Legal Proceedings	6 Months Ended
Jun. 30, 2011
Legal Proceedings [Abstract]
Legal Proceedings	Note 16 Legal Proceedings We establish accruals for legal proceedings when information related to the loss contingencies represented by those matters indicates both that a loss is probable and that the amount of loss can be reasonably estimated. Any such accruals are adjusted thereafter as appropriate to reflect changed circumstances. We also determine estimates of possible losses or ranges of possible losses, whether in excess of any related accrued liability or where there is no accrued liability, for those matters disclosed in this Note 16 and also those matters disclosed in Note 22 Legal Proceedings in Part II, Item 8 of our 2010 Form 10-K and Note 16 Legal Proceedings in Part I, Item 1 of our first quarter 2011 Form 10-Q and still pending (collectively, “Prior Disclosure”) when we are able to do so. For disclosed matters where we are able to estimate such possible losses or ranges of possible losses, as of June 30, 2011, we estimate that it is reasonably possible that we could incur losses in an aggregate amount up to approximately $425 million. The estimates included in this amount are based on our analysis of currently available information and are subject to significant judgment and a variety of assumptions and uncertainties. As new information is obtained we may change our estimates. Due to the inherent subjectivity of the assessments and unpredictability of outcomes of legal proceedings, any amounts accrued or included in this aggregate amount may not represent the ultimate loss to us from the legal proceedings in question. Thus, our exposure and ultimate losses may be higher or lower, and possibly significantly so, than the amounts accrued or this aggregate amount. The aggregate estimated amount provided above does not include an estimate for every matter disclosed in this Note 16 or in Prior Disclosure, as we are unable, at this time, to estimate the losses that it is reasonably possible that we could incur or ranges of such losses with respect to some of the matters disclosed for one or more of the following reasons. In our experience, legal proceedings are inherently unpredictable. In many legal proceedings, various factors exacerbate this inherent unpredictability, including, among others, one or more of the following: the proceeding is in its early stages; the damages sought are unspecified, unsupported or uncertain; it is unclear whether a case brought as a class action will be allowed to proceed on that basis or, if permitted to proceed as a class action, how the class will be defined; the plaintiff is seeking relief other than compensatory damages; the matter presents meaningful legal uncertainties, including novel issues of law; we have not engaged in meaningful settlement discussions; discovery has not started or is not complete; there are significant facts in dispute; and there are a large number of parties named as defendants (including where it is uncertain how liability, if any, will be shared among multiple defendants). Generally, the less progress that has been made in the proceedings or the broader the range of potential results, the harder it is for us to estimate losses or ranges of losses that it is reasonably possible we could incur. Therefore, as the estimated aggregate amount disclosed above does not include all of the matters disclosed below, the amount disclosed above does not represent our maximum reasonably possible loss exposure for all of the matters disclosed in this Note 16 or in Prior Disclosure. The estimated aggregate amount also does not reflect any of our exposure to matters not so disclosed, as discussed below under “Other.” We include in some of the descriptions of individual matters in this Note 16 and in Prior Disclosure certain quantitative information related to the plaintiff's claim against us alleged in the plaintiff's pleadings or otherwise publicly available. While information of this type may provide insight into the potential magnitude of a matter, it does not necessarily represent our estimate of reasonably possible loss or our judgment as to any currently appropriate accrual. Some of our exposure in matters described below may be offset by applicable insurance coverage. We do not consider the possible availability of insurance coverage in determining the amounts of any accruals (although we record the amount of related insurance recoveries that are deemed probable up to the amount of the accrual) or in determining any estimates of possible losses or ranges of possible losses. Securities and State Law Fiduciary Cases Against National City In In re National City Corporation Securities, Derivative & ERISA Litigation (The Securities Case) (MDL No. 2003, Case No: 1:08-nc-70004), pending in the United States District Court for the Northern District of Ohio, the parties entered into a memorandum of understanding in August 2011 providing for the settlement of the lawsuit for $168 million. The settlement is conditioned on, among other things, final documentation, notice to the class and court approval. As a result of existing accruals and recorded probable insurance recoveries, the impact of this settlement on PNC's future results of operations is expected to be immaterial. CBNV Mortgage Litigation Status of MDL Proceedings in Pennsylvania. In May 2011, in the lawsuits pending in the United States District Court for the Western District of Pennsylvania under the caption In re: Community Bank of Northern Virginia Mortgage Lending Practices Litigation (MDL No. 1674), the plaintiffs collectively filed a motion seeking to file a joint amended consolidated class action complaint covering all of the class action lawsuits pending in this proceeding. The proposed amended complaint names the Community Bank of Northern Virginia (CBNV), a predecessor to PNC Bank, another bank, and purchasers of loans originated by CBNV and the other bank (including the Residential Funding Company, LLC) as defendants. The proposed amended complaint alleges, among other things, that a group of persons and entities collectively characterized as the “Shumway/Bapst Organization” referred prospective