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Loans and Allowance for Credit Losses
3 Months Ended
Mar. 31, 2020
Receivables [Abstract]  
Loans and Allowance for Credit Losses
     
 Note 4
 
   Loans and Allowance for Credit Losses
The composition of the loan portfolio, disaggregated by class and underlying specific portfolio type, was as follows:
 
                                         
    March 31, 2020             December 31, 2019  
(Dollars in Millions)   Amount      Percent
of Total
            Amount      Percent
of Total
 
Commercial
              
Commercial
  $ 120,670       
37.9
       $ 98,168        33.2
Lease financing
    5,647       
1.8
               5,695        1.9  
Total commercial
    126,317       
39.7
           103,863        35.1  
Commercial Real Estate
              
Commercial mortgages
    30,124       
9.5
           29,404        9.9  
Construction and development
    10,856       
3.4
               10,342        3.5  
Total commercial real estate
    40,980       
12.9
           39,746        13.4  
Residential Mortgages
              
Residential mortgages
    60,708       
19.1
           59,865        20.2  
Home equity loans, first liens
    10,467       
3.3
               10,721        3.6  
Total residential mortgages
    71,175       
22.4
           70,586        23.8  
Credit Card
    22,781       
7.1
           24,789        8.4  
Other Retail
              
Retail leasing
    8,495       
2.7
           8,490        2.9  
Home equity and second mortgages
    14,836       
4.6
           15,036        5.1  
Revolving credit
    2,786       
.9
           2,899        1.0  
Installment
    11,540       
3.6
           11,038        3.7  
Automobile
    19,189       
6.0
           19,435        6.5  
Student
    206       
.1
               220        .1  
Total other retail
    57,052       
17.9
               57,118        19.3  
Total loans
  $ 318,305       
100.0
           $ 296,102        100.0
 
 
 
 
 
The Company had loans of $96.5 billion at March 31, 2020, and $96.2 billion at December 31, 2019, pledged at the Federal Home Loan Bank, and loans of $75.5 billion at March 31, 2020, and $76.3 billion at December 31, 2019, pledged at the Federal Reserve Bank.
Originated loans are reported at the principal amount outstanding, net of unearned interest and deferred fees and costs, and any partial charge-offs recorded. Net unearned interest and deferred fees and costs amounted to $744 million at March 31, 2020 and $781 million
 
at December 31, 2019. All purchased loans are recorded at fair value at the date of purchase. Beginning January 1, 2020, the Company evaluates purchased loans for more-than-insignificant deterioration at the date of purchase in accordance with applicable authoritative accounting guidance. Purchased loans that have experienced more-than-insignificant deterioration from origination are considered purchased credit deteriorated (“PCD”) loans. All other purchased loans are considered
non-purchased
credit deteriorated loans.
The Company offers a broad array of lending products and categorizes its loan portfolio into two segments, which is the level at which it develops and documents a systematic methodology to determine the allowance for credit losses. The Company’s two loan portfolio segments are commercial lending and consumer lending.
Allowance for Credit Losses
Effective January 1, 2020, the allowance for credit losses is established for current expected credit losses on the Company’s loan and lease portfolio, including unfunded credit commitments. Prior to January 1, 2020, the allowance for credit losses was established based on an incurred loss model. The allowance for credit losses is increased through provisions charged to earnings and reduced by net charge-offs, inclusive of expected recoveries. Management evaluates the appropriateness of the allowance for credit losses on a quarterly basis. The allowance considers expected losses for the remaining lives of the applicable assets. Multiple economic scenarios are considered over a three-year reasonable and supportable forecast period, which incorporates historical loss experience in years two and three. After the forecast period, the Company fully reverts to long-term historical loss experience, adjusted for prepayments and characteristics of the current loan and lease portfolio, to estimate losses over the remaining lives. The economic scenarios are updated at least quarterly and are designed to provide a range of reasonable estimates, both better and worse than current expectations. Scenarios are weighted based on the Company’s expectation of future conditions. Final loss estimates also consider factors affecting credit losses not reflected in the scenarios, due to the unique aspects of current conditions and expectations. These
factors may include loan servicing practices, regulatory guidance, and/or fiscal and monetary policy actions.
The allowance recorded for credit losses utilizes forward-looking expected loss models to consider a variety of factors affecting lifetime credit losses. These factors include loan and borrower characteristics, such as internal risk
ratings on commercial
loans and consumer credit scores, delinquency status, collateral type and available valuation information, consideration of end-of-term losses on
 
