Loans and Allowance for Credit Losses

12 Months Ended

Dec. 31, 2020

NOTE 4 – ALLOWANCE FOR CREDIT LOSSES AND ASSET QUALITY

Loans and leases, net of unearned income

Loans and leases, net of unearned income are summarized as follows as of December 31:


	2020		2019
	(in thousands)
Real estate - commercial mortgage	$	7,105,092	$	6,700,776
Commercial and industrial (1)	5,670,828		4,446,701
Real-estate - residential mortgage	3,141,915		2,641,465
Real-estate - home equity	1,202,913		1,314,944
Real-estate - construction	1,047,218		971,079
Consumer	466,772		463,164
Equipment lease financing and other	284,377		322,625
Overdrafts	4,806		3,582
Gross loans	18,923,921		16,864,336
Unearned income	(23,101)		(26,810)
Net Loans	$	18,900,820	$	16,837,526

(1) Includes PPP loans totaling $1.6 billion as of December 31, 2020.

The Corporation has extended credit to officers and directors of the Corporation and to their associates. These related-party loans are made on substantially the same terms, including interest rates and collateral, as those prevailing at the time for comparable transactions with unrelated persons and do not involve more than the normal risk of collection. The aggregate dollar amount of these loans, including unadvanced commitments, was $162.5 million and $90.1 million as of December 31, 2020 and 2019, respectively. During 2020, additions totaled $103.5 million and repayments totaled $31.1 million for related-party loans.

Allowance for Credit Losses, effective January 1, 2020

As discussed in Note 1, "Summary of Significant Accounting Policies," the Corporation adopted CECL effective January 1, 2020. CECL requires estimated credit losses on loans to be determined based on an expected life of loan model, as compared to an incurred loss model (in effect for periods prior to 2020). Accordingly, ACL disclosures subsequent to January 1, 2020 are not always comparable to prior periods. In addition, certain new disclosures required under CECL are not applicable to prior periods. As a result, the following tables present disclosures separately for each period, where appropriate. New disclosures required under CECL are only shown for the current period and are noted. See Note 1, "Summary of Significant Accounting Policies," for a summary of the impact of adopting CECL on January 1, 2020.

Under CECL, loans evaluated individually for impairment consist of non-accrual loans and TDRs. Under the incurred loss model in effect prior to the adoption of CECL, loans evaluated individually for impairment were referred to as impaired loans.

The ACL related to loans consists of loans evaluated collectively and individually for expected credit losses. The ACL related to loans represents an estimate of expected credit losses over the expected life of the loans as of the balance sheet date and is recorded as a reduction to Net Loans. The ACL for OBS credit exposures includes estimated losses on unfunded loan commitments, letters of credit and other OBS credit exposures. The total ACL is increased by charges to expense, through the provision for credit losses, and decreased by charge-offs, net of recoveries.

The following table presents the components of the ACL under CECL:



	2020
	(in thousands)
ACL - loans	$	277,567
ACL - OBS credit exposure	14,373
Total ACL	$	291,940

The following table presents the activity in the ACL in 2020:





		2020
	(in thousands)
Balance at beginning of period		$	166,209
Impact of adopting CECL on January 1, 2020 (1)		58,348
Loans charged off		(30,557)
Recoveries of loans previously charged off		21,020
Net loans recovered (charged off)		(9,537)
Provision for credit losses (2)		76,920
Balance at the end of the period (3)		$	291,940

(1) Includes $12.6 million of reserves for OBS credit exposures as of January 1, 2020.

(2) Includes $(840,000) related to OBS credit exposures for the year ended December 31, 2020.

(3) Includes $14.4 million of reserves for OBS credit exposures as of December 31, 2020.

The following table presents the activity in the ACL - loans by portfolio segment, for the year ended December 31, 2020:


	Real Estate - Commercial Mortgage		Commercial and Industrial		Real Estate - Home Equity		Real Estate - Residential Mortgage		Real Estate - Construction		Consumer		Equipment lease financing, other and overdrafts		Total
	(in thousands)
Year ended December 31, 2020
Balance at December 31, 2019	$	45,610	$	68,602	$	17,744	$	19,771	$	4,443	$	3,762	$	3,690	$	163,622
Impact of adopting CECL on January 1, 2020	29,361		(18,576)		(65)		21,235		4,015		5,969		3,784		45,723
Loans charged off	(4,225)		(18,915)		(1,193)		(620)		(17)		(3,400)		(2,187)		(30,557)
Recoveries of loans previously charged off	1,027		11,396		504		491		5,122		1,875		605		21,020
Net loans recovered (charged off)	(3,198)		(7,519)		(689)		(129)		5,105		(1,525)		(1,582)		(9,537)
Provision for loan losses (1)	31,652		32,264		(2,758)		11,118		2,045		2,699		741		77,760
Balance at December 31, 2020	$	103,425	$	74,771	$	14,232	$	51,995	$	15,608	$	10,905	$	6,633	$	277,567

(1) Provision included in the table only includes the portion related to Net Loans.

The higher provision during 2020 was largely driven by the overall downturn in economic forecasts due to COVID-19, resulting in higher expected future credit losses under CECL. The ACL includes qualitative adjustments, as appropriate, intended to capture the impact of uncertainties not reflected in the quantitative models. Qualitative adjustments include and consider changes in national, regional and local economic and business conditions, an assessment of the lending environment, including underwriting standards and other factors affecting credit quality. Qualitative adjustments have increased compared to those at the time of the adoption of CECL on January 1, 2020 primarily as a result of uncertainties related to the economic impact of COVID-19, including consideration for the future performance of loans that received deferrals or forbearances as a result of COVID-19 and the impact COVID-19 had on certain industries where the quantitative models was not fully capturing the appropriate level of risk. PPP loans that were issued during 2020 are fully guaranteed by the SBA and as such, no ACL were recorded against the PPP loan portfolio.

Allowance for Credit Losses, prior to January 1, 2020

Prior to January 1, 2020, the ACL consisted of the allowance for loan losses and the reserve for unfunded lending commitments. The allowance for loan losses represented management’s estimate of incurred losses in the loan portfolio as of the balance sheet date and is recorded as a reduction to Net Loans. The reserve for unfunded lending commitments represented management’s estimate of incurred losses in unfunded loan commitments and letters of credit, and was recorded in other liabilities on the consolidated balance sheets. The ACL was increased by charges to expense, through the provision for credit losses, and decreased by charge-offs, net of recoveries.

The following table presents the components of the ACL as of December 31:


	2019		2018
	(in thousands)
Allowance for loan losses	$	163,622	$	160,537
Reserve for unfunded lending commitments	2,587		8,873
Total ACL	$	166,209	$	169,410

The following table presents the activity in the ACL for the years ended December 31:


	2019		2018
	(in thousands)
Balance at beginning of period	$	169,410	$	176,084

Loans charged off	(53,189)		(66,076)
Recoveries of loans previously charged off	17,163		12,495
Net loans recovered (charged off)	(36,026)		(53,581)
Provisions for credit losses (1)	32,825		46,907
Balance at the end of the period (2)	$	166,209	$	169,410

(1) Includes $(6.3) million and $2.7 million related to OBS credit exposures for the years ended 2019 and 2018, respectively.

(2) Includes $2.6 million and $8.9 million of reserves for OBS credit exposures as of December 31, 2019 and 2018.

The following tables present the activity in the allowance for loan losses by portfolio segment for the year ended December 31, 2019 and 2018, by portfolio segment:


	Real Estate - Commercial Mortgage		Commercial and Industrial		Real Estate - Home Equity		Real Estate - Residential Mortgage		Real Estate - Construction		Consumer		Equipment Finance Leasing and Other			Total
	(in thousands)
Balance at December 31, 2018	52,889		58,868		18,911		18,921		5,061		3,217		2,670			160,537
Loans charged off	(1,837)		(42,410)		(1,291)		(1,545)		(143)		(3,403)		(2,560)			(53,189)
Recoveries of loans previously charged off	2,202		8,721		688		989		2,591		1,306		666			17,163
Net loans recovered (charged off)	365		(33,689)		(603)		(556)		2,448		(2,097)		(1,894)			(36,026)
Provision for loan losses (1)	(7,644)		43,423		(564)		1,406		(3,066)		2,642		2,914			39,111
Balance at December 31, 2019	$	45,610	$	68,602	$	17,744	$	19,771	$	4,443	$	3,762	$	3,690	0	$	163,622

(1) Provision included in the table only includes the portion related to Net Loans

Non-accrual Loans

All loans individually evaluated for impairment are measured for losses on a quarterly basis. As of December 31, 2020 and December 31, 2019, substantially all of the Corporation’s individually evaluated loans with total commitments greater than or equal to $1.0 million were measured based on the estimated fair value of each loan’s collateral, if any. Collateral could be in the form of real estate, in the case of commercial mortgages and construction loans, or business assets, such as accounts receivable or inventory, in the case of commercial and industrial loans. Commercial and industrial loans may also be secured by real estate.