second residential mortgage loan borrowers to CBNV and the other bank, that CBNV and the other bank charged these borrowers improper title and loan fees at loan closings, that the disclosures provided to the borrowers at loan closings were inaccurate, and that CBNV and the other bank paid some of the loan fees to the Shumway/Bapst Organization as purported “kickbacks” for the referrals. The proposed amended complaint asserts claims for violations of the Real Estate Settlement Procedures Act, the Truth in Lending Act, as amended by the Home Owners Equity Protection Act (HOEPA), and the Racketeer Influenced and Corrupt Organizations Act. The proposed amended complaint seeks to certify a class of all persons nationwide who obtained a second or subordinate, residential, federally related, non-purchase money, HOEPA qualifying mortgage loan from CBNV or the other bank that was secured by residential real property used by the class member as a principal dwelling. The plaintiffs allege that there are approximately 50,000 members of this class. They seek, among other things, unspecified damages (including tripled damages under RICO and RESPA), rescission of loans, declaratory and injunctive relief, interest, and attorneys' fees. Overdraft Litigation In Henry v. PNC Bank, National Association (No. GD-10-022974), the Court of Common Pleas of Allegheny County, Pennsylvania held a hearing on our Preliminary Objections in June 2011. The hearing on final approval of the proposed settlement in Trombley, et al. v. National City Bank (Civil Action No. 10-00232 (JDB)), pending in the United States District Court for the District of Columbia, took place in July 2011. The settlement remains subject to final court approval. The amount of the settlement is not material to PNC and has been accrued. Other Mortgage-Related Litigation • In May 2011, the defendants filed a motion to dismiss the corrected amended complaint in Federal Home Loan Bank of Chicago v. Bank of America Funding Corp., et al. (Case No. 10CH45033), pending in the Circuit Court of Cook County, Illinois. • In February 2011, a lawsuit (National Organization of Assistance for Homeowners of California, et al. v. America's Servicing Company, et al., (Case No. 30-2011-00447677-CU-OR-CXC)) was filed in the Superior Court of the State of California for Orange County against PNC and numerous other financial institutions and mortgage servicing organizations. In July 2011, the plaintiffs voluntarily dismissed the lawsuit without prejudice. The lawsuit had been brought as a class action by individual plaintiffs, who alleged that they have obtained loans secured by deeds of trust on California real estate, and by a non-profit organization which purported, along with the individual plaintiffs, to represent a class of similarly situated individuals. The plaintiffs had contended, among other things, that the defendants engaged in misrepresentations and fraudulent concealment in connection with the mortgage loan origination process, engaged in wrongful foreclosure practices, caused notices of default to be issued against the plaintiffs in a manner not authorized by California law, made inaccurate credit disclosures regarding the plaintiffs, and disclosed the plaintiffs' private information without their authorization. The plaintiffs had alleged violations, among other things, of various provisions of California statutory law, the right to privacy provisions of the California Constitution, the federal Fair Credit Reporting Act and the Gramm-Leach Bliley Act. The plaintiffs had sought, among other things, unspecified actual and punitive damages, statutory civil penalties, restitution, injunctive relief, interest, and attorneys' fees. Weavering Macro Fixed Income Fund In July 2010, PNC completed the sale of GIS to The Bank of New York Mellon Corporation (BNY-Mellon), pursuant to a stock purchase agreement dated February 1, 2010. In July 2009, the liquidators of the Weavering Macro Fixed Income Fund Limited (Weavering) issued a Plenary Summons in the High Court, Dublin, Ireland, in connection with a European subsidiary of GIS's provision of administration services to Weavering. The Plenary Summons was served on the GIS subsidiary on or about June 30, 2010. In May 2011, the liquidator served a Notice of Intention to Proceed and Statement of Claim, which alleges that the GIS subsidiary breached its contractual duties to Weavering as well as an alleged duty of care to Weavering, and investors in Weavering, and makes claims of breach of the administration and accounting services agreement, negligence, gross negligence, breach of duty, misrepresentation and negligent misstatement. The complaint further alleges that investors in Weavering lost approximately €282 million and also expended approximately €98 million in brokerage and exchange commissions, interest, and fees as a result of the transactions at issue. The Statement of Claim seeks damages, costs, and interest. In May 2011, BNY-Mellon provided notice to PNC of an indemnification claim pursuant to the stock purchase agreement. 365/360 Litigation PNC Bank and National City Bank have been named as defendants in three lawsuits seeking to certify classes of commercial borrowers bringing claims for breach of contract arising from the use of the 365/360 method of interest computation in certain commercial promissory notes. The first of these cases (DK&D Properties, LLC v. National City Bank (Case no. 08 cv 680078)), was filed in December 2008 against National City Bank in the Court of Common Pleas of Cuyahoga County, Ohio. It seeks to certify a class consisting of certain Ohio commercial borrowers of National City Bank for these claims. In July 2009, the court denied National City Bank's motion to dismiss. The second case (Kreisler & Kreisler, LLC v. National City Bank, et al. (Case no. 4:10-cv-00956)) was filed in the United States District Court for the Eastern District of Missouri in May 2010 against National City Bank and also purports to name “PNC Bank Corp.” as a defendant. It seeks to certify a national class of commercial borrowers for these claims. In March 2011, the district court granted the defendants' motion to dismiss the