lease residuals, and the remaining term of the loan, adjusted for expected prepayments. Where loans do not exhibit similar risk characteristics, an individual analysis is performed to consider expected credit losses. For each loan portfolio, model estimates are adjusted as necessary to consider any relevant changes in portfolio composition, lending policies, underwriting standards, risk management practices or economic conditions that would affect the accuracy of the model. The results of the analysis are evaluated quarterly to confirm the estimates are appropriate for each loan portfolio. Expected credit loss estimates also include consideration of expected cash recoveries on loans previously charged-off, or expected recoveries on collateral dependent loans where recovery is expected through sale of the collateral. The allowance recorded for individually evaluated loans greater than $5 million in the commercial lending segment is based on an analysis utilizing expected cash flows discounted using the original effective interest rate, the observable market price of the loan, or the fair value of the collateral, less selling costs, for collateral-dependent loans.
The allowance recorded for Troubled Debt Restructuring (“TDR”) loans in the consumer lending segment is determined on a homogenous pool basis utilizing expected cash flows discounted using the original effective interest rate of the pool. TDRs do not include loan modifications granted to customers resulting directly from the
economic effects
of the COVID-19 pandemic. The allowance for collateral-dependent loans in the consumer lending segment is determined based on the fair value of the collateral less costs to sell and any expected future write-offs or recoveries. The allowance for credit losses on consumer lending segment TDR loans includes the consideration of subsequent payment defaults since modification, the borrower’s ability to pay under the restructured terms, and the timing and amount of payments. With respect to the commercial lending segment, TDRs may be collectively evaluated for impairment where observed performance history, including defaults, is a primary driver of the loss allocation. For commercial TDRs individually evaluated for impairment, attributes of the borrower are the primary factors in determining the allowance for credit losses. However, historical loss experience is also incorporated into the allowance methodology applied to this category of loans.
Beginning January 1, 2020, when a loan portfolio is purchased, an allowance is established for those loans considered purchased with more-than-insignificant credit deterioration, or PCD loans, and those not considered purchased with more-than-insignificant credit deterioration. The allowance established for each population considers product mix, risk characteristics of the portfolio, bankruptcy experience, delinquency status, refreshed loan-to-value ratios when possible, and portfolio growth. The allowance established for purchased loans not considered PCD is recognized through provision expense upon acquisition, whereas the allowance established for loans considered PCD at acquisition is offset by an increase in the basis of the acquired loans. Any subsequent increases and decreases in the allowance related to purchased loans are recognized through provision expense, with future charge-offs charged to the allowance.
The Company’s methodology for determining the appropriate allowance for credit losses for each loan segment also considers the imprecision inherent in the methodologies used. As a result, amounts determined under the methodologies described above are adjusted by management to consider the potential impact of other qualitative factors which include, but are not limited to, the following: model imprecision, imprecision in economic scenario assumptions, and emerging risks related to either changes in the environment that are affecting specific portfolio segments, or changes in portfolio concentrations over time that may affect model performance. The consideration of these items results in adjustments to allowance amounts included in the Company’s allowance for credit losses specific to each portfolio class.
The Company also assesses the credit risk associated with off-balance sheet loan commitments, letters of credit, investment securities and derivatives. Credit risk associated with derivatives is reflected in the fair values recorded for those positions. The liability for off-balance sheet credit exposure related to loan commitments and other credit guarantees is included in other liabilities. Because business processes and credit risks associated with unfunded credit commitments are essentially the same as for loans, the Company utilizes similar processes to estimate its liability for unfunded credit commitments.
 
