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Loans and Related Allowance for Credit Losses

9 Months Ended

Sep. 30, 2022

LOANS AND RELATED ALLOWANCE FOR CREDIT LOSSES

Loan Portfolio

Our loan portfolio consists of two portfolio segments – Commercial and Consumer. Each of these segments comprises multiple loan classes. Classes are characterized by similarities in risk attributes and the manner in which we monitor and assess credit risk.


Commercial						Consumer

• Commercial and industrial						• Residential real estate
• Commercial real estate						• Home equity
• Equipment lease financing						• Automobile
						• Credit card
						• Education
						• Other consumer

See Note 1 Accounting Policies included in Item 8 of our 2021 Form 10-K for additional information on our loan related policies.

Credit Quality

We closely monitor economic conditions and loan performance trends to manage and evaluate our exposure to credit risk within the loan portfolio based on our defined loan classes. In doing so, we use several credit quality indicators, including trends in delinquency rates, nonperforming status, analysis of PD and LGD ratings, updated credit scores and originated and updated LTV ratios.

The measurement of delinquency status is based on the contractual terms of each loan. Loans that are 30 days or more past due in terms of payment are considered delinquent. Loan delinquencies include government insured or guaranteed loans, loans accounted for under the fair value option and PCD loans.

Table 40 presents the composition and delinquency status of our loan portfolio at September 30, 2022 and December 31, 2021. We manage credit risk based on the risk profile of the borrower, repayment sources, underlying collateral and other support given current events, economic conditions and expectations. We refine our practices to meet the changing environment resulting from rising inflation levels, supply chain disruptions, higher rates, and secular changes fostered by the COVID-19 pandemic. To mitigate losses and enhance customer support, we have customer assistance, loan modification and collection programs that align with the CARES Act and subsequent interagency guidance. As a result, under the CARES Act credit reporting rules, certain loans modified due to COVID-19 related hardships are not being reported as past due as of September 30, 2022 and December 31, 2021 based on the contractual terms of the loan, even where borrowers may not be making payments on their loans during the modification period.

Table 40: Analysis of Loan Portfolio (a) (b)


	Accruing
Dollars in millions	Current or Less Than 30 Days Past Due			30-59 Days Past Due			60-89 Days Past Due			90 Days Or More Past Due			Total Past Due (c)				Nonperforming Loans			Fair Value Option Nonaccrual Loans (d)			Total Loans (e)(f)
September 30, 2022
Commercial
Commercial and industrial	$	172,550		$	321		$	55		$	139		$	515			$	748					$	173,813
Commercial real estate	35,424			11			4			5			20				148						35,592
Equipment lease financing	6,173			6			6						12				7						6,192
Total commercial	214,147			338			65			144			547				903						215,597
Consumer
Residential real estate	43,467			298			95			196			589			(c)	429			$	572		45,057
Home equity	24,693			46			16						62				530			82			25,367
Automobile	14,735			96			21			6			123				167						15,025
Credit card	6,636			44			30			58			132				6						6,774
Education	2,162			36			26			63			125			(c)							2,287
Other consumer	5,212			21			15			12			48				33						5,293
Total consumer	96,905			541			203			335			1,079				1,165			654			99,803
Total	$	311,052		$	879		$	268		$	479		$	1,626			$	2,068		$	654		$	315,400
Percentage of total loans	98.61		%	0.28		%	0.08		%	0.15		%	0.52		%		0.66		%	0.21		%	100.00		%
December 31, 2021
Commercial
Commercial and industrial	$	151,698		$	235		$	72		$	132		$	439			$	796					$	152,933
Commercial real estate	33,580			46			24			1			71				364						34,015
Equipment lease financing	6,095			25			2						27				8						6,130
Total commercial	191,373			306			98			133			537				1,168						193,078
Consumer
Residential real estate	37,706			379			119			328			826			(c)	517			$	663		39,712
Home equity	23,305			53			18						71				596			89			24,061
Automobile	16,252			146			40			14			200				183						16,635
Credit card	6,475			49			33			62			144				7						6,626
Education	2,400			43			25			65			133			(c)							2,533
Other consumer	5,644			35			22			17			74				9						5,727
Total consumer	91,782			705			257			486			1,448				1,312			752			95,294
Total	$	283,155		$	1,011		$	355		$	619		$	1,985			$	2,480		$	752		$	288,372
Percentage of total loans	98.19		%	0.35		%	0.12		%	0.21		%	0.69		%		0.86		%	0.26		%	100.00		%

(a)Amounts in table represent loans held for investment and do not include any associated ALLL.