complaint. The plaintiff has appealed the district court's grant of this motion to the United States Court of Appeals for the Eighth Circuit. In the third case (PNC Bank, National Association v. St. Louis PET Centers, LLC, et al. (Case no. 10SL-CC01076)), a borrower filed a counterclaim against PNC Bank in the Circuit Court of County of St. Louis, Missouri in November, 2010. The claims and proposed class set forth in this complaint are similar to those in Kreisler & Kreisler. We have filed a motion to strike the class action allegations in the counterclaim. Plaintiffs in these cases allege generally that they obtained fixed or variable rate commercial loans from PNC Bank or National City Bank pursuant to promissory notes or loan agreements setting forth annual or per annum interest rates, that the bank's use of the 365/360 method of calculation of interest caused the borrower to pay interest over a calendar year at a higher rate than the per annum rate stated in the promissory notes, and that this was a breach of the terms of the promissory notes. Plaintiffs in each of these cases seek declaratory and injunctive relief, compensatory damages, prejudgment interest, and attorneys' fees. Regulatory and Governmental Inquiries As a result of the regulated nature of our business and that of a number of our subsidiaries, particularly in the banking and securities areas, we and our subsidiaries are the subject of investigations, audits and other forms of regulatory inquiry, in some cases as part of regulatory reviews of specified activities at multiple industry participants, including those described below and in Prior Disclosure. In April 2011, as a result of a publicly-disclosed interagency horizontal review of residential mortgage servicing operations at fourteen federally regulated mortgage servicers, PNC entered into a consent order with the Board of Governors of the Federal Reserve System and PNC Bank entered into a consent order with the Office of the Comptroller of the Currency. Collectively, these consent orders describe certain foreclosure-related practices and controls that the regulators found to be deficient and require PNC and PNC Bank to, among other things, develop and implement plans and programs to enhance PNC's residential mortgage servicing and foreclosure processes, retain an independent consultant to review certain residential mortgage foreclosure actions, take certain remedial actions, and oversee compliance with the orders and the new plans and programs. The two orders do not foreclose the potential for civil money penalties from either of these regulators. In connection with these orders, PNC has established a Compliance Committee of the Boards of PNC and PNC Bank to monitor and coordinate PNC's and PNC Bank's implementation of the commitments under the orders. PNC and PNC Bank have submitted proposed Action Plans to the regulators setting forth the plan to meet the requirements of the orders. Consistent with the orders, PNC has also engaged an independent consultant to conduct a review of certain residential foreclosure actions, including those identified through borrower complaints, and identify whether any remedial actions for borrowers are necessary. Pursuant to the proposed Action Plans, PNC is endeavoring to meet all of the requirements of the orders. Other governmental, legislative and regulatory inquiries on this topic, referred to in Prior Disclosure, are ongoing, and may result in significant additional actions, penalties or other remedies. These additional inquiries include a review of the servicers subject to the above-mentioned horizontal review by the Department of Justice, other federal regulators and state attorneys general. In connection with that review, it is understood that the governmental regulators may seek substantial payments and other relief from the entities subject to the horizontal review, including PNC, and may also seek to impose national mortgage servicing standards. It is not currently known what relief will be sought against PNC. In addition, PNC has received subpoenas from the U.S. Attorney's Office for the Southern District of New York concerning lending practices of National City Bank and successors in connection with loans insured by the Federal Housing Administration (FHA) as well as certain non-FHA-insured loan origination, sale and securitization practices. The U.S. Attorney's Office inquiry is in its early stage and PNC is cooperating with the investigation. The outcome of the investigation is unknown, but it could result in penalties or other remedial actions. Our practice is to cooperate fully with regulatory and governmental investigations, audits and other inquiries, including those described above and in Prior Disclosure. Such investigations, audits and other inquiries may lead to remedies including fines, penalties, restitution or alterations in our business practices. Other In addition to the proceedings or other matters described above, PNC and persons to whom we may have indemnification obligations, in the normal course of business, are subject to various other pending and threatened legal proceedings in which claims for monetary damages and other relief are asserted. We do not anticipate, at the present time, that the ultimate aggregate liability, if any, arising out of such other legal proceedings will have a material adverse effect on our financial position. However, we cannot now determine whether or not any claims asserted against us or others to whom we may have indemnification obligations, whether in the proceedings or other matters described above, described in Prior Disclosure, or otherwise, will have a material adverse effect on our results of operations in any future reporting period, which will depend on, among other things, the amount of the loss resulting from the claim and the amount of income otherwise reported for the reporting period. See Note 17 Commitments and Guarantees for additional information regarding the Visa indemnification and our other obligations to provide indemnification, including to current and former officers, directors, employees and agents of PNC and companies we have acquired, including National City.

