Loans and Allowance for Credit Losses

3 Months Ended

Mar. 31, 2021

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, 2021					December 31, 2020
(Dollars in Millions)	Amount		Percent of Total			Amount		Percent of Total
Commercial
Commercial	$	98,847		33.6	%	$	97,315		32.7	%
Lease financing		5,311		1.8			5,556		1.9
Total commercial		104,158		35.4			102,871		34.6
Commercial Real Estate
Commercial mortgages		27,649		9.4			28,472		9.6
Construction and development		10,783		3.6			10,839		3.6
Total commercial real estate		38,432		13.0			39,311		13.2
Residential Mortgages
Residential mortgages		64,238		21.8			66,525		22.4
Home equity loans, first liens		9,386		3.2			9,630		3.2
Total residential mortgages		73,624		25.0			76,155		25.6
Credit Card		20,872		7.1			22,346		7.5
Other Retail
Retail leasing		7,880		2.7			8,150		2.7
Home equity and second mortgages		11,679		4.0			12,472		4.2
Revolving credit		2,536		.9			2,688		.9
Installment		14,562		4.9			13,823		4.6
Automobile		20,527		7.0			19,722		6.6
Student		157		–			169		.1
Total other retail		57,341		19.5			57,024		19.1
Total loans	$	294,427		100.0	%	$	297,707		100.0	%

The Company had loans of $94.4 billion at March 31, 2021, and $96.1 billion at December 31, 2020, pledged at the Federal Home Loan Bank, and loans of $65.4 billion at March 31, 2021, and $67.8 billion at December 31, 2020, 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 $849 million at March 31, 2021 and $763 million at December 31, 2020. 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 loans. All other purchased loans are considered non-purchased credit deteriorated loans.

Allowance for Credit Losses Beginning 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. The allowance considers expected losses for the remaining lives of the applicable assets, inclusive of expected recoveries. The allowance for credit losses is increased through provisions charged to earnings and reduced by net charge-offs. Management evaluates the appropriateness of the allowance for credit losses on a quarterly basis. Multiple economic scenarios are considered over a three-year reasonable and supportable forecast period, which includes increasing consideration of historical loss experience over years two and three. These economic scenarios are constructed with interrelated projections of multiple economic variables, and loss estimates are produced that consider the historical correlation of those economic variables with credit losses. 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 life of the portfolio. 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 economic conditions for the foreseeable future and reflect significant judgment and consider uncertainties that exist. 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, but are not limited to, 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, but are not limited to, macroeconomic variables such as unemployment rate, real estate prices, gross domestic product levels, corporate bonds spreads and long-term interest rate forecasts, as well as 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. 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, economic conditions or other factors that would affect the accuracy of the model. 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. Where loans do not exhibit similar risk characteristics, an individual analysis is performed to consider expected credit losses. 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 as appropriate.

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 generally do not include loan modifications granted to customers resulting directly from the economic effects of the COVID-19 pandemic, who were otherwise in current payment status. The expected cash flows on TDR loans consider subsequent payment defaults since modification, the borrower’s ability to pay under the restructured terms, and the timing and amount of payments. 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. 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, the acquired loans are divided into those considered purchased with more than insignificant credit deterioration (“PCD”) and those not considered purchased with more than insignificant credit deterioration. An allowance is established for each population and considers product mix, risk characteristics of the portfolio, bankruptcy experience, delinquency status and refreshed LTV ratios when possible. 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, regardless of PCD status, are recognized through provision expense, with charge-offs charged to the allowance. The Company did not have a material amount of PCD loans included in its loan portfolio at March 31, 2021.

The Company’s methodology for determining the appropriate allowance for credit losses also considers the imprecision inherent in the methodologies used and allocated to the various loan portfolios. As a result, amounts determined under the methodologies described above, are adjusted by management to consider the potential impact of other qualitative factors not captured in the quantitative model adjustments 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 portfolios, 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 for each loan portfolio.

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.

Prior to January 1, 2020, the allowance for credit losses was established based on an incurred loss model. The allowance recorded for loans in the commercial lending segment was based on the migration analysis of commercial loans and actual loss experience. The allowance recorded for loans in the consumer lending segment was determined on a homogenous pool basis and primarily included consideration of delinquency status and historical losses. In addition to the amounts determined under the methodologies described above, management also considered the potential impact of qualitative factors.

