We closely monitor economic conditions and loan performance trends to manage and evaluate our exposure to credit risk. Trends in delinquency rates are a key indicator, among other considerations, of credit risk within the loan portfolios. 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 exclude loans held for sale and purchased impaired loans, but include government insured or guaranteed loans.

The trends in nonperforming assets represent another key indicator of the potential for future credit losses. Nonperforming assets include nonperforming loans, TDRs, and other real estate owned (OREO) and foreclosed assets, but exclude certain government insured or guaranteed loans, loans held for sale, loans accounted for under the fair value option and purchased impaired loans. See Note 6 Purchased Loans for further information.

See Note 1 Accounting Policies for additional delinquency, nonperforming, and charge-off information.

The following tables display the delinquency status of our loans and our nonperforming assets at June 30, 2012 and December 31, 2011.

Table 64: Age Analysis of Past Due Accruing Loans

			Accruing
			Current or Less											90 Days
			Than 30 Days				30-59 Days			60-89 Days				Or More				Total Past			Nonperforming				Purchased				Total
In millions			Past Due				Past Due			Past Due				Past Due				Due (a)			Loans				Impaired				Loans
June 30, 2012
	Commercial			$	77,476		$	130			$	65			$	34		$	229			$	791		$	405		$	78,901
	Commercial real estate				15,967			123				105				16			244				1,142			1,127			18,480
	Equipment lease financing				6,737			5				2				1			8				19						6,764
	Home equity (b) (c)				32,152			124				68							192				722			2,772			35,838
	Residential real estate (d) (e)				8,864			271				143				2,029			2,443				739			3,777			15,823
	Credit card				4,024			33				22				38			93				6						4,123
	Other consumer (f)				19,754			207				129				365			701				39			2			20,496
		Total		$	164,974		$	893			$	534			$	2,483		$	3,910			$	3,458		$	8,083		$	180,425
	Percentage of total loans				91.43	%		.49	%			.30	%			1.38	%		2.17	%			1.92	%		4.48	%		100.00	%
December 31, 2011
	Commercial			$	64,437		$	122			$	47			$	49		$	218			$	899		$	140		$	65,694
	Commercial real estate				14,010			96				35				6			137				1,345			712			16,204
	Equipment lease financing				6,367			22				5							27				22						6,416
	Home equity (b) (c)				29,288			173				114				221			508				529			2,764			33,089
	Residential real estate (d) (e)				7,935			302				176				2,281			2,759				726			3,049			14,469
	Credit card				3,857			38				25				48			111				8						3,976
	Other consumer (f)				18,355			265				145				368			778				31			2			19,166
		Total		$	144,249		$	1,018			$	547			$	2,973		$	4,538			$	3,560		$	6,667		$	159,014
	Percentage of total loans				90.72	%		.64	%			.34	%			1.87	%		2.85	%			2.24	%		4.19	%		100.00	%
(a)		Past due loan amounts exclude purchased impaired loans as they are considered performing, even if contractually past due (or if we do not expect to receive payment in full based on the original contractual terms), as we are currently accreting interest income over the expected life of the loans.
(b)		In the first quarter of 2012, we adopted a policy stating that Home equity loans past due 90 days or more would be placed on nonaccrual status. Prior policy required that these loans be past due 180 days before being placed on nonaccrual status.
(c)		In the second quarter of 2012, the Home equity amounts as of June 30, 2012 were reduced by $42 million and $27 million for the accruing loans past due 30 to 59 Days and 60 to 89 Days respectively, to correct for immaterial amounts. Prior period amounts have not been adjusted.
(d)		Past due loan amounts at June 30, 2012, include government insured or guaranteed residential real estate mortgages, totaling $.1 billion for 30 to 59 days past due, $.1
		billion for 60 to 89 days past due and $1.9 billion for 90 days or more past due. Past due loan amounts at December 31, 2011, include government insured or guaranteed
		residential real estate mortgages, totaling $.1 billion for 30 to 59 days past due, $.1 billion for 60 to 89 days past due and $2.1 billion for 90 days or more past due.
(e)		In the second quarter of 2012, the Residential real estate amounts as of June 30, 2012 were reduced by $28 million, $14 million and $28 million for the accruing loans past due 30 to 59 Days, 60 to 89 Days and 90 Days or More respectively, to correct for immaterial amounts. Prior period amounts have not been adjusted.
(f)		Past due loan amounts at June 30, 2012, include government insured or guaranteed other consumer loans, totaling $.2 billion for 30 to 59 days past due, $.1 billion for
		60 to 89 days past due and $.3 billion for 90 days or more past due. Past due loan amounts at December 31, 2011, include government insured or guaranteed other consumer
		loans, totaling $.2 billion for 30 to 59 days past due, $.1 billion for 60 to 89 days past due and $.3 billion for 90 days or more past due.