Activity in the allowance for credit losses by portfolio class was as follows:
 
 
                                                 
(Dollars in Millions)   Commercial     Commercial
Real Estate
    Residential
Mortgages
    Credit
Card
    Other
Retail
    Total
Loans
 
Balance at December 31, 2019
  $ 1,484     $ 799     $ 433     $ 1,128     $ 647     $ 4,491  
Add
           
Change in accounting principle (a)
    378       (122     (30     872       401       1,499  
Provision for credit losses
    452       162       10       246       123       993  
Deduct
           
Loans
charged-off
    88             8       274       121       491  
Less recoveries of loans
charged-off
    (14     (2     (7     (40     (35     (98
Net loans
charged-off
    74       (2     1       234       86       393  
Balance at March 31, 2020
  $ 2,240     $ 841     $ 412     $ 2,012     $ 1,085     $ 6,590  
Balance at December 31, 2018
  $ 1,454     $ 800     $ 455     $ 1,102     $ 630     $ 4,441  
Add
           
Provision for credit losses
    64       12       (7     238       70       377  
Deduct
           
Loans
charged-off
    111       1       8       257       96       473  
Less recoveries of loans
charged-off
    (38     (1     (5     (32     (30     (106
Net loans
charged-off
    73             3       225       66       367  
Balance at March 31, 2019
  $ 1,445     $ 812     $ 445     $ 1,115     $ 634     $ 4,451  
 
 
 
 
 
 
 
 
 
 
(a)
Effective January 1, 2020, the Company adopted accounting guidance which changed impairment recognition of financial instruments to a model that is based on expected losses rather than incurred losses.
 
 
 
 
 
 
 
The increase in the allowance for credit losses from December 31, 2019 to March 31, 2020 reflected the adoption of new accounting guidance and deteriorating economic conditions driven by the impact of
COVID-19
on the domestic and global economies. Expected loss estimates consider both the decrease in economic activity, and the mitigating effects of government stimulus and industrywide loan modification efforts designed to limit long term effects of the pandemic.
The increase in the allowance for credit losses resulted from the estimated impact of deteriorating economic conditions and higher unemployment, partially offset by the benefits of government stimulus programs.
Credit Quality
The credit quality of the Company’s loan portfolios is assessed as a function of net credit losses, levels of nonperforming assets and delinquencies, and credit quality ratings as defined by the Company.
For all loan classes, loans are considered past due based on the number of days delinquent except for monthly amortizing loans which are classified delinquent based upon the number of contractually required payments not made (for example, two missed payments is considered 30 days delinquent). When a loan is placed on nonaccrual status, unpaid accrued interest is reversed, reducing interest income in the current period.
Commercial lending segment loans are generally placed on nonaccrual status when the collection of principal and interest has become 90 days past due or is otherwise considered doubtful. Commercial lending segment loans are generally fully or partially charged down to the fair value of the collateral securing the loan, less costs to sell, when the loan is placed on nonaccrual.
Consumer lending segment loans are generally
charged-off
at a specific number of days or payments past due. Residential mortgages and other retail loans secured by
1-4
family properties are generally charged down to the fair value of the collateral securing the loan, less costs to sell, at 180 days past due. Residential mortgage loans and lines in a first lien position are placed on nonaccrual status in instances where a partial
charge-off
occurs unless the loan is well secured and in the process of collection. Residential mortgage loans and lines in a junior lien position secured by
1-4 family
properties are placed on nonaccrual status at 120 days past due or when they are behind a first lien that has become 180 days or greater past due or placed on nonaccrual status. Any secured consumer lending segment loan whose borrower has had debt discharged through bankruptcy, for which the loan amount exceeds the fair value of the collateral, is charged down to the fair value of the related collateral and the remaining balance is placed on nonaccrual status. Credit card loans continue to accrue interest until the account is
charged-off.
Credit cards are
charged-off
at 180 days past due. Other retail loans not secured by
1-4
family properties are
charged-off
at 120 days past due; and revolving consumer lines are
charged-off
at 180 days past due. Similar to credit cards, other retail loans are generally not placed on nonaccrual status because of the relative short period of time to
charge-off.
Certain retail customers having financial difficulties may have the terms of their credit card and other loan agreements modified to require only principal payments and, as such, are reported as nonaccrual.
For all loan classes, interest payments received on nonaccrual loans are generally recorded as a reduction to a loan’s carrying amount while a loan is on nonaccrual and are recognized as interest income upon payoff of the loan. However, interest income may be recognized for interest payments if the remaining carrying amount of the loan is
believed to be collectible. In certain circumstances, loans in any class may be restored to accrual status, such as when a loan has demonstrated sustained repayment performance or no amounts are past due and prospects for future payment are no longer in doubt; or when the loan becomes well secured and is in the process of collection. Loans where there has been a partial
charge-off
may be returned to accrual status if all principal and interest (including amounts previously
charged-off)
is expected to be collected and the loan is current. Generally, purchased credit deteriorated loans are considered accruing loans. However, the timing and amount of future cash flows for some loans is not reasonably estimable, and those loans are classified as nonaccrual loans with interest income not recognized until the timing and amount of the future cash flows can be reasonably estimated.
The following table provides a summary of loans by portfolio class, including the delinquency status of those that continue to accrue interest, and those that are nonperforming:
 
