40		25		21		86		31		7,565		7,682
Total commercial mortgage	52		26		21		99		34		9,860		9,993
Lease financing	14		—		1		15		1		561		577
International	—		2		—		2		—		988		990
Total business loans	178		93		41		312		266		46,112		46,690
Retail loans:
Residential mortgage	8		4		—		12		33		1,754		1,799
Consumer:
Home equity	5		4		—		9		15		1,546		1,570
Other consumer	10		—		19		29		—		494		523
Total consumer	15		4		19		38		15		2,040		2,093
Total retail loans	23		8		19		50		48		3,794		3,892
Total loans	$	201	$	101	$	60	$	362	$	314	$	49,906	$	50,582
December 31, 2020
Business loans:
Commercial	$	62	$	115	$	33	$	210	$	252	$	32,291	$	32,753
Real estate construction:
Commercial Real Estate business line (b)	31		—		—		31		—		3,626		3,657
Other business lines (c)	9		—		—		9		1		415		425
Total real estate construction	40		—		—		40		1		4,041		4,082
Commercial mortgage:
Commercial Real Estate business line (b)	51		1		—		52		3		2,218		2,273
Other business lines (c)	48		40		5		93		26		7,520		7,639
Total commercial mortgage	99		41		5		145		29		9,738		9,912
Lease financing	14		—		1		15		1		578		594
International	—		—		—		—		—		926		926
Total business loans	215		156		39		410		283		47,574		48,267
Retail loans:
Residential mortgage	11		4		—		15		47		1,768		1,830
Consumer:
Home equity	7		1		—		8		17		1,563		1,588
Other consumer	10		—		6		16		—		590		606
Total consumer	17		1		6		24		17		2,153		2,194
Total retail loans	28		5		6		39		64		3,921		4,024
Total loans	$	243	$	161	$	45	$	449	$	347	$	51,495	$	52,291

(a)Includes $87 million and $141 million of loans with deferred payments not considered past due in accordance with the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) at March 31, 2021 and December 31, 2020, respectively.

(b)Primarily loans to real estate developers.

(c)Primarily loans secured by owner-occupied real estate.

Loans By Credit Quality Indicator and Vintage Year

The following table presents loans by credit quality indicator (CQI) and vintage year. CQI is based on internal risk ratings assigned to each business loan at the time of approval and subjected to subsequent reviews, generally at least annually, and to pools of retail loans with similar risk characteristics. Vintage year is the year of origination or major modification.

	March 31, 2021
	Vintage Year
(in millions)	2021			2020			2019		2018		2017		Prior		Revolvers		Revolvers Converted to Term		Total
Business loans:
Commercial:
Pass (a)	$	1,632	(b)	$	5,073	(b)	$	2,191	$	1,445	$	944	$	1,061	$	16,601	$	16	$	28,963
Criticized (c)	30			41			217		173		86		211		1,163		2		1,923
Total commercial	1,662			5,114			2,408		1,618		1,030		1,272		17,764		18		30,886
Real estate construction
Pass (a)	44			604			1,206		1,142		571		426		183		—		4,176
Criticized (c)	—			3			29		17		8		9		2		—		68
Total real estate construction	44			607			1,235		1,159		579		435		185		—		4,244
Commercial mortgage
Pass (a)	398			2,107			1,587		1,161		1,062		2,858		399		—		9,572
Criticized (c)	3			31			63		43		33		232		16		—		421
Total commercial mortgage	401			2,138			1,650		1,204		1,095		3,090		415		—		9,993
Lease financing
Pass (a)	28			104			115		61		47		186		—		—		541
Criticized (c)	—			3			19		11		2		1		—		—		36
Total lease financing	28			107			134		72		49		187		—		—		577
International
Pass (a)	137			155			159		85		10		66		316		—		928
Criticized (c)	—			14			8		17		4		8		11		—		62
Total international	137			169			167		102		14		74		327		—		990
Total business loans	2,272			8,135			5,594		4,155		2,767		5,058		18,691		18		46,690
Retail loans:
Residential mortgage
Pass (a)	97			631			213		108		162		555		—		—		1,766
Criticized (c)	2			1			2		2		7		19		—		—		33
Total residential mortgage	99			632			215		110		169		574		—		—		1,799
Consumer:
Home equity
Pass (a)	—			—			—		—		—		16		1,474		58		1,548
Criticized (c)	—			—			—		—		—		—		16		6		22
Total home equity	—			—			—		—		—		16		1,490		64		1,570
Other consumer
Pass (a)	15			107			19		12		2		36		316		—		507
Criticized (c)	—			—			—		1		—		7		8		—		16
Total other consumer	15			107			19		13		2		43		324		—		523
Total consumer	15			107			19		13		2		59		1,814		64		2,093
Total retail loans	114			739			234		123		171		633		1,814		64		3,892
Total loans	$	2,386		$	8,874		$	5,828	$	4,278	$	2,938	$	5,691	$	20,505	$	82	$	50,582
Table continues on the following page.

	December 31, 2020
	Vintage Year
	2020			2019		2018		2017		2016		Prior		Revolvers		Revolvers Converted to Term		Total
Business loans:
Commercial:
Pass (a)	$	5,991	(b)	$	2,316	$	1,563	$	1,051	$	429	$	755	$	18,416	$	17	$	30,538
Criticized (c)	30			281		191		116		64		166		1,365		2		2,215
Total commercial	6,021			2,597		1,754		1,167		493		921		19,781		19		32,753
Real estate construction:
Pass (a)	433			1,080		1,244		631		335		141		171		—		4,035
Criticized (c)	3			28		5		8		—		1		2		—		47
Total real estate construction	436			1,108		1,249		639		335		142		173		—		4,082
Commercial mortgage:
Pass (a)	2,053			1,559		1,146		1,120		818		2,272		431		—		9,399
Criticized (c)	47			130		42		45		41		193		15		—		513
Total commercial mortgage	2,100			1,689		1,188		1,165		859		2,465		446		—		9,912
Lease financing
Pass (a)	109			122		71		50		14		201		—		—		567
Criticized (c)	2			17		5		2		1		—		—		—		27
Total lease financing	111			139		76		52		15		201		—		—		594
International
Pass (a)	274			161		103		11		3		64		245		—		861
Criticized (c)	13			8		18		4		7		2		13		—		65
Total international	287			169		121		15		10		66		258		—		926
Total business loans	8,955			5,702		4,388		3,038		1,712		3,795		20,658		19		48,267
Retail loans:
Residential mortgage
Pass (a)	639			230		119		197		196		398		—		—		1,779
Criticized (c)	7			2		2		6		2		32		—		—		51
Total residential mortgage	646			232		121		203		198		430		—		—		1,830
Consumer:
Home equity
Pass (a)	—			—		—		—		—		15		1,489		63		1,567
Criticized (c)	—			—		—		—		—		1		13		7		21
Total home equity	—			—		—		—		—		16		1,502		70		1,588
Other consumer
Pass (a)	113			23		12		2		3		41		404		—		598
Criticized (c)	—			—		2		—		—		—		6		—		8
Total other consumer	113			23		14		2		3		41		410		—		606
Total consumer	113			23		14		2		3		57		1,912		70		2,194
Total retail loans	759			255		135		205		201		487		1,912		70		4,024
Total loans	$	9,714		$	5,957	$	4,523	$	3,243	$	1,913	$	4,282	$	22,570	$	89	$	52,291

(a)Includes all loans not included in the categories of special mention, substandard or nonaccrual.

(b)Includes Small Business Administration Paycheck Protection Program (PPP) loans of $925 million and $2.9 billion in 2021 and 2020, respectively, at March 31, 2021, and PPP loans of $3.5 billion in 2020 at December 31, 2020.

(c)Includes loans with an internal rating of special mention, substandard loans for which the accrual of interest has not been discontinued and nonaccrual loans. Special mention loans have potential credit weaknesses that deserve management’s close attention, such as loans to borrowers who may be experiencing financial difficulties that may result in deterioration of repayment prospects from the borrower at some future date. Accruing substandard loans have a well-defined weakness, or weaknesses, such as loans to borrowers who may be experiencing losses from operations or inadequate liquidity of a degree and duration that jeopardizes the orderly repayment of the loan. Substandard loans are also distinguished by the distinct possibility of loss in the future if these weaknesses are not corrected. Nonaccrual loans are loans for which the accrual of interest has been discontinued. For further information regarding nonaccrual loans, refer to the Nonperforming Assets subheading in Note 1 - Basis of Presentation and Accounting Policies on page F-59 in the Corporation's 2020 Annual Report. These categories are generally consistent with the "special mention" and "substandard" categories as defined by regulatory authorities. A minority of nonaccrual loans are consistent with the "doubtful" category.

Changes In The Allowance For Loan Losses

The following table details the changes in the allowance for credit losses.

	2021									2020
(in millions)	Business Loans			Retail Loans			Total			Business Loans			Retail Loans			Total
Three Months Ended March 31
Balance at beginning of period:
Allowance for loan losses	$	895		$	53		$	948		$	601		$	36		$	637
Allowance for credit losses on lending-related commitments	35			9			44			28			3			31
Allowance for credit losses	930			62			992			629			39			668
Cumulative effect of change in accounting principle	—			—			—			(42)			25			(17)
Loan charge-offs	(15)			(1)			(16)			(87)			(2)			(89)
Recoveries on loans previously charged-off	12			1			13			5			—			5
Net loan charge-offs	(3)			—			(3)			(82)			(2)			(84)
Provision for credit losses:
Provision for loan losses	(183)			15			(168)			384			(4)			380
Provision for credit losses on lending-related commitments	(13)			(1)			(14)			24			7			31
Provision for credit losses	(196)			14			(182)			408			3			411
Balance at end of period:
Allowance for loan losses	709			68			777			861			55			916
Allowance for credit losses on lending-related commitments	22			8			30			52			10			62
Allowance for credit losses	$	731		$	76		$	807		$	913		$	65		$	978
Allowance for loan losses as a percentage of total loans	1.52		%	1.74		%	1.54		%	1.75		%	1.35		%	1.71		%
Allowance for loan losses as a percentage of total loans excluding PPP loans	1.65			n/a			1.66			n/a			n/a			n/a
Allowance for credit losses as a percentage of total loans	1.57			1.94			1.59			1.85			1.57			1.83
Allowance for credit losses as a percentage of total loans excluding PPP loans	1.70			n/a			1.72			n/a			n/a			n/a

n/a - not applicable

Nonaccrual Loans

The following table presents additional information regarding nonaccrual loans. No interest income was recognized on nonaccrual loans for the three-month periods ended March 31, 2021 and 2020.

(in millions)	Nonaccrual Loans with No Related Allowance		Nonaccrual Loans with Related Allowance		Total Nonaccrual Loans
March 31, 2021
Business loans:
Commercial	$	50	$	180	$	230
Real estate construction:
Other business lines (a)	—		1		1
Commercial mortgage:
Commercial Real Estate business line (b)	1		2		3
Other business lines (a)	7		24		31
Total commercial mortgage	8		26		34
Lease financing	—		1		1
Total business loans	58		208		266
Retail loans:
Residential mortgage	33		—		33
Consumer:
Home equity	15		—		15
Total retail loans	48		—		48
Total nonaccrual loans	$	106	$	208	$	314
December 31, 2020
Business loans:
Commercial	$	57	$	195	$	252
Real estate construction:
Other business lines (a)	—		1		1
Commercial mortgage:
Commercial Real Estate business line (b)	1		2		3
Other business lines (a)	5		21		26
Total commercial mortgage	6		23		29
Lease financing	—		1		1
Total business loans	63		220		283
Retail loans:
Residential mortgage	47		—		47
Consumer:
Home equity	17		—		17
Total retail loans	64		—		64
Total nonaccrual loans	$	127	$	220	$	347

(a)Primarily loans secured by owner-occupied real estate.

(b)Primarily loans to real estate developers.

Troubled Debt Restructurings By Type Of Modification

The following table details the amortized cost basis at March 31, 2021 and 2020 of loans considered to be TDRs that were restructured during the three-month periods ended March 31, 2021 and 2020, by type of modification. In cases of loans with more than one type of modification, the loans were categorized based on the most significant modification.

	Principal Deferrals (a)
(in millions)	2021		2020
Three Months Ended March 31,
Commercial	$	—	$	22
Commercial mortgage:
Other business lines (b)	—		2
Total loans	$	—	$	24

(a)Primarily represents loan balances where terms were extended by more than an insignificant time period, typically more than 180 days, at or above contractual interest rates. Also includes commercial loans restructured in bankruptcy. In accordance with the provisions of the CARES Act, balances exclude $71 million, primarily retail loans, with terms extended by more than an insignificant time period.

(b)Primarily loans secured by owner-occupied real estate.

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Derivative And Credit-Related Financial Instruments (Tables)

3 Months Ended

Mar. 31, 2021

Derivative Instruments and Hedging Activities Disclosure [Abstract]

Schedule Of Derivative Instruments

The following table presents the composition of the Corporation’s derivative instruments held or issued for risk management purposes or in connection with customer-initiated and other activities at March 31, 2021 and December 31, 2020.

	March 31, 2021						December 31, 2020
			Fair Value						Fair Value
(in millions)	Notional/ Contract Amount (a)		Gross Derivative Assets		Gross Derivative Liabilities		Notional/ Contract Amount (a)		Gross Derivative Assets		Gross Derivative Liabilities
Risk management purposes
Derivatives designated as hedging instruments
Interest rate contracts:
Swaps - fair value - receive fixed/pay floating	$	2,650	$	—	$	—	$	2,650	$	—	$	—
Swaps - cash flow - receive fixed/pay floating	5,550		—		—		5,550		—		—
Derivatives used as economic hedges
Foreign exchange contracts:
Spot, forwards and swaps	390		1		1		442		1		4
Total risk management purposes	8,590		1		1		8,642		1		4
Customer-initiated and other activities
Interest rate contracts:
Caps and floors written	909		—		2		869		—		—
Caps and floors purchased	909		2		—		869		—		—
Swaps	19,693		338		63		19,783		531		61
Total interest rate contracts	21,511		340		65		21,521		531		61
Energy contracts:
Caps and floors written	665		1		60		503		1		33
Caps and floors purchased	665		60		1		503		33		1
Swaps	2,873		208		204		2,115		117		115
Total energy contracts	4,203		269		265		3,121		151		149
Foreign exchange contracts:
Spot, forwards, options and swaps	1,429		11		9		1,901		17		15
Total customer-initiated and other activities	27,143		620		339		26,543		699		225
Total gross derivatives	$	35,733	$	621	$	340	$	35,185	$	700	$	229
Amounts offset in the Consolidated Balance Sheets:
Netting adjustment - Offsetting derivative assets/liabilities			(59)		(59)				(83)		(83)
Netting adjustment - Cash collateral received/posted			(2)		(227)				(17)		(48)
Net derivatives included in the Consolidated Balance Sheets (b)			560		54				600		98
Amounts not offset in the Consolidated Balance Sheets:
Marketable securities pledged under bilateral collateral agreements			—		(26)				—		(42)
Net derivatives after deducting amounts not offset in the Consolidated Balance Sheets			$	560	$	28			$	600	$	56

(a)Notional or contractual amounts, which represent the extent of involvement in the derivatives market, are used to determine the contractual cash flows required in accordance with the terms of the agreement. These amounts are typically not exchanged, significantly exceed amounts subject to credit or market risk and are not reflected in the Consolidated Balance Sheets.