Table 65: Nonperforming Assets

Dollars in millions				June 30, 2012				December 31, 2011
Nonperforming loans
	Commercial lending
		Commercial			$	791			$	899
		Commercial real estate				1,142				1,345
		Equipment lease financing				19				22
			Total commercial lending			1,952				2,266
	Consumer lending (a)
		Home equity (b)				722				529
		Residential real estate (c)				739				726
		Credit card				6				8
		Other consumer				39				31
			Total consumer lending			1,506				1,294
Total nonperforming loans (d)						3,458				3,560
OREO and foreclosed assets
	Other real estate owned (OREO) (e)					670				561
	Foreclosed and other assets					48				35
			Total OREO and foreclosed assets			718				596
Total nonperforming assets					$	4,176			$	4,156
Nonperforming loans to total loans						1.92	%			2.24	%
Nonperforming assets to total loans, OREO and foreclosed assets						2.31				2.60
Nonperforming assets to total assets						1.39				1.53
(a)	Excludes most consumer loans and lines of credit, not secured by residential real estate, which are charged off after 120 to 180 days past due and are not placed on nonperforming status.
(b)	In the first quarter of 2012, we adopted a policy stating that Home equity loans past due 90 days or more would be placed on nonaccrual status. Prior policy required that these loans be past due 180 days before being placed on nonaccrual status.
(c)	Nonperforming residential real estate excludes loans of $55 million and $61 million accounted for under the fair value option as of June 30, 2012 and December 31, 2011, respectively.
(d)	Nonperforming loans exclude certain government insured or guaranteed loans, loans held for sale, loans accounted for under the fair value option and purchased impaired loans.
(e)	OREO excludes $262 million and $280 million at June 30, 2012 and December 31, 2011, respectively, related to residential real estate that was acquired by us upon foreclosure of serviced loans because they are insured by the Federal Housing Administration (FHA) or guaranteed by the Department of Veterans Affairs (VA).

Nonperforming loans also include 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 and the TDR section of this Note 5 for additional information. For the six months ended June 30, 2012, $1.6 billion of loans held for sale, loans accounted for under the fair value option, pooled purchased impaired loans, as well as certain consumer government insured or guaranteed loans which were evaluated for TDR consideration, are not classified as TDRs. The comparable amount for the six months ended June 30, 2011 was $1.1 billion.

Total nonperforming loans in the nonperforming assets table above include TDRs of $1.2 billion at June 30, 2012 and $1.1 billion at December 31, 2011. TDRs returned to performing (accruing) status totaled $878 million and $771 million at June 30, 2012 and December 31, 2011, respectively, and are excluded from nonperforming loans. These loans have demonstrated a period of at least six months of consecutive performance under the restructured terms. At June 30, 2012 and December 31, 2011, remaining commitments to lend additional funds to debtors in a commercial or consumer TDR were immaterial.

We have two overall portfolio segments – Commercial Lending and Consumer Lending. Each of these two segments is comprised of one or more loan classes. Classes are characterized by similarities in initial measurement, risk attributes and the manner in which we monitor and assess credit risk. The commercial segment is comprised of the commercial, commercial real estate, equipment lease financing, and commercial purchased impaired loan classes. The consumer segment is comprised of the home equity, residential real estate, credit card, other consumer, and consumer purchased impaired loan classes. Asset quality indicators for each of these loan classes are discussed in more detail below.

For commercial loans, we monitor the performance of the borrower in a disciplined and regular manner based upon the level of credit risk inherent in the loan. To evaluate the level of credit risk, we assign an internal risk rating reflecting the borrower's PD and LGD. This two-dimensional credit risk rating methodology provides risk granularity in the monitoring process on an ongoing basis. At least annually, we update PDs based upon market data. Additionally, when statistically significant historical data exists, we update our LGDs. The combination of the PD and LGD ratings assigned to a commercial loan, capturing both the combination of expectations of default and loss severity in event of default, reflects the relative estimated likelihood of loss for that loan at the reporting date. Loans with better PD and LGD have a lower likelihood of loss. Conversely, loans with worse PD and LGD have a higher likelihood of loss. The loss amount also considers EAD, which we update when statistically significant historical data exists.

Based upon the amount of the lending arrangement and our risk rating assessment, we follow a formal schedule of written periodic review. On a quarterly basis, we conduct formal reviews of a market's or business unit's entire loan portfolio, focusing on those loans which we perceive to be of higher risk, based upon PDs and LGDs, or weakening credit quality. If circumstances warrant, it is our practice to review any customer obligation and its level of credit risk more frequently. We attempt to proactively manage our loans by using various procedures that are customized to the risk of a given loan, including ongoing outreach, contact, and assessment of obligor financial conditions, collateral inspection and appraisal.

We manage credit risk associated with our commercial real estate projects and commercial mortgage activities similar to commercial loans by analyzing PD and LGD. However, due to the nature of the collateral, for commercial real estate projects and commercial mortgages, the LGDs tend to be significantly lower than those seen in the commercial class. Additionally, risks connected with commercial real estate projects and commercial mortgage activities tend to be correlated to the loan structure and collateral location, project progress and business environment. As a result, these attributes are also monitored and utilized in assessing credit risk.

As with the commercial class, a formal schedule of periodic review is performed to also assess market/geographic risk and business unit/industry risk. Often as a result of these overviews, more in-depth reviews and increased scrutiny is placed on areas of higher risk, including adverse changes in risk ratings, deteriorating operating trends, and/or areas that concern management. The goal of these reviews is to assess risk and take actions to mitigate our exposure to such risks.

We manage credit risk associated with our equipment lease financing class similar to commercial loans by analyzing PD and LGD.

Based upon the dollar amount of the lease and of the level of credit risk, we follow a formal schedule of periodic review. Generally, this occurs on a quarterly basis, although we have established practices to review such credit risk more frequently, if circumstances warrant. Our review process entails analysis of the following factors: equipment value/residual value, exposure levels, jurisdiction risk, industry risk, guarantor requirements, and regulatory compliance.