As of December 31, 2020 and 2019, approximately 83% and 93%, respectively, of loans evaluated individually for impairment with principal balances greater than or equal to $1.0 million, whose primary collateral is real estate, were measured at estimated fair value using appraisals performed by state certified third-party appraisers that had been updated in the preceding 12 months.

The following table presents total non-accrual loans, by class segment:


	2020						2019
	With a Related Allowance		Without a Related Allowance		Total		Total
	(in thousands)
Real estate - commercial mortgage	$	19,909	$	31,561	$	51,470	$	33,166
Commercial and industrial	13,937		18,056		31,993		48,106
Real estate - residential mortgage	24,590		1,517		26,107		16,676
Real estate - home equity	9,398		190		9,588		7,004
Real estate - construction	437		958		1,395		3,618
Consumer	332		—		332		—
Equipment lease financing and other	—		16,313		16,313		16,528
Total	$	68,603	$	68,595	$	137,198	$	125,098

As of December 31, 2020, there were $68.6 million of non-accrual loans that did not have a related allowance for credit losses. The estimated fair values of the collateral securing these loans exceeded their carrying amount, or the loans were previously charged down to realizable collateral values. Accordingly, no specific valuation allowance was considered to be necessary. In 2020, the total interest income that would have been recorded if non-accrual loans had been current in accordance with their original terms was $5.8 million. The amount of interest income on non-accrual loans that was recognized in 2020 was approximately $290,000.

Asset Quality

Maintaining an appropriate ACL is dependent on various factors, including the ability to identify potential problem loans in a timely manner. For commercial construction, residential construction, commercial and industrial, and commercial real estate, an internal risk rating process is used. The Corporation believes that internal risk ratings are the most relevant credit quality indicator for these types of loans. The migration of loans through the various internal risk categories is a significant component of the ACL methodology for these loans, under both the CECL and incurred loss models, which bases the probability of default on this migration. Assigning risk ratings involves judgment. The Corporation's loan review officers provide a separate assessment of risk rating accuracy. Risk ratings may be changed based on the ongoing monitoring procedures performed by loan officers or credit administration staff, or if specific loan review assessments identify a deterioration or an improvement in the loans.

The following table summarizes designated internal risk categories by portfolio segment and loan class, by origination year, in the current period:


		December 31, 2020
		Term Loans Amortized Cost Basis by Origination Year												Revolving Loans		Revolving Loans converted to Term Loans
		(dollars in thousands)												Amortized		Amortized
		2020		2019		2018		2017		2016		Prior		Cost Basis		Cost Basis		Total
Real estate - construction (1)
	Pass	$	185,883	$	229,097	$	217,604	$	81,086	$	37,976	$	110,470	$	38,026	$	—	$	900,142
	Special Mention	—		—		—		—		7,047		6,212		—		—		13,259
	Substandard or Lower	—		447		—		2,000		753		1,637		632		—		5,469
	Total real estate - construction	185,883		229,544		217,604		83,086		45,776		118,319		38,658		—		918,870
Real estate - construction (1)
	Current period gross charge-offs	—		—		—		—		—		(17)		—		—		(17)
	Current period recoveries	—		—		—		—		68		5,054		—		—		5,122
	Total net (charge-offs) recoveries	—		—		—		—		68		5,037		—		—		5,105
Commercial and industrial (2)
	Pass	2,283,533		508,541		298,567		214,089		208,549		596,646		1,278,689		—		5,388,614
	Special Mention	6,633		23,834		29,167		10,945		11,506		25,960		45,994		—		154,039
	Substandard or Lower	3,221		5,947		8,434		11,251		11,192		23,852		64,278		—		128,175
	Total commercial and industrial	2,293,387		538,322		336,168		236,285		231,247		646,458		1,388,961		—		5,670,828
Commercial and industrial
	Current period gross charge-offs	—		(114)		(30)		(488)		(393)		(520)		(17,370)		—		(18,915)
	Current period recoveries	—		43		486		216		162		4,531		5,958		—		11,396
	Total net (charge-offs) recoveries	—		(71)		456		(272)		(231)		4,011		(11,412)		—		(7,519)
Real estate - commercial mortgage
	Pass	973,664		917,510		708,946		794,955		783,094		2,213,343		53,041		404		6,444,957
	Special Mention	13,639		40,874		84,047		80,705		89,112		167,424		2,364		—		478,165
	Substandard or Lower	1,238		6,681		6,247		39,027		22,605		103,007		2,225		940		181,970
	Total real estate - commercial mortgage	988,541		965,065		799,240		914,687		894,811		2,483,774		57,630		1,344		7,105,092
Real estate - commercial mortgage
	Current period gross charge-offs	(60)		(21)		(36)		(2,515)		(29)		(1,547)		(17)		—		(4,225)
	Current period recoveries	—		6		—		—		1		1,020		—		—		1,027
	Total net (charge-offs) recoveries	(60)		(15)		(36)		(2,515)		(28)		(527)		(17)		—		(3,198)
Total
	Pass	$	3,443,080	$	1,655,148	$	1,225,117	$	1,090,130	$	1,029,619	$	2,920,459	$	1,369,756	$	404	$	12,733,713
	Special Mention	20,272		64,708		113,214		91,650		107,665		199,596		48,358		—		645,463
	Substandard or Lower	4,459		13,075		14,681		52,278		34,550		128,496		67,135		940		315,614
	Total	$	3,467,811	$	1,732,931	$	1,353,012	$	1,234,058	$	1,171,834	$	3,248,551	$	1,485,249	$	1,344	$	13,694,790