Legal Proceedings

6 Months Ended

Jun. 30, 2011

Note 16 Legal Proceedings

We establish accruals for legal proceedings when information related to the loss contingencies represented by those matters indicates both that a loss is probable and that the amount of loss can be reasonably estimated. Any such accruals are adjusted thereafter as appropriate to reflect changed circumstances. We also determine estimates of possible losses or ranges of possible losses, whether in excess of any related accrued liability or where there is no accrued liability, for those matters disclosed in this Note 16 and also those matters disclosed in Note 22 Legal Proceedings in Part II, Item 8 of our 2010 Form 10-K and Note 16 Legal Proceedings in Part I, Item 1 of our first quarter 2011 Form 10-Q and still pending (collectively, “Prior Disclosure”) when we are able to do so. For disclosed matters where we are able to estimate such possible losses or ranges of possible losses, as of June 30, 2011, we estimate that it is reasonably possible that we could incur losses in an aggregate amount up to approximately $425 million. The estimates included in this amount are based on our analysis of currently available information and are subject to significant judgment and a variety of assumptions and uncertainties. As new information is obtained we may change our estimates. Due to the inherent subjectivity of the assessments and unpredictability of outcomes of legal proceedings, any amounts accrued or included in this aggregate amount may not represent the ultimate loss to us from the legal proceedings in question. Thus, our exposure and ultimate losses may be higher or lower, and possibly significantly so, than the amounts accrued or this aggregate amount.