                                         
    Accruing                
(Dollars in Millions)   Current     
30-89 Days

Past Due
     90 Days or
More Past Due
     Nonperforming (b)      Total  
March 31, 2020
             
Commercial
  $ 125,576      $ 352      $ 80      $ 309      $ 126,317  
Commercial real estate
    40,795        82        2        101        40,980  
Residential mortgages (a)
    70,660        164        108        243        71,175  
Credit card
    22,194        293        294               22,781  
Other retail
    56,408        387        95        162        57,052  
Total loans
  $ 315,633      $ 1,278      $ 579      $ 815      $ 318,305  
December 31, 2019
             
Commercial
  $ 103,273      $ 307      $ 79      $ 204      $ 103,863  
Commercial real estate
    39,627        34        3        82        39,746  
Residential mortgages (a)
    70,071        154        120        241        70,586  
Credit card
    24,162        321        306               24,789  
Other retail
    56,463        393        97        165        57,118  
Total loans
  $ 293,596      $ 1,209      $ 605      $ 692      $ 296,102  
 
 
 
 
 
 
 
 
 
 
(a)
At March 31, 2020, $396 million of loans 30–89 days past due and $1.6 billion of loans 90 days or more past due purchased from Government National Mortgage Association (“GNMA”) mortgage pools whose repayments are insured by the Federal Housing Administration or guaranteed by the United States Department of Veterans Affairs, were classified as current, compared with $428 million and $1.7 billion at December 31, 2019, respectively.
 
 
 
 
 
 
 
 
 
(b)
Substantially all nonperforming loans at March 31, 2020 and December 31, 2019, had an associated allowance for credit losses. The Company recognized $4
 
million and $5 million of interest income on nonperforming loans for the three months ended March 31, 2020 and 2019, respectively.
 
 
 
 
 
 
 
At March 31, 2020, the amount of foreclosed residential real estate held by the Company, and included in
other real estate owned (“OREO”) was
 
$67 million, compared with $74 million at December 31, 2019. These amounts exclude $122 million and $155 million at March 31, 2020 and December 31, 2019, respectively, of foreclosed residential real estate related to mortgage loans whose payments are primarily insured by the Federal Housing Administration or guaranteed by the United States Department of Veterans Affairs. In addition, the amount of residential mortgage loans secured by residential real estate in the process of foreclosure at March 31, 2020 and December 31, 2019, was $1.4 billion and $1.5 billion, respectively, of which $1.1 billion and $1.2 billion, respectively, related to loans purchased from Government National Mortgage Association (“GNMA”) mortgage pools whose repayments are insured by the Federal Housing Administration or guaranteed by the United States Department of Veterans Affairs.
The Company classifies its loan portfolios using internal credit quality ratings on a quarterly basis. These ratings include pass, special mention and classified, and are an important part of the Company’s overall credit risk management process and evaluation of the allowance for credit losses. Loans with a pass rating represent those loans not classified on the Company’s rating scale for problem credits, as minimal credit risk has been identified. Special mention loans are those loans that have a potential weakness deserving management’s close attention. Classified loans are those loans where a well-defined weakness has been identified that may put full collection of contractual cash flows at risk. It is possible that others, given the same information, may reach different reasonable conclusions regarding the credit quality rating classification of specific loans.
The following table provides a summary of loans by portfolio class and the Company’s internal credit quality rating:
 