The credit impacts of purchased impaired loans are primarily determined through the estimation of expected cash flows. Commercial cash flow estimates are influenced by a number of credit related items, which include but are not limited to: estimated collateral value, receipt of additional collateral, secondary trading prices, circumstances of possible and/or ongoing liquidation, capital availability, business operations and payment patterns.

We attempt to proactively manage these factors by using various procedures that are customized to the risk of a given loan. These procedures include a review by our Special Asset Committee (SAC), ongoing outreach, contact, and assessment of obligor financial conditions, collateral inspection and appraisal.

Table 66: Commercial Lending Asset Quality Indicators (a)
					Criticized Commercial Loans
				Pass	Special									Total
In millions				Rated (b)	Mention (c)		Substandard (d)			Doubtful (e)				Loans
June 30, 2012
	Commercial		$	73,232	$	2,204		$	2,784		$	276	$	78,496
	Commercial real estate			13,551		957			2,512			333		17,353
	Equipment lease financing			6,599		34			123			8		6,764
	Purchased impaired loans			76		64			843			549		1,532
		Total commercial lending (f)	$	93,458	$	3,259		$	6,262		$	1,166	$	104,145
December 31, 2011
	Commercial		$	60,649	$	1,831		$	2,817		$	257	$	65,554
	Commercial real estate			11,478		791			2,823			400		15,492
	Equipment lease financing			6,210		48			153			5		6,416
	Purchased impaired loans			107		35			542			168		852
		Total commercial lending (f)	$	78,444	$	2,705		$	6,335		$	830	$	88,314
(a)	Based upon PDs and LGDs.
(b)	Pass Rated loans include loans not classified as "Special Mention", "Substandard", or "Doubtful".
(c)	Special Mention rated loans have a potential weakness that deserves management’s close attention. If left uncorrected, these potential weaknesses may result in deterioration
	of repayment prospects at some future date. These loans do not expose us to sufficient risk to warrant a more adverse classification at this time.
(d)	Substandard rated loans have a well-defined weakness or weaknesses that jeopardize the collection or liquidation of debt. They are characterized by the distinct possibility
	that we will sustain some loss if the deficiencies are not corrected.
(e)	Doubtful rated loans possess all the inherent weaknesses of a Substandard loan with the additional characteristics that the weakness makes collection or liquidation in full
	improbable due to existing facts, conditions, and values.
(f)	Loans are included above based on their contractual terms as "Pass", "Special Mention", "Substandard" or "Doubtful".

We use several credit quality indicators, including delinquency information, nonperforming loan information, updated credit scores, originated and updated LTV ratios, and geography, to monitor and manage credit risk within the home equity and residential real estate loan classes. We evaluate mortgage loan performance by source originators and loan servicers. A summary of asset quality indicators follows:

Delinquency/Delinquency Rates: We monitor trending of delinquency/delinquency rates for home equity and residential real estate loans. See the Asset Quality section of this Note 5 for additional information.

Nonperforming Loans: We monitor trending of nonperforming loans for home equity and residential real estate loans. See the Asset Quality section of this Note 5 for additional information.

Credit Scores: We use a national third-party provider to update FICO credit scores for home equity loans and lines of credit and residential real estate loans on at least a quarterly basis. The updated scores are incorporated into a series of credit management reports, which are utilized to monitor the risk in the loan classes.

LTV (inclusive of combined loan-to-value (CLTV) ratios for second lien positions): Semi-annually, we update the property values of real estate collateral and calculate an updated LTV ratio. For open-end credit lines secured by real estate in regions experiencing significant declines in property values, more frequent valuations may occur. We examine LTV migration and stratify LTV into categories to monitor the risk in the loan classes.

Historically, we used, and we continue to use, a combination of original LTV and updated LTV for internal risk management reporting and risk management purposes (e.g., line management, loss mitigation strategies). In addition to the fact that estimated property values by their nature are estimates, given certain data limitations it is important to note that updated LTVs may be based upon management's assumptions (e.g., if an updated LTV is not provided by the third-party service provider, home price index (HPI) changes will be incorporated in arriving at management's estimate of updated LTV).

Geography: Geographic concentrations are monitored to evaluate and manage exposures. Loan purchase programs are sensitive to, and focused within, certain regions to manage geographic exposures and associated risks.

A combination of updated FICO scores, originated and updated LTV ratios and geographic location assigned to home equity loans and lines of credit and residential real estate loans are used to monitor the risk in the loan classes. Loans with higher FICO scores and lower LTVs tend to have a lower level of risk. Conversely, loans with lower FICO scores, higher LTVs, and in certain geographic locations tend to have a higher level of risk.

In the table below, we provide information on home equity and residential real estate outstanding balances and recorded investment. See Note 4 Loans and Commitments to Extend Credit for additional information.

