Our consumer charge-off and nonaccrual policies are summarized below. As previously discussed, in September 2016, we transferred all of our remaining receivables to held for sale, which are carried at the lower of amortized cost or fair value. As a result, we no longer record charge-offs on our remaining receivable portfolio.



Product	Charge-off Policies and Practices	Nonaccrual Policies and Practices
Real estate secured	Carrying amounts in excess of fair value less cost to sell were generally charged-off at or before the time foreclosure was completed or settlement was reached with the borrower but, in any event, generally no later than the end of the month in which the account became six months contractually delinquent. If foreclosure was not pursued (which frequently occurs on second lien loans) and there was no reasonable expectation for recovery (insurance claim, title claim, pre-discharge bankrupt account), the account was generally charged-off no later than the end of the month in which the account became six months contractually delinquent.⁽¹⁾	Interest income accruals are suspended when principal or interest payments are more than three months contractually past due. Interest accruals are resumed and suspended interest recognized when the customer makes the equivalent of six qualifying payments under the terms of the loan, while maintaining a current payment status when we receive the sixth payment. If the re-aged receivable again becomes more than three months contractually delinquent, any interest accrued beyond three months delinquency is reversed. Interest income for all accounts that have been written down to the lower of amortized cost or fair value of the collateral less cost to sell is recognized on a cash basis as received.


⁽¹⁾	Values were determined based upon broker price opinions or appraisals, which were updated at least every 180 days, less estimated costs to sell. During the quarterly period between updates, real estate price trends were reviewed on a geographic basis and additional reductions in value were recorded as necessary.

Fair values of foreclosed properties at the time of acquisition are initially determined based upon broker price opinions. Subsequent to acquisition, a more detailed property valuation is performed, reflecting information obtained from a walk-through of the property in the form of a listing agent broker price opinion as well as an independent broker price opinion or appraisal. A valuation is determined from this information within 90 days and any additional write-downs required are recorded at that time.

In determining the appropriate amounts to charge-off when a property was acquired in exchange for a loan, we did not consider losses on sales of foreclosed properties resulting from deterioration in value during the period the collateral was held because these losses resulted from future loss events which cannot be considered in determining the fair value of the collateral at the acquisition date.