(b)Net derivative assets are included in accrued income and other assets and net derivative liabilities are included in accrued expenses and other liabilities on the Consolidated Balance Sheets. Included in the fair value of net derivative assets and net derivative liabilities are credit valuation adjustments reflecting counterparty credit risk and credit risk of the Corporation. The fair value of net derivative assets included credit valuation adjustments for counterparty credit risk of $16 million and $27 million at March 31, 2021 and December 31, 2020, respectively.

Schedule of the Effects of Fair Value Hedging on the Consolidated Statements of Comprehensive Income

The following table details the effects of fair value hedging on the Consolidated Statements of Comprehensive Income.

	Interest on Medium- and Long-Term Debt
	Three Months Ended March 31,
(in millions)	2021		2020
Total interest on medium- and long-term debt (a)	$	9	$	40
Fair value hedging relationships:
Interest rate contracts:
Hedged items	25		30
Derivatives designated as hedging instruments	(17)		(6)

(a) Includes the effects of hedging.

Schedule Of Weighted Average Maturity And Interest Rates On Risk Management Cash Flow Swaps

The following table summarizes the expected weighted average remaining maturity of the notional amount of risk management interest rate swaps, the carrying amount of the related hedged items and the weighted average interest rates associated with amounts expected to be received or paid on interest rate swap agreements as of March 31, 2021 and December 31, 2020.

Cash flow swaps - receive fixed/pay floating rate on variable-rate loans

(dollar amounts in millions)	March 31, 2021			December 31, 2020
Derivative notional amount	$	5,550		$	5,550
Weighted average:
Remaining maturity (in years)	2.0			2.3
Receive rate	1.87		%	1.87		%
Pay rate (a)	0.12			0.15

(a)Variable rates paid on receive fixed swaps designated as cash flow hedges are based on one-month LIBOR rates in effect at March 31, 2021 and December 31, 2020.

Schedule Of Weighted Average Maturity And Interest Rates On Risk Management Interest Rate Swaps

Fair value swaps - receive fixed/pay floating rate on medium- and long-term debt

(dollar amounts in millions)	March 31, 2021			December 31, 2020
Derivative notional amount	$	2,650		$	2,650
Carrying value of hedged items (a)	2,852			2,928
Weighted average:
Remaining maturity (in years)	4.4			4.6
Receive rate	3.68		%	3.68		%
Pay rate (b)	1.10			1.16

(a)Included $202 million and $279 million of cumulative hedging adjustments at March 31, 2021 and December 31, 2020, respectively, which included $5 million and $6 million, respectively, of hedging adjustment on a discontinued hedging relationship.

(b)Variable rates paid on receive fixed swaps designated as fair value hedges are based on one- and six-month LIBOR rates in effect at March 31, 2021 and December 31, 2020.

Schedule Of Net Gains Recognized In Income On Customer-Initiated Derivatives

The net gains recognized in income on customer-initiated derivative instruments, net of the impact of offsetting positions included in derivative income, were as follows:

	Three Months Ended March 31,
(in millions)	2021		2020
Interest rate contracts	$	15	$	8
Energy contracts	4		1
Foreign exchange contracts	11		11
Total derivative income	$	30	$	20

Schedule Of Financial Instruments With Off-Balance Sheet Credit Risk

The Corporation’s credit risk associated with these instruments is represented by the contractual amounts indicated in the following table.

(in millions)	March 31, 2021		December 31, 2020
Unused commitments to extend credit:
Commercial and other	$	24,598	$	23,443
Bankcard, revolving check credit and home equity loan commitments	3,322		3,297
Total unused commitments to extend credit	$	27,920	$	26,740
Standby letters of credit	$	3,278	$	3,273
Commercial letters of credit	40		30

Summary Of Criticized Letters Of Credit

The following table presents a summary of criticized standby and commercial letters of credit at March 31, 2021 and December 31, 2020. The Corporation's criticized list is generally consistent with the Special Mention, Substandard and

Doubtful categories defined by regulatory authorities. The Corporation manages credit risk through underwriting, periodically reviewing and approving its credit exposures using Board committee approved credit policies and guidelines.

(dollar amounts in millions)	March 31, 2021			December 31, 2020
Total criticized standby and commercial letters of credit	$	54		$	73
As a percentage of total outstanding standby and commercial letters of credit	1.6		%	2.2		%

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Variable Interest Entities (VIEs) (Tables)

3 Months Ended

Mar. 31, 2021

Variable Interest Entity, Not Primary Beneficiary, Disclosures [Abstract]

Impact of VIEs on the Consolidated Statements of Income

The following table summarizes the impact of these tax credit entities on the Corporation’s Consolidated Statements of Comprehensive Income.

	Three Months Ended March 31,
(in millions)	2021		2020
Provision for income taxes:
Amortization of LIHTC investments	$	17	$	17
Low income housing tax credits	(16)		(16)
Other tax benefits related to tax credit entities	(4)		(4)
Total provision for income taxes	$	(3)	$	(3)

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Medium- And Long-Term Debt (Tables)

3 Months Ended

Mar. 31, 2021

Debt Disclosure [Abstract]

Schedule Of Medium- And Long-Term Debt

Medium- and long-term debt is summarized as follows:

(in millions)	March 31, 2021		December 31, 2020
Parent company
Subordinated notes:
3.80% subordinated notes due 2026 (a)	$	270	$	280
Medium- and long-term notes:
3.70% notes due 2023 (a)	898		905
4.00% notes due 2029 (a)	597		633
Total medium- and long-term notes	1,495		1,538
Total parent company	1,765		1,818
Subsidiaries
Subordinated notes:
4.00% subordinated notes due 2025 (a)	371		380
7.875% subordinated notes due 2026 (a)	199		207
Total subordinated notes	570		587
Medium- and long-term notes:
2.50% notes due 2024 (a)	517		523
Total medium- and long-term notes	517		523
FHLB advances:
Floating-rate based on FHLB auction rate due 2026	—		2,800
Total FHLB advances	—		2,800
Total subsidiaries	1,087		3,910
Total medium- and long-term debt	$	2,852	$	5,728

(a)The fixed interest rates on these notes have been swapped to a variable rate and designated in a hedging relationship. Accordingly, carrying value has been adjusted to reflect the change in the fair value of the debt as a result of changes in the benchmark rate.

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Accumulated Other Comprehensive Income (Loss) (Tables)

3 Months Ended

Mar. 31, 2021

Accumulated Other Comprehensive Income (Loss), Net of Tax [Abstract]

Schedule Of Accumulated Other Comprehensive Income (Loss)

The following table presents a reconciliation of the changes in the components of accumulated other comprehensive (loss) income and details the components of other comprehensive (loss) income for the three months ended March 31, 2021 and 2020, including the amount of income tax expense (benefit) allocated to each component of other comprehensive (loss) income.

	Three Months Ended March 31,
(in millions)	2021		2020
Accumulated net unrealized gains on investment securities:
Balance at beginning of period, net of tax	$	211	$	65
Net unrealized holding (losses) gains arising during the period	(183)		323
Less: (Benefit) provision for income taxes	(43)		76
Change in net unrealized gains on investment securities, net of tax	(140)		247
Balance at end of period, net of tax	$	71	$	312
Accumulated net gains on cash flow hedges:
Balance at beginning of period, net of tax	$	155	$	34
Net cash flow hedge (losses) gains arising during the period	(18)		205
Less: (Benefit) provision for income taxes	(4)		48
Change in net cash flow hedge (losses) gains arising during the period, net of tax	(14)		157
Less:
Net cash flow hedge gains included in interest and fees on loans	24		3
Less: Provision for income taxes	6		1
Reclassification adjustment for net cash flow hedge gains included in net income, net of tax	18		2
Change in net cash flow hedge (losses) gains, net of tax	(32)		155
Balance at end of period, net of tax (a)	$	123	$	189
Accumulated defined benefit pension and other postretirement plans adjustment:
Balance at beginning of period, net of tax (b)	$	(302)	$	(415)
Actuarial loss arising during the period (b)	—		(3)
Less: Benefit for income taxes (b)	—		(1)
Net defined benefit pension and other postretirement plans adjustment arising during the period, net of tax (b)	—		(2)
Amounts recognized in other noninterest expenses:
Amortization of actuarial net loss (b)	10		11
Amortization of prior service credit	(6)		(7)
Total amounts recognized in other noninterest expenses (b)	4		4
Less: Provision for income taxes (b)	1		1
Adjustment for amounts recognized as components of net periodic benefit cost during the period, net of tax (b)	3		3
Change in defined benefit pension and other postretirement plans adjustment, net of tax (b)	3		1
Balance at end of period, net of tax (b)	$	(299)	$	(414)
Total accumulated other comprehensive (loss) income at end of period, net of tax (b)	$	(105)	$	87

(a)The Corporation expects to reclassify $67 million of gains, net of tax, from accumulated other comprehensive income to earnings over the next twelve months if interest yield curves and notional amounts remain at March 31, 2021 levels.

(b)Balances at beginning of period, net of tax and changes for the three months ended March 31, 2020 have been recast to reflect the retrospective application of the Corporation's election to change the accounting method for certain components of the qualified defined benefit pension plan as of January 1, 2021. Refer to Note 1 for further information.

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Net Income (Loss) Per Common Share (Tables)

3 Months Ended

Mar. 31, 2021

Earnings Per Share [Abstract]

Basic And Diluted Net Income Per Common Share

Basic and diluted net income (loss) per common share are presented in the following table.

	Three Months Ended March 31,
(in millions, except per share data)	2021		2020
Basic and diluted
Net income (loss)	$	350	$	(59)
Less:
Income allocated to participating securities	1		—
Preferred stock dividends	6		—
Net income (loss) attributable to common shares	$	343	$	(59)
Basic average common shares	140		141
Basic net income (loss) per common share	$	2.46	$	(0.42)
Basic average common shares	140		141
Dilutive common stock equivalents:
Net effect of the assumed exercise of stock awards	1		—
Diluted average common shares	141		141
Diluted net income (loss) per common share	$	2.43	$	(0.42)

Schedule of Average Shares Excluded From Diluted Net Income Per Common Share Computation

The following average shares related to outstanding options to purchase shares of common stock were not included in the computation of diluted net income (loss) per common share because the exercise price was greater than the average market price of common shares for the period.

	Three Months Ended March 31,
(average outstanding options in thousands)	2021	2020
Average outstanding options	782	1,210
Range of exercise prices	67.53 - 95.25	56.79 - 95.25

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Employee Benefit Plans (Tables)

3 Months Ended

Mar. 31, 2021

Defined Benefit Plans and Other Postretirement Benefit Plans Disclosures [Abstract]

Components of Net Periodic Benefit Cost

The components of net periodic benefit cost (credit) for the Corporation's qualified pension plan, non-qualified pension plan and postretirement benefit plan are as follows.

Qualified Defined Benefit Pension Plan	Three Months Ended March 31,
(in millions)	2021		2020 (a)
Service cost	$	10	$	8
Other components of net benefit credit:
Interest cost	15		18
Expected return on plan assets	(50)		(46)
Amortization of prior service credit	(5)		(5)
Amortization of net loss	7		9
Total other components of net benefit credit	(33)		(24)
Net periodic defined benefit credit	$	(23)	$	(16)

(a)Expected return on plan assets increased $3 million and amortization of net loss was reduced by $5 million to reflect the retrospective application of the Corporation's election to change the accounting method for certain components of the qualified defined benefit pension plan as of January 1, 2021, resulting in an increase of $8 million to total other components of net benefit credit. Refer to Note 1 for further information.

Non-Qualified Defined Benefit Pension Plan	Three Months Ended March 31,
(in millions)	2021		2020
Service cost	$	—	$	1
Other components of net benefit cost:
Interest cost	2		2
Amortization of prior service credit	(1)		(2)
Amortization of net loss	3		2
Total other components of net benefit cost	4		2
Net periodic defined benefit cost	$	4	$	3

Postretirement Benefit Plan	Three Months Ended March 31,
(in millions)	2021		2020
Other components of net benefit credit:
Expected return on plan assets	$	(1)	$	—
Net periodic defined benefit credit	$	(1)	$	—

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Strategic Lines of Business and Markets (Tables)

3 Months Ended

Mar. 31, 2021

Segment Reporting [Abstract]

Business Segment Financial Results

Business segment financial results are as follows:

	Commercial Bank			Retail Bank			Wealth Management			Finance		Other		Total
(dollar amounts in millions)
Three Months Ended March 31, 2021
Earnings summary:
Net interest income (expense)	$	382		$	133		$	42		$	(117)	$	3	$	443
Provision for credit losses	(177)			6			(12)			—		1		(182)
Noninterest income	159			28			67			12		4		270
Noninterest expenses	215			149			76			—		7		447
Provision (benefit) for income taxes	113			—			10			(25)		—		98
Net income (loss)	$	390		$	6		$	35		$	(80)	$	(1)	$	350
Net credit-related charge-offs	$	2		$	1		$	—		$	—	$	—	$	3
Selected average balances:
Assets	$	44,448		$	3,463		$	5,162		$	16,959	$	14,527	$	84,559
Loans	42,904			2,620			5,059			—		6		50,589
Deposits	41,102			24,322			4,826			985		157		71,392
Statistical data:
Return on average assets (a)	3.56		%	0.11		%	2.72		%	n/m		n/m		1.68		%
Efficiency ratio (b)	39.66			91.68			69.84			n/m		n/m		62.55
Three Months Ended March 31, 2020
Earnings summary:
Net interest income (expense)	$	380		$	125		$	41		$	(44)	$	11	$	513
Provision for credit losses	396			3			12			—		—		411
Noninterest income	127			28			70			14		(2)		237
Noninterest expenses (c)	192			145			70			—		10		417
(Benefit) provision for income taxes (c)	(19)			1			6			(8)		1		(19)
Net (loss) income (c)	$	(62)		$	4		$	23		$	(22)	$	(2)	$	(59)
Net credit-related charge-offs	$	83		$	1		$	—		$	—	$	—	$	84
Selected average balances:
Assets	$	44,254		$	2,864		$	5,078		$	14,285	$	6,784	$	73,265
Loans	42,593			2,075			4,936			—		—		49,604
Deposits	30,230			21,195			4,025			1,136		182		56,768
Statistical data:
Return on average assets (a) (c)	(0.56)		%	0.07		%	1.81		%	n/m		n/m		(0.32)		%
Efficiency ratio (b) (c)	37.95			94.07			62.68			n/m		n/m		55.58

(a)Return on average assets is calculated based on the greater of average assets or average liabilities and attributed equity.