Table 68: Consumer Real Estate Secured Asset Quality Indicators - Excluding Purchased Impaired Loans (a) (b)

			Home Equity				Residential Real Estate
June 30, 2012 - in millions			1st Liens		2nd Liens				Total
Current estimated LTV ratios (c) (d)
	Greater than or equal to 125% and updated FICO scores:
		Greater than 660	$	517	$	3,149	$	817	$	4,483
		Less than or equal to 660 (e) (f)		82		714		273		1,069
		Missing FICO		11		15		41		67

	Greater than or equal to 100% to less than 125% and updated FICO scores:
		Greater than 660		838		3,069		940		4,847
		Less than or equal to 660 (e) (f)		124		568		232		924
		Missing FICO		23		12		18		53

	Greater than or equal to 90% to less than 100% and updated FICO scores:
		Greater than 660		752		1,719		695		3,166
		Less than or equal to 660		105		258		144		507
		Missing FICO		38		21		15		74

	Less than 90% and updated FICO scores:
		Greater than 660		7,726		10,698		5,111		23,535
		Less than or equal to 660		952		1,585		931		3,468
		Missing FICO		909		260		438		1,607

	Missing LTV and updated FICO scores:
		Greater than 660				9				9
		Less than or equal to 660				1				1
		Missing FICO						902		902
Total home equity and residential real estate loans			$	12,077	$	22,078	$	10,557	$	44,712

			Home Equity (g)				Residential Real Estate
December 31, 2011 - in millions			1st Liens		2nd Liens				Total
Current estimated LTV ratios (c) (d)
	Greater than or equal to 125% and updated FICO scores:
		Greater than 660	$	481	$	3,222	$	1,845	$	5,548
		Less than or equal to 660 (e) (f)		78		747		463		1,288
		Missing FICO		1		9		289		299

	Greater than or equal to 100% to less than 125% and updated FICO scores:
		Greater than 660		706		2,940		1,336		4,982
		Less than or equal to 660 (e) (f)		127		582		349		1,058
		Missing FICO		1		5		53		59

	Greater than or equal to 90% to less than 100% and updated FICO scores:
		Greater than 660		660		1,587		760		3,007
		Less than or equal to 660		98		255		200		553
		Missing FICO		8		15		12		35

	Less than 90% and updated FICO scores:
		Greater than 660		6,588		9,747		3,152		19,487
		Less than or equal to 660		821		1,405		799		3,025
		Missing FICO		679		218		32		929

	Missing LTV and updated FICO scores:
		Greater than 660				11				11
		Less than or equal to 660				2				2
		Missing FICO						731		731
Total home equity and residential real estate loans			$	10,248	$	20,745	$	10,021	$	41,014
(a)	Excludes purchased impaired loans of approximately $7.3 billion and $6.5 billion in outstanding balances, certain government insured or guaranteed residential real estate mortgages of approximately $2.5 billion and $2.9 billion, and loans held for sale at June 30, 2012 and December 31, 2011, respectively. See the Consumer Real Estate Secured Asset Quality Indicators - Purchased Impaired Loans table below for additional information on purchased impaired loans.
(b)	Amounts shown represent outstanding balance.
(c)	Based upon updated LTV (inclusive of CLTV for second lien positions).
(d)	Updated LTV (inclusive of CLTV for second lien positions) are estimated using modeled property values. These ratios are updated semi-annually. The related estimates and inputs are based upon an approach that uses a combination of third-party automated valuation models (AVMs), HPI indices, property location, internal and external balance information, origination data and management assumptions. In cases where we are in an originated second lien position, we generally utilize origination balances provided by a third-party which do not include an amortization assumption when calculating updated LTV. Accordingly, the results of these calculations do not represent actual appraised loan level collateral or updated LTV based upon a current first lien balance, and as such, are necessarily imprecise and subject to change as we enhance our methodology.
(e)	Higher risk loans are defined as loans with both an updated FICO score of less than or equal to 660 and an updated LTV greater than or equal to 100%.
(f)	The following states have the highest percentage of higher risk loans at June 30, 2012: New Jersey 12%, Illinois 10%, Florida 10%, California 10%, Pennsylvania 9%, Ohio 9%, Maryland 6%, and Michigan 5%. The remainder of the states have lower than 4% of the high risk loans individually, and collectively they represent approximately 29% of the higher risk loans. At December 31, 2011, the states with the highest percentage of higher risk loans were as follows: Pennsylvania 13%, New Jersey 13%, Illinois 10%, Ohio 9%, Florida 8%, California 8%, Maryland 5%, and Michigan 5%. The remainder of the states had lower than 3% of the high risk loans individually, and collectively they represented approximately 29% of the higher risk loans.
(g)	In the second quarter of 2012, we made changes to the assumptions used to determine home equity first and second lien positions. This resulted in an increase in Home equity 2nd liens of $2.4 billion and a corresponding decrease in Home equity 1st liens as of December 31, 2011.

Table 69: Consumer Real Estate Secured Asset Quality Indicators - Purchased Impaired Loans (a)

			Home Equity (b) (c)				Residential Real Estate (b) (c)
June 30, 2012 - in millions			1st Liens		2nd Liens				Total
Current estimated LTV ratios (d) (e)
	Greater than or equal to 125% and updated FICO scores:
		Greater than 660	$	16	$	681	$	369	$	1,066
		Less than or equal to 660		16		379		335		730
		Missing FICO				19		17		36

	Greater than or equal to 100% to less than 125% and updated FICO scores:
		Greater than 660		23		427		367		817
		Less than or equal to 660		20		217		308		545
		Missing FICO				16		13		29

	Greater than or equal to 90% to less than 100% and updated FICO scores:
		Greater than 660		14		109		189		312
		Less than or equal to 660		12		67		175		254
		Missing FICO				5		3		8

