We closely monitor economic conditions and loan performance trends to manage and evaluate our exposure to credit risk. Trends in delinquency rates may be 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, certain 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 September 30, 2012 and December 31, 2011.

Table 64: Age Analysis of Past Due Accruing Loans (a)

			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 (b)			Loans				Impaired				Loans
September 30, 2012
	Commercial			$	78,291		$	141			$	92			$	41		$	274			$	749		$	354		$	79,668
	Commercial real estate				16,368			91				66				36			193				1,000			1,048			18,609
	Equipment lease financing				6,894			8				5				1			14				15						6,923
	Home equity (c)				32,166			130				69							199				818			2,695			35,878
	Residential real estate (d)				8,530			274				146				1,993			2,413				790			3,650			15,383
	Credit card				4,047			31				20				32			83				5						4,135
	Other consumer (e)				20,524			208				144				353			705				37			2			21,268
		Total		$	166,820		$	883			$	542			$	2,456		$	3,881			$	3,414		$	7,749		$	181,864
	Percentage of total loans				91.72	%		.49	%			.30	%			1.35	%		2.14	%			1.88	%		4.26	%		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 (c)				29,288			173				114				221			508				529			2,764			33,089
	Residential real estate (d)				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 (e)				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)		Amounts in table represent recorded investment.
(b)		Past due loan amounts exclude purchased impaired loans, 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.
(c)		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.
(d)		Past due loan amounts at September 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)		Past due loan amounts at September 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

				September 30			December 31
Dollars in millions					2012			2011
Nonperforming loans
	Commercial lending
		Commercial		$	749		$	899
		Commercial real estate			1,000			1,345
		Equipment lease financing			15			22
			Total commercial lending		1,764			2,266
	Consumer lending (a)
		Home equity (b)			818			529
		Residential real estate (c)			790			726
		Credit card			5			8
		Other consumer			37			31
			Total consumer lending (d)		1,650			1,294
Total nonperforming loans (e)					3,414			3,560
OREO and foreclosed assets
	Other real estate owned (OREO) (f)				578			561
	Foreclosed and other assets				29			35
			Total OREO and foreclosed assets		607			596
Total nonperforming assets				$	4,021		$	4,156
Nonperforming loans to total loans					1.88	%		2.24	%
Nonperforming assets to total loans, OREO and foreclosed assets					2.20			2.60
Nonperforming assets to total assets					1.34			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 $61 million accounted for under the fair value option for both September 30, 2012 and December 31, 2011.
(d)	Pursuant to regulatory guidance, in the third quarter of 2012, nonperforming consumer loans, primarily home equity and residential mortgage, increased $112 million related to changes in treatment of certain loans classified as TDRs, net of charge-offs, resulting from bankruptcy where no formal reaffirmation was provided by the borrower and therefore a concession has been granted based upon discharge from personal liability. Of these loans, approximately 90% are current on their payments. Charge-offs have been taken where the fair value less costs to sell the collateral was less than the recorded investment of the loan and were $82.9 million.
(e)	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.
(f)	OREO excludes $363 million and $280 million at September 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 nine months ended September 30, 2012, $2.3 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 nine months ended September 30, 2011 was $1.9 billion.

Total nonperforming loans in the nonperforming assets table above include TDRs of $1.4 billion at September 30, 2012 and $1.1 billion at December 31, 2011. TDRs returned to performing (accruing) status totaled $950 million and $771 million at September 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 September 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 internal historical data, including 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
September 30, 2012
	Commercial		$	74,228	$	2,130		$	2,749		$	207	$	79,314
	Commercial real estate			14,252		842			2,277			190		17,561
	Equipment lease financing			6,750		49			119			5		6,923
	Purchased impaired loans			89		57			860			396		1,402
		Total commercial lending (f)	$	95,319	$	3,078		$	6,005		$	798	$	105,200
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
September 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	$	574	$	3,418	$	1,017	$	5,009
		Less than or equal to 660 (e) (f)		90		788		252		1,130
		Missing FICO		28		18		29		75

	Greater than or equal to 100% to less than 125% and updated FICO scores:
		Greater than 660		904		3,058		1,122		5,084
		Less than or equal to 660 (e) (f)		144		564		251		959
		Missing FICO		47		15		23		85

	Greater than or equal to 90% to less than 100% and updated FICO scores:
		Greater than 660		849		1,650		840		3,339
		Less than or equal to 660		117		235		139		491
		Missing FICO		75		40		21		136