The aggregate estimated amount provided above does not include an estimate for every matter disclosed in this Note 16 or in Prior Disclosure, as we are unable, at this time, to estimate the losses that it is reasonably possible that we could incur or ranges of such losses with respect to some of the matters disclosed for one or more of the following reasons. In our experience, legal proceedings are inherently unpredictable. In many legal proceedings, various factors exacerbate this inherent unpredictability, including, among others, one or more of the following: the proceeding is in its early stages; the damages sought are unspecified, unsupported or uncertain; it is unclear whether a case brought as a class action will be allowed to proceed on that basis or, if permitted to proceed as a class action, how the class will be defined; the plaintiff is seeking relief other than compensatory damages; the matter presents meaningful legal uncertainties, including novel issues of law; we have not engaged in meaningful settlement discussions; discovery has not started or is not complete; there are significant facts in dispute; and there are a large number of parties named as defendants (including where it is uncertain how liability, if any, will be shared among multiple defendants). Generally, the less progress that has been made in the proceedings or the broader the range of potential results, the harder it is for us to estimate losses or ranges of losses that it is reasonably possible we could incur. Therefore, as the estimated aggregate amount disclosed above does not include all of the matters disclosed below, the amount disclosed above does not represent our maximum reasonably possible loss exposure for all of the matters disclosed in this Note 16 or in Prior Disclosure. The estimated aggregate amount also does not reflect any of our exposure to matters not so disclosed, as discussed below under “Other.”

We include in some of the descriptions of individual matters in this Note 16 and in Prior Disclosure certain quantitative information related to the plaintiff's claim against us alleged in the plaintiff's pleadings or otherwise publicly available. While information of this type may provide insight into the potential magnitude of a matter, it does not necessarily represent our estimate of reasonably possible loss or our judgment as to any currently appropriate accrual.

Some of our exposure in matters described below may be offset by applicable insurance coverage. We do not consider the possible availability of insurance coverage in determining the amounts of any accruals (although we record the amount of related insurance recoveries that are deemed probable up to the amount of the accrual) or in determining any estimates of possible losses or ranges of possible losses.

Securities and State Law Fiduciary Cases Against National City

In In re National City Corporation Securities, Derivative & ERISA Litigation (The Securities Case) (MDL No. 2003, Case No: 1:08-nc-70004), pending in the United States District Court for the Northern District of Ohio, the parties entered into a memorandum of understanding in August 2011 providing for the settlement of the lawsuit for $168 million. The settlement is conditioned on, among other things, final documentation, notice to the class and court approval. As a result of existing accruals and recorded probable insurance recoveries, the impact of this settlement on PNC's future results of operations is expected to be immaterial.

CBNV Mortgage Litigation

Status of MDL Proceedings in Pennsylvania. In May 2011, in the lawsuits pending in the United States District Court for the Western District of Pennsylvania under the caption In re: Community Bank of Northern Virginia Mortgage Lending Practices Litigation (MDL No. 1674), the plaintiffs collectively filed a motion seeking to file a joint amended consolidated class action complaint covering all of the class action lawsuits pending in this proceeding. The proposed amended complaint names the Community Bank of Northern Virginia (CBNV), a predecessor to PNC Bank, another bank, and purchasers of loans originated by CBNV and the other bank (including the Residential Funding Company, LLC) as defendants. The proposed amended complaint alleges, among other things, that a group of persons and entities collectively characterized as the “Shumway/Bapst Organization” referred prospective second residential mortgage loan borrowers to CBNV and the other bank, that CBNV and the other bank charged these borrowers improper title and loan fees at loan closings, that the disclosures provided to the borrowers at loan closings were inaccurate, and that CBNV and the other bank paid some of the loan fees to the Shumway/Bapst Organization as purported “kickbacks” for the referrals. The proposed amended complaint asserts claims for violations of the Real Estate Settlement Procedures Act, the Truth in Lending Act, as amended by the Home Owners Equity Protection Act (HOEPA), and the Racketeer Influenced and Corrupt Organizations Act.

The proposed amended complaint seeks to certify a class of all persons nationwide who obtained a second or subordinate, residential, federally related, non-purchase money, HOEPA qualifying mortgage loan from CBNV or the other bank that was secured by residential real property used by the class member as a principal dwelling. The plaintiffs allege that there are approximately 50,000 members of this class. They seek, among other things, unspecified damages (including tripled damages under RICO and RESPA), rescission of loans, declaratory and injunctive relief, interest, and attorneys' fees.

Overdraft Litigation

In Henry v. PNC Bank, National Association (No. GD-10-022974), the Court of Common Pleas of Allegheny County, Pennsylvania held a hearing on our Preliminary Objections in June 2011.

The hearing on final approval of the proposed settlement in Trombley, et al. v. National City Bank (Civil Action No. 10-00232 (JDB)), pending in the United States District Court for the District of Columbia, took place in July 2011. The settlement remains subject to final court approval. The amount of the settlement is not material to PNC and has been accrued.