	Less than 90% and updated FICO scores:
		Greater than 660		59		646		1,124		1,829
		Less than or equal to 660		104		432		953		1,489
		Missing FICO		1		20		44		65

	Missing LTV and updated FICO scores:
		Greater than 660						1		1
		Less than or equal to 660						1		1
		Missing FICO				6		142		148
Total home equity and residential real estate loans			$	265	$	3,024	$	4,041	$	7,330

			Home Equity (b) (c) (f)				Residential Real Estate (b) (c)
December 31, 2011 - in millions			1st Liens		2nd Liens				Total
Current estimated LTV ratios (d) (e)
	Greater than or equal to 125% and updated FICO scores:
		Greater than 660	$	15	$	833	$	361	$	1,209
		Less than or equal to 660		15		513		681		1,209
		Missing FICO				23		38		61

	Greater than or equal to 100% to less than 125% and updated FICO scores:
		Greater than 660		17		509		229		755
		Less than or equal to 660		16		286		375		677
		Missing FICO				19		7		26

	Greater than or equal to 90% to less than 100% and updated FICO scores:
		Greater than 660		10		127		116		253
		Less than or equal to 660		11		79		208		298
		Missing FICO				5		4		9

	Less than 90% and updated FICO scores:
		Greater than 660		46		423		404		873
		Less than or equal to 660		72		366		679		1,117
		Missing FICO		1		17		22		40

	Missing LTV and updated FICO scores:
		Greater than 660						1		1
		Less than or equal to 660				1		1		2
		Missing FICO				1		2		3
Total home equity and residential real estate loans			$	203	$	3,202	$	3,128	$	6,533
(a)	Amounts shown represent outstanding balance. See Note 6 Purchased Loans for additional information.
(b)	For the estimate of cash flows utilized in our purchased impaired loan accounting, other assumptions and estimates are made, including amortization of first lien balances, pre-payment rates, etc., which are not reflected in this table.
(c)	The following states have the highest percentage of loans at June 30, 2012: California 21%, Florida 21%, Illinois 8%, Ohio 6%, North Carolina 5%, and Michigan 4%. The remainder of the states have lower than a 4% concentration of purchased impaired loans individually, and collectively they represent approximately 35% of the purchased impaired portfolio. At December 31, 2011, the states with the highest percentage of loans were as follows: California 22%, Florida 13%, Illinois 12%, Ohio 9%, Michigan 5% and New York 4%. The remainder of the states have lower than a 4% concentration of purchased impaired loans individually, and collectively they represent approximately 35% of the purchased impaired portfolio.
(d)	Based upon updated LTV (inclusive of CLTV for second lien positions).
(e)	Updated LTV (inclusive of CLTV for second lien positions) are estimated using modeled property values. These ratios are updated semi-annually. The related estimates and inputs are based upon an approach that uses a combination of third-party AVMs, HPI indices, property location, internal and external balance information, origination data and management assumptions. In cases where we are in an originated second lien position, we generally utilize origination balances provided by a third-party which do not include an amortization assumption when calculating updated LTV. Accordingly, the results of these calculations do not represent actual appraised loan level collateral or updated LTV based upon a current first lien balance, and as such, are necessarily imprecise and subject to change as we enhance our methodology.
(f)	In the second quarter of 2012, we made changes to the assumptions used to determine lien position. This resulted in a decrease in Home equity 1st liens of $65 million and a corresponding increase in Home equity 2nd liens as of December 31, 2011.

We monitor a variety of asset quality information in the management of the credit card and other consumer loan classes. Other consumer loan classes include education, automobile, and other secured and unsecured lines and loans. Along with the trending of delinquencies and losses for each class, FICO credit score updates are generally obtained on a monthly basis, as well as a variety of credit bureau attributes. Loans with high FICO scores tend to have a lower likelihood of loss. Conversely, loans with low FICO scores tend to have a higher likelihood of loss.

Estimates of the expected cash flows primarily determine the credit impacts of consumer purchased impaired loans. Consumer cash flow estimates are influenced by a number of credit related items, which include, but are not limited to: estimated real estate values, payment patterns, updated FICO scores, the current economic environment, updated LTV ratios and the date of origination. These key factors are monitored to help ensure that concentrations of risk are mitigated and cash flows are maximized.

