The Company conducts a qualitative goodwill assessment at the reporting unit level at least quarterly, or more frequently as events occur or circumstances change that would more-likely-than-not reduce the fair value of a reporting unit below its carrying amount. The Company performed a qualitative goodwill assessment for the Consumer and Wholesale reporting units in the first quarter of 2019, and concluded that a quantitative goodwill impairment test was not necessary for either reporting

unit as it was more-likely-than-not that the fair value of both reporting units were greater than their respective carrying amounts. See Note 1, “Significant Accounting Policies,” to the Company's 2018 Annual Report on Form 10-K for additional information and the Company’s goodwill accounting policy.



(Dollars in millions)	Residential MSRs - Fair Value			Commercial Mortgage Servicing Rights and Other			Total
Balance, January 1, 2019		$1,983			$79			$2,062
Amortization ¹	—			(3		)	(3		)
Servicing rights originated	63			4			67
Changes in fair value:
Due to changes in inputs and assumptions ²	(110		)	—			(110		)
Other changes in fair value ³	(52		)	—			(52		)
Servicing rights sold	(1		)	—			(1		)
Balance, March 31, 2019		$1,883			$80			$1,963

Balance, January 1, 2018		$1,710			$81			$1,791
Amortization ¹	—			(5		)	(5		)
Servicing rights originated	76			4			80
Servicing rights purchased	74			—			74
Changes in fair value:
Due to changes in inputs and assumptions ²	111			—			111
Other changes in fair value ³	(55		)	—			(55		)
Balance, March 31, 2018		$1,916			$80			$1,996

¹ Does not include expense associated with community development investments. See Note 11, “Certain Transfers of Financial Assets and Variable Interest Entities,” for additional information.



	March 31, 2019							December 31, 2018
(Dollars in millions)	Gross Carrying Value		Accumulated Amortization			Net Carrying Value		Gross Carrying Value		Accumulated Amortization			Net Carrying Value
Amortized other intangible assets ¹:
Commercial mortgage servicing rights		$99		($32	)		$67		$95		($29	)		$66
Other	6		(5		)	1		6		(5		)	1
Unamortized other intangible assets:
Residential MSRs	1,883		—			1,883		1,983		—			1,983
Other	12		—			12		12		—			12
Total other intangible assets		$2,000		($37	)		$1,963		$2,096		($34	)		$2,062

The Company acquires servicing rights and retains servicing rights for certain of its sales or securitizations of residential mortgages and commercial loans. Servicing rights on residential and commercial mortgages are capitalized by the Company and are classified as Other intangible assets on the Company's Consolidated Balance Sheets.

Income earned by the Company on its residential MSRs is derived primarily from contractually specified mortgage servicing fees and late fees, net of curtailment costs, and is presented in the following table.

No MSRs on residential loans were purchased during the three months ended March 31, 2019. The Company purchased MSRs on residential loans with a UPB of $5.9 billion during the three months ended March 31, 2018. During the three months ended March 31, 2019 and 2018, the Company sold MSRs on residential loans, at a price approximating their fair value, with a UPB of $518 million and $102 million, respectively.

The Company measures the fair value of its residential MSRs using a valuation model that calculates the present value of estimated future net servicing income using prepayment projections, spreads, and other assumptions. The Consumer Valuation Committee reviews and approves all significant assumption changes at least annually, drawing upon various market and empirical data sources. Changes to valuation model inputs are reflected in the periods’ results. See Note 17, “Fair Value Election and Measurement,” for further information regarding the Company’s residential MSR valuation methodology.

A summary of the significant unobservable inputs used to estimate the fair value of the Company’s residential MSRs and the uncertainty of the fair values in response to 10% and 20% adverse changes in those inputs at the reporting date are presented in the following table.



(Dollars in millions)	March 31, 2019			December 31, 2018
Fair value of residential MSRs		$1,883			$1,983
Prepayment rate assumption (annual)	13		%	13		%
Decline in fair value from 10% adverse change		$99			$96
Decline in fair value from 20% adverse change	188			183
Option adjusted spread (annual)	2		%	2		%
Decline in fair value from 10% adverse change		$40			$44
Decline in fair value from 20% adverse change	78			86
Weighted-average life (in years)	5.2			5.5
Weighted-average coupon	4.0		%	4.0		%

Residential MSR uncertainties are hypothetical and should be used with caution. Changes in fair value based on variations in assumptions generally cannot be extrapolated because (i) the relationship of the change in an assumption to the change in fair value may not be linear and (ii) changes in one assumption may result in changes in another, which might magnify or counteract the uncertainties. The uncertainties do not reflect the effect of hedging activity undertaken by the Company to offset changes in the fair value of MSRs. See Note 16, “Derivative Financial Instruments,” for further information regarding these hedging activities.

servicing fees and other ancillary fees. The Company also earns income from subservicing certain third party commercial mortgages for which the Company does not record servicing rights. The following table presents the Company’s income earned from servicing commercial mortgages.



	Three Months Ended March 31
(Dollars in millions)	2019		2018
Income from commercial mortgage servicing rights ¹		$6		$7
Income from subservicing third party commercial mortgages¹	3		3



(Dollars in millions)	March 31, 2019		December 31, 2018
UPB of commercial mortgages subserviced for third parties		$29,195		$28,140
UPB of loans underlying commercial mortgage servicing rights	6,585		6,399
Total UPB of commercial mortgages serviced for third parties		$35,780		$34,539

Commercial mortgage servicing rights are accounted for at amortized cost and are monitored for impairment on an ongoing basis. The Company calculates the fair value of commercial servicing rights based on the present value of estimated future net servicing income, considering prepayment projections and other assumptions. Impairment, if any, is recognized when the carrying value of the servicing asset exceeds the fair value at the measurement date. The amortized cost of the Company’s commercial mortgage servicing rights was $67 million and $66 million at March 31, 2019 and December 31, 2018, respectively.

A summary of the significant unobservable inputs used to estimate the fair value of the Company’s commercial mortgage servicing rights and the uncertainty of the fair values in response to 10% and 20% adverse changes in those inputs at the reporting date, are presented in the following table.



(Dollars in millions)	March 31, 2019			December 31, 2018
Fair value of commercial mortgage servicing rights		$78			$77
Discount rate (annual)	12		%	12		%
Decline in fair value from 10% adverse change		$3			$3
Decline in fair value from 20% adverse change	6			6
Prepayment rate assumption (annual)	6		%	5		%
Decline in fair value from 10% adverse change		$1			$1
Decline in fair value from 20% adverse change	2			2
Weighted-average life (in years)	8.2			8.1
Float earnings rate (annual)	1.1		%	1.1		%