(b)The accrued interest associated with our loan portfolio totaled $1.0 billion and $0.7 billion at September 30, 2022 and December 31, 2021, respectively. These amounts are included in Other assets on the Consolidated Balance Sheet.

(c)Past due loan amounts include government insured or guaranteed Residential real estate loans and Education loans totaling $0.3 billion and $0.1 billion at September 30, 2022. Comparable amounts at December 31, 2021 were $0.4 billion and $0.1 billion.

(d)Consumer loans accounted for under the fair value option for which we do not expect to collect substantially all principal and interest are subject to nonaccrual accounting and classification upon meeting any of our nonaccrual policies. Given that these loans are not accounted for at amortized cost, these loans have been excluded from the nonperforming loan population.

(e)Includes unearned income, unamortized deferred fees and costs on originated loans and premiums or discounts on purchased loans totaling $0.7 billion at both September 30, 2022 and December 31, 2021.

(f)Collateral dependent loans totaled $1.3 billion and $1.7 billion at September 30, 2022 and December 31, 2021, respectively.

At September 30, 2022, we pledged $26.0 billion of commercial and other loans to the Federal Reserve Bank and $90.7 billion of residential real estate and other loans to the FHLB as collateral for the ability to borrow, if necessary. The comparable amounts at December 31, 2021 were $25.7 billion and $66.2 billion, respectively. Amounts pledged reflect the unpaid principal balances.

Nonperforming Assets

Nonperforming assets include nonperforming loans and leases, OREO and foreclosed assets. Nonperforming loans are those loans accounted for at amortized cost whose credit quality has deteriorated to the extent that full collection of contractual principal and interest is not probable and include nonperforming TDRs and PCD loans. Interest income is not recognized on these loans. Loans accounted for under the fair value option are reported as performing loans; however, when nonaccrual criteria is met, interest income is not recognized on these loans. Additionally, certain government insured or guaranteed loans for which we expect to collect

substantially all principal and interest are not reported as nonperforming loans and continue to accrue interest. See Note 1 Accounting Policies included in Item 8 of our 2021 Form 10-K for additional information on our nonperforming loan and lease policies.

The following table presents our nonperforming assets as of September 30, 2022 and December 31, 2021, respectively:

Table 41: Nonperforming Assets


Dollars in millions	September 30 2022			December 31 2021
Nonperforming loans
Commercial	$	903		$	1,168
Consumer (a)	1,165			1,312
Total nonperforming loans (b)	2,068			2,480
OREO and foreclosed assets	33			26
Total nonperforming assets	$	2,101		$	2,506
Nonperforming loans to total loans	0.66		%	0.86		%
Nonperforming assets to total loans, OREO and foreclosed assets	0.67		%	0.87		%
Nonperforming assets to total assets	0.38		%	0.45		%

(a)Excludes most unsecured consumer loans and lines of credit, which are charged off after 120 to 180 days past due and are not placed on nonperforming status.

(b)Nonperforming loans for which there is no related ALLL totaled $0.9 billion at September 30, 2022 and primarily include loans with a fair value of collateral that exceeds the amortized cost basis. The comparable amount at December 31, 2021 was $1.0 billion.

Nonperforming loans include certain loans whose terms have been restructured in a manner that grants a concession to a borrower experiencing financial difficulties. In accordance with applicable accounting guidance, these loans are considered TDRs. See Note 1 Accounting Policies included in Item 8 of our 2021 Form 10-K and the Troubled Debt Restructurings section of this Note 4 for additional information on TDRs.

Total nonperforming loans in Table 41 include TDRs of $0.7 billion and $1.0 billion at September 30, 2022 and December 31, 2021, respectively. TDRs that are performing, including consumer credit card TDR loans, are excluded from nonperforming loans and totaled $0.7 billion and $0.6 billion at September 30, 2022 and December 31, 2021, respectively.

Additional Credit Quality Indicators by Loan Class

Commercial Loan Classes

See Note 4 Loans and Related Allowance for Credit Losses included in Item 8 of our 2021 Form 10-K for additional information related to these loan classes, including discussion around the credit quality indicators that we use to monitor and manage the credit risk associated with each loan class.