Table 70: Credit Card and Other Consumer Loan Classes Asset Quality Indicators

		Credit Card (a)				Other Consumer (b)
				% of Total Loans				% of Total Loans
				Using FICO				Using FICO
Dollars in millions			Amount	Credit Metric			Amount	Credit Metric
June 30, 2012
	FICO score greater than 719	$	2,107	50	%	$	6,315	56	%
	650 to 719		1,145	28			2,527	23
	620 to 649		188	5			400	4
	Less than 620		255	7			542	5
	No FICO score available or required (c)		428	10			1,407	12
Total loans using FICO credit metric			4,123	100	%		11,191	100	%
	Consumer loans using other internal credit metrics (b)						9,305
Total loan balance		$	4,123			$	20,496
Weighted-average updated FICO score (d)				725				740
December 31, 2011
	FICO score greater than 719	$	2,016	51	%	$	5,556	61	%
	650 to 719		1,100	28			2,125	23
	620 to 649		184	5			370	4
	Less than 620		284	7			548	6
	No FICO score available or required (c)		392	9			574	6
Total loans using FICO credit metric			3,976	100	%		9,173	100	%
	Consumer loans using other internal credit metrics (b)						9,993
Total loan balance		$	3,976			$	19,166
Weighted-average updated FICO score (d)				723				739
(a)	At June 30, 2012, we had $38 million of credit card loans that are higher risk (i.e., loans with both updated FICO scores less than 660 and in late stage (90+ days)
	delinquency status). The majority of the June 30, 2012 balance related to higher risk credit card loans is geographically distributed throughout the following areas: Ohio 18%,
	Michigan 14%, Pennsylvania 13%, Illinois 7%, Indiana 7%, Florida 6%, New Jersey 5% and Kentucky 4%. All other states, none of which comprise more than 4%, make up
	the remainder of the balance. At December 31, 2011, we had $49 million of credit card loans that are higher risk. The majority of the December 31, 2011 balance related to
	higher risk credit card loans is geographically distributed throughout the following areas: Ohio 20%, Michigan 14%, Pennsylvania 13%, Illinois 7%, Indiana 7%, Florida 6%
	and Kentucky 5%. All other states, none of which comprise more than 4%, make up the remainder of the balance.
(b)	Other consumer loans for which updated FICO scores are used as an asset quality indicator include non-government guaranteed or insured education loans, automobile
	loans and other secured and unsecured lines and loans. Other consumer loans for which other internal credit metrics are used as an asset quality indicator include primarily
	government guaranteed or insured education loans, as well as consumer loans to high net worth individuals. Other internal credit metrics may include delinquency status,
	geography or other factors.
(c)	Credit card loans and other consumer loans with no FICO score available or required refers to new accounts issued to borrowers with limited credit history, accounts for
	which we cannot obtain an updated FICO (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 portfolio and, when necessary, takes actions to mitigate the credit risk.
(d)	Weighted-average updated FICO score excludes accounts with no FICO score available or required.

A TDR is a loan whose terms have been restructured in a manner that grants a concession to a borrower experiencing financial difficulties. TDRs typically result from our loss mitigation activities and include rate reductions, principal forgiveness, postponement/reduction of scheduled amortization, and extensions, which are intended to minimize economic loss and to avoid foreclosure or repossession of collateral. In those situations where principal is forgiven, the amount of such principal forgiveness is immediately charged off.

Some TDRs may not ultimately result in the full collection of principal and interest, as restructured, and result in potential incremental losses. These potential incremental losses have been factored into our overall ALLL estimate. The level of any subsequent defaults will likely be affected by future economic conditions. Once a loan becomes a TDR, it will continue to be reported as a TDR until it is ultimately repaid in full, the collateral is foreclosed upon, or it is fully charged off. We held specific reserves in the ALLL of $572 million and $580 million at June 30, 2012, and December 31, 2011, respectively, for the total TDR portfolio.

Table 71: Summary of Troubled Debt Restructurings

			June 30		Dec. 31
In millions			2012		2011
Total consumer lending		$	1,836	$	1,798
Total commercial lending			483		405
	Total TDRs	$	2,319	$	2,203
Nonperforming		$	1,189	$	1,141
Accruing (a)			878		771
Credit card (b)			252		291
	Total TDRs	$	2,319	$	2,203
(a)	Accruing loans have demonstrated a period of at least six months of performance under the restructured terms and are excluded from nonperforming loans.
(b)	Includes credit cards and certain small business and consumer credit agreements whose terms have been restructured and are TDRs. However, since our policy is to exempt these loans from being placed on nonaccrual status as permitted by regulatory guidance as generally these loans are directly charged off in the period that they become 180 days past due, these loans are excluded from nonperforming loans.

The table below quantifies the number of loans that were classified as TDRs as well as the change in the recorded investments as a result of the TDR classification during the three months and six months ended June 30, 2012 and 2011. Additionally, the table provides information about the types of TDR concessions. The Principal Forgiveness TDR category includes principal forgiveness and accrued interest forgiveness. These types of TDRs result in a write down of the recorded investment and a charge-off if such action has not already taken place. The Rate Reduction TDR category includes reduced interest rate and interest deferral. The TDRs within this category would result in reductions to future interest income. The Other TDR category primarily includes postponement/reduction of scheduled amortization, as well as contractual extensions.

In some cases, there have been multiple concessions granted on one loan. When there have been multiple concessions granted, the principal forgiveness TDR was prioritized for purposes of determining the inclusion in the table below. For example, if there is principal forgiveness in conjunction with lower interest rate and postponement of amortization, the type of concession will be reported as Principal Forgiveness. Second in priority would be rate reduction. For example, if there is an interest rate reduction in conjunction with postponement of amortization, the type of concession will be reported as a Rate Reduction.