(b)Noninterest expenses as a percentage of the sum of net interest income and noninterest income excluding net losses from securities and a derivative contract tied to the conversion rate of Visa Class B shares.

(c)See Defined Benefit Pension and Other Postretirement Costs in Note 1.

n/m – not meaningful

Market Segment Financial Results

Market segment financial results are as follows:

	Michigan			California			Texas			Other Markets			Finance & Other		Total
(dollar amounts in millions)
Three Months Ended March 31, 2021
Earnings summary:
Net interest income (expense)	$	154		$	172		$	114		$	117		$	(114)	$	443
Provision for credit losses	(28)			(54)			(86)			(15)			1		(182)
Noninterest income	66			48			36			104			16		270
Noninterest expenses	135			104			88			113			7		447
Provision (benefit) for income taxes	22			40			31			30			(25)		98
Net income (loss)	$	91		$	130		$	117		$	93		$	(81)	$	350
Net credit-related charge-offs	$	—		$	1		$	2		$	—		$	—	$	3
Selected average balances:
Assets	$	12,916		$	18,143		$	10,668		$	11,348		$	31,484	$	84,559
Loans	12,247			17,946			10,161			10,231			4		50,589
Deposits	25,683			19,968			10,783			13,816			1,142		71,392
Statistical data:
Return on average assets (a)	1.40		%	2.51		%	3.88		%	2.54		%	n/m		1.68		%
Efficiency ratio (b)	60.86			47.09			58.85			51.18			n/m		62.55
Three Months Ended March 31, 2020
Earnings summary:
Net interest income (expense)	$	163		$	176		$	115		$	92		$	(33)	$	513
Provision for credit losses	24			46			290			51			—		411
Noninterest income	72			33			30			90			12		237
Noninterest expenses (c)	137			93			83			94			10		417
Provision (benefit) for income taxes (c)	16			17			(50)			5			(7)		(19)
Net income (loss) (c)	$	58		$	53		$	(178)		$	32		$	(24)	$	(59)
Net credit-related charge-offs	$	3		$	8		$	70		$	3		$	—	$	84
Selected average balances:
Assets	$	12,895		$	18,007		$	11,154		$	10,140		$	21,069	$	73,265
Loans	12,191			17,742			10,566			9,105			—		49,604
Deposits	20,748			16,627			9,204			8,871			1,318		56,768
Statistical data:
Return on average assets (a) (c)	1.10		%	1.19		%	(6.47)		%	1.27		%	n/m		(0.32)		%
Efficiency ratio (b) (c)	57.92			44.60			57.38			51.69			n/m		55.58

(a)Return on average assets is calculated based on the greater of average assets or average liabilities and attributed equity.

(b)Noninterest expenses as a percentage of the sum of net interest income and noninterest income excluding net losses from securities and a derivative contract tied to the conversion rate of Visa Class B shares.

(c)See Defined Benefit Pension and Other Postretirement Costs in Note 1.

n/m – not meaningful.

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Revenue from Contracts with Customers (Tables)

3 Months Ended

Mar. 31, 2021

Revenue from Contract with Customer [Abstract]

Composition of Revenue from Contracts with Customers

The following table presents the composition of revenue from contracts with customers, segregated from other sources of noninterest income, by business segment.

	Commercial Bank		Retail Bank		Wealth Management		Finance & Other		Total
(in millions)
Three Months Ended March 31, 2021
Revenue from contracts with customers:
Card fees	$	60	$	10	$	1	$	—	$	71
Fiduciary income	—		—		53		—		53
Service charges on deposit accounts	34		13		1		—		48
Commercial loan servicing fees (a)	4		—		—		—		4
Brokerage fees	—		—		4		—		4
Other noninterest income (b)	5		4		5		—		14
Total revenue from contracts with customers	103		27		64		—		194
Other sources of noninterest income	56		1		3		16		76
Total noninterest income	$	159	$	28	$	67	$	16	$	270
Three Months Ended March 31, 2020
Revenue from contracts with customers:
Card fees	$	49	$	9	$	1	$	—	$	59
Fiduciary income	—		—		54		—		54
Service charges on deposit accounts	32		16		1		—		49
Commercial loan servicing fees (a)	4		—		—		—		4
Brokerage fees	—		—		7		—		7
Other noninterest income (b)	4		3		5		—		12
Total revenue from contracts with customers	89		28		68		—		185
Other sources of noninterest income	38		—		2		12		52
Total noninterest income	$	127	$	28	$	70	$	12	$	237

(a)Included in commercial lending fees on the Consolidated Statements of Comprehensive Income.

(b)Excludes derivative, warrant and other miscellaneous income.

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Basis of Presentation and Accounting Policies (Change in Accounting Principle - Consolidated Balance Sheets)(Details) - USD ($) $ in Millions	Mar. 31, 2021		Dec. 31, 2020	Mar. 31, 2020	[1]
Accumulated other comprehensive (loss) income	$ (105)	[1]	$ 64	$ 87
Retained earnings	9,975		9,727
Accounting change impact
Accumulated other comprehensive (loss) income	(3)		(104)
Retained earnings	$ 3		104
Previously Reported
Accumulated other comprehensive (loss) income			168
Retained earnings			$ 9,623

[1] Balances at beginning of period, net of tax and changes for the three months ended March 31, 2020 have been recast to reflect the retrospective application of the Corporation's election to change the accounting method for certain components of the qualified defined benefit pension plan as of January 1, 2021. Refer to Note 1 for further information.

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Basis of Presentation and Accounting Policies (Change in Accounting Principle - Consolidated Statements of Comprehensive Income) (Details) - USD ($) $ / shares in Units, $ in Millions	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020
Other noninterest expenses	$ (1)	$ 17
Provision (benefit) for income taxes	98	(19)	[1]
Net income (loss)	$ 350	$ (59)	[1]
Basic earnings (losses) per common share	$ 2.46	$ (0.42)
Diluted earnings (losses) per common share	$ 2.43	$ (0.42)
Accounting change impact
Other noninterest expenses	$ (5)	$ (8)
Provision (benefit) for income taxes	2	2
Net income (loss)	$ 3	$ 6
Basic earnings (losses) per common share	$ 0.03	$ 0.04
Diluted earnings (losses) per common share	$ 0.02	$ 0.04
Previously Reported
Other noninterest expenses		$ 25
Provision (benefit) for income taxes		(21)
Net income (loss)		$ (65)
Basic earnings (losses) per common share		$ (0.46)
Diluted earnings (losses) per common share		$ (0.46)

[1] See Defined Benefit Pension and Other Postretirement Costs in Note 1.

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Basis of Presentation and Accounting Policies (Change in Accounting Principle - Consolidated Statements of Cash Flows) (Details) - USD ($) $ in Millions	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020
Net income (loss)	$ 350	$ (59)	[1]
Provision (benefit) for deferred income taxes	39	(71)
Net periodic defined benefit credit	(20)	(13)
Accounting change impact
Net income (loss)	3	6
Provision (benefit) for deferred income taxes	2	2
Net periodic defined benefit credit	$ (5)	(8)
Previously Reported
Net income (loss)		(65)
Provision (benefit) for deferred income taxes		(73)
Net periodic defined benefit credit		$ (5)

[1] See Defined Benefit Pension and Other Postretirement Costs in Note 1.

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Fair Value Measurements (Narrative) (Details) - USD ($) $ in Millions	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020	Dec. 31, 2020
Recurring
Transfers into or out of Level 3	$ 0	$ 0
Total liabilities at fair value	448		$ 336
Nonrecurring
Total liabilities at fair value	$ 0		$ 0

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Fair Value Measurements (Assets And Liabilities Recorded At Fair Value On A Recurring Basis) (Details) - USD ($) $ in Millions		Mar. 31, 2021	Dec. 31, 2020
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale		$ 15,595	$ 15,028
Derivative assets		621	700
Derivative liabilities		340	229
U.S. Treasury and other U.S. government agency securities
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale		4,613	4,658
Residential mortgage-backed securities
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale	[1]	10,982	10,370
Recurring
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale		15,595	15,028
Derivative assets		621	700
Total assets at fair value		16,378	15,895
Derivative liabilities		340	229
Deferred compensation plan liabilities		108	107
Total liabilities at fair value		448	336
Recurring | Level 1
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale		4,613	4,658
Derivative assets		0	0
Total assets at fair value		4,775	4,825
Derivative liabilities		0	0
Deferred compensation plan liabilities		108	107
Total liabilities at fair value		108	107
Recurring | Level 2
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale		10,982	10,370
Derivative assets		597	661
Total assets at fair value		11,579	11,031
Derivative liabilities		340	229
Deferred compensation plan liabilities		0	0
Total liabilities at fair value		340	229
Recurring | Level 3
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale		0	0
Derivative assets		24	39
Total assets at fair value		24	39
Derivative liabilities		0	0
Deferred compensation plan liabilities		0	0
Total liabilities at fair value		0	0
Recurring | Interest rate contracts
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Derivative assets		340	531
Derivative liabilities		65	61
Recurring | Interest rate contracts | Level 1
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Derivative assets		0	0
Derivative liabilities		0	0
Recurring | Interest rate contracts | Level 2
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Derivative assets		316	492
Derivative liabilities		65	61
Recurring | Interest rate contracts | Level 3
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Derivative assets		24	39
Derivative liabilities		0	0
Recurring | Energy derivative contracts
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Derivative assets		269	151
Derivative liabilities		265	149
Recurring | Energy derivative contracts | Level 1
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Derivative assets		0	0
Derivative liabilities		0	0
Recurring | Energy derivative contracts | Level 2
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Derivative assets		269	151
Derivative liabilities		265	149
Recurring | Energy derivative contracts | Level 3
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Derivative assets		0	0
Derivative liabilities		0	0
Recurring | Foreign exchange contracts
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Derivative assets		12	18
Derivative liabilities		10	19
Recurring | Foreign exchange contracts | Level 1
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Derivative assets		0	0
Derivative liabilities		0	0
Recurring | Foreign exchange contracts | Level 2
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Derivative assets		12	18
Derivative liabilities		10	19
Recurring | Foreign exchange contracts | Level 3
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Derivative assets		0	0
Derivative liabilities		0	0
Recurring | Deferred compensation plan assets
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Trading securities		108	107
Recurring | Deferred compensation plan assets | Level 1
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Trading securities		108	107
Recurring | Deferred compensation plan assets | Level 2
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Trading securities		0	0
Recurring | Deferred compensation plan assets | Level 3
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Trading securities		0	0
Recurring | Equity and other non-debt securities
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Other equity securities		54	60
Recurring | Equity and other non-debt securities | Level 1
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Other equity securities		54	60
Recurring | Equity and other non-debt securities | Level 2
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Other equity securities		0	0
Recurring | Equity and other non-debt securities | Level 3
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Other equity securities		0	0
Recurring | U.S. Treasury and other U.S. government agency securities
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale		4,613	4,658
Recurring | U.S. Treasury and other U.S. government agency securities | Level 1
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale		4,613	4,658
Recurring | U.S. Treasury and other U.S. government agency securities | Level 2
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale		0	0
Recurring | U.S. Treasury and other U.S. government agency securities | Level 3
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale		0	0
Recurring | Residential mortgage-backed securities
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale	[1]	10,982	10,370
Recurring | Residential mortgage-backed securities | Level 1
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale	[1]	0	0
Recurring | Residential mortgage-backed securities | Level 2
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale	[1]	10,982	10,370
Recurring | Residential mortgage-backed securities | Level 3
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Investment securities available-for-sale	[1]	$ 0	$ 0

[1] Issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.

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Fair Value Measurements (Changes In Level 3 Assets And Liabilities Measured At Fair Value On A Recurring Basis) (Details) - Interest rate contracts - USD ($) $ in Millions		3 Months Ended
		Mar. 31, 2021	Mar. 31, 2020
Balance at beginning of period		$ 39	$ 22
Realized gains (losses) recorded in earnings	[1]	0	0
Unrealized gains (losses) recorded in earnings	[1]	(15)	21
Sales		0	0
Balance at end of period		$ 24	$ 43

[1] Realized and unrealized gains and losses due to changes in fair value are recorded in other noninterest income on the Consolidated Statements of Comprehensive Income.

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Fair Value Measurements (Assets And Liabilities Recorded At Fair Value On A Nonrecurring Basis) (Details) - Nonrecurring - Level 3 - USD ($) $ in Millions	Mar. 31, 2021	Dec. 31, 2020
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Loans	$ 137
Other real estate	8
Total assets at fair value	145	$ 150
Commercial borrower | Domestic loans
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Loans	125	134
Commercial borrower | Commercial mortgage | Domestic loans
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Loans	$ 12	$ 16

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Fair Value Measurements (Estimated Fair Values Of Financial Instruments Not Recorded At Fair Value In Their Entirety On A Recurring Basis) (Details) - USD ($) $ in Millions		Mar. 31, 2021	Dec. 31, 2020
Cash and due from banks		$ 1,064	$ 1,031
Interest-bearing deposits with banks		13,807	14,736
Total loans, net of allowance for loan losses		49,805	51,343
Demand deposits (noninterest-bearing)		38,822	39,420
Customer certificates of deposit		2,141	2,133
Total deposits		73,807	72,869
Total Medium- and long-term debt		2,852	5,728
Carrying Amount
Cash and due from banks		1,064	1,031
Interest-bearing deposits with banks		13,807	14,736
Loans held-for-sale		14	5
Total loans, net of allowance for loan losses	[1]	49,805	51,343
Customers' liability on acceptances outstanding		13	1
Restricted equity investments		92	207
Nonmarketable equity securities	[2]	7	5
Demand deposits (noninterest-bearing)		38,822	39,420
Interest-bearing deposits		32,844	31,316
Customer certificates of deposit		2,141	2,133
Total deposits		73,807	72,869
Acceptances outstanding		13	1
Total Medium- and long-term debt		2,852	5,728
Credit-related financial instruments		(50)	(68)
Estimated Fair Value
Cash and due from banks		1,064	1,031
Interest-bearing deposits with banks		13,807	14,736
Loans held-for-sale		14	5
Total loans, net of allowance for loan losses	[1]	48,880	50,601
Customers' liability on acceptances outstanding		13	1
Restricted equity investments		92	207
Nonmarketable equity securities	[2]	9	9
Demand deposits (noninterest-bearing)		38,822	39,420
Interest-bearing deposits		32,844	31,316
Customer certificates of deposit		2,140	2,133
Total deposits		73,806	72,869
Acceptances outstanding		13	1
Total Medium- and long-term debt		2,919	5,790
Credit-related financial instruments		(50)	(68)
Level 1 | Estimated Fair Value
Cash and due from banks		1,064	1,031
Interest-bearing deposits with banks		13,807	14,736
Loans held-for-sale		0	0
Total loans, net of allowance for loan losses	[1]	0	0
Customers' liability on acceptances outstanding		13	1
Restricted equity investments		92	207
Demand deposits (noninterest-bearing)		0	0
Interest-bearing deposits		0	0
Customer certificates of deposit		0	0
Total deposits		0	0
Acceptances outstanding		13	1
Total Medium- and long-term debt		0	0
Credit-related financial instruments		0	0
Level 2 | Estimated Fair Value
Cash and due from banks		0	0
Interest-bearing deposits with banks		0	0
Loans held-for-sale		14	5
Total loans, net of allowance for loan losses	[1]	0	0
Customers' liability on acceptances outstanding		0	0
Restricted equity investments		0	0
Demand deposits (noninterest-bearing)		38,822	39,420
Interest-bearing deposits		32,844	31,316
Customer certificates of deposit		2,140	2,133
Total deposits		73,806	72,869
Acceptances outstanding		0	0
Total Medium- and long-term debt		2,919	5,790
Credit-related financial instruments		0	0
Level 3 | Estimated Fair Value
Cash and due from banks		0	0
Interest-bearing deposits with banks		0	0
Loans held-for-sale		0	0
Total loans, net of allowance for loan losses	[1]	48,880	50,601
Customers' liability on acceptances outstanding		0	0
Restricted equity investments		0	0
Demand deposits (noninterest-bearing)		0	0
Interest-bearing deposits		0	0
Customer certificates of deposit		0	0
Total deposits		0	0
Acceptances outstanding		0	0
Total Medium- and long-term debt		0	0
Credit-related financial instruments		(50)	(68)
Nonrecurring
Total loans, net of allowance for loan losses		$ 137	$ 150

[1] Included $137 million and $150 million of loans recorded at fair value on a nonrecurring basis at March 31, 2021 and December 31, 2020, respectively.