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, 2020	$	2,423		$	1,544		$	573		$	2,355		$	1,115		$	8,010
Add
Provision for credit losses		(435	)		(19	)		(39	)		(259	)		(75	)		(827	)
Deduct
Loans charged-off		86			10			5			190			83			374
Less recoveries of loans charged-off		(30	)		(17	)		(10	)		(46	)		(48	)		(151	)
Net loan charge-offs (recoveries)		56			(7	)		(5	)		144			35			223
Balance at March 31, 2021	$	1,932		$	1,532		$	539		$	1,952		$	1,005		$	6,960
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 loan charge-offs (recoveries)		74			(2	)		1			234			86			393
Balance at March 31, 2020	$	2,240		$	841		$	412		$	2,012		$	1,085		$	6,590

(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 decrease in the allowance for credit losses from December 31, 2020 to March 31, 2021 reflected factors affecting economic conditions during the first quarter of 2021, including the enactment of additional benefits from government stimulus programs, vaccine availability in the United States and reduced levels of new COVID-19 cases.

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 portfolio 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.

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, 2021
Commercial	$	103,557	$	193	$	61	$	347	$	104,158
Commercial real estate		37,953		119		4		356		38,432
Residential mortgages (a)		73,024		204		143		253		73,624
Credit card		20,486		188		198		–		20,872
Other retail		56,878		221		70		172		57,341
Total loans	$	291,898	$	925	$	476	$	1,128	$	294,427
December 31, 2020
Commercial	$	102,127	$	314	$	55	$	375	$	102,871
Commercial real estate		38,676		183		2		450		39,311
Residential mortgages (a)		75,529		244		137		245		76,155
Credit card		21,918		231		197		–		22,346
Other retail		56,466		318		86		154		57,024
Total loans	$	294,716	$	1,290	$	477	$	1,224	$	297,707

(a) At March 31, 2021, $1.5 billion of loans 30–89 days past due and $1.7 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 $1.4 billion and $1.8 billion at December 31, 2020, respectively.    

(b) Substantially all nonperforming loans at March 31, 2021 and December 31, 2020, had an associated allowance for credit losses. The Company recognized interest income on nonperforming loans of $3 million and $5 million for the three months ended March 31, 2021 and 2020, respectively.    

At March 31, 2021, the amount of foreclosed residential real estate held by the Company, and included in OREO, was $18 million, compared with $23 million at December 31, 2020. These amounts excluded $29 million and $33 million at March 31, 2021 and December 31, 2020, 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, 2021 and December 31, 2020, was $936 million and $1.0 billion, respectively, of which $756 million and $812 million, 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 portfolio classes 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, 2021										December 31, 2020
			Criticized										Criticized
(Dollars in Millions)	Pass		Special Mention		Classified (a)		Total Criticized		Total		Pass		Special Mention		Classified (a)		Total Criticized		Total
Commercial
Originated in 2021	$	12,604	$	313	$	218	$	531	$	13,135	$	–	$	–	$	–	$	–	$	–
Originated in 2020		28,890		1,003		1,302		2,305		31,195		34,557		1,335		1,753		3,088		37,645
Originated in 2019		15,710		351		223		574		16,284		17,867		269		349		618		18,485
Originated in 2018		10,909		372		151		523		11,432		12,349		351		176		527		12,876
Originated in 2017		4,658		81		181		262		4,920		5,257		117		270		387		5,644
Originated prior to 2017		4,133		168		73		241		4,374		4,954		128		115		243		5,197
Revolving		22,377		206		235		441		22,818		22,445		299		280		579		23,024
Total commercial		99,281		2,494		2,383		4,877		104,158		97,429		2,499		2,943		5,442		102,871
Commercial real estate
Originated in 2021		2,368		39		408		447		2,815		–		–		–		–		–
Originated in 2020		8,889		336		901		1,237		10,126		9,446		461		1,137		1,598		11,044
Originated in 2019		8,788		450		947		1,397		10,185		9,514		454		1,005		1,459		10,973
Originated in 2018		5,296		373		499		872		6,168		6,053		411		639		1,050		7,103
Originated in 2017		2,375		141		350		491		2,866		2,650		198		340		538		3,188
Originated prior to 2017		4,272		151		161		312		4,584		4,762		240		309		549		5,311
Revolving		1,457		5		226		231		1,688		1,445		9		238		247		1,692
Total commercial real estate		33,445		1,495		3,492		4,987		38,432		33,870		1,773		3,668		5,441		39,311
Residential mortgages (b)
Originated in 2021		4,208		–		–		–		4,208		–		–		–		–		–
Originated in 2020		22,053		–		5		5		22,058		23,262		1		3		4		23,266
Originated in 2019		12,084		1		23		24		12,108		13,969		1		17		18		13,987
Originated in 2018		4,989		1		25		26		5,015		5,670		1		22		23		5,693
Originated in 2017		6,091		1		22		23		6,114		6,918		1		24		25		6,943
Originated prior to 2017		23,782		3		335		338		24,120		25,921		2		342		344		26,265
Revolving		1		–		–		–		1		1		–		–		–		1
Total residential mortgages		73,208		6		410		416		73,624		75,741		6		408		414		76,155
Credit card (c)		20,674		–		198		198		20,872		22,149		–		197		197		22,346
Other retail
Originated in 2021		5,690		–		1		1		5,691		–		–		–		–		–
Originated in 2020		15,954		–		6		6		15,960		17,589		–		7		7		17,596
Originated in 2019		10,351		–		16		16		10,367		11,605		–		23		23		11,628
Originated in 2018		5,822		–		20		20		5,842		6,814		–		27		27		6,841
Originated in 2017		3,106		–		14		14		3,120		3,879		–		22		22		3,901
Originated prior to 2017		3,134		–		18		18		3,152		3,731		–		29		29		3,760
Revolving		12,536		–		135		135		12,671		12,647		–		110		110		12,757
Revolving converted to term		495		–		43		43		538		503		–		38		38		541
Total other retail		57,088		–		253		253		57,341		56,768		–		256		256		57,024
Total loans	$	283,696	$	3,995	$	6,736	$	10,731	$	294,427	$	285,957	$	4,278	$	7,472	$	11,750	$	297,707
Total outstanding commitments	$	629,280	$	8,140	$	9,239	$	17,379	$	646,659	$	627,606	$	8,772	$	9,374	$	18,146	$	645,752