	Less than 90% and updated FICO scores:
		Greater than 660		8,033		10,061		4,665		22,759
		Less than or equal to 660		949		1,525		886		3,360
		Missing FICO		862		227		410		1,499

	Missing LTV and updated FICO scores:
		Greater than 660				7		1		8
		Less than or equal to 660				2				2
		Missing FICO						831		831
Total home equity and residential real estate loans			$	12,672	$	21,608	$	10,487	$	44,767

			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 $7.0 billion and $6.5 billion in outstanding balances, certain government insured or guaranteed residential real estate mortgages of approximately $2.3 billion and $2.9 billion, and loans held for sale at September 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 September 30, 2012: New Jersey 13%, Illinois 12%, Pennsylvania 10%, Ohio 10%, California 9%, Florida 9%, Maryland 5%, Michigan 4%, and North Carolina 4%. The remainder of the states have lower than 3% of the high risk loans individually, and collectively they represent approximately 24% 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)
September 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	$	17	$	696	$	529	$	1,242
		Less than or equal to 660		17		383		330		730
		Missing FICO				21		14		35

	Greater than or equal to 100% to less than 125% and updated FICO scores:
		Greater than 660		22		375		498		895
		Less than or equal to 660		18		194		317		529
		Missing FICO				14		15		29

	Greater than or equal to 90% to less than 100% and updated FICO scores:
		Greater than 660		10		104		233		347
		Less than or equal to 660		12		59		212		283
		Missing FICO				4		6		10

	Less than 90% and updated FICO scores:
		Greater than 660		56		602		724		1,382
		Less than or equal to 660		97		400		868		1,365
		Missing FICO		1		19		34		54

	Missing LTV and updated FICO scores:
		Greater than 660						1		1
		Less than or equal to 660				1				1
		Missing FICO		11		10		52		73
Total home equity and residential real estate loans			$	261	$	2,882	$	3,833	$	6,976

			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 September 30, 2012: California 22%, Florida 14%, Illinois 11%, Ohio 6%, Michigan 5%, and North Carolina, Georgia, New York, and Maryland at 4%, respectively. The remainder of the states have lower than a 3% concentration of purchased impaired loans individually, and collectively they represent approximately 26% 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
September 30, 2012
	FICO score greater than 719	$	2,117	51	%	$	7,172	58	%
	650 to 719		1,157	28			2,885	23
	620 to 649		193	5			428	4
	Less than 620		267	6			555	5
	No FICO score available or required (c)		401	10			1,354	10
Total loans using FICO credit metric			4,135	100	%		12,394	100	%
	Consumer loans using other internal credit metrics (b)						8,874
Total loan balance		$	4,135			$	21,268
Weighted-average updated FICO score (d)				724				741
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 September 30, 2012, we had $33 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 September 30, 2012 balance related to higher risk credit card loans is geographically distributed throughout the following areas: Ohio
	20%, Pennsylvania 13%, Michigan 12%, Illinois 8%, Indiana 6%, Florida 6%, New Jersey 5%, Kentucky 4%, and North Carolina 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, extensions, and bankruptcy discharges from personal liability, 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 $570 million and $580 million at September 30, 2012, and December 31, 2011, respectively, for the total TDR portfolio.

Table 71: Summary of Troubled Debt Restructurings

			Sept. 30		Dec. 31
In millions			2012		2011
Total consumer lending (a)		$	2,019	$	1,798
Total commercial lending			556		405
	Total TDRs	$	2,575	$	2,203
Nonperforming		$	1,383	$	1,141
Accruing (b)			950		771
Credit card (c)			242		291
	Total TDRs	$	2,575	$	2,203
(a)	Pursuant to regulatory guidance, additional troubled debt restructurings related to changes in treatment of certain loans of $154.8 million, net of charge-offs, resulting from bankruptcy where no formal reaffirmation was provided by the borrower and therefore a concession has been granted based upon discharge from personal liability were added to the consumer lending population in the third quarter of 2012. The additional TDR population increased nonperforming loans by $112 million, approximately 90% of which were current on their payments. Charge-offs have been taken where the fair value less costs to sell the collateral was less than the recorded investment of the loan and were $82.9 million.
(b)	Accruing loans have demonstrated a period of at least six months of performance under the restructured terms and are excluded from nonperforming loans.
(c)	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.