[2] Certain investments that are measured at fair value using the net asset value have not been classified in the fair value hierarchy. The fair value amounts presented in the table are intended to permit reconciliation of the fair value hierarchy to the amounts presented in the Consolidated Balance Sheets.

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Investment Securities (Narrative) (Details) $ in Millions		Mar. 31, 2021 USD ($)	Dec. 31, 2020 USD ($)
Securities with no credit impairment in unrealized loss position		138
Interest receivable		$ 19	$ 18
Investment securities available-for-sale, Amortized Cost		15,502	14,752
Investment securities available-for-sale, Fair Value		15,595	15,028
Carrying value of securities pledged		4,700
Pledged to the FHLB as collateral for potential future borrowings		4,000
FHLB potential future borrowings		3,900
Collateral for potential future borrowings		648
Liabilities secured by pledged collateral		$ 485
U.S. Treasury and other U.S. government agency securities
Securities with no credit impairment in unrealized loss position		19
Investment securities available-for-sale, Amortized Cost		$ 4,578	4,583
Investment securities available-for-sale, Fair Value		$ 4,613	4,658
Residential mortgage-backed securities
Securities with no credit impairment in unrealized loss position		119
Investment securities available-for-sale, Amortized Cost	[1]	$ 10,924	10,169
Investment securities available-for-sale, Fair Value	[1]	10,982	$ 10,370
Debt securities
Investment securities available-for-sale, Amortized Cost		15,502
Investment securities available-for-sale, Fair Value		15,595
Prepayment options | Residential mortgage-backed securities
Investment securities available-for-sale, Amortized Cost		10,900
Investment securities available-for-sale, Fair Value		$ 11,000

[1] Issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.

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Investment Securities (Summary Of Investment Securities) (Details) - USD ($) $ in Millions		Mar. 31, 2021	Dec. 31, 2020
Investment securities available-for-sale, Amortized Cost		$ 15,502	$ 14,752
Investment securities available-for-sale, Gross Unrealized Gains		237	279
Investment securities available-for-sale, Gross Unrealized Losses		144	3
Investment securities available-for-sale, Fair Value		15,595	15,028
U.S. Treasury and other U.S. government agency securities
Investment securities available-for-sale, Amortized Cost		4,578	4,583
Investment securities available-for-sale, Gross Unrealized Gains		59	76
Investment securities available-for-sale, Gross Unrealized Losses		24	1
Investment securities available-for-sale, Fair Value		4,613	4,658
Residential mortgage-backed securities
Investment securities available-for-sale, Amortized Cost	[1]	10,924	10,169
Investment securities available-for-sale, Gross Unrealized Gains	[1]	178	203
Investment securities available-for-sale, Gross Unrealized Losses	[1]	120	2
Investment securities available-for-sale, Fair Value	[1]	$ 10,982	$ 10,370

[1] Issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.

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Investment Securities (Summary Of Investment Securities In Unrealized Loss Positions) (Details) - USD ($) $ in Millions		Mar. 31, 2021	Dec. 31, 2020
Temporarily Impaired Less than 12 months, Fair Value		$ 5,411	$ 2,071
Temporarily Impaired Less than 12 Months, Unrealized Losses		144	3
Temporarily Impaired 12 months or more, Fair Value		0	0
Temporarily Impaired 12 Months or more, Unrealized Losses		0	0
Temporarily Impaired Total, Fair Value		5,411	2,071
Temporarily Impaired Total, Unrealized Losses		144	3
U.S. Treasury and other U.S. government agency securities
Temporarily Impaired Less than 12 months, Fair Value		1,834	1,119
Temporarily Impaired Less than 12 Months, Unrealized Losses		24	1
Temporarily Impaired 12 months or more, Fair Value		0	0
Temporarily Impaired 12 Months or more, Unrealized Losses		0	0
Temporarily Impaired Total, Fair Value		1,834	1,119
Temporarily Impaired Total, Unrealized Losses		24	1
Residential mortgage-backed securities
Temporarily Impaired Less than 12 months, Fair Value	[1]	3,577	952
Temporarily Impaired Less than 12 Months, Unrealized Losses	[1]	120	2
Temporarily Impaired 12 months or more, Fair Value	[1]	0	0
Temporarily Impaired 12 Months or more, Unrealized Losses	[1]	0	0
Temporarily Impaired Total, Fair Value	[1]	3,577	952
Temporarily Impaired Total, Unrealized Losses	[1]	$ 120	$ 2

[1] Issued and/or guaranteed by U.S. government agencies or U.S. government-sponsored enterprises.

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Investment Securities Investment Securities (Summary of Net Securities Gains (Losses)) (Details) - Debt securities - USD ($) $ in Millions	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020
Investments, Debt, and Equity Securities [Abstract]
Securities losses	$ 0	$ (1)
Net securities losses	$ 0	$ (1)

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Investment Securities (Contractual Maturity Distribution Of Debt Securities) (Details) - USD ($) $ in Millions	Mar. 31, 2021	Dec. 31, 2020
Investment securities available-for-sale, Amortized Cost	$ 15,502	$ 14,752
Investment securities available-for-sale, Fair Value	15,595	$ 15,028
Debt securities
Available-for-sale, Within one year, Amortized Cost	1,617
Available-for-sale, After one year through five years, Amortized Cost	3,177
Available-for-sale, After five years through ten years, Amortized Cost	570
Available-for-sale, After ten years, Amortized Cost	10,138
Investment securities available-for-sale, Amortized Cost	15,502
Available-for-sale, Within one year, Fair Value	1,634
Available-for-sale, After one year through five years, Fair Value	3,208
Available-for-sale, After five years through ten years, Fair Value	587
Available-for-sale, After ten years, Fair Value	10,166
Investment securities available-for-sale, Fair Value	$ 15,595

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Credit Quality And Allowance For Credit Losses (Narrative) (Details) - USD ($) $ in Millions	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020	Dec. 31, 2020
Loan interest receivable	$ 142		$ 141
Financing Receivable, Nonaccrual, Interest Income	0	$ 0
Foreclosed property	8		8
Retail loans secured by residential real estate in process of foreclosure	0		0
Commitments to lend additional funds to TDR borrowers	$ 0		$ 0
Principal Deferrals
Minimum period loan terms were extended	90 days	90 days
Subsequent default during period	$ 0	$ 10
Interest Rate Reductions
Minimum period loan terms were extended	90 days	90 days
Subsequent default during period	$ 0	$ 0

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Credit Quality And Allowance For Credit Losses (Aging Analysis Of Loans) (Details) - USD ($) $ in Millions		Mar. 31, 2021	Dec. 31, 2020
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		$ 362	$ 449
Nonaccrual loans		314	347
Current loans	[1]	49,906	51,495
Total loans		50,582	52,291
30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		201	243
60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		101	161
90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		60	45
Business loans | Commercial borrower
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		312	410
Nonaccrual loans		266	283
Current loans	[1]	46,112	47,574
Total loans		46,690	48,267
Business loans | Commercial borrower | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		178	215
Business loans | Commercial borrower | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		93	156
Business loans | Commercial borrower | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		41	39
Business loans | Commercial borrower | Domestic loans
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		177	210
Nonaccrual loans		230	252
Current loans	[1]	30,479	32,291
Total loans		30,886	32,753
Business loans | Commercial borrower | Domestic loans | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		103	62
Business loans | Commercial borrower | Domestic loans | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		57	115
Business loans | Commercial borrower | Domestic loans | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		17	33
Business loans | Commercial borrower | International loans
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		2	0
Nonaccrual loans		0	0
Current loans	[1]	988	926
Total loans		990	926
Business loans | Commercial borrower | International loans | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		0	0
Business loans | Commercial borrower | International loans | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		2	0
Business loans | Commercial borrower | International loans | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		0	0
Business loans | Commercial borrower | Real estate construction | Domestic loans
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		19	40
Nonaccrual loans		1	1
Current loans	[1]	4,224	4,041
Total loans		4,244	4,082
Business loans | Commercial borrower | Real estate construction | Domestic loans | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		9	40
Business loans | Commercial borrower | Real estate construction | Domestic loans | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		8	0
Business loans | Commercial borrower | Real estate construction | Domestic loans | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		2	0
Business loans | Commercial borrower | Real estate construction | Domestic loans | Commercial Real Estate business line
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[2]	0	31
Nonaccrual loans	[2]	0	0
Current loans	[1],[2]	3,810	3,626
Total loans	[2]	3,810	3,657
Business loans | Commercial borrower | Real estate construction | Domestic loans | Commercial Real Estate business line | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[2]	0	31
Business loans | Commercial borrower | Real estate construction | Domestic loans | Commercial Real Estate business line | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[2]	0	0
Business loans | Commercial borrower | Real estate construction | Domestic loans | Commercial Real Estate business line | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[2]	0	0
Business loans | Commercial borrower | Real estate construction | Domestic loans | Other business lines
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[3]	19	9
Nonaccrual loans	[3]	1	1
Current loans	[1],[3]	414	415
Total loans	[3]	434	425
Business loans | Commercial borrower | Real estate construction | Domestic loans | Other business lines | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[3]	9	9
Business loans | Commercial borrower | Real estate construction | Domestic loans | Other business lines | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[3]	8	0
Business loans | Commercial borrower | Real estate construction | Domestic loans | Other business lines | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[3]	2	0
Business loans | Commercial borrower | Commercial mortgage | Domestic loans
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		99	145
Nonaccrual loans		34	29
Current loans	[1]	9,860	9,738
Total loans		9,993	9,912
Business loans | Commercial borrower | Commercial mortgage | Domestic loans | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		52	99
Business loans | Commercial borrower | Commercial mortgage | Domestic loans | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		26	41
Business loans | Commercial borrower | Commercial mortgage | Domestic loans | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		21	5
Business loans | Commercial borrower | Commercial mortgage | Domestic loans | Commercial Real Estate business line
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[2]	13	52
Nonaccrual loans	[2]	3	3
Current loans	[1],[2]	2,295	2,218
Total loans	[2]	2,311	2,273
Business loans | Commercial borrower | Commercial mortgage | Domestic loans | Commercial Real Estate business line | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[2]	12	51
Business loans | Commercial borrower | Commercial mortgage | Domestic loans | Commercial Real Estate business line | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[2]	1	1
Business loans | Commercial borrower | Commercial mortgage | Domestic loans | Commercial Real Estate business line | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[2]	0	0
Business loans | Commercial borrower | Commercial mortgage | Domestic loans | Other business lines
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[3]	86	93
Nonaccrual loans	[3]	31	26
Current loans	[1],[3]	7,565	7,520
Total loans	[3]	7,682	7,639
Business loans | Commercial borrower | Commercial mortgage | Domestic loans | Other business lines | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[3]	40	48
Business loans | Commercial borrower | Commercial mortgage | Domestic loans | Other business lines | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[3]	25	40
Business loans | Commercial borrower | Commercial mortgage | Domestic loans | Other business lines | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing	[3]	21	5
Business loans | Commercial borrower | Lease financing | Domestic loans
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		15	15
Nonaccrual loans		1	1
Current loans	[1]	561	578
Total loans		577	594
Business loans | Commercial borrower | Lease financing | Domestic loans | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		14	14
Business loans | Commercial borrower | Lease financing | Domestic loans | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		0	0
Business loans | Commercial borrower | Lease financing | Domestic loans | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		1	1
Retail loans
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		50	39
Nonaccrual loans		48	64
Current loans	[1]	3,794	3,921
Total loans		3,892	4,024
Retail loans | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		23	28
Retail loans | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		8	5
Retail loans | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		19	6
Retail loans | Residential mortgage
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		12	15
Nonaccrual loans		33	47
Current loans	[1]	1,754	1,768
Total loans		1,799	1,830
Retail loans | Residential mortgage | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		8	11
Retail loans | Residential mortgage | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		4	4
Retail loans | Residential mortgage | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		0	0
Retail loans | Retail
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		38	24
Nonaccrual loans		15	17
Current loans	[1]	2,040	2,153
Total loans		2,093	2,194
Retail loans | Retail | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		15	17
Retail loans | Retail | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		4	1
Retail loans | Retail | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		19	6
Retail loans | Retail | Home equity
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		9	8
Nonaccrual loans		15	17
Current loans	[1]	1,546	1,563
Total loans		1,570	1,588
Retail loans | Retail | Home equity | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		5	7
Retail loans | Retail | Home equity | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		4	1
Retail loans | Retail | Home equity | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		0	0
Retail loans | Retail | Other consumer
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		29	16
Nonaccrual loans		0	0
Current loans	[1]	494	590
Total loans		523	606
Retail loans | Retail | Other consumer | 30 to 59 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		10	10
Retail loans | Retail | Other consumer | 60 to 89 days past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		0	0
Retail loans | Retail | Other consumer | 90 days or more past due and still accruing
Financing Receivable, Past Due [Line Items]
Loans past due and still accruing		$ 19	$ 6

[1] Includes $87 million and $141 million of loans with deferred payments not considered past due in accordance with the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) at March 31, 2021 and December 31, 2020, respectively.

[2] Primarily loans to real estate developers.

[3] Primarily loans secured by owner-occupied real estate.