 
 
March 31, 2020
 
  
  
 
 
December 31, 2019
 
 
 
 
 
 
Criticized
 
 
 
 
  
 
 
 
 
 
 
Criticized
 
 
 
 
(Dollars in Millions)
 
Pass
 
 
Special
Mention
 
 
Classified (a)
 
 
Total
Criticized
 
 
Total
 
  
  
 
 
Pass
 
 
Special
Mention
 
 
Classified (a)
 
 
Total
Criticized
 
 
Total
 
Commercial
 
     
 
     
 
     
 
     
 
     
  
   
 
 
     
 
     
 
     
 
     
 
     
Originated in 2020
 
$
13,238
 
 
$
392
 
 
$
85
 
 
$
477
 
 
$
13,715
 
  
   
 
 
$
 
 
$
 
 
$
 
 
$
 
 
$
 
Originated in 2019
 
 
35,323
 
 
 
846
 
 
 
275
 
 
 
1,121
 
 
 
36,444
 
  
   
 
 
 
33,550
 
 
 
174
 
 
 
222
 
 
 
396
 
 
 
33,946
 
Originated in 2018
 
 
23,843
 
 
 
991
 
 
 
369
 
 
 
1,360
 
 
 
25,203
 
  
   
 
 
 
21,394
 
 
 
420
 
 
 
136
 
 
 
556
 
 
 
21,950
 
Originated in 2017
 
 
10,983
 
 
 
318
 
 
 
192
 
 
 
510
 
 
 
11,493
 
  
   
 
 
 
10,464
 
 
 
165
 
 
 
97
 
 
 
262
 
 
 
10,726
 
Originated in 2016
 
 
5,236
 
 
 
85
 
 
 
37
 
 
 
122
 
 
 
5,358
 
  
   
 
 
 
4,984
 
 
 
10
 
 
 
37
 
 
 
47
 
 
 
5,031
 
Originated prior to 2016
 
 
4,745
 
 
 
148
 
 
 
125
 
 
 
273
 
 
 
5,018
 
  
   
 
 
 
5,151
 
 
 
86
 
 
 
96
 
 
 
182
 
 
 
5,333
 
Revolving
 
 
27,904
 
 
 
911
 
 
 
271
 
 
 
1,182
 
 
 
29,086
 
  
 
 
 
 
 
26,307
 
 
 
292
 
 
 
278
 
 
 
570
 
 
 
26,877
 
Total commercial
 
 
121,272
 
 
 
3,691
 
 
 
1,354
 
 
 
5,045
 
 
 
126,317
 
  
   
 
 
 
101,850
 
 
 
1,147
 
 
 
866
 
 
 
2,013
 
 
 
103,863
 
           
 
         
Commercial real estate
 
     
 
     
 
     
 
     
 
     
  
   
 
 
     
 
     
 
     
 
     
 
     
Originated in 2020
 
 
2,824
 
 
 
339
 
 
 
20
 
 
 
359
 
 
 
3,183
 
  
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Originated in 2019
 
 
12,058
 
 
 
705
 
 
 
208
 
 
 
913
 
 
 
12,971
 
  
   
 
 
 
12,976
 
 
 
108
 
 
 
108
 
 
 
216
 
 
 
13,192
 
Originated in 2018
 
 
8,367
 
 
 
705
 
 
 
100
 
 
 
805
 
 
 
9,172
 
  
   
 
 
 
9,455
 
 
 
71
 
 
 
56
 
 
 
127
 
 
 
9,582
 
Originated in 2017
 
 
4,721
 
 
 
568
 
 
 
98
 
 
 
666
 
 
 
5,387
 
  
   
 
 
 
5,863
 
 
 
99
 
 
 
64
 
 
 
163
 
 
 
6,026
 
Originated in 2016
 
 
3,242
 
 
 
215
 
 
 
74
 
 
 
289
 
 
 
3,531
 
  
   
 
 
 
3,706
 
 
 
117
 
 
 