As described in Table 71: Summary of Troubled Debt Restructurings, regulatory guidance was implemented in the third quarter of 2012 to (a) classify loans as TDRs where borrowers have been discharged from bankruptcy and have not formally reaffirmed their loan obligation and (b) charge-off the difference when the fair value less costs to sell the collateral was less than the recorded investment of the loan. Pursuant to adoption of this guidance as of September 30, 2012, we recorded $154.8 million of troubled debt restructurings, net of charge-offs. Because our estimated allowance for loan loss reserves is driven primarily by defaults as opposed to bankruptcy status, prior to this quarter, certain information relevant under this guidance was not collected for financial reporting purposes. Therefore, our estimate of additional TDRs and related charge-off amounts, nonperforming assets and ALLL may change as management confirms the accuracy and completeness of information related to the population of loans in bankruptcy as used in determining these estimates.

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 nine months ended September 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 September 30, 2012		Number		Recorded			Principal		Rate
Dollars in millions		of Loans		Investment (b)			Forgiveness		Reduction		Other		Total
Commercial lending
	Commercial		35	$	112		$	9	$	50	$	35	$	94
	Commercial real estate		17		74			5				59		64
	Equipment lease financing (d)		2		3
Total commercial lending			54		189			14		50		94		158
Consumer lending
	Home equity		962		65					53		10		63
	Residential real estate		205		40					18		21		39
	Credit card		2,435		18					17				17
	Other consumer		157		4					1		4		5
Total consumer lending			3,759		127					89		35		124
	Total TDRs		3,813	$	316		$	14	$	139	$	129	$	282
During the three months ended September 30, 2011 (e)
Dollars in millions
Commercial lending
	Commercial		174	$	39		$	1	$	14	$	22	$	37
	Commercial real estate		17		81			29		26		17		72
	Equipment lease financing (d)		2
Total commercial lending			193		120			30		40		39		109
Consumer lending
	Home equity		817		64					52		11		63
	Residential real estate		399		116					70		42		112
	Credit card		2,800		21					20				20
	Other consumer		129		3							3		3
Total consumer lending			4,145		204					142		56		198
	Total TDRs		4,338	$	324		$	30	$	182	$	95	$	307

				Pre-TDR		Post-TDR Recorded Investment (c)
During the nine months ended September 30, 2012		Number		Recorded			Principal		Rate
Dollars in millions		of Loans		Investment (b)			Forgiveness		Reduction		Other		Total
Commercial lending
	Commercial		173	$	226		$	13	$	81	$	88	$	182
	Commercial real estate		51		174			22		43		89		154
	Equipment lease financing		8		21			2				11		13
Total commercial lending			232		421			37		124		188		349
Consumer lending
	Home equity		3,148		208					165		40		205
	Residential real estate		587		114					47		63		110
	Credit card		6,643		49					48				48
	Other consumer		570		14					2		13		15
Total consumer lending			10,948		385					262		116		378
	Total TDRs		11,180	$	806		$	37	$	386	$	304	$	727
During the nine months ended September 30, 2011 (e)
Dollars in millions
Commercial lending
	Commercial		493	$	96		$	11	$	24	$	47	$	82
	Commercial real estate		56		225			64		97		39		200
	Equipment lease financing (d)		2
Total commercial lending			551		321			75		121		86		282
Consumer lending
	Home equity		3,259		264					240		23		263
	Residential real estate		1,298		316					210		83		293
	Credit card		9,786		73					70				70
	Other consumer		303		8					1		7		8
Total consumer lending			14,646		661					521		113		634
	Total TDRs		15,197	$	982		$	75	$	642	$	199	$	916
(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)	During the three months ended September 30, 2012, the Post-TDR amount for the Equipment lease financing loan class totals less than $1 million. During both the three months and nine months ended September 30, 2011, the Pre-TDR and Post-TDR amounts for the Equipment lease financing loan class total less than $1 million.
(e)	Includes loans modified during the three months and nine months ended September 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.

TDRs may result in charge-offs and interest income not being recognized. At or around the time of modification, there was $6 million in recorded investment of commercial TDRs, and zero in recorded investment of commercial real estate TDRs charged off during the three months ended September 30, 2012. Comparable amounts for the three months ended September 30, 2011 were zero and $5 million respectively. For residential real estate, there was $2 million of recorded investment charged off during the three months ended September 30, 2012, related to modifications in which principal was partially deferred and deemed uncollectible. The comparable amount for the three months ended September 30, 2011 was $3 million. There were no charge offs around the time of modification related to equipment lease financing, home equity, credit card, and other consumer TDR portfolios for either period.

At or around the time of modification, there was $18 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 nine months ended September 30, 2012. Comparable amounts for the nine months ended September 30, 2011 were $23 million, $12 million, and zero respectively. For residential real estate, there was $5 million of recorded investment charged off during the nine months ended September 30, 2012 related to modifications in which principal was partially deferred and deemed uncollectible. The comparable amount for the nine months ended September 30, 2011 was $15 million. There were no charge offs around the time of modification related to home equity, credit card, and other consumer TDR portfolios for either period.