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Credit Quality And Allowance For Credit Losses (Loans By Credit Quality Indicator and Vintage Year) (Details) - USD ($) $ in Millions		Mar. 31, 2021		Dec. 31, 2020
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans		$ 50,582		$ 52,291
Financing Receivable, Originated in Current Fiscal Year		2,386		9,714
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year		8,874		5,957
Financing Receivable, Originated Two Years before Latest Fiscal Year		5,828		4,523
Financing Receivable, Originated Three Years before Latest Fiscal Year		4,278		3,243
Financing Receivable, Originated Four Years before Latest Fiscal Year		2,938		1,913
Financing Receivable, Originated Five or More Years before Latest Fiscal Year		5,691		4,282
Financing Receivable, Revolving		20,505		22,570
Financing Receivable, Revolving, Converted to Term Loan		82		89
Business loans | Commercial borrower
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans		46,690		48,267
Financing Receivable, Originated in Current Fiscal Year		2,272		8,955
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year		8,135		5,702
Financing Receivable, Originated Two Years before Latest Fiscal Year		5,594		4,388
Financing Receivable, Originated Three Years before Latest Fiscal Year		4,155		3,038
Financing Receivable, Originated Four Years before Latest Fiscal Year		2,767		1,712
Financing Receivable, Originated Five or More Years before Latest Fiscal Year		5,058		3,795
Financing Receivable, Revolving		18,691		20,658
Financing Receivable, Revolving, Converted to Term Loan		18		19
Business loans | Commercial borrower | Domestic loans
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans		30,886		32,753
Financing Receivable, Originated in Current Fiscal Year		1,662		6,021
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year		5,114		2,597
Financing Receivable, Originated Two Years before Latest Fiscal Year		2,408		1,754
Financing Receivable, Originated Three Years before Latest Fiscal Year		1,618		1,167
Financing Receivable, Originated Four Years before Latest Fiscal Year		1,030		493
Financing Receivable, Originated Five or More Years before Latest Fiscal Year		1,272		921
Financing Receivable, Revolving		17,764		19,781
Financing Receivable, Revolving, Converted to Term Loan		18		19
Business loans | Commercial borrower | Domestic loans | Pass
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[1]	28,963		30,538
Financing Receivable, Originated in Current Fiscal Year	[1],[2]	1,632		5,991
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[1]	5,073	[2]	2,316
Financing Receivable, Originated Two Years before Latest Fiscal Year	[1]	2,191		1,563
Financing Receivable, Originated Three Years before Latest Fiscal Year	[1]	1,445		1,051
Financing Receivable, Originated Four Years before Latest Fiscal Year	[1]	944		429
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[1]	1,061		755
Financing Receivable, Revolving	[1]	16,601		18,416
Financing Receivable, Revolving, Converted to Term Loan	[1]	16		17
Business loans | Commercial borrower | Domestic loans | Criticized
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[3]	1,923		2,215
Financing Receivable, Originated in Current Fiscal Year	[3]	30		30
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[3]	41		281
Financing Receivable, Originated Two Years before Latest Fiscal Year	[3]	217		191
Financing Receivable, Originated Three Years before Latest Fiscal Year	[3]	173		116
Financing Receivable, Originated Four Years before Latest Fiscal Year	[3]	86		64
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[3]	211		166
Financing Receivable, Revolving	[3]	1,163		1,365
Financing Receivable, Revolving, Converted to Term Loan	[3]	2		2
Business loans | Commercial borrower | International loans
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans		990		926
Financing Receivable, Originated in Current Fiscal Year		137		287
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year		169		169
Financing Receivable, Originated Two Years before Latest Fiscal Year		167		121
Financing Receivable, Originated Three Years before Latest Fiscal Year		102		15
Financing Receivable, Originated Four Years before Latest Fiscal Year		14		10
Financing Receivable, Originated Five or More Years before Latest Fiscal Year		74		66
Financing Receivable, Revolving		327		258
Financing Receivable, Revolving, Converted to Term Loan		0		0
Business loans | Commercial borrower | International loans | Pass
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[1]	928		861
Financing Receivable, Originated in Current Fiscal Year	[1]	137		274
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[1]	155		161
Financing Receivable, Originated Two Years before Latest Fiscal Year	[1]	159		103
Financing Receivable, Originated Three Years before Latest Fiscal Year	[1]	85		11
Financing Receivable, Originated Four Years before Latest Fiscal Year	[1]	10		3
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[1]	66		64
Financing Receivable, Revolving	[1]	316		245
Financing Receivable, Revolving, Converted to Term Loan	[1]	0		0
Business loans | Commercial borrower | International loans | Criticized
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[3]	62		65
Financing Receivable, Originated in Current Fiscal Year	[3]	0		13
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[3]	14		8
Financing Receivable, Originated Two Years before Latest Fiscal Year	[3]	8		18
Financing Receivable, Originated Three Years before Latest Fiscal Year	[3]	17		4
Financing Receivable, Originated Four Years before Latest Fiscal Year	[3]	4		7
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[3]	8		2
Financing Receivable, Revolving	[3]	11		13
Financing Receivable, Revolving, Converted to Term Loan	[3]	0		0
Business loans | Commercial borrower | Real estate construction | Domestic loans
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans		4,244		4,082
Financing Receivable, Originated in Current Fiscal Year		44		436
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year		607		1,108
Financing Receivable, Originated Two Years before Latest Fiscal Year		1,235		1,249
Financing Receivable, Originated Three Years before Latest Fiscal Year		1,159		639
Financing Receivable, Originated Four Years before Latest Fiscal Year		579		335
Financing Receivable, Originated Five or More Years before Latest Fiscal Year		435		142
Financing Receivable, Revolving		185		173
Financing Receivable, Revolving, Converted to Term Loan		0		0
Business loans | Commercial borrower | Real estate construction | Domestic loans | Pass
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[1]	4,176		4,035
Financing Receivable, Originated in Current Fiscal Year	[1]	44		433
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[1]	604		1,080
Financing Receivable, Originated Two Years before Latest Fiscal Year	[1]	1,206		1,244
Financing Receivable, Originated Three Years before Latest Fiscal Year	[1]	1,142		631
Financing Receivable, Originated Four Years before Latest Fiscal Year	[1]	571		335
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[1]	426		141
Financing Receivable, Revolving	[1]	183		171
Financing Receivable, Revolving, Converted to Term Loan	[1]	0		0
Business loans | Commercial borrower | Real estate construction | Domestic loans | Criticized
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[3]	68		47
Financing Receivable, Originated in Current Fiscal Year	[3]	0		3
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[3]	3		28
Financing Receivable, Originated Two Years before Latest Fiscal Year	[3]	29		5
Financing Receivable, Originated Three Years before Latest Fiscal Year	[3]	17		8
Financing Receivable, Originated Four Years before Latest Fiscal Year	[3]	8		0
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[3]	9		1
Financing Receivable, Revolving	[3]	2		2
Financing Receivable, Revolving, Converted to Term Loan	[3]	0		0
Business loans | Commercial borrower | Commercial mortgage | Domestic loans
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans		9,993		9,912
Financing Receivable, Originated in Current Fiscal Year		401		2,100
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year		2,138		1,689
Financing Receivable, Originated Two Years before Latest Fiscal Year		1,650		1,188
Financing Receivable, Originated Three Years before Latest Fiscal Year		1,204		1,165
Financing Receivable, Originated Four Years before Latest Fiscal Year		1,095		859
Financing Receivable, Originated Five or More Years before Latest Fiscal Year		3,090		2,465
Financing Receivable, Revolving		415		446
Financing Receivable, Revolving, Converted to Term Loan		0		0
Business loans | Commercial borrower | Commercial mortgage | Domestic loans | Pass
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[1]	9,572		9,399
Financing Receivable, Originated in Current Fiscal Year	[1]	398		2,053
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[1]	2,107		1,559
Financing Receivable, Originated Two Years before Latest Fiscal Year	[1]	1,587		1,146
Financing Receivable, Originated Three Years before Latest Fiscal Year	[1]	1,161		1,120
Financing Receivable, Originated Four Years before Latest Fiscal Year	[1]	1,062		818
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[1]	2,858		2,272
Financing Receivable, Revolving	[1]	399		431
Financing Receivable, Revolving, Converted to Term Loan	[1]	0		0
Business loans | Commercial borrower | Commercial mortgage | Domestic loans | Criticized
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[3]	421		513
Financing Receivable, Originated in Current Fiscal Year	[3]	3		47
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[3]	31		130
Financing Receivable, Originated Two Years before Latest Fiscal Year	[3]	63		42
Financing Receivable, Originated Three Years before Latest Fiscal Year	[3]	43		45
Financing Receivable, Originated Four Years before Latest Fiscal Year	[3]	33		41
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[3]	232		193
Financing Receivable, Revolving	[3]	16		15
Financing Receivable, Revolving, Converted to Term Loan	[3]	0		0
Business loans | Commercial borrower | Lease financing | Domestic loans
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans		577		594
Financing Receivable, Originated in Current Fiscal Year		28		111
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year		107		139
Financing Receivable, Originated Two Years before Latest Fiscal Year		134		76
Financing Receivable, Originated Three Years before Latest Fiscal Year		72		52
Financing Receivable, Originated Four Years before Latest Fiscal Year		49		15
Financing Receivable, Originated Five or More Years before Latest Fiscal Year		187		201
Financing Receivable, Revolving		0		0
Financing Receivable, Revolving, Converted to Term Loan		0		0
Business loans | Commercial borrower | Lease financing | Domestic loans | Pass
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[1]	541		567
Financing Receivable, Originated in Current Fiscal Year	[1]	28		109
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[1]	104		122
Financing Receivable, Originated Two Years before Latest Fiscal Year	[1]	115		71
Financing Receivable, Originated Three Years before Latest Fiscal Year	[1]	61		50
Financing Receivable, Originated Four Years before Latest Fiscal Year	[1]	47		14
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[1]	186		201
Financing Receivable, Revolving	[1]	0		0
Financing Receivable, Revolving, Converted to Term Loan	[1]	0		0
Business loans | Commercial borrower | Lease financing | Domestic loans | Criticized
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[3]	36		27
Financing Receivable, Originated in Current Fiscal Year	[3]	0		2
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[3]	3		17
Financing Receivable, Originated Two Years before Latest Fiscal Year	[3]	19		5
Financing Receivable, Originated Three Years before Latest Fiscal Year	[3]	11		2
Financing Receivable, Originated Four Years before Latest Fiscal Year	[3]	2		1
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[3]	1		0
Financing Receivable, Revolving	[3]	0		0
Financing Receivable, Revolving, Converted to Term Loan	[3]	0		0
Retail loans
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans		3,892		4,024
Financing Receivable, Originated in Current Fiscal Year		114		759
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year		739		255
Financing Receivable, Originated Two Years before Latest Fiscal Year		234		135
Financing Receivable, Originated Three Years before Latest Fiscal Year		123		205
Financing Receivable, Originated Four Years before Latest Fiscal Year		171		201
Financing Receivable, Originated Five or More Years before Latest Fiscal Year		633		487
Financing Receivable, Revolving		1,814		1,912
Financing Receivable, Revolving, Converted to Term Loan		64		70
Retail loans | Residential mortgage
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans		1,799		1,830
Financing Receivable, Originated in Current Fiscal Year		99		646
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year		632		232
Financing Receivable, Originated Two Years before Latest Fiscal Year		215		121
Financing Receivable, Originated Three Years before Latest Fiscal Year		110		203
Financing Receivable, Originated Four Years before Latest Fiscal Year		169		198
Financing Receivable, Originated Five or More Years before Latest Fiscal Year		574		430
Financing Receivable, Revolving		0		0
Financing Receivable, Revolving, Converted to Term Loan		0		0
Retail loans | Residential mortgage | Pass
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[1]	1,766		1,779
Financing Receivable, Originated in Current Fiscal Year	[1]	97		639
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[1]	631		230
Financing Receivable, Originated Two Years before Latest Fiscal Year	[1]	213		119
Financing Receivable, Originated Three Years before Latest Fiscal Year	[1]	108		197
Financing Receivable, Originated Four Years before Latest Fiscal Year	[1]	162		196
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[1]	555		398
Financing Receivable, Revolving	[1]	0		0
Financing Receivable, Revolving, Converted to Term Loan	[1]	0		0
Retail loans | Residential mortgage | Criticized
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[3]	33		51
Financing Receivable, Originated in Current Fiscal Year	[3]	2		7
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[3]	1		2
Financing Receivable, Originated Two Years before Latest Fiscal Year	[3]	2		2
Financing Receivable, Originated Three Years before Latest Fiscal Year	[3]	2		6
Financing Receivable, Originated Four Years before Latest Fiscal Year	[3]	7		2
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[3]	19		32
Financing Receivable, Revolving	[3]	0		0
Financing Receivable, Revolving, Converted to Term Loan	[3]	0		0
Retail loans | Retail
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans		2,093		2,194
Financing Receivable, Originated in Current Fiscal Year		15		113
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year		107		23
Financing Receivable, Originated Two Years before Latest Fiscal Year		19		14
Financing Receivable, Originated Three Years before Latest Fiscal Year		13		2
Financing Receivable, Originated Four Years before Latest Fiscal Year		2		3
Financing Receivable, Originated Five or More Years before Latest Fiscal Year		59		57
Financing Receivable, Revolving		1,814		1,912
Financing Receivable, Revolving, Converted to Term Loan		64		70
Retail loans | Retail | Home equity
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans		1,570		1,588
Financing Receivable, Originated in Current Fiscal Year		0		0
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year		0		0
Financing Receivable, Originated Two Years before Latest Fiscal Year		0		0
Financing Receivable, Originated Three Years before Latest Fiscal Year		0		0
Financing Receivable, Originated Four Years before Latest Fiscal Year		0		0
Financing Receivable, Originated Five or More Years before Latest Fiscal Year		16		16
Financing Receivable, Revolving		1,490		1,502
Financing Receivable, Revolving, Converted to Term Loan		64		70
Retail loans | Retail | Home equity | Pass
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[1]	1,548		1,567
Financing Receivable, Originated in Current Fiscal Year	[1]	0		0
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[1]	0		0
Financing Receivable, Originated Two Years before Latest Fiscal Year	[1]	0		0
Financing Receivable, Originated Three Years before Latest Fiscal Year	[1]	0		0
Financing Receivable, Originated Four Years before Latest Fiscal Year	[1]	0		0
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[1]	16		15
Financing Receivable, Revolving	[1]	1,474		1,489
Financing Receivable, Revolving, Converted to Term Loan	[1]	58		63
Retail loans | Retail | Home equity | Criticized
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[3]	22		21
Financing Receivable, Originated in Current Fiscal Year	[3]	0		0
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[3]	0		0
Financing Receivable, Originated Two Years before Latest Fiscal Year	[3]	0		0
Financing Receivable, Originated Three Years before Latest Fiscal Year	[3]	0		0
Financing Receivable, Originated Four Years before Latest Fiscal Year	[3]	0		0
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[3]	0		1
Financing Receivable, Revolving	[3]	16		13
Financing Receivable, Revolving, Converted to Term Loan	[3]	6		7
Retail loans | Retail | Other consumer
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans		523		606
Financing Receivable, Originated in Current Fiscal Year		15		113
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year		107		23
Financing Receivable, Originated Two Years before Latest Fiscal Year		19		14
Financing Receivable, Originated Three Years before Latest Fiscal Year		13		2
Financing Receivable, Originated Four Years before Latest Fiscal Year		2		3
Financing Receivable, Originated Five or More Years before Latest Fiscal Year		43		41
Financing Receivable, Revolving		324		410
Financing Receivable, Revolving, Converted to Term Loan		0		0
Retail loans | Retail | Other consumer | Pass
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[1]	507		598
Financing Receivable, Originated in Current Fiscal Year	[1]	15		113
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[1]	107		23
Financing Receivable, Originated Two Years before Latest Fiscal Year	[1]	19		12
Financing Receivable, Originated Three Years before Latest Fiscal Year	[1]	12		2
Financing Receivable, Originated Four Years before Latest Fiscal Year	[1]	2		3
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[1]	36		41
Financing Receivable, Revolving	[1]	316		404
Financing Receivable, Revolving, Converted to Term Loan	[1]	0		0
Retail loans | Retail | Other consumer | Criticized
Financing Receivable, Credit Quality Indicator [Line Items]
Total loans	[3]	16		8
Financing Receivable, Originated in Current Fiscal Year	[3]	0		0
Financing Receivable, Originated in Fiscal Year before Latest Fiscal Year	[3]	0		0
Financing Receivable, Originated Two Years before Latest Fiscal Year	[3]	0		2
Financing Receivable, Originated Three Years before Latest Fiscal Year	[3]	1		0
Financing Receivable, Originated Four Years before Latest Fiscal Year	[3]	0		0
Financing Receivable, Originated Five or More Years before Latest Fiscal Year	[3]	7		0
Financing Receivable, Revolving	[3]	8		6
Financing Receivable, Revolving, Converted to Term Loan	[3]	$ 0		$ 0

[1] Includes all loans not included in the categories of special mention, substandard or nonaccrual.