The following table presents credit quality indicators for the commercial loan classes:

Table 42: Commercial Credit Quality Indicators (a)


	Term Loans by Origination Year
September 30, 2022 In millions	2022		2021		2020		2019		2018		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Commercial and industrial
Pass Rated	$	31,271	$	14,475	$	9,018	$	7,607	$	4,858	$	14,602	$	85,101	$	69	$	167,001
Criticized	802		439		360		429		334		643		3,777		28		6,812
Total commercial and industrial	32,073		14,914		9,378		8,036		5,192		15,245		88,878		97		173,813
Commercial real estate
Pass Rated	6,789		4,114		3,684		5,975		3,198		7,957		266				31,983
Criticized	332		39		235		583		833		1,584		3				3,609
Total commercial real estate	7,121		4,153		3,919		6,558		4,031		9,541		269				35,592
Equipment lease financing
Pass Rated	1,168		1,010		1,000		718		454		1,599						5,949
Criticized	45		59		61		42		21		15						243
Total equipment lease financing	1,213		1,069		1,061		760		475		1,614						6,192
Total commercial	$	40,407	$	20,136	$	14,358	$	15,354	$	9,698	$	26,400	$	89,147	$	97	$	215,597


	Term Loans by Origination Year
December 31, 2021 In millions	2021		2020		2019		2018		2017		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Commercial and industrial
Pass Rated	$	27,104	$	12,053	$	10,731	$	6,698	$	6,355	$	11,759	$	71,230	$	90	$	146,020
Criticized	283		368		815		649		496		824		3,448		30		6,913
Total commercial and industrial	27,387		12,421		11,546		7,347		6,851		12,583		74,678		120		152,933
Commercial real estate
Pass Rated	4,110		4,109		6,355		4,234		2,634		7,562		436				29,440
Criticized	294		298		999		820		566		1,552		46				4,575
Total commercial real estate	4,404		4,407		7,354		5,054		3,200		9,114		482				34,015
Equipment lease financing
Pass Rated	1,212		1,190		942		682		507		1,410						5,943
Criticized	37		54		41		29		19		7						187
Total equipment lease financing	1,249		1,244		983		711		526		1,417						6,130
Total commercial	$	33,040	$	18,072	$	19,883	$	13,112	$	10,577	$	23,114	$	75,160	$	120	$	193,078

(a)Loans in our commercial portfolio are classified as Pass Rated or Criticized based on the regulatory definitions, which are driven by the PD and LGD ratings that we assign. The Criticized classification includes loans that were rated special mention, substandard or doubtful as of September 30, 2022 and December 31, 2021.

Consumer Loan Classes

associated with each loan class.

Residential Real Estate and Home Equity

The following table presents credit quality indicators for the residential real estate and home equity loan classes:

Table 43: Credit Quality Indicators for Residential Real Estate and Home Equity Loan Classes


	Term Loans by Origination Year
September 30, 2022 In millions	2022		2021		2020		2019		2018		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Residential real estate
Current estimated LTV ratios
Greater than 100%			$	46	$	24	$	6	$	6	$	40					$	122
Greater than or equal to 80% to 100%	$	979	529		173		67		19		95						1,862
Less than 80%	8,168		16,197		7,240		2,409		852		7,493						42,359
No LTV available			53		1						8						62
Government insured or guaranteed loans	3		9		50		35		24		531						652
Total residential real estate	$	9,150	$	16,834	$	7,488	$	2,517	$	901	$	8,167					$	45,057
Updated FICO scores
Greater than or equal to 780	$	5,416	$	12,138	$	5,267	$	1,644	$	465	$	4,113					$	29,043
720 to 779	3,152		3,294		1,457		499		212		1,610						10,224
660 to 719	442		752		403		190		91		806						2,684
Less than 660	42		109		112		83		71		775						1,192
No FICO score available	95		532		199		66		38		332						1,262
Government insured or guaranteed loans	3		9		50		35		24		531						652
Total residential real estate	$	9,150	$	16,834	$	7,488	$	2,517	$	901	$	8,167					$	45,057
Home equity
Current estimated LTV ratios
Greater than 100%			$	2	$	12	$	7	$	1	$	14	$	220	$	95	$	351
Greater than or equal to 80% to 100%			4		52		27		4		30		748		1,058		1,923
Less than 80%			179		2,143		1,004		300		3,021		7,861		8,585		23,093
Total home equity			$	185	$	2,207	$	1,038	$	305	$	3,065	$	8,829	$	9,738	$	25,367
Updated FICO scores
Greater than or equal to 780			$	109	$	1,400	$	577	$	162	$	1,895	$	5,154	$	5,123	$	14,420
720 to 779			51		537		269		69		602		2,274		2,582		6,384
660 to 719			21		212		138		44		307		1,059		1,331		3,112
Less than 660			4		55		53		29		251		324		633		1,349
No FICO score available					3		1		1		10		18		69		102
Total home equity			$	185	$	2,207	$	1,038	$	305	$	3,065	$	8,829	$	9,738	$	25,367