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 nine months ended September 30, 2012 and 2011 related to both commercial TDRs and consumer TDRs was not material.

Pursuant to regulatory guidance issued in the third quarter, management compiled TDR information related to changes in treatment of certain loans where a borrower has been discharged from personal liability in bankruptcy and has not formally reaffirmed its loan obligation to PNC. This information was compiled as of September 30, 2012 and has been reflected in period end disclosures. Because of the timing of the compilation of the TDR information and the fact that it pertains to several prior periods, such information has not been reflected as part of the third quarter activity included in Table 72: Financial Impact and TDRs by Concession Type.

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 July 1, 2012, July 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 September 30, 2012
Dollars in millions		Number of Contracts		Recorded Investment
Commercial lending
	Commercial		20	$	19
	Commercial real estate		9		18
Total commercial lending (a)			29		37
Consumer lending
	Home equity		140		13
	Residential real estate		148		20
	Credit card		2,037		15
	Other consumer		38		1
Total consumer lending			2,363		49
	Total TDRs		2,392	$	86
During the three months ended September 30, 2011 (b)
Dollars in millions		Number of Contracts		Recorded Investment
Commercial lending
	Commercial		16	$	16
	Commercial real estate		9		60
Total commercial lending (a)			25		76
Consumer lending
	Home equity		291		23
	Residential real estate		140		32
	Credit card		2,363		16
	Other consumer (c)		14
Total consumer lending			2,808		71
	Total TDRs		2,833	$	147

During the nine months ended September 30, 2012
Dollars in millions		Number of Contracts		Recorded Investment
Commercial lending
	Commercial		78	$	34
	Commercial real estate		32		58
	Equipment lease financing		5		11
Total commercial lending			115		103
Consumer lending
	Home equity		506		46
	Residential real estate		455		66
	Credit card		2,979		21
	Other consumer		114		4
Total consumer lending			4,054		137
	Total TDRs		4,169	$	240
During the nine months ended September 30, 2011 (b)
Dollars in millions		Number of Contracts		Recorded Investment
Commercial lending
	Commercial		20	$	39
	Commercial real estate		28		111
Total commercial lending (a)			48		150
Consumer lending
	Home equity		848		68
	Residential real estate		255		63
	Credit card		3,696		24
	Other consumer		18		1
Total consumer lending			4,817		156
	Total TDRs		4,865	$	306
(a)	During the three months ended September 30, 2012, there were no loans classified as TDRs in the Equipment lease financing loan class that have subsequently defaulted. During both the three months and nine months ended September 30, 2011, there were no loans classified as TDRs in the Equipment lease financing loan class that have subsequently defaulted.
(b)	Includes loans modified during the three months and nine months ended September 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.
(c)	During the three months ended September 30, 2011, the total recorded investment for the Other consumer loan class was less than $1 million.

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, consideration of collateral value, and/or the application of a present value discount rate, when compared to the recorded investment, results in a charge-off or increased ALLL. As TDRs are individually evaluated under the specific reserve methodology, which builds in expectations of future performance, subsequent defaults do not generally have a significant additional impact to the ALLL.

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, consideration of collateral value, and/or 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 $15 million and $22 million at September 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 nine months ended September 30, 2012 and September 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)
September 30, 2012
	Impaired loans with an associated allowance
		Commercial	$	888	$	598		$	163	$	690
		Commercial real estate		924		611			167		819
		Home equity (c)		971		951			298		831
		Residential real estate (c)		964		790			174		747
		Credit card (c)		211		211			51		233
		Other consumer (c)		67		67			4		58
	Total impaired loans with an associated allowance		$	4,025	$	3,228		$	857	$	3,378
	Impaired loans without an associated allowance
		Commercial	$	458	$	209				$	165
		Commercial real estate		765		474					411
	Total impaired loans without an associated allowance		$	1,223	$	683				$	576
	Total impaired loans		$	5,248	$	3,911		$	857	$	3,954
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 nine months ended September 30, 2012, and year ended December 31, 2011.
(b)	Associated allowance amounts include $570 million and $580 million for TDRs at September 30, 2012, and December 31, 2011, respectively.
(c)	Pursuant to regulatory guidance in the third quarter of 2012, the impact of TDRs where no formal reaffirmation was provided by the borrower and therefore a concession has
	been granted based upon discharge from personal liability in bankruptcy is included in the table.