[2] Includes Small Business Administration Paycheck Protection Program (PPP) loans of $925 million and $2.9 billion in 2021 and 2020, respectively, at March 31, 2021, and PPP loans of $3.5 billion in 2020 at December 31, 2020.

[3] Includes loans with an internal rating of special mention, substandard loans for which the accrual of interest has not been discontinued and nonaccrual loans. Special mention loans have potential credit weaknesses that deserve management’s close attention, such as loans to borrowers who may be experiencing financial difficulties that may result in deterioration of repayment prospects from the borrower at some future date. Accruing substandard loans have a well-defined weakness, or weaknesses, such as loans to borrowers who may be experiencing losses from operations or inadequate liquidity of a degree and duration that jeopardizes the orderly repayment of the loan. Substandard loans are also distinguished by the distinct possibility of loss in the future if these weaknesses are not corrected. Nonaccrual loans are loans for which the accrual of interest has been discontinued. For further information regarding nonaccrual loans, refer to the Nonperforming Assets subheading in Note 1 - Basis of Presentation and Accounting Policies on page F-59 in the Corporation's 2020 Annual Report. These categories are generally consistent with the "special mention" and "substandard" categories as defined by regulatory authorities. A minority of nonaccrual loans are consistent with the "doubtful" category.

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Credit Quality And Allowance For Credit Losses (Changes In The Allowance For Loan Losses And Related Loan Amounts) (Details) - USD ($) $ in Millions	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020	Jan. 01, 2021	Jan. 01, 2020
Financing Receivable, Allowance for Credit Loss [Line Items]
Balance at beginning of period	$ 992	$ 668
Provision for credit losses	(182)	411
Balance at end of period	$ 807	$ 978
As a percentage of total loans	1.59%	1.83%
As a percentage of total loans excluding PPP Loans	1.72%
Accounting Standards Update 2016-13 [Member]
Financing Receivable, Allowance for Credit Loss [Line Items]
Reduction in business loans allowance for credit losses			$ 0	$ (42)
Increase in retail loans allowance for credit losses			0	25
Day-one decrease in the overall allowance for credit losses			$ 0	$ (17)
Financing Receivable
Financing Receivable, Allowance for Credit Loss [Line Items]
Balance at beginning of period	$ 948	$ 637
Loan charge-offs	(16)	(89)
Recoveries on loans previously charged-off	13	5
Net loan charge-offs	(3)	(84)
Provision for credit losses	(168)	380
Balance at end of period	$ 777	$ 916
As a percentage of total loans	1.54%	1.71%
As a percentage of total loans excluding PPP Loans	1.66%
Unused Commitments to Extend Credit
Financing Receivable, Allowance for Credit Loss [Line Items]
Balance at beginning of period	$ 44	$ 31
Provision for credit losses	(14)	31
Balance at end of period	30	62
Business loans
Financing Receivable, Allowance for Credit Loss [Line Items]
Balance at beginning of period	930	629
Provision for credit losses	(196)	408
Balance at end of period	$ 731	$ 913
As a percentage of total loans	1.57%	1.85%
As a percentage of total loans excluding PPP Loans	1.70%
Business loans | Financing Receivable
Financing Receivable, Allowance for Credit Loss [Line Items]
Balance at beginning of period	$ 895	$ 601
Loan charge-offs	(15)	(87)
Recoveries on loans previously charged-off	12	5
Net loan charge-offs	(3)	(82)
Provision for credit losses	(183)	384
Balance at end of period	$ 709	$ 861
As a percentage of total loans	1.52%	1.75%
As a percentage of total loans excluding PPP Loans	1.65%
Business loans | Unused Commitments to Extend Credit
Financing Receivable, Allowance for Credit Loss [Line Items]
Balance at beginning of period	$ 35	$ 28
Provision for credit losses	(13)	24
Balance at end of period	22	52
Retail loans
Financing Receivable, Allowance for Credit Loss [Line Items]
Balance at beginning of period	62	39
Provision for credit losses	14	3
Balance at end of period	$ 76	$ 65
As a percentage of total loans	1.94%	1.57%
Retail loans | Financing Receivable
Financing Receivable, Allowance for Credit Loss [Line Items]
Balance at beginning of period	$ 53	$ 36
Loan charge-offs	(1)	(2)
Recoveries on loans previously charged-off	1	0
Net loan charge-offs	0	(2)
Provision for credit losses	15	(4)
Balance at end of period	$ 68	$ 55
As a percentage of total loans	1.74%	1.35%
Retail loans | Unused Commitments to Extend Credit
Financing Receivable, Allowance for Credit Loss [Line Items]
Balance at beginning of period	$ 9	$ 3
Provision for credit losses	(1)	7
Balance at end of period	$ 8	$ 10

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Credit Quality And Allowance For Credit Losses (Nonaccrual Loans) (Details) - USD ($) $ in Millions		Mar. 31, 2021	Dec. 31, 2020
Financing Receivable, Nonaccrual [Line Items]
Financing Receivable, Nonaccrual, No Allowance		$ 106	$ 127
Financing Receivable, Nonaccrual		208	220
Nonaccrual loans		314	347
Business loans | Commercial borrower
Financing Receivable, Nonaccrual [Line Items]
Financing Receivable, Nonaccrual, No Allowance		58	63
Financing Receivable, Nonaccrual		208	220
Nonaccrual loans		266	283
Business loans | Commercial borrower | Domestic loans
Financing Receivable, Nonaccrual [Line Items]
Financing Receivable, Nonaccrual, No Allowance		50	57
Financing Receivable, Nonaccrual		180	195
Nonaccrual loans		230	252
Business loans | Commercial borrower | International loans
Financing Receivable, Nonaccrual [Line Items]
Nonaccrual loans		0	0
Retail loans
Financing Receivable, Nonaccrual [Line Items]
Financing Receivable, Nonaccrual, No Allowance		48	64
Financing Receivable, Nonaccrual		0	0
Nonaccrual loans		48	64
Retail loans | Retail
Financing Receivable, Nonaccrual [Line Items]
Nonaccrual loans		15	17
Real estate construction | Business loans | Commercial borrower | Domestic loans
Financing Receivable, Nonaccrual [Line Items]
Nonaccrual loans		1	1
Real estate construction | Commercial Real Estate business line | Business loans | Commercial borrower | Domestic loans
Financing Receivable, Nonaccrual [Line Items]
Nonaccrual loans	[1]	0	0
Real estate construction | Other business lines | Business loans | Commercial borrower | Domestic loans
Financing Receivable, Nonaccrual [Line Items]
Financing Receivable, Nonaccrual, No Allowance	[2]	0	0
Financing Receivable, Nonaccrual	[2]	1	1
Nonaccrual loans	[2]	1	1
Commercial mortgage | Business loans | Commercial borrower | Domestic loans
Financing Receivable, Nonaccrual [Line Items]
Financing Receivable, Nonaccrual, No Allowance		8	6
Financing Receivable, Nonaccrual		26	23
Nonaccrual loans		34	29
Commercial mortgage | Commercial Real Estate business line | Business loans | Commercial borrower | Domestic loans
Financing Receivable, Nonaccrual [Line Items]
Financing Receivable, Nonaccrual, No Allowance	[1]	1	1
Financing Receivable, Nonaccrual	[1]	2	2
Nonaccrual loans	[1]	3	3
Commercial mortgage | Other business lines | Business loans | Commercial borrower | Domestic loans
Financing Receivable, Nonaccrual [Line Items]
Financing Receivable, Nonaccrual, No Allowance	[2]	7	5
Financing Receivable, Nonaccrual	[2]	24	21
Nonaccrual loans	[2]	31	26
Residential mortgage | Retail loans
Financing Receivable, Nonaccrual [Line Items]
Financing Receivable, Nonaccrual, No Allowance		33	47
Financing Receivable, Nonaccrual		0	0
Nonaccrual loans		33	47
Home equity | Retail loans | Retail
Financing Receivable, Nonaccrual [Line Items]
Financing Receivable, Nonaccrual, No Allowance		15	17
Financing Receivable, Nonaccrual		0	0
Nonaccrual loans		15	17
Other consumer | Retail loans | Retail
Financing Receivable, Nonaccrual [Line Items]
Nonaccrual loans		0	0
Business Loans | Lease financing | Commercial borrower | Domestic loans
Financing Receivable, Nonaccrual [Line Items]
Financing Receivable, Nonaccrual, No Allowance		0	0
Financing Receivable, Nonaccrual		1	1
Nonaccrual loans		$ 1	$ 1

[1] Primarily loans to real estate developers.

[2] Primarily loans secured by owner-occupied real estate.

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Credit Quality And Allowance For Credit Losses Foreclosed Properties (Details) - USD ($) $ in Millions	Mar. 31, 2021	Dec. 31, 2020
Nonaccrual Loans [Abstract]
Foreclosed property	$ 8	$ 8

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Credit Quality And Allowance For Credit Losses (Troubled Debt Restructurings Subsequent Default) (Details) - Principal Deferrals - USD ($) $ in Millions		3 Months Ended
		Mar. 31, 2021	Mar. 31, 2020
Financing Receivable, Troubled Debt Restructuring [Line Items]
Financing Receivable, Troubled Debt Restructuring, Postmodification	[1]	$ 0	$ 24
Business loans | Commercial borrower | Domestic loans
Financing Receivable, Troubled Debt Restructuring [Line Items]
Financing Receivable, Troubled Debt Restructuring, Postmodification	[1]	0	22
Business loans | Commercial mortgage | Commercial borrower | Domestic loans | Other business lines
Financing Receivable, Troubled Debt Restructuring [Line Items]
Financing Receivable, Troubled Debt Restructuring, Postmodification	[1],[2]	$ 0	$ 2

[1] Primarily represents loan balances where terms were extended by more than an insignificant time period, typically more than 180 days, at or above contractual interest rates. Also includes commercial loans restructured in bankruptcy. In accordance with the provisions of the CARES Act, balances exclude $71 million, primarily retail loans, with terms extended by more than an insignificant time period.

[2] Primarily loans secured by owner-occupied real estate.

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Derivative And Credit-Related Financial Instruments (Narrative) (Details) - USD ($) $ in Millions	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020	Dec. 31, 2020
Derivative Instruments and Hedging Activities Disclosure [Abstract]
Cash received as collateral for derivative assets	$ 11
Fair value of securities pledged as collateral for derivative assets	29
Cash posted as collateral for derivative liabilities	256
Aggregate fair value of all derivative instruments with credit-risk contingent features that were in a liability position	0
Net cash flow hedge gains included in interest and fees on loans	24	$ 3
Net gain on open foreign currency positions	0	$ 0
Allowance for credit losses on lending-related commitments	30		$ 44
Allowance for credit losses on lending-related commitments, amount related to unused commitments to extend credit	$ 25		37
Final year of expiration for outstanding letters of credit	2028
Standby and commercial letters of credit	$ 3,300		3,300
Risk participation agreements covering standby and commercial letters of credit	149		150
Carrying value of standby and commercial letters of credit included in accrued expenses and other liabilities	25		31
Deferred fees on standby and commercial letters of credit included in accrued expenses and other liabilities	20		24
Allowance for credit losses on lending-related commitments, amount related to standby and commercial letters of credit	5		7
Notional amount of derivative credit risk participation agreements	1,000		1,100
Fair Value Amount of Derivative Credit Risk Participation Agreements	1		3
Maximum estimated exposure to credit risk participation agreements assuming 100% default	$ 40		$ 62
Weighted average remaining maturity of credit risk participation agreements, in years	4 years 4 months 24 days