60
 
 
 
177
 
 
 
3,883
 
Originated prior to 2016
 
 
4,314
 
 
 
189
 
 
 
134
 
 
 
323
 
 
 
4,637
 
  
   
 
 
 
4,907
 
 
 
78
 
 
 
101
 
 
 
179
 
 
 
5,086
 
Revolving
 
 
2,072
 
 
 
23
 
 
 
4
 
 
 
27
 
 
 
2,099
 
  
   
 
 
 
1,965
 
 
 
11
 
 
 
1
 
 
 
12
 
 
 
1,977
 
Total commercial real estate
 
 
37,598
 
 
 
2,744
 
 
 
638
 
 
 
3,382
 
 
 
40,980
 
  
   
 
 
 
38,872
 
 
 
484
 
 
 
390
 
 
 
874
 
 
 
39,746
 
           
 
         
Residential mortgages (b)
 
     
 
     
 
     
 
     
 
     
  
   
 
 
     
 
     
 
     
 
     
 
     
Originated in 2020
 
 
5,108
 
 
 
 
 
 
 
 
 
 
 
 
5,108
 
  
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Originated in 2019
 
 
17,909
 
 
 
 
 
 
3
 
 
 
3
 
 
 
17,912
 
  
   
 
 
 
18,819
 
 
 
2
 
 
 
1
 
 
 
3
 
 
 
18,822
 
Originated in 2018
 
 
8,211
 
 
 
 
 
 
11
 
 
 
11
 
 
 
8,222
 
  
   
 
 
 
9,204
 
 
 
 
 
 
11
 
 
 
11
 
 
 
9,215
 
Originated in 2017
 
 
8,961
 
 
 
 
 
 
17
 
 
 
17
 
 
 
8,978
 
  
   
 
 
 
9,605
 
 
 
 
 
 
21
 
 
 
21
 
 
 
9,626
 
Originated in 2016
 
 
10,779
 
 
 
 
 
 
29
 
 
 
29
 
 
 
10,808
 
  
   
 
 
 
11,378
 
 
 
 
 
 
29
 
 
 
29
 
 
 
11,407
 
Originated prior to 2016
 
 
19,821
 
 
 
 
 
 
326
 
 
 
326
 
 
 
20,147
 
  
 
 
 
 
 
21,168
 
 
 
 
 
 
348
 
 
 
348
 
 
 
21,516
 
Total residential mortgages
 
 
70,789
 
 
 
 
 
 
386
 
 
 
386
 
 
 
71,175
 
  
   
 
 
 
70,174
 
 
 
2
 
 
 
410
 
 
 
412
 
 
 
70,586
 
           
 
         
Credit card (c)
 
 
22,487
 
 
 
 
 
 
294
 
 
 
294
 
 
 
22,781
 
  
   
 
 
 
24,483
 
 
 
 
 
 
306
 
 
 
306
 
 
 
24,789
 
           
 
         
Other retail
 
     
 
     
 
     
 
     
 
     
  
   
 
 
     
 
     
 
     
 
     
 
     
Originated in 2020
 
 
4,172
 
 
 
 
 
 
1
 
 
 
1
 
 
 
4,173
 
  
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Originated in 2019
 
 
14,747
 
 
 
 
 
 
14
 
 
 
14
 
 
 
14,761
 
  
   
 
 
 
15,907
 
 
 
 
 
 
11
 
 
 
11
 
 
 
15,918
 
Originated in 2018
 
 
9,308
 
 
 
 
 
 
24
 
 
 
24
 
 
 
9,332
 
  
   
 
 
 
10,131
 
 
 
 
 
 
23
 
 
 
23
 
 
 
10,154
 
Originated in 2017
 
 
6,836
 
 
 
 
 
 
26
 
 
 
26
 
 
 
6,862
 
  
   
 
 
 
7,907
 
 
 
 
 
 
28
 
 
 
28
 
 
 
7,935
 
Originated in 2016
 
 
3,096
 
 
 
 
 
 
16
 
 
 
16
 
 
 
3,112
 
  
   
 
 
 
3,679
 
 
 
 
 
 
20
 
 
 
20
 
 
 