Other Mortgage-Related Litigation

• In May 2011, the defendants filed a motion to dismiss the corrected amended complaint in Federal Home Loan Bank of Chicago v. Bank of America Funding Corp., et al. (Case No. 10CH45033), pending in the Circuit Court of Cook County, Illinois.

• In February 2011, a lawsuit (National Organization of Assistance for Homeowners of California, et al. v. America's Servicing Company, et al., (Case No. 30-2011-00447677-CU-OR-CXC)) was filed in the Superior Court of the State of California for Orange County against PNC and numerous other financial institutions and mortgage servicing organizations. In July 2011, the plaintiffs voluntarily dismissed the lawsuit without prejudice. The lawsuit had been brought as a class action by individual plaintiffs, who alleged that they have obtained loans secured by deeds of trust on California real estate, and by a non-profit organization which purported, along with the individual plaintiffs, to represent a class of similarly situated individuals. The plaintiffs had contended, among other things, that the defendants engaged in misrepresentations and fraudulent concealment in connection with the mortgage loan origination process, engaged in wrongful foreclosure practices, caused notices of default to be issued against the plaintiffs in a manner not authorized by California law, made inaccurate credit disclosures regarding the plaintiffs, and disclosed the plaintiffs' private information without their authorization. The plaintiffs had alleged violations, among other things, of various provisions of California statutory law, the right to privacy provisions of the California Constitution, the federal Fair Credit Reporting Act and the Gramm-Leach Bliley Act. The plaintiffs had sought, among other things, unspecified actual and punitive damages, statutory civil penalties, restitution, injunctive relief, interest, and attorneys' fees.

Weavering Macro Fixed Income Fund

In July 2010, PNC completed the sale of GIS to The Bank of New York Mellon Corporation (BNY-Mellon), pursuant to a stock purchase agreement dated February 1, 2010. In July 2009, the liquidators of the Weavering Macro Fixed Income Fund Limited (Weavering) issued a Plenary Summons in the High Court, Dublin, Ireland, in connection with a European subsidiary of GIS's provision of administration services to Weavering. The Plenary Summons was served on the GIS subsidiary on or about June 30, 2010. In May 2011, the liquidator served a Notice of Intention to Proceed and Statement of Claim, which alleges that the GIS subsidiary breached its contractual duties to Weavering as well as an alleged duty of care to Weavering, and investors in Weavering, and makes claims of breach of the administration and accounting services agreement, negligence, gross negligence, breach of duty, misrepresentation and negligent misstatement. The complaint further alleges that investors in Weavering lost approximately €282 million and also expended approximately €98 million in brokerage and exchange commissions, interest, and fees as a result of the transactions at issue. The Statement of Claim seeks damages, costs, and interest.

In May 2011, BNY-Mellon provided notice to PNC of an indemnification claim pursuant to the stock purchase agreement.

365/360 Litigation

PNC Bank and National City Bank have been named as defendants in three lawsuits seeking to certify classes of commercial borrowers bringing claims for breach of contract arising from the use of the 365/360 method of interest computation in certain commercial promissory notes. The first of these cases (DK&D Properties, LLC v. National City Bank (Case no. 08 cv 680078)), was filed in December 2008 against National City Bank in the Court of Common Pleas of Cuyahoga County, Ohio. It seeks to certify a class consisting of certain Ohio commercial borrowers of National City Bank for these claims. In July 2009, the court denied National City Bank's motion to dismiss. The second case (Kreisler & Kreisler, LLC v. National City Bank, et al. (Case no. 4:10-cv-00956)) was filed in the United States District Court for the Eastern District of Missouri in May 2010 against National City Bank and also purports to name “PNC Bank Corp.” as a defendant. It seeks to certify a national class of commercial borrowers for these claims. In March 2011, the district court granted the defendants' motion to dismiss the complaint. The plaintiff has appealed the district court's grant of this motion to the United States Court of Appeals for the Eighth Circuit. In the third case (PNC Bank, National Association v. St. Louis PET Centers, LLC, et al. (Case no. 10SL-CC01076)), a borrower filed a counterclaim against PNC Bank in the Circuit Court of County of St. Louis, Missouri in November, 2010. The claims and proposed class set forth in this complaint are similar to those in Kreisler & Kreisler. We have filed a motion to strike the class action allegations in the counterclaim.