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Derivative And Credit-Related Financial Instruments (Schedule Of Derivative Instruments) (Details) - USD ($) $ in Millions		Mar. 31, 2021	Dec. 31, 2020
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	$ 35,733	$ 35,185
Fair Value of Gross Derivative Assets		621	700
Fair Value of Gross Derivative Liabilities		340	229
Derivative assets, Netting adjustment - Offsetting derivative liabilities		(59)	(83)
Derivative liabilities, Netting adjustment - Offsetting derivative assets		(59)	(83)
Derivative assets, Netting adjustment - Cash collateral received		(2)	(17)
Derivative liabilities, Netting adjustment, Cash collateral posted		(227)	(48)
Net derivative assets included in the Consolidated Balance Sheets	[2]	560	600
Net derivative liabilities included in the Consolidated Balance Sheets	[2]	54	98
Derivative asset, securities pledged as collateral		0	0
Derivative liability, securities pledged as collateral		(26)	(42)
Net derivative assets after deducting amounts not offset in the Consolidated Balance Sheets		560	600
Net derivative liabilities after deducting amounts not offset in the Consolidated Balance Sheets		28	56
Credit valuation adjustments for counterparty credit risk		16	27
Risk management purposes
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	8,590	8,642
Fair Value of Gross Derivative Assets		1	1
Fair Value of Gross Derivative Liabilities		1	4
Risk management purposes | Derivatives designated as hedging instruments | Swaps - fair value - receive fixed/pay floating | Interest rate swap
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	2,650	2,650
Fair Value of Gross Derivative Assets		0	0
Fair Value of Gross Derivative Liabilities		0	0
Risk management purposes | Derivatives designated as hedging instruments | Swaps - cash flow - receive fixed/pay floating rate | Interest rate swap
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	5,550	5,550
Fair Value of Gross Derivative Assets		0	0
Fair Value of Gross Derivative Liabilities		0	0
Risk management purposes | Derivatives used as economic hedges | Foreign exchange spot, forwards and swaps
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	390	442
Fair Value of Gross Derivative Assets		1	1
Fair Value of Gross Derivative Liabilities		1	4
Customer-initiated and other activities
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	27,143	26,543
Fair Value of Gross Derivative Assets		620	699
Fair Value of Gross Derivative Liabilities		339	225
Customer-initiated and other activities | Interest rate contracts
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	21,511	21,521
Fair Value of Gross Derivative Assets		340	531
Fair Value of Gross Derivative Liabilities		65	61
Customer-initiated and other activities | Interest rate caps and floors written
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	909	869
Fair Value of Gross Derivative Assets		0	0
Fair Value of Gross Derivative Liabilities		2	0
Customer-initiated and other activities | Interest rate caps and floors purchased
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	909	869
Fair Value of Gross Derivative Assets		2	0
Fair Value of Gross Derivative Liabilities		0	0
Customer-initiated and other activities | Interest rate swap
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	19,693	19,783
Fair Value of Gross Derivative Assets		338	531
Fair Value of Gross Derivative Liabilities		63	61
Customer-initiated and other activities | Energy contracts
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	4,203	3,121
Fair Value of Gross Derivative Assets		269	151
Fair Value of Gross Derivative Liabilities		265	149
Customer-initiated and other activities | Energy caps and floors written
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	665	503
Fair Value of Gross Derivative Assets		1	1
Fair Value of Gross Derivative Liabilities		60	33
Customer-initiated and other activities | Energy caps and floors purchased
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	665	503
Fair Value of Gross Derivative Assets		60	33
Fair Value of Gross Derivative Liabilities		1	1
Customer-initiated and other activities | Energy swaps
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	2,873	2,115
Fair Value of Gross Derivative Assets		208	117
Fair Value of Gross Derivative Liabilities		204	115
Customer-initiated and other activities | Foreign exchange spot, options and swaps
Derivatives, Fair Value [Line Items]
Derivative, Notional Amount	[1]	1,429	1,901
Fair Value of Gross Derivative Assets		11	17
Fair Value of Gross Derivative Liabilities		$ 9	$ 15

[1] Notional or contractual amounts, which represent the extent of involvement in the derivatives market, are used to determine the contractual cash flows required in accordance with the terms of the agreement. These amounts are typically not exchanged, significantly exceed amounts subject to credit or market risk and are not reflected in the Consolidated Balance Sheets.

[2] Net derivative assets are included in accrued income and other assets and net derivative liabilities are included in accrued expenses and other liabilities on the Consolidated Balance Sheets. Included in the fair value of net derivative assets and net derivative liabilities are credit valuation adjustments reflecting counterparty credit risk and credit risk of the Corporation. The fair value of net derivative assets included credit valuation adjustments for counterparty credit risk of $16 million and $27 million at March 31, 2021 and December 31, 2020, respectively.

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Derivative And Credit-Related Financial Instruments Derivative and Credit-Related Financial Instruments (Schedule of the Effects of Fair Value Hedging on the Consolidated Statements of Comprehensive Income (Details) - USD ($) $ in Millions		3 Months Ended
		Mar. 31, 2021	Mar. 31, 2020
Total interest on medium- and long-term debt	[1]	$ 9	$ 40
Swaps - fair value - receive fixed/pay floating | Risk management purposes | Interest rate swap
Interest rate contract: Hedge items interest expense		25	30
Interest rate contracts: Derivatives designated as hedging instruments net interest income		$ (17)	$ (6)

[1] Includes the effects of hedging.

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Derivative And Credit-Related Financial Instruments (Schedule Of Weighted Average Maturity And Interest Rates On Risk Management Cash Flow Swaps) (Details) - USD ($) $ in Millions		3 Months Ended	12 Months Ended
		Mar. 31, 2021	Dec. 31, 2020
Derivative, Notional Amount	[1]	$ 35,733	$ 35,185
Risk management purposes
Derivative, Notional Amount	[1]	8,590	8,642
Variable rate loans | Swaps - cash flow - receive fixed/pay floating rate | Risk management purposes | Cash flow swap
Derivative, Notional Amount		$ 5,550	$ 5,550
Weighted Average Remaining Maturity		2 years	2 years 3 months 18 days
Weighted Average Receive Rate		1.87%	1.87%
Weighted Average Pay Rate	[2]	0.12%	0.15%

[1] Notional or contractual amounts, which represent the extent of involvement in the derivatives market, are used to determine the contractual cash flows required in accordance with the terms of the agreement. These amounts are typically not exchanged, significantly exceed amounts subject to credit or market risk and are not reflected in the Consolidated Balance Sheets.

[2] Variable rates paid on receive fixed swaps designated as cash flow hedges are based on one-month LIBOR rates in effect at March 31, 2021 and December 31, 2020.

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Derivative And Credit-Related Financial Instruments Derivative And Credit-Related Financial Instruments (Schedule Of Weighted Average Maturity And Interest Rates On Risk Management Fair Value Swaps) (Details) - USD ($) $ in Millions		3 Months Ended	12 Months Ended
		Mar. 31, 2021	Dec. 31, 2020
Derivative, Notional Amount	[1]	$ 35,733	$ 35,185
Risk management purposes
Derivative, Notional Amount	[1]	8,590	8,642
Interest rate swap | Fair Value Hedging [Member] | Risk management purposes | Long-term Debt [Member]
Derivative, Notional Amount		2,650	2,650
Carrying Value of Hedged Item	[2]	$ 2,852	$ 2,928
Weighted Average Remaining Maturity		4 years 4 months 24 days	4 years 7 months 6 days
Weighted Average Receive Rate		3.68%	3.68%
Weighted Average Pay Rate	[3]	1.10%	1.16%

[1] Notional or contractual amounts, which represent the extent of involvement in the derivatives market, are used to determine the contractual cash flows required in accordance with the terms of the agreement. These amounts are typically not exchanged, significantly exceed amounts subject to credit or market risk and are not reflected in the Consolidated Balance Sheets.

[2] Included $202 million and $279 million of cumulative hedging adjustments at March 31, 2021 and December 31, 2020, respectively, which included $5 million and $6 million, respectively, of hedging adjustment on a discontinued hedging relationship.

[3] Variable rates paid on receive fixed swaps designated as fair value hedges are based on one- and six-month LIBOR rates in effect at March 31, 2021 and December 31, 2020.

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Derivative And Credit-Related Financial Instruments (Schedule Of Net Gains Recognized In Income On Customer-Initiated Derivatives) (Details) - USD ($) $ in Millions	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020
Derivative Instruments, Gain (Loss) [Line Items]
Net derivative gain recognized in income	$ 30	$ 20
Customer-initiated and other activities
Derivative Instruments, Gain (Loss) [Line Items]
Net derivative gain recognized in income	30	20
Interest rate contracts | Customer-initiated and other activities | Other noninterest income
Derivative Instruments, Gain (Loss) [Line Items]
Net derivative gain recognized in income	15	8
Energy contracts | Customer-initiated and other activities | Other noninterest income
Derivative Instruments, Gain (Loss) [Line Items]
Net derivative gain recognized in income	4	1
Foreign exchange contracts | Customer-initiated and other activities | Foreign exchange income
Derivative Instruments, Gain (Loss) [Line Items]
Net derivative gain recognized in income	$ 11	$ 11

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Derivative And Credit-Related Financial Instruments (Schedule Of Financial Instruments With Off-Balance Sheet Credit Risk) (Details) - Maximum - USD ($) $ in Millions	Mar. 31, 2021	Dec. 31, 2020
Unused Commitments to Extend Credit
Loss contingency, estimate of possible loss	$ 27,920	$ 26,740
Commercial And Other | Unused Commitments to Extend Credit
Loss contingency, estimate of possible loss	24,598	23,443
Bankcard, Revolving Check Credit And Home Equity Loan Commitments | Unused Commitments to Extend Credit
Loss contingency, estimate of possible loss	3,322	3,297
Standby Letters Of Credit
Loss contingency, estimate of possible loss	3,278	3,273
Commercial Letters Of Credit
Loss contingency, estimate of possible loss	$ 40	$ 30

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Derivative And Credit-Related Financial Instruments (Summary Of Internally Classified Watch List Letters Of Credit) (Details) - USD ($) $ in Millions	Mar. 31, 2021	Dec. 31, 2020
Derivative Instruments and Hedging Activities Disclosure [Abstract]
Total criticized standby and commercial letters of credit	$ 54	$ 73
As a percentage of total outstanding standby and commercial letters of credit	1.60%	2.20%

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Variable Interest Entities (VIEs) (Narrative) (Details) - USD ($) $ in Millions	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020
Variable Interest Entity
Unfunded commitments to fund tax credit entities	$ 173
Amount of financial or other support not contractually required provided by the Corporation to VIEs	0	$ 0
Low Income Housing Tax Credit Entities
Variable Interest Entity
Exposure to loss as a result of involvement with VIEs	458
Other Tax Credit Entities [Member]
Variable Interest Entity
Exposure to loss as a result of involvement with VIEs	$ 12

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Variable Interest Entities (VIEs) (Impact Of VIEs On The Consolidated Statements Of Comprehensive Income) (Details) - USD ($) $ in Millions	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020
Variable Interest Entity
Provision (benefit) for income taxes	$ 98	$ (19)	[1]
Variable Interest Entity
Variable Interest Entity
Provision (benefit) for income taxes	(3)	(3)
Low income housing tax credits | Variable Interest Entity
Variable Interest Entity
Provision for income taxes, amortization of LIHTC investments	17	17
Provision for income taxes, affordable housing tax credits and other tax benefits	(16)	(16)
Other tax benefits related to tax credit entities | Variable Interest Entity
Variable Interest Entity
Provision for income taxes, affordable housing tax credits and other tax benefits	$ (4)	$ (4)

[1] See Defined Benefit Pension and Other Postretirement Costs in Note 1.

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Medium- And Long-Term Debt (Narrative) (Details) - USD ($) $ in Millions	Mar. 31, 2021	Dec. 31, 2020
Debt Instrument [Line Items]
Real estate-related loans securing FHLB advances	$ 18,600
Pledged to the FHLB as collateral for potential future borrowings	4,000
Potential future borrowings	13,900
Unamortized debt issuance cost	$ 9	$ 10

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Medium- And Long-Term Debt (Schedule Of Medium- And Long-Term Debt) (Details) - USD ($) $ in Millions		3 Months Ended
		Mar. 31, 2021	Dec. 31, 2020
Debt Instrument [Line Items]
Total Medium- and long-term debt		$ 2,852	$ 5,728
Parent Company
Debt Instrument [Line Items]
Medium- and long-term notes		1,495	1,538
Total Medium- and long-term debt		1,765	1,818
Subsidiaries
Debt Instrument [Line Items]
Subordinated notes		570	587
Medium- and long-term notes		517	523
Long-term Federal Home Loan Bank Advances		0	2,800
Total Medium- and long-term debt		1,087	3,910
3.80% subordinated notes due 2026 | Parent Company
Debt Instrument [Line Items]
Subordinated notes	[1]	$ 270	280
Stated interest rate		3.80%
Maturity year		2026
3.70% Notes Due 2023 | Parent Company
Debt Instrument [Line Items]
Medium- and long-term notes	[1]	$ 898	905
Stated interest rate		3.70%
Maturity year		2023
4.00% Notes Due 2029 | Parent Company
Debt Instrument [Line Items]
Medium- and long-term notes	[1]	$ 597	633
Stated interest rate		4.00%
Maturity year		2029
4.00% subordinated notes due 2025 | Subsidiaries
Debt Instrument [Line Items]
Subordinated notes	[1]	$ 371	380
Stated interest rate		4.00%
Maturity year		2025
7.875% subordinated notes due 2026 | Subsidiaries
Debt Instrument [Line Items]
Subordinated notes	[1]	$ 199	207
Stated interest rate		7.875%
Maturity year		2026
2.50% notes due 2024 | Subsidiaries
Debt Instrument [Line Items]
Medium- and long-term notes	[1]	$ 517	523
Stated interest rate		2.50%
Maturity year		2024
Floating-rate based on FHLB auction rate due 2026 | Subsidiaries
Debt Instrument [Line Items]
Maturity year		2026
Floating-rate based on FHLB auction rate due 2026 | Subsidiaries
Debt Instrument [Line Items]
Long-term Federal Home Loan Bank Advances		$ 0	$ 2,800

[1] The fixed interest rates on these notes have been swapped to a variable rate and designated in a hedging relationship. Accordingly, carrying value has been adjusted to reflect the change in the fair value of the debt as a result of changes in the benchmark rate.

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Accumulated Other Comprehensive Income (Loss) (Schedule Of Accumulated Other Comprehensive Loss) (Details) - USD ($) $ in Millions		3 Months Ended
		Mar. 31, 2021		Mar. 31, 2020		Dec. 31, 2020
Accumulated Other Comprehensive Income (Loss), Net of Tax [Abstract]
Investment securities, Balance at beginning of period, net of tax		$ 211		$ 65
Net unrealized holding (losses) gains arising during the period		(183)		323
Investment securities, Less: (Benefit) provision for income taxes		(43)		76
Investment securities, Change in net unrealized gains on investment securities, net of tax		(140)		247
Investment securities, Balance at end of period, net of tax		71		312
Cash flow hedges, Balance at beginning of period, net of tax		155		34
Cash flow hedges, Net (losses) gains arising during the period		(18)		205
Cash flow hedges, Less: (Benefit) provision for income tax		(4)		48
Change in net cash flow hedge (losses) gains arising during the period, net of tax		(14)		157
Net cash flow hedge gains included in interest and fees on loans		24		3
Cash flow hedges, Less: Provision for income taxes		6		1
Cash flow hedges, reclassification adjustment for net cash flow hedge gains included in net income, net of tax		18		2
Change in net cash flow hedge (losses) gains, net of tax		(32)		155
Cash flow hedges, Balance at end of period, net of tax	[1]	123		189
Benefit plans, Balance at beginning of period, net of tax	[2]	(302)		(415)
Benefit plans, Actuarial loss arising during the period	[2]	0		(3)
Benefit plans, Less: Benefit for income taxes	[2]	0		(1)
Benefit plans, Net defined benefit pension and other postretirement adjustment arising during the period, net of tax	[2]	0		(2)
Benefit plans, Amortization of actuarial net loss	[2]	10		11
Benefit plans, Amortization of prior service credit		(6)		(7)
Benefit plans, Amounts recognized in other noninterest expenses	[2]	4		4
Benefit plans, Less: Provision for income taxes	[2]	1		1
Benefit plans, Adjustment for amounts recognized as components of net periodic benefit cost during the period, net of tax	[2]	3		3
Benefit plans, Change in defined benefit pension and other postretirement plans adjustment, net of tax	[2]	3		1
Benefit plans, Balance at end of period, net of tax	[2]	(299)		(414)
Total accumulated other comprehensive (loss) income at end of period, net of tax		$ (105)	[2]	$ 87	[2]	$ 64

[1] The Corporation expects to reclassify $67 million of gains, net of tax, from accumulated other comprehensive income to earnings over the next twelve months if interest yield curves and notional amounts remain at March 31, 2021 levels.