Table 72: Financial Impact and TDRs by Concession Type (a)

				Pre-TDR		Post-TDR Recorded Investment (c)
During the three months ended June 30, 2012		Number		Recorded			Principal		Rate
Dollars in millions		of Loans		Investment (b)			Forgiveness		Reduction		Other		Total
Commercial lending
	Commercial		33	$	102		$	1	$	40	$	42	$	83
	Commercial real estate		13		26			8		5		9		22
	Equipment lease financing		1		3			1						1
Total commercial lending			47		131			10		45		51		106
Consumer lending
	Home equity		1,083		69					60		8		68
	Residential real estate		200		41					18		20		38
	Credit card		2,268		17					16				16
	Other consumer		61		1							1		1
Total consumer lending			3,612		128					94		29		123
	Total TDRs		3,659	$	259		$	10	$	139	$	80	$	229
During the three months ended June 30, 2011 (d)
Dollars in millions
Commercial lending
	Commercial		169	$	38		$	8	$	9	$	14	$	31
	Commercial real estate		19		75			22		29		9		60
Total commercial lending (e)			188		113			30		38		23		91
Consumer lending
	Home equity		669		59					55		4		59
	Residential real estate		356		69					50		15		65
	Credit card		3,492		26					25				25
	Other consumer		117		4					1		3		4
Total consumer lending			4,634		158					131		22		153
	Total TDRs		4,822	$	271		$	30	$	169	$	45	$	244

				Pre-TDR		Post-TDR Recorded Investment (c)
During the six months ended June 30, 2012		Number		Recorded			Principal		Rate
Dollars in millions		of Loans		Investment (b)			Forgiveness		Reduction		Other		Total
Commercial lending
	Commercial		137	$	128		$	3	$	44	$	53	$	100
	Commercial real estate		34		100			17		43		29		89
	Equipment lease financing		6		18			1				11		12
Total commercial lending			177		246			21		87		93		201
Consumer lending
	Home equity		2,186		143					112		30		142
	Residential real estate		382		74					29		42		71
	Credit card		4,651		35					33				33
	Other consumer		413		10					1		9		10
Total consumer lending			7,632		262					175		81		256
	Total TDRs		7,809	$	508		$	21	$	262	$	174	$	457
During the six months ended June 30, 2011 (d)
Dollars in millions
Commercial lending
	Commercial		319	$	57		$	10	$	11	$	25	$	46
	Commercial real estate		39		144			35		71		22		128
Total commercial lending (e)			358		201			45		82		47		174
Consumer lending
	Home equity		1,739		145					139		7		146
	Residential real estate		730		161					123		23		146
	Credit card		7,459		56					53				53
	Other consumer		138		5					1		4		5
Total consumer lending			10,066		367					316		34		350
	Total TDRs		10,424	$	568		$	45	$	398	$	81	$	524
(a)	Impact of partial charge offs at TDR date are included in this table.
(b)	Represents the recorded investment of the loans as of the quarter end prior to the TDR designation, and excludes immaterial amounts of accrued interest receivable.
(c)	Represents the recorded investment of the TDRs as of the quarter end the TDR occurs, and excludes immaterial amounts of accrued interest receivable.
(d)	Includes loans modified during the three months and six months ended June 30, 2011 that were determined to be TDRs under the requirements of ASU 2011-02, which was adopted on July 1, 2011 and prospectively applied to all modifications entered into on and after January 1, 2011.
(e)	During both the three months and six months ended June 30, 2011, there were no loans classified as TDRs in the Equipment lease financing loan class.

TDRs may result in charge-offs and interest income not being recognized. At or around the time of modification, there was $11 million in recorded investment of commercial TDRs, less than $1 million in recorded investment of commercial real estate TDRs, and less than $1 million in recorded investment of equipment lease financing TDRs charged off during the three months ended June 30, 2012. Comparable amounts for the three months ended June 30, 2011were $21 million, $5 million, and zero respectively. For residential real estate, there was $3 million of recorded investment charged off during the three months ended June 30, 2012, related to modifications in which principal was partially deferred and deemed uncollectible. The comparable amount for the three months ended June 30, 2011 was $4 million. There were no charge offs around the time of modification related to home equity, credit card, and other consumer TDR portfolios for either periods.

At or around the time of modification, there was $12 million in recorded investment of commercial TDRs, $2 million in recorded investment of commercial real estate TDRs, and $5 million in recorded investment of equipment lease financing TDRs charged off during the six months ended June 30, 2012. Comparable amounts for the six months ended June 30, 2011 were $23 million, $7 million, and zero respectively. For residential real estate, there was $3 million of recorded investment charged off during the six months ended June 30, 2012 related to modifications in which principal was partially deferred and deemed uncollectible. The comparable amount for the six months ended June 30, 2011 was $12 million. There were no charge offs around the time of modification related to home equity, credit card, and other consumer TDR portfolios for either periods.

A financial effect of rate reduction TDRs is that interest income is not recognized. Interest income not recognized that otherwise would have been earned in the three months and six months ended June 30, 2012 and 2011 related to both commercial TDRs and consumer TDRs was not material.

After a loan is determined to be a TDR, we continue to track its performance under its most recent restructured terms. In the table below, 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 presents the recorded investment of loans that were classified as TDRs or were subsequently modified during each 12-month period prior to the reporting periods preceding April 1, 2012, April 1, 2011, January 1, 2012 and January 1, 2011, respectively, in the table below and subsequently defaulted during these reporting periods.