3,699
 
Originated prior to 2016
 
 
2,866
 
 
 
 
 
 
22
 
 
 
22
 
 
 
2,888
 
  
   
 
 
 
3,274
 
 
 
 
 
 
28
 
 
 
28
 
 
 
3,302
 
Revolving
 
 
15,336
 
 
 
8
 
 
 
125
 
 
 
133
 
 
 
15,469
 
  
   
 
 
 
15,509
 
 
 
10
 
 
 
138
 
 
 
148
 
 
 
15,657
 
Revolving converted to term
 
 
442
 
 
 
 
 
 
33
 
 
 
33
 
 
 
455
 
  
 
 
 
 
 
418
 
 
 
 
 
 
35
 
 
 
35
 
 
 
453
 
Total other retail
 
 
56,783
 
 
 
8
 
 
 
261
 
 
 
269
 
 
 
57,052
 
  
 
 
 
 
 
56,825
 
 
 
10
 
 
 
283
 
 
 
293
 
 
 
57,118
 
Total loans
 
$
308,929
 
 
$
6,443
 
 
$
2,933
 
 
$
9,376
 
 
$
318,305
 
  
 
 
 
 
$
292,204
 
 
$
1,643
 
 
$
2,255
 
 
$
3,898
 
 
$
296,102
 
Total outstanding commitments
 
$
623,649
 
 
$
8,604
 
 
$
3,560
 
 
$
12,164
 
 
$
635,813
 
  
 
 
 
 
$
619,224
 
 
$
2,451
 
 
$
2,873
 
 
$
5,324
 
 
$
624,548
 
 
(a)
Classified rating on consumer loans primarily based on delinquency status.
(b)
At March 31, 2020, $1.6 billion of GNMA loans 90 days or more past due and $1.6 billion of restructured GNMA loans whose repayments are insured by the Federal Housing Administration or guaranteed by the United States Department of Veterans Affairs were classified with a pass rating, compared with $1.7 billion and $1.6 billion at December 31, 2018, respectively.
(c)
All credit card loans are considered revolving loans.
Troubled Debt Restructurings
In certain circumstances, the Company may modify the terms of a loan to maximize the collection of amounts due when a borrower is experiencing financial difficulties or is expected to experience difficulties in the near-term. Concessionary modifications are classified as TDRs unless the modification results in only an insignificant delay in payments to be received. The Company recognizes interest on TDRs if the borrower complies with the revised terms and conditions as agreed upon with the Company and has demonstrated repayment performance at a level commensurate with the modified terms over several payment cycles, which is generally six months or greater. To the extent a previous restructuring was insignificant, the Company considers the cumulative effect of past restructurings related to the receivable when determining whether a current restructuring is a TDR.
The following table provides a summary of loans modified as TDRs during the periods presented by portfolio class:
 
    2020              2019  
Three Months Ended March 31 (Dollars in Millions)   Number
of Loans
    