[2] Balances at beginning of period, net of tax and changes for the three months ended March 31, 2020 have been recast to reflect the retrospective application of the Corporation's election to change the accounting method for certain components of the qualified defined benefit pension plan as of January 1, 2021. Refer to Note 1 for further information.

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Net Income (Loss) Per Common Share (Narrative) (Details)	3 Months Ended
	Mar. 31, 2020 shares
Earnings Per Share [Abstract]
Stock awards excluded due to net loss	2,600,000

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Net Income (Loss) Per Common Share (Basic And Diluted Net Income Per Share) (Details) - USD ($) $ / shares in Units, shares in Millions, $ in Millions	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020
Earnings Per Share [Abstract]
Net income (loss)	$ 350	$ (59)	[1]
Income allocated to participating securities	1	0
Preferred stock dividends	6	0
Net income (loss) income attributable to common shares	$ 343	$ (59)
Basic average common shares	140.0	141.0
Basic net income (loss) per common share	$ 2.46	$ (0.42)
Basic average common shares	140.0	141.0
Net effect of the assumed exercise of stock options	1.0	0.0
Diluted average common shares	141.0	141.0
Diluted net income (loss) per common share	$ 2.43	$ (0.42)

[1] See Defined Benefit Pension and Other Postretirement Costs in Note 1.

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Net Income (Loss) Per Common Share (Ant-Dilutive Schedule) (Details) - $ / shares shares in Thousands	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020
Antidilutive Securities Excluded from Computation of Earnings Per Share [Line Items]
Average outstanding options	782	1,210
Minimum | Stock Options
Antidilutive Securities Excluded from Computation of Earnings Per Share [Line Items]
Range of exercise prices	$ 67.53	$ 56.79
Maximum | Stock Options
Antidilutive Securities Excluded from Computation of Earnings Per Share [Line Items]
Range of exercise prices	$ 95.25	$ 95.25

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Employee Benefit Plans (Net Periodic Defined Benefit Cost) (Details) - USD ($) $ in Millions	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020
Defined Benefit Plan Disclosure [Line Items]
Net periodic defined benefit credit	$ (20)	$ (13)
Qualified Plan
Defined Benefit Plan Disclosure [Line Items]
Service cost	10	8	[1]
Interest Cost	15	18	[1]
Expected return on plan assets	(50)	(46)	[1]
Amortization of prior service credit	(5)	(5)	[1]
Amortization of net loss	7	9	[1]
Total other components of net benefit credit	(33)	(24)	[1]
Net periodic defined benefit credit	(23)	(16)	[1]
Non-Qualified Plan
Defined Benefit Plan Disclosure [Line Items]
Service cost	0	1
Interest Cost	2	2
Amortization of prior service credit	(1)	(2)
Amortization of net loss	3	2
Total other components of net benefit credit	4	2
Net periodic defined benefit credit	4	3
Postretirement Benefit Plan
Defined Benefit Plan Disclosure [Line Items]
Expected return on plan assets	(1)	0
Net periodic defined benefit credit	$ (1)	$ 0

[1] Expected return on plan assets increased $3 million and amortization of net loss was reduced by $5 million to reflect the retrospective application of the Corporation's election to change the accounting method for certain components of the qualified defined benefit pension plan as of January 1, 2021, resulting in an increase of $8 million to total other components of net benefit credit. Refer to Note 1 for further information.

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Income Taxes And Tax-Related Items Income Taxes And Tax-Related Items (Narrative) (Details) - USD ($) $ in Millions	3 Months Ended
	Mar. 31, 2021	Dec. 31, 2020
Unrecognized tax benefits	$ 20	$ 19
Unrecognized Tax Benefits, Change Resulting from Settlements with Taxing Authorities	6
Tax-related interest and penalties payable	6	6
Net deferred tax assets	15	4
State net operating loss carryforwards	3	3
Valuation allowance for deferred tax assets	$ 3	$ 3
Minimum
Operating loss carryforwards, expiration year	2021
Maximum
Operating loss carryforwards, expiration year	2030

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Contingent Liabilities (Narrative) (Details) - USD ($) $ in Millions	3 Months Ended
	Mar. 31, 2021	Mar. 31, 2020
Loss Contingencies [Line Items]
Legal fees	$ 2	$ 2
Pending Litigation | Minimum
Loss Contingencies [Line Items]
Loss contingency, estimate of possible loss	0
Pending Litigation | Maximum
Loss Contingencies [Line Items]
Loss contingency, estimate of possible loss	$ 94

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Strategic Lines of Business and Markets (Narrative) (Details)	3 Months Ended
	Mar. 31, 2021 markets segments
Segment Reporting [Abstract]
Number of Major Business Segments | segments	3
Number of Primary Market Segments | markets	3

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Strategic Lines of Business and Markets (Business Segment Financial Results) (Details) - USD ($) $ in Millions		3 Months Ended
		Mar. 31, 2021	Mar. 31, 2020
Net interest income (expense)		$ 443	$ 513
Provision for credit losses		(182)	411
Noninterest income		270	237
Noninterest expenses		447	417	[1]
Provision (benefit) for income taxes		98	(19)	[1]
Net income (loss)		350	(59)	[1]
Net credit-related charge-offs		3	84
Assets, average		84,559	73,265
Loans, average		50,589	49,604
Deposits, average		$ 71,392	$ 56,768
Return on average assets	[2]	1.68%	(0.32%)	[1]
Efficiency ratio	[3]	62.55%	55.58%	[1]
Commercial Bank
Net interest income (expense)		$ 382	$ 380
Provision for credit losses		(177)	396
Noninterest income		159	127
Noninterest expenses		215	192	[1]
Provision (benefit) for income taxes		113	(19)	[1]
Net income (loss)		390	(62)	[1]
Net credit-related charge-offs		2	83
Assets, average		44,448	44,254
Loans, average		42,904	42,593
Deposits, average		$ 41,102	$ 30,230
Return on average assets	[2]	3.56%	(0.56%)	[1]
Efficiency ratio	[3]	39.66%	37.95%	[1]
Retail Bank
Net interest income (expense)		$ 133	$ 125
Provision for credit losses		6	3
Noninterest income		28	28
Noninterest expenses		149	145	[1]
Provision (benefit) for income taxes		0	1	[1]
Net income (loss)		6	4	[1]
Net credit-related charge-offs		1	1
Assets, average		3,463	2,864
Loans, average		2,620	2,075
Deposits, average		$ 24,322	$ 21,195
Return on average assets	[2]	0.11%	0.07%	[1]
Efficiency ratio	[3]	91.68%	94.07%	[1]
Wealth Management
Net interest income (expense)		$ 42	$ 41
Provision for credit losses		(12)	12
Noninterest income		67	70
Noninterest expenses		76	70	[1]
Provision (benefit) for income taxes		10	6	[1]
Net income (loss)		35	23	[1]
Net credit-related charge-offs		0	0
Assets, average		5,162	5,078
Loans, average		5,059	4,936
Deposits, average		$ 4,826	$ 4,025
Return on average assets	[2]	2.72%	1.81%	[1]
Efficiency ratio	[3]	69.84%	62.68%	[1]
Finance
Net interest income (expense)		$ (117)	$ (44)
Provision for credit losses		0	0
Noninterest income		12	14
Noninterest expenses		0	0	[1]
Provision (benefit) for income taxes		(25)	(8)	[1]
Net income (loss)		(80)	(22)	[1]
Net credit-related charge-offs		0	0
Assets, average		16,959	14,285
Loans, average		0	0
Deposits, average		985	1,136
Other
Net interest income (expense)		3	11
Provision for credit losses		1	0
Noninterest income		4	(2)
Noninterest expenses		7	10	[1]
Provision (benefit) for income taxes		0	1	[1]
Net income (loss)		(1)	(2)	[1]
Net credit-related charge-offs		0	0
Assets, average		14,527	6,784
Loans, average		6	0
Deposits, average		$ 157	$ 182

[1] See Defined Benefit Pension and Other Postretirement Costs in Note 1.

[2] Return on average assets is calculated based on the greater of average assets or average liabilities and attributed equity.

[3] Noninterest expenses as a percentage of the sum of net interest income and noninterest income excluding net losses from securities and a derivative contract tied to the conversion rate of Visa Class B shares.

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Strategic Lines of Business and Markets (Market Segment Financial Results) (Details) - USD ($) $ in Millions		3 Months Ended
		Mar. 31, 2021	Mar. 31, 2020
Net interest income (expense)		$ 443	$ 513
Provision for credit losses		(182)	411
Noninterest income		270	237
Noninterest expenses		447	417	[1]
Provision (benefit) for income taxes		98	(19)	[1]
Net income (loss)		350	(59)	[1]
Net credit-related charge-offs		3	84
Assets, average		84,559	73,265
Loans, average		50,589	49,604
Deposits, average		$ 71,392	$ 56,768
Return on average assets	[2]	1.68%	(0.32%)	[1]
Efficiency ratio	[3]	62.55%	55.58%	[1]
Michigan [Domain]
Net interest income (expense)		$ 154	$ 163
Provision for credit losses		(28)	24
Noninterest income		66	72
Noninterest expenses		135	137	[1]
Provision (benefit) for income taxes		22	16	[1]
Net income (loss)		91	58	[1]
Net credit-related charge-offs		0	3
Assets, average		12,916	12,895
Loans, average		12,247	12,191
Deposits, average		$ 25,683	$ 20,748
Return on average assets	[2]	1.40%	1.10%	[1]
Efficiency ratio	[3]	60.86%	57.92%	[1]
California [Domain]
Net interest income (expense)		$ 172	$ 176
Provision for credit losses		(54)	46
Noninterest income		48	33
Noninterest expenses		104	93	[1]
Provision (benefit) for income taxes		40	17	[1]
Net income (loss)		130	53	[1]
Net credit-related charge-offs		1	8
Assets, average		18,143	18,007
Loans, average		17,946	17,742
Deposits, average		$ 19,968	$ 16,627
Return on average assets	[2]	2.51%	1.19%	[1]
Efficiency ratio	[3]	47.09%	44.60%	[1]
Texas [Domain]
Net interest income (expense)		$ 114	$ 115
Provision for credit losses		(86)	290
Noninterest income		36	30
Noninterest expenses		88	83	[1]
Provision (benefit) for income taxes		31	(50)	[1]
Net income (loss)		117	(178)	[1]
Net credit-related charge-offs		2	70
Assets, average		10,668	11,154
Loans, average		10,161	10,566
Deposits, average		$ 10,783	$ 9,204
Return on average assets	[2]	3.88%	(6.47%)	[1]
Efficiency ratio	[3]	58.85%	57.38%	[1]
Other Markets
Net interest income (expense)		$ 117	$ 92
Provision for credit losses		(15)	51
Noninterest income		104	90
Noninterest expenses		113	94	[1]
Provision (benefit) for income taxes		30	5	[1]
Net income (loss)		93	32	[1]
Net credit-related charge-offs		0	3
Assets, average		11,348	10,140
Loans, average		10,231	9,105
Deposits, average		$ 13,816	$ 8,871
Return on average assets	[2]	2.54%	1.27%	[1]
Efficiency ratio	[3]	51.18%	51.69%	[1]
Finance & Other
Net interest income (expense)		$ (114)	$ (33)
Provision for credit losses		1	0
Noninterest income		16	12
Noninterest expenses		7	10	[1]
Provision (benefit) for income taxes		(25)	(7)	[1]
Net income (loss)		(81)	(24)	[1]
Net credit-related charge-offs		0	0
Assets, average		31,484	21,069
Loans, average		4	0
Deposits, average		$ 1,142	$ 1,318

[1] See Defined Benefit Pension and Other Postretirement Costs in Note 1.

[2] Return on average assets is calculated based on the greater of average assets or average liabilities and attributed equity.

[3] Noninterest expenses as a percentage of the sum of net interest income and noninterest income excluding net losses from securities and a derivative contract tied to the conversion rate of Visa Class B shares.

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Revenue from Contracts with Customers (Details) - USD ($) $ in Millions		3 Months Ended
		Mar. 31, 2021	Mar. 31, 2020
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		$ 194	$ 185
Other sources of noninterest income		76	52
Total noninterest income		270	237
Commercial Bank
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		103	89
Other sources of noninterest income		56	38
Total noninterest income		159	127
Retail Bank
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		27	28
Other sources of noninterest income		1	0
Total noninterest income		28	28
Wealth Management
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		64	68
Other sources of noninterest income		3	2
Total noninterest income		67	70
Finance & Other
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		0	0
Other sources of noninterest income		16	12
Total noninterest income		16	12
Card fees
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		71	59
Card fees | Commercial Bank
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		60	49
Card fees | Retail Bank
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		10	9
Card fees | Wealth Management
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		1	1
Card fees | Finance & Other
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		0	0
Fiduciary income
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		53	54
Fiduciary income | Commercial Bank
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		0	0
Fiduciary income | Retail Bank
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		0	0
Fiduciary income | Wealth Management
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		53	54
Fiduciary income | Finance & Other
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		0	0
Service charges on deposit accounts
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		48	49
Service charges on deposit accounts | Commercial Bank
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		34	32
Service charges on deposit accounts | Retail Bank
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		13	16
Service charges on deposit accounts | Wealth Management
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		1	1
Service charges on deposit accounts | Finance & Other
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		0	0
Commercial loan servicing fees
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers	[1]	4	4
Commercial loan servicing fees | Commercial Bank
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers	[1]	4	4
Commercial loan servicing fees | Retail Bank
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers	[1]	0	0
Commercial loan servicing fees | Wealth Management
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers	[1]	0	0
Commercial loan servicing fees | Finance & Other
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers	[1]	0	0
Brokerage fees
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		4	7
Brokerage fees | Commercial Bank
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		0	0
Brokerage fees | Retail Bank
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		0	0
Brokerage fees | Wealth Management
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		4	7
Brokerage fees | Finance & Other
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers		0	0
Other noninterest income
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers	[2]	14	12
Other noninterest income | Commercial Bank
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers	[2]	5	4
Other noninterest income | Retail Bank
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers	[2]	4	3
Other noninterest income | Wealth Management
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers	[2]	5	5
Other noninterest income | Finance & Other
Segment Reporting, Revenue Reconciling Item
Total revenue from contracts with customers	[2]	$ 0	$ 0

[1] Included in commercial lending fees on the Consolidated Statements of Comprehensive Income.

[2] Excludes derivative, warrant and other miscellaneous income.