(1) Excludes real estate - construction - other.

(2) Loans originated in 2020 include $1.6 million of PPP loans that were assigned a rating of Pass based on the existence of a federal government guaranty through the SBA.

The information presented in the preceding table is not required to be disclosed for periods prior to the adoption of CECL. The following table presents the most comparable required information for the prior period, internal credit risk ratings for the indicated loan class segments:


	December 31, 2019
	Pass			Special Mention			Substandard or Lower			Total
	(dollars in thousands)
Real estate - commercial mortgage	$	6,429,407		$	137,163		$	134,206		$	6,700,776
Commercial and industrial - secured	3,830,847			171,442			195,884			4,198,173
Commercial and industrial - unsecured	234,987			9,665			3,876			248,528
Total commercial and industrial	4,065,834			181,107			199,760			4,446,701
Construction - commercial residential	100,808			2,897			3,461			107,166
Construction - commercial	765,562			1,322			2,676			769,560
Total construction (excluding construction - other)	866,370			4,219			6,137			876,726
	$	11,361,611		$	322,489		$	340,103		$	12,024,203
% of Total	94.5		%	2.7		%	2.8		%	100.0		%

The Corporation does not assign internal risk ratings to smaller balance, homogeneous loans, such as home equity, residential mortgage, construction loans to individuals secured by residential real estate, consumer and equipment lease financing. For these loans, the most relevant credit quality indicator is delinquency status. The migration of loans through the various delinquency status categories is a significant component of the ACL methodology for those loans, under both the CECL and incurred loss models, which base the PD on this migration.

The Corporation considers the performance of the loan portfolio and its impact on the ACL. For certain loans classes, the Corporation evaluates credit quality based on the aging status of the loan. The following table presents the amortized cost of these loans based on payment activity, by origination year, for the current period:


		December 31, 2020
		Term Loans Amortized Cost Basis by Origination Year												Revolving Loans		Revolving Loans converted to Term Loans
		(dollars in thousands)												Amortized		Amortized
		2020		2019		2018		2017		2016		Prior		Cost Basis		Cost Basis		Total
Real estate - home equity
	Performing	$	31,445	$	8,176	$	13,906	$	11,024	$	11,667	$	126,749	$	982,285	$	5,321	$	1,190,573
	Non-performing	—		88		23		233		221		2,290		9,485		—		12,340
	Total real estate - home equity	31,445		8,264		13,929		11,257		11,888		129,039		991,770		5,321		1,202,913
Real estate - home equity
	Current period gross charge-offs	—		—		—		—		—		(34)		(1,159)		—		(1,193)
	Current period recoveries	—		—		—		—		—		138		366		—		504
	Total net (charge-offs) recoveries	—		—		—		—		—		104		(793)		—		(689)
Real estate - residential mortgage
	Performing	1,255,532		585,878		228,398		341,563		264,990		434,889		—		—		3,111,250
	Non-performing	217		2,483		3,177		2,483		722		21,583		—		—		30,665
	Total real estate - residential mortgage	1,255,749		588,361		231,575		344,046		265,712		456,472		—		—		3,141,915
Real estate - residential mortgage
	Current period gross charge-offs	—		(68)		(101)		(190)		(7)		(254)		—		—		(620)
	Current period recoveries	—		68		16		1		1		405		—		—		491
	Total net (charge-offs) recoveries	—		—		(85)		(189)		(6)		151		—		—		(129)
Consumer
	Performing	114,399		98,587		95,072		43,334		25,804		36,086		52,698		42		466,022
	Non-performing	168		19		124		141		114		150		34		—		750
	Total consumer	114,567		98,606		95,196		43,475		25,918		36,236		52,732		42		466,772
Consumer
	Current period gross charge-offs	(134)		(542)		(524)		(444)		(489)		(769)		(498)		—		(3,400)
	Current period recoveries	—		64		165		159		94		101		1,292		—		1,875
	Total net (charge-offs) recoveries	(134)		(478)		(359)		(285)		(395)		(668)		794		—		(1,525)
Equipment lease financing and other
	Performing	102,324		65,303		49,453		34,995		15,631		5,040		—		—		272,746
	Non-performing	—		—		30		15,983		142		282		—		—		16,437
	Total leasing and other	102,324		65,303		49,483		50,978		15,773		5,322		—		—		289,183
Equipment lease financing and other
	Current period gross charge-offs	(606)		(1,581)		—		—		—		—		—		—		(2,187)
	Current period recoveries	185		349		21		18		11		21		—		—		605
	Total net (charge-offs) recoveries	(421)		(1,232)		21		18		11		21		—		—		(1,582)
Construction - other
	Performing	96,444		24,888		6,822		—		16		—		—		—		128,170
	Non-performing	—		—		—		178		—		—		—		—		178
	Total construction - other	96,444		24,888		6,822		178		16		—		—		—		128,348
Construction - other
	Current period gross charge-offs	—		—		—		—		—		—		—		—		—
	Current period recoveries	—		—		—		—		—		—		—		—		—
	Total net (charge-offs) recoveries	—		—		—		—		—		—		—		—		—
Total
	Performing	$	1,600,144	$	782,832	$	393,651	$	430,916	$	318,108	$	602,764	$	1,034,983	$	5,363	$	5,168,761
	Non-performing	385		2,590		3,354		19,018		1,199		24,305		9,519		—		60,370
	Total	$	1,600,529	$	785,422	$	397,005	$	449,934	$	319,307	$	627,069	$	1,044,502	$	5,363	$	5,229,131

The information presented in the preceding table not required to be disclosed for periods prior to the adoption of CECL. The following table presents the most comparable required information for the prior period, a summary of performing, delinquent and non-performing loans for the indicated class segments:


	December 31, 2019
	Performing			Delinquent (1)			Non-performing (2)			Total
	(dollars in thousands)
Real estate - home equity	$	1,292,035		$	12,341		$	10,568		$	1,314,944
Real estate - residential mortgage	2,584,763			34,291			22,411			2,641,465
Construction - other	92,649			895			809			94,353
Consumer - direct	63,582			465			190			64,237
Consumer - indirect	393,974			4,685			268			398,927
Total consumer	457,556			5,150			458			463,164
Equipment lease financing and other	278,743			4,012			16,642			299,397
	$	4,705,746		$	56,689		$	50,888		$	4,813,323
% of Total	97.8		%	1.2		%	1.0		%	100		%

(1)Includes all accruing loans 30 days to 89 days past due.

(2)Includes all accruing loans 90 days or more past due and all non-accrual loans.

The following table presents non-performing assets:


	December 31, 2020		December 31, 2019
	(in thousands)
Non-accrual loans	$	137,198	$	125,098
Loans 90 days or more past due and still accruing	9,929		16,057
Total non-performing loans	147,127		141,155
OREO (1)	4,178		6,831
Total non-performing assets	$	151,305	$	147,986

(1) Excludes $8.1 million of residential mortgage properties for which formal foreclosure proceedings were in process as of December 31, 2020.

