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VARIABLE INTEREST ENTITIES (Tables)

9 Months Ended

Sep. 30, 2020

Organization, Consolidation and Presentation of Financial Statements [Abstract]

Schedule of Variable Interest Entities, Assets and Liabilities

The following tables provide a summary of the assets and liabilities included in our Consolidated Financial Statements, as well as the maximum exposure to losses, associated with its interests related to unconsolidated VIEs for which we hold an interest, but are not the primary beneficiary, at September 30, 2020 and December 31, 2019.

TABLE 9.1


(in millions)	Total Assets		Total Liabilities		Maximum Exposure to Loss
September 30, 2020
Trust preferred securities (1)	$	1	$	66	$	—
Affordable housing tax credit partnerships	121		51		121
Other investments	32		8		32
Total	$	154	$	125	$	153
December 31, 2019
Trust preferred securities (1)	$	1	$	66	$	—
Affordable housing tax credit partnerships	120		60		120
Other investments	33		10		33
Total	$	154	$	136	$	153
(1) Represents our investment in unconsolidated subsidiaries.

Low Income Housing Tax Credits, Balances Of Affordable Housing Tax Credit Investments And Related Unfunded Commitments

The following table presents the balances of our affordable housing tax credit investments and related unfunded commitments:

TABLE 9.2


(in millions)	September 30, 2020		December 31, 2019
Proportional amortization method investments included in other assets	$	67	$	55
Equity method investments included in other assets	3		5
Total LIHTC investments included in other assets	$	70	$	60
Unfunded LIHTC commitments	$	51	$	60

Low Income Housing Tax Credits, Income Statement Effect

The following table summarizes the impact of these LIHTC investments on specific line items of our Consolidated Statements of Income:

TABLE 9.3


	Three Months Ended September 30,				Nine Months Ended September 30,
(in millions)	2020		2019		2020		2019
Non-interest income:
Amortization of tax credit investments under equity method, net of tax benefit	$	—	$	—	$	1	$	1
Provision for income taxes:
Amortization of LIHTC investments under proportional method	$	2	$	2	$	8	$	6
Low-income housing tax credits	(3)		(3)		(9)		(7)
Other tax benefits related to tax credit investments	—		—		(2)		(1)
Total provision for income taxes	$	(1)	$	(1)	$	(3)	$	(2)

- Definition

Tabular disclosure of the significant judgments and assumptions made in determining whether a variable interest (as defined) held by the entity requires the variable interest entity (VIE) (as defined) to be consolidated and (or) disclose information about its involvement with the VIE, individually or in aggregate (as applicable); the nature of restrictions, if any, on the consolidated VIE's assets and on the settlement of its liabilities reported by an entity in its statement of financial position, including the carrying amounts of such assets and liabilities; the nature of, and changes in, the risks associated with involvement in the VIE; how involvement with the VIE affects the entity's financial position, financial performance, and cash flows; the lack of recourse if creditors (or beneficial interest holders) of the consolidated VIE have no recourse to the general credit of the primary beneficiary (if applicable); the terms of arrangements, giving consideration to both explicit arrangements and implicit variable interests, if any, that could require the entity to provide financial support to the VIE, including events or circumstances that could expose the entity to a loss; the methodology used by the entity for determining whether or not it is the primary beneficiary of the variable interest entity; the significant factors considered and judgments made in determining that the power to direct the activities of a VIE that most significantly impact the VIE's economic performance are shared (as defined); the carrying amounts and classification of assets and liabilities of the VIE included in the statement of financial position; the entity's maximum exposure to loss, if any, as a result of its involvement with the VIE, including how the maximum exposure is determined and significant sources of the entity's exposure to the VIE; a comparison of the carrying amounts of the assets and liabilities and the entity's maximum exposure to loss; information about any liquidity arrangements, guarantees, and (or) other commitments by third parties that may affect the fair value or risk of the entity's variable interest in the VIE; whether or not the entity has provided financial support or other support (explicitly or implicitly) to the VIE that it was not previously contractually required to provide or whether the entity intends to provide that support, including the type and amount of the support and the primary reasons for providing the support; and supplemental information the entity determines necessary to provide.

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