Note: Year of origination is based on the origination date of a loan or the date when the maturity date, pricing or commitment amount is amended.

(a) Classified rating on consumer loans primarily based on delinquency status.

(b) At March 31, 2021, $1.7 billion of GNMA loans 90 days or more past due and $1.3 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 $1.8 billion and $1.4 billion at December 31, 2020, 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 for the periods presented by portfolio class:

	2021						2020
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		704	$	75	$	60		999	$	99	$	101
Commercial real estate		56		86		71		27		21		21
Residential mortgages		336		104		104		90		10		10
Credit card		5,786		33		34		8,415		46		47
Other retail		1,325		37		32		655		15		14
Total loans, excluding loans purchased from GNMA mortgage pools		8,207		335		301		10,186		191		193
Loans purchased from GNMA mortgage pools		559		87		89		1,904		266		260
Total loans		8,766	$	422	$	390		12,090	$	457	$	453

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. At March 31, 2021, 89 residential mortgages, 33 home equity and second mortgage loans and 304 loans purchased from GNMA mortgage pools with outstanding balances of $28 million, $2 million and $52 million, respectively, were in a trial period and have estimated post-modification balances of $28 million, $2 million and $53 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 generally not considered to be TDRs. As of March 31, 2021, approximately $7.3 billion of loan modifications included on the Company’s consolidated balance sheet related to borrowers impacted by the COVID-19 pandemic, consisting primarily of payment deferrals.

The following table provides a summary of TDR loans that defaulted (fully or partially charged-off or became 90 days or more past due) for the periods presented, that were modified as TDRs within 12 months previous to default:

	2021				2020
Three Months Ended March 31 (Dollars in Millions)	Number of Loans		Amount Defaulted		Number of Loans		Amount Defaulted
Commercial		285	$	16		287	$	20
Commercial real estate		7		5		16		10
Residential mortgages		15		2		13		1
Credit card		1,764		9		2,070		10
Other retail		280		5		108		1
Total loans, excluding loans purchased from GNMA mortgage pools		2,351		37		2,494		42
Loans purchased from GNMA mortgage pools		30		4		304		41
Total loans		2,381	$	41		2,798	$	83

In addition to the defaults in the table above, the Company had a total of 19 residential mortgage loans, home equity and second mortgage loans and loans purchased from GNMA mortgage pools for the three months ended March 31, 2021, 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 $4 million for the three months ended March 31, 2021.

As of March 31, 2021, the Company had $134 million of commitments to lend additional funds to borrowers whose terms of their outstanding owed balances have been modified in TDRs.