Allowance for Credit Losses

3 Months Ended

Mar. 31, 2019

Allowance for Credit Losses [Abstract]

NOTE 7 - ALLOWANCE FOR CREDIT LOSSES

The allowance for credit losses consists of the ALLL and the unfunded commitments reserve. Activity in the allowance for credit losses by LHFI segment is presented in the following tables:



	Three Months Ended March 31, 2019
(Dollars in millions)	Commercial			Consumer			Total
ALLL, beginning of period		$1,080			$535			$1,615
Provision for loan losses	84			72			156
Loan charge-offs	(33		)	(92		)	(125		)
Loan recoveries	5			23			28
Other ¹	—			(31		)	(31		)
ALLL, end of period	1,136			507			1,643

Unfunded commitments reserve, beginning of period ²	69			—			69
Benefit for unfunded commitments	(3		)	—			(3		)
Unfunded commitments reserve, end of period ²	66			—			66

Allowance for credit losses, end of period		$1,202			$507			$1,709

¹ Represents the allowance for restructured loans that were transferred from LHFI to LHFS during the period and subsequently sold in the second quarter of 2019.

²The unfunded commitments reserve is recorded in Other liabilities in the Consolidated Balance Sheets.



	Three Months Ended March 31, 2018
(Dollars in millions)	Commercial			Consumer			Total
ALLL, beginning of period		$1,101			$634			$1,735
(Benefit)/provision for loan losses	(16		)	54			38
Loan charge-offs	(23		)	(83		)	(106		)
Loan recoveries	6			21			27
ALLL, end of period	1,068			626			1,694

Unfunded commitments reserve, beginning of period ¹	79			—			79
Benefit for unfunded commitments	(10		)	—			(10		)
Unfunded commitments reserve, end of period ¹	69			—			69

Allowance for credit losses, end of period		$1,137			$626			$1,763

¹ The unfunded commitments reserve is recorded in Other liabilities in the Consolidated Balance Sheets.

As discussed in Note 1, “Significant Accounting Policies,” to the Company's 2018 Annual Report on Form 10-K, the ALLL is composed of both specific allowances for certain nonaccrual loans and TDRs held for investment, and general allowances for groups of LHFI with similar risk characteristics. No allowance

is required for LHFI measured at fair value. Additionally, the Company records an immaterial allowance for LHFI products that are insured by federal agencies or guaranteed by GSEs, as there is nominal risk of principal loss.

The Company’s LHFI portfolio and related ALLL are presented in the following tables:



	March 31, 2019
	Commercial Loans				Consumer Loans				Total
(Dollars in millions)	Carrying Value		Related ALLL		Carrying Value		Related ALLL		Carrying Value		Related ALLL
LHFI evaluated for impairment:
Individually evaluated		$260		$39		$1,942		$115		$2,202		$154
Collectively evaluated	83,469		1,097		69,428		392		152,897		1,489
Total evaluated	83,729		1,136		71,370		507		155,099		1,643
LHFI measured at fair value	—		—		134		—		134		—
Total LHFI		$83,729		$1,136		$71,504		$507		$155,233		$1,643



	December 31, 2018
	Commercial Loans				Consumer Loans				Total
(Dollars in millions)	Carrying Value		Related ALLL		Carrying Value		Related ALLL		Carrying Value		Related ALLL
LHFI evaluated for impairment:
Individually evaluated		$149		$13		$2,462		$154		$2,611		$167
Collectively evaluated	80,791		1,067		68,274		381		149,065		1,448
Total evaluated	80,940		1,080		70,736		535		151,676		1,615
LHFI measured at fair value	—		—		163		—		163		—
Total LHFI		$80,940		$1,080		$70,899		$535		$151,839		$1,615