Table 73: TDRs which have Subsequently Defaulted

During the three months ended June 30, 2012
Dollars in millions		Number of Contracts		Recorded Investment
Commercial lending
	Commercial		27	$	5
	Commercial real estate		15		35
	Equipment lease financing		5		11
Total commercial lending			47		51
Consumer lending
	Home equity		161		14
	Residential real estate		144		23
	Credit card		2,114		15
	Other consumer		39		1
Total consumer lending			2,458		53
	Total TDRs		2,505	$	104
During the three months ended June 30, 2011 (a)
Dollars in millions		Number of Contracts		Recorded Investment
Commercial lending
	Commercial real estate		14	$	18
Total commercial lending (b)			14		18
Consumer lending
	Home equity		313		24
	Residential real estate		63		15
	Credit card		2,380		17
	Other consumer		4		1
Total consumer lending			2,760		57
	Total TDRs		2,774	$	75

During the six months ended June 30, 2012
Dollars in millions		Number of Contracts		Recorded Investment
Commercial lending
	Commercial		58	$	15
	Commercial real estate		23		40
	Equipment lease financing		5		11
Total commercial lending			86		66
Consumer lending
	Home equity		366		33
	Residential real estate		307		46
	Credit card		2,815		20
	Other consumer		76		3
Total consumer lending			3,564		102
	Total TDRs		3,650	$	168
During the six months ended June 30, 2011 (a)
Dollars in millions		Number of Contracts		Recorded Investment
Commercial lending
	Commercial		4	$	22
	Commercial real estate		19		52
Total commercial lending (b)			23		74
Consumer lending
	Home equity		557		45
	Residential real estate		115		31
	Credit card		3,228		22
	Other consumer		4		1
Total consumer lending			3,904		99
	Total TDRs		3,927	$	173
(a)	Includes loans modified during the three months and six months ended June 30, 2011 that were determined to be TDRs under the requirements of ASU 2011-02, which was adopted on July 1, 2011 and prospectively applied to all modifications entered into on and after January 1, 2011.
(b)	During both the three months and six months ended June 30, 2011, there were no loans classified as TDRs in the Equipment lease financing loan class that have subsequently defaulted. Additionally, during the three months ended June 30, 2011 there were no loans classified as TDRs in the Commercial loan class that have subsequently defaulted.

The impact to the ALLL for commercial lending TDRs is the effect of moving to the specific reserve methodology from the quantitative reserve methodology for those loans that were not already put on nonaccrual status. There is an impact to the ALLL as a result of the concession made, which generally results in the expectation of fewer future cash flows. The decline in expected cash flows, as well as the application of a present value discount rate, when compared to the recorded investment, results in a charge-off or increased ALLL. Subsequent defaults of commercial lending TDRs do not have a significant impact on the ALLL as these TDRs are individually evaluated under the specific reserve methodology.

For consumer lending TDRs the ALLL is calculated using a discounted cash flow model, which leverages subsequent default, prepayment, and severity rate assumptions based upon historically observed data. Similar to the commercial lending specific reserve methodology, the reduced expected cash flows resulting from the concessions granted impact the consumer lending ALLL. The decline in expected cash flows, as well as the application of a present value discount rate, when compared to the recorded investment, results in a charge-off or increased ALLL.

Impaired loans include commercial nonperforming loans and consumer and commercial TDRs, regardless of nonperforming status. Excluded from impaired loans are nonperforming leases, loans held for sale, smaller balance homogeneous type loans and purchased impaired loans. See Note 6 Purchased Loans for additional information. Nonperforming equipment lease financing loans of $19 million and $22 million at June 30, 2012, and December 31, 2011, respectively, are excluded from impaired loans pursuant to authoritative lease accounting guidance. We did not recognize any interest income on impaired loans that have not returned to performing status, while they were impaired during the six months ended June 30, 2012 and June 30, 2011. The following table provides further detail on impaired loans individually evaluated for impairment and the associated ALLL. Certain commercial impaired loans do not have a related ALLL as the valuation of these impaired loans exceeded the recorded investment.

Table 74: Impaired Loans

			Unpaid							Average
			Principal		Recorded		Associated			Recorded
In millions			Balance		Investment (a)		Allowance (b)			Investment (a)
June 30, 2012
	Impaired loans with an associated allowance
		Commercial	$	992	$	670		$	216	$	715
		Commercial real estate		1,090		713			248		895
		Home equity		830		819			291		791
		Residential real estate		902		741			174		733
		Credit card		220		220			58		240
		Other consumer		56		56			4		54
	Total impaired loans with an associated allowance		$	4,090	$	3,219		$	991	$	3,428
	Impaired loans without an associated allowance
		Commercial	$	412	$	157				$	150
		Commercial real estate		792		466					390
	Total impaired loans without an associated allowance		$	1,204	$	623				$	540
	Total impaired loans		$	5,294	$	3,842		$	991	$	3,968
December 31, 2011
	Impaired loans with an associated allowance
		Commercial	$	1,125	$	785		$	241	$	979
		Commercial real estate		1,452		1,043			318		1,247
		Home equity		774		762			292		702
		Residential real estate		853		730			193		609
		Credit card		258		258			53		281
		Other consumer		48		48			3		39
	Total impaired loans with an associated allowance		$	4,510	$	3,626		$	1,100	$	3,857
	Impaired loans without an associated allowance
		Commercial	$	347	$	125				$	104
		Commercial real estate		592		342					413
	Total impaired loans without an associated allowance		$	939	$	467				$	517
	Total impaired loans		$	5,449	$	4,093		$	1,100	$	4,374
(a)	Recorded investment in a loan includes the unpaid principal balance plus accrued interest and net accounting adjustments, less any charge-offs. Recorded investment does not
	include any associated valuation allowance. Average recorded investment is for the six months ended June 30, 2012, and year ended December 31, 2011.
(b)	Associated allowance amounts include $572 million and $580 million for TDRs at June 30, 2012, and December 31, 2011, respectively.