Plaintiffs in these cases allege generally that they obtained fixed or variable rate commercial loans from PNC Bank or National City Bank pursuant to promissory notes or loan agreements setting forth annual or per annum interest rates, that the bank's use of the 365/360 method of calculation of interest caused the borrower to pay interest over a calendar year at a higher rate than the per annum rate stated in the promissory notes, and that this was a breach of the terms of the promissory notes. Plaintiffs in each of these cases seek declaratory and injunctive relief, compensatory damages, prejudgment interest, and attorneys' fees.

Regulatory and Governmental Inquiries

As a result of the regulated nature of our business and that of a number of our subsidiaries, particularly in the banking and securities areas, we and our subsidiaries are the subject of investigations, audits and other forms of regulatory inquiry, in some cases as part of regulatory reviews of specified activities at multiple industry participants, including those described below and in Prior Disclosure.

In April 2011, as a result of a publicly-disclosed interagency horizontal review of residential mortgage servicing operations at fourteen federally regulated mortgage servicers, PNC entered into a consent order with the Board of Governors of the Federal Reserve System and PNC Bank entered into a consent order with the Office of the Comptroller of the Currency. Collectively, these consent orders describe certain foreclosure-related practices and controls that the regulators found to be deficient and require PNC and PNC Bank to, among other things, develop and implement plans and programs to enhance PNC's residential mortgage servicing and foreclosure processes, retain an independent consultant to review certain residential mortgage foreclosure actions, take certain remedial actions, and oversee compliance with the orders and the new plans and programs. The two orders do not foreclose the potential for civil money penalties from either of these regulators.

In connection with these orders, PNC has established a Compliance Committee of the Boards of PNC and PNC Bank to monitor and coordinate PNC's and PNC Bank's implementation of the commitments under the orders. PNC and PNC Bank have submitted proposed Action Plans to the regulators setting forth the plan to meet the requirements of the orders. Consistent with the orders, PNC has also engaged an independent consultant to conduct a review of certain residential foreclosure actions, including those identified through borrower complaints, and identify whether any remedial actions for borrowers are necessary. Pursuant to the proposed Action Plans, PNC is endeavoring to meet all of the requirements of the orders.

Other governmental, legislative and regulatory inquiries on this topic, referred to in Prior Disclosure, are ongoing, and may result in significant additional actions, penalties or other remedies. These additional inquiries include a review of the servicers subject to the above-mentioned horizontal review by the Department of Justice, other federal regulators and state attorneys general. In connection with that review, it is understood that the governmental regulators may seek substantial payments and other relief from the entities subject to the horizontal review, including PNC, and may also seek to impose national mortgage servicing standards. It is not currently known what relief will be sought against PNC.

In addition, PNC has received subpoenas from the U.S. Attorney's Office for the Southern District of New York concerning lending practices of National City Bank and successors in connection with loans insured by the Federal Housing Administration (FHA) as well as certain non-FHA-insured loan origination, sale and securitization practices. The U.S. Attorney's Office inquiry is in its early stage and PNC is cooperating with the investigation. The outcome of the investigation is unknown, but it could result in penalties or other remedial actions.

Our practice is to cooperate fully with regulatory and governmental investigations, audits and other inquiries, including those described above and in Prior Disclosure. Such investigations, audits and other inquiries may lead to remedies including fines, penalties, restitution or alterations in our business practices.

Other

In addition to the proceedings or other matters described above, PNC and persons to whom we may have indemnification obligations, in the normal course of business, are subject to various other pending and threatened legal proceedings in which claims for monetary damages and other relief are asserted. We do not anticipate, at the present time, that the ultimate aggregate liability, if any, arising out of such other legal proceedings will have a material adverse effect on our financial position. However, we cannot now determine whether or not any claims asserted against us or others to whom we may have indemnification obligations, whether in the proceedings or other matters described above, described in Prior Disclosure, or otherwise, will have a material adverse effect on our results of operations in any future reporting period, which will depend on, among other things, the amount of the loss resulting from the claim and the amount of income otherwise reported for the reporting period.

See Note 17 Commitments and Guarantees for additional information regarding the Visa indemnification and our other obligations to provide indemnification, including to current and former officers, directors, employees and agents of PNC and companies we have acquired, including National City.