The following tables present the aging of the amortized cost basis of loans, by class segment:


	30-59		60-89		≥ 90 Days
	Days Past		Days Past		Past Due		Non-
	Due		Due		and Accruing		Accrual		Current		Total
	(in thousands)
December 31, 2020
Real estate – commercial mortgage	$	14,999	$	9,273	$	1,177	$	51,470	$	7,028,173	$	7,105,092
Commercial and industrial	11,285		1,068		616		31,993		5,625,866		5,670,828
Real estate – residential mortgage	22,281		7,675		4,687		26,107		3,081,165		3,141,915
Real estate – home equity	5,622		1,654		2,753		9,588		1,183,296		1,202,913
Real estate – construction	1,938		—		155		1,395		1,043,730		1,047,218
Consumer	3,036		501		417		332		462,486		466,772
Equipment lease financing and other	838		150		124		16,313		248,657		266,082
Total	$	59,999	$	20,321	$	9,929	$	137,198	$	18,673,373	$	18,900,820


	30-59 Days Past Due		60-89 Days Past Due		≥ 90 Days Past Due and Accruing		Non- accrual		Current		Total
	(in thousands)
December 31, 2019
Real estate – commercial mortgage	$	10,912	$	1,543	$	4,113	$	33,166	$	6,651,042	$	6,700,776
Commercial and industrial	2,302		2,630		1,385		48,106		4,392,278		4,446,701
Real estate – residential mortgage	26,982		7,309		5,735		16,676		2,584,763		2,641,465
Real estate – home equity	9,635		2,706		3,564		7,004		1,292,035		1,314,944
Real estate – construction	1,715		900		688		3,618		964,158		971,079
Consumer	4,228		922		458		—		457,556		463,164
Equipment lease financing and other	552		3,460		114		16,528		278,743		299,397
Total	$	56,326	$	19,470	$	16,057	$	125,098	$	16,620,575	$	16,837,526

Collateral-Dependent Loans

A financial asset is considered to be collateral-dependent when the debtor is experiencing financial difficulty and repayment is expected to be provided substantially through the sale or operation of the collateral. For all classes of financial assets deemed collateral-dependent, the Corporation elected the practical expedient to estimate expected credit losses based on the collateral’s fair value less cost to sell. In most cases, the Corporation records a partial charge-off to reduce the loan’s carrying value to the collateral’s fair value less cost to sell. Substantially all of the collateral supporting collateral-dependent financial assets consists of various types of real estate including residential properties; commercial properties such as retail centers, office buildings, and lodging; agriculture land; and vacant land.

Troubled Debt Restructurings

The following table presents TDRs, by class segment for the years ended December 31:


	2020		2019
	(in thousands)
Real estate - commercial mortgage	$	28,451	$	13,330
Commercial and industrial	6,982		5,193
Real estate - residential mortgage	18,602		21,551
Real estate - home equity	14,391		15,068

Consumer	—		8

Total accruing TDRs	68,426		55,150
Non-accrual TDRs (1)	35,755		20,825
Total TDRs	$	104,181	$	75,975

(1) Included within non-accrual loans in the preceding table.

The following table presents TDRs, by class segment, for loans that were modified during the years ended December 31:


	2020			2019			2018
	Number of Loans	Post-Modification Recorded Investment		Number of Loans	Post-Modification Recorded Investment		Number of Loans	Post-Modification Recorded Investment
	(dollars in thousands)
Real estate - commercial mortgage	12	$	24,868	2	$	263	6	$	8,261
Commercial and industrial	20	5,218		16	5,378		8	4,226
Real estate - residential mortgage	48	10,493		6	2,252		7	801
Real estate - home equity	48	4,359		59	2,706		96	5,087

Consumer	14	345		—	—		—	—

Total	142	$	45,283	83	$	10,599	117	$	18,375

Restructured loan modifications may include payment schedule modifications, interest rate concessions, bankruptcies, principal reduction or some combination of these concessions. The restructured loan modifications primarily included maturity date extensions, rate modifications and payment schedule modifications.

In accordance with regulatory guidance, payment schedule modifications granted after March 13, 2020, to borrowers impacted by the effects of COVID-19 pandemic and who are not delinquent at the time of the payment schedule modifications, have been excluded from TDRs. For the year ended December 31, 2020, payment schedule modifications having a recorded investment of $3.5 billion were excluded from TDRs based on this regulatory guidance.