(Continued from previous page)	Term Loans by Origination Year
December 31, 2021 In millions	2021		2020		2019		2018		2017		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Residential real estate
Current estimated LTV ratios
Greater than 100%	$	10	$	52	$	21	$	12	$	13	$	77					$	185
Greater than or equal to 80% to 100%	1,460		560		221		86		66		190						2,583
Less than 80%	15,213		7,822		2,834		1,004		1,570		7,385						35,828
No LTV available	275		6		1		1				22						305
Government insured or guaranteed loans	3		33		37		30		39		669						811
Total residential real estate	$	16,961	$	8,473	$	3,114	$	1,133	$	1,688	$	8,343					$	39,712
Updated FICO scores
Greater than or equal to 780	$	11,110	$	5,898	$	1,996	$	596	$	1,029	$	4,052					$	24,681
720 to 779	4,921		1,735		643		247		345		1,619						9,510
660 to 719	717		463		255		136		133		796						2,500
Less than 660	83		103		96		75		94		848						1,299
No FICO score available	127		241		87		49		48		359						911
Government insured or guaranteed loans	3		33		37		30		39		669						811
Total residential real estate	$	16,961	$	8,473	$	3,114	$	1,133	$	1,688	$	8,343					$	39,712
Home equity
Current estimated LTV ratios
Greater than 100%	$	1	$	16	$	14	$	3	$	2	$	25	$	329	$	90	$	480
Greater than or equal to 80% to 100%	7		85		62		13		11		66		990		674		1,908
Less than 80%	204		2,487		1,189		370		549		3,200		7,868		5,806		21,673
Total home equity	$	212	$	2,588	$	1,265	$	386	$	562	$	3,291	$	9,187	$	6,570	$	24,061
Updated FICO scores
Greater than or equal to 780	$	124	$	1,619	$	692	$	201	$	364	$	2,035	$	5,490	$	3,320	$	13,845
720 to 779	61		666		348		96		116		642		2,283		1,679		5,891
660 to 719	23		248		167		56		53		327		1,071		872		2,817
Less than 660	4		53		57		32		28		277		325		615		1,391
No FICO score available			2		1		1		1		10		18		84		117
Total home equity	$	212	$	2,588	$	1,265	$	386	$	562	$	3,291	$	9,187	$	6,570	$	24,061

Automobile, Credit Card, Education and Other Consumer

The following table presents credit quality indicators for the automobile, credit card, education and other consumer loan classes:

Table 44: Credit Quality Indicators for Automobile, Credit Card, Education and Other Consumer Loan Classes


	Term Loans by Origination Year
September 30, 2022 In millions	2022		2021		2020		2019		2018		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Updated FICO Scores
Automobile
FICO score greater than or equal to 780	$	1,984	$	2,327	$	1,041	$	887	$	301	$	111					$	6,651
720 to 779	1,277		1,503		649		635		277		100						4,441
660 to 719	622		728		388		470		229		79						2,516
Less than 660	117		289		242		404		266		99						1,417

Total automobile	$	4,000	$	4,847	$	2,320	$	2,396	$	1,073	$	389					$	15,025
Credit card
FICO score greater than or equal to 780													$	1,835	$	2	$	1,837
720 to 779													1,945		7		1,952
660 to 719													1,876		15		1,891
Less than 660													952		32		984
No FICO score available or required (a)													107		3		110
Total credit card													$	6,715	$	59	$	6,774
Education
FICO score greater than or equal to 780	$	18	$	55	$	51	$	63	$	52	$	373					$	612
720 to 779	20		28		25		31		25		151						280
660 to 719	12		8		8		10		9		64						111
Less than 660	2		1		1		2		2		22						30
No FICO score available or required (a)	16		8		9		6		2		1						42
Education loans using FICO credit metric	68		100		94		112		90		611						1,075
Other internal credit metrics											1,212						1,212
Total education	$	68	$	100	$	94	$	112	$	90	$	1,823					$	2,287
Other consumer
FICO score greater than or equal to 780	$	176	$	118	$	68	$	59	$	20	$	22	$	51	$	2	$	516
720 to 779	240		149		84		80		28		16		93		2		692
660 to 719	182		122		83		83		37		11		96		3		617
Less than 660	15		49		42		48		26		7		45		2		234