Pre-Modification

Outstanding
Loan Balance
    
Post-Modification

Outstanding
Loan Balance
             Number
of Loans
    
Pre-Modification

Outstanding
Loan Balance
    
Post-Modification

Outstanding
Loan Balance
 
Commercial
    999      $ 99      $ 101             913      $ 36      $ 29  
Commercial real estate
    27        21        21             20        47        46  
Residential mortgages
    90        10        10             96        14        13  
Credit card
    8,415        46        47             9,648        50        51  
Other retail
    655        15        14                 573        11        10  
Total loans, excluding loans purchased from GNMA mortgage pools
    10,186        191        193             11,250        158        149  
Loans purchased from GNMA mortgage pools
    1,904        266        260                 1,538        203        195  
Total loans
    12,090      $ 457      $ 453                 12,788      $ 361      $ 344  
Residential mortgages, home equity and second mortgages, and loans purchased from GNMA mortgage pools in the table above include trial period arrangements offered to customers during the periods presented. The post-modification balances for these loans reflect the current outstanding balance until a permanent modification is made. In addition, the post-modification balances typically include capitalization of unpaid accrued interest and/or fees under the various modification programs. For those loans modified as TDRs during the first quarter of 2020, at March 31, 2020, 39 residential mortgages, 22 home equity and second mortgage loans and 1,024 loans purchased from GNMA mortgage pools with outstanding balances of $5 million, $2 million and $141 million, respectively, were in a trial period and have estimated post-modification balances of $5 million, $2 million and $140 million, respectively, assuming permanent modification occurs at the end of the trial period.
The Company has implemented certain restructuring programs that may result in TDRs. However, many of the Company’s TDRs are also determined on a
case-by-case
basis in connection with ongoing loan collection processes.
For the commercial lending segment, modifications generally result in the Company working with borrowers on a
case-by-case
basis. Commercial and commercial real estate modifications generally include extensions of the maturity date and may be accompanied by an increase or decrease to the interest rate, which may not be deemed a market interest rate. In addition, the Company may work with the borrower in identifying other changes that mitigate loss to the Company, which may include additional collateral or guarantees to support the loan. To a lesser extent, the Company may waive contractual principal. The Company classifies all of the above concessions as TDRs to the extent the Company determines that the borrower is experiencing financial difficulty.
Modifications for the consumer lending segment are generally part of programs the Company has initiated. The Company modifies residential mortgage loans under Federal Housing Administration, United States Department of Veterans Affairs, or its own internal programs. Under these programs, the Company offers qualifying homeowners the opportunity to permanently modify their loan and achieve more affordable monthly payments by providing loan concessions. These concessions may include adjustments to interest rates, conversion of adjustable rates to fixed rates, extension of maturity dates or deferrals of payments, capitalization of accrued interest and/or outstanding advances, or in limited situations, partial forgiveness of loan principal. In most instances, participation in residential mortgage loan restructuring programs requires the customer to complete a short-term trial period. A permanent loan modification is contingent on the customer successfully completing the trial period arrangement, and the loan documents are not modified until that time. The Company reports loans in a trial period arrangement as TDRs and continues to report them as TDRs after the trial period.
Credit card and other retail loan TDRs are generally part of distinct restructuring programs providing customers experiencing financial difficulty with modifications whereby balances may be amortized up to 60 months, and generally include waiver of fees and reduced interest rates.
In addition, the Company considers secured loans to consumer borrowers that have debt discharged through bankruptcy where the borrower has not reaffirmed the debt to be TDRs.
Loan modifications or concessions granted to borrowers resulting directly from the effects of the
COVID-19
pandemic, who were otherwise in current payment status, are not considered to be TDRs. As of March 31, 2020, the Company had approved
modifications to 
approximately $3.1 billion of loan
s
included on its consolidated balance sheet related to borrowers impacted by the
COVID-19
pandemic, consisting primarily of payment deferrals of 90 days or less on loans within the consumer lending segment.
The following table provides a summary of TDR loans that defaulted (fully or partially
charged-off
or became 90 days or more past due) during the periods presented that were modified as TDRs within 12 months previous to default:
 
                                         
    2020              2019  
Three Months Ended March 31
(Dollars in Millions)
  Number
of Loans
     Amount
Defaulted
             Number
of Loans
     Amount
Defaulted
 
Commercial
    287      $ 20             234      $ 5  
Commercial real estate
    16        10             8        6  
Residential mortgages
    13        1             96        10  
Credit card
    2,070        10             2,054        9  
Other retail
    108        1                 147        7  
Total loans, excluding loans purchased from GNMA mortgage pools
    2,494        42             2,539        37  
Loans purchased from GNMA mortgage pools
    304        41                 124        17  
Total loans
    2,798      $ 83                 2,663      $ 54  
 
 
 
 
 
 
In addition to the defaults in the table above, the Company had a total of 137 residential mortgage loans, home equity and second mortgage loans and loans purchased from GNMA mortgage pools for the three months ended March 31, 2020, where borrowers did not successfully complete the trial period arrangement and, therefore, are no longer eligible for a permanent modification under the applicable modification program. These loans had aggregate outstanding balances of $19 million for the three months ended March 31, 2020.
As of March 31, 2020, the Company had $119 million of commitments to lend additional funds to borrowers whose terms of their outstanding owed balances have been modified in troubled debt restructurings.