Other consumer loans using FICO credit metric	613		438		277		270		111		56		285		9		2,059
Other internal credit metrics	78		44		39		59		8		31		2,950		25		3,234
Total other consumer	$	691	$	482	$	316	$	329	$	119	$	87	$	3,235	$	34	$	5,293


(Continued from previous page)	Term Loans by Origination Year
December 31, 2021 In millions	2021		2020		2019		2018		2017		Prior		Revolving Loans		Revolving Loans Converted to Term		Total Loans
Updated FICO Scores
Automobile
FICO score greater than or equal to 780	$	3,247	$	1,496	$	1,380	$	533	$	226	$	79					$	6,961
720 to 779	2,119		983		1,030		499		195		62						4,888
660 to 719	969		609		772		413		155		44						2,962
Less than 660	277		315		583		429		162		58						1,824
Total automobile	$	6,612	$	3,403	$	3,765	$	1,874	$	738	$	243					$	16,635
Credit card
FICO score greater than or equal to 780													$	1,815	$	2	$	1,817
720 to 779													1,836		9		1,845
660 to 719													1,856		19		1,875
Less than 660													943		29		972
No FICO score available or required (a)													114		3		117
Total credit card													$	6,564	$	62	$	6,626
Education
FICO score greater than or equal to 780	$	37	$	60	$	77	$	62	$	48	$	392					$	676
720 to 779	20		29		37		30		21		160						297
660 to 719	7		9		11		11		7		73						118
Less than 660	1		1		2		2		2		25						33
No FICO score available or required (a)	11		10		7		2				1						31
Education loans using FICO credit metric	76		109		134		107		78		651						1,155
Other internal credit metrics											1,378						1,378
Total education	$	76	$	109	$	134	$	107	$	78	$	2,029					$	2,533
Other consumer
FICO score greater than or equal to 780	$	199	$	131	$	123	$	47	$	12	$	32	$	95	$	1	$	640
720 to 779	250		172		167		68		15		19		125				816
660 to 719	190		145		165		82		16		11		122				731
Less than 660	50		62		85		54		10		6		50		1		318
Other consumer loans using FICO credit metric	689		510		540		251		53		68		392		2		2,505
Other internal credit metrics	87		31		35		23		22		48		2,955		21		3,222
Total other consumer	$	776	$	541	$	575	$	274	$	75	$	116	$	3,347	$	23	$	5,727

(a)Loans with no FICO score available or required generally refers to new accounts issued to borrowers with limited credit history, accounts for which we cannot obtain an updated FICO score (e.g., recent profile changes), cards issued with a business name and/or cards secured by collateral. Management proactively assesses the risk and size of this loan category and, when necessary, takes actions to mitigate the credit risk.

Troubled Debt Restructurings

Table 45 quantifies the number of loans that were classified as TDRs as well as the change in the loans’ balance as a result of becoming a TDR during the three and nine months ended September 30, 2022 and September 30, 2021. Additionally, the table provides information about the types of TDR concessions. See Note 1 Accounting Policies and Note 4 Loans and Related Allowance for Credit Losses included in Item 8 of our 2021 Form 10-K for additional discussion of TDRs.

Table 45: Financial Impact and TDRs by Concession Type (a)


			Pre-TDR Amortized Cost Basis (b)		Post-TDR Amortized Cost Basis (c)
During the three months ended September 30, 2022 Dollars in millions	Number of Loans				Principal Forgiveness		Rate Reduction		Other		Total
Commercial		15	$	96			$	10	$	67	$	77
Consumer		2,232	40				29		6		35
Total TDRs		2,247	$	136			$	39	$	73	$	112
During the nine months ended September 30, 2022 Dollars in millions
Commercial		42	$	184	$	9	$	10	$	135	$	154
Consumer		8,152	126				95		18		113
Total TDRs		8,194	$	310	$	9	$	105	$	153	$	267

			Pre-TDR Amortized Cost Basis (b)		Post-TDR Amortized Cost Basis (c)
During the three months ended September 30, 2021 Dollars in millions	Number of Loans				Principal Forgiveness		Rate Reduction		Other		Total
Commercial		13	$	123					$	139	$	139
Consumer		1,340	31				$	21	7		28
Total TDRs		1,353	$	154			$	21	$	146	$	167
During the nine months ended September 30, 2021 Dollars in millions
Commercial		43	$	320					$	315	$	315
Consumer		4,822	86				$	49	28		77
Total TDRs		4,865	$	406			$	49	$	343	$	392

(a) Impact of partial charge-offs at TDR date is included in this table.

(b) Represents the amortized cost basis of the loans as of the quarter end prior to TDR designation.

After a loan is determined to be a TDR, we continue to track its performance under its most recent restructured terms. We consider a TDR to have subsequently defaulted when it becomes 60 days past due after the most recent date the loan was restructured. The following table provides a summary of TDRs that subsequently defaulted during the periods presented and were classified as TDRs during the applicable 12-month period preceding September 30, 2022 and September 30, 2021.

Table 46: Subsequently Defaulted TDRs


In millions	2022		2021
Three months ended September 30	$	23	$	6
Nine months ended September 30	$	45	$	25

Allowance for Credit Losses

We maintain the ACL related to loans at levels that we believe to be appropriate to absorb expected credit losses in the portfolios as of the balance sheet date. See Note 1 Accounting Policies included in Item 8 of our 2021 Form 10-K for a discussion of the methodologies used to determine this allowance. A rollforward of the ACL related to loans follows:

Table 47: Rollforward of Allowance for Credit Losses


	Three months ended September 30												Nine months ended September 30
	2022						2021						2022						2021
In millions	Commercial		Consumer		Total		Commercial		Consumer		Total		Commercial		Consumer		Total		Commercial		Consumer		Total
Allowance for loan and lease losses
Beginning balance	$	2,937	$	1,525	$	4,462	$	3,812	$	1,918	$	5,730	$	3,185	$	1,683	$	4,868	$	3,337	$	2,024	$	5,361
Acquisition PCD reserves							(54)		(5)		(59)								774		282		1,056
Charge-offs	(73)		(149)		(222)		(50)		(156)		(206)		(162)		(506)		(668)		(393)		(484)		(877)
Recoveries	25		78		103		29		96		125		78		251		329		81		263		344
Net (charge-offs)	(48)		(71)		(119)		(21)		(60)		(81)		(84)		(255)		(339)		(312)		(221)		(533)
Provision for (recapture of) credit losses	174		67		241		(129)		(100)		(229)		(34)		93		59		(193)		(332)		(525)
Other	(2)		(1)		(3)		(5)		(1)		(6)		(6)		$	(1)	(7)		(3)		(1)		(4)
Ending balance	$	3,061	$	1,520	$	4,581	$	3,603	$	1,752	$	5,355	$	3,061	$	1,520	$	4,581	$	3,603	$	1,752	$	5,355
Allowance for unfunded lending related commitments (a)
Beginning balance	$	630	$	51	$	681	$	533	$	112	$	645	$	564	$	98	$	662	$	485	$	99	$	584
Acquisition PCD reserves																			43		3		46
Provision for (recapture of) credit losses	(22)		23		1		2		(1)		1		44		(24)		20		7		9		16
Ending balance	$	608	$	74	$	682	$	535	$	111	$	646	$	608	$	74	$	682	$	535	$	111	$	646
Allowance for credit losses at September 30 (b)	$	3,669	$	1,594	$	5,263	$	4,138	$	1,863	$	6,001	$	3,669	$	1,594	$	5,263	$	4,138	$	1,863	$	6,001

(a) See Note 9 Commitments for additional information about the underlying commitments related to this allowance.

(b) Represents the ALLL plus allowance for unfunded lending related commitments and excludes allowances for investment securities and other financial assets, which together totaled $162 million at both September 30, 2022 and 2021.

The ACL related to loans at September 30, 2022 totaled $5.3 billion, a decrease of $0.2 billion since December 31, 2021. The following summarizes the changes in factors that influenced the ACL decline during the nine months ended September 30, 2022.

•The reassessment of pandemic-related risks drove reduced reserves at September 30, 2022, partially offset by the heightened economic stress which impacted our macroeconomic scenarios and related weightings.

•Portfolio changes also drove reserve declines at September 30, 2022 reflecting improvements in credit quality and changes in portfolio composition, partially offset by the impact from loan growth primarily in the commercial and industrial portfolio.