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Loans
6 Months Ended
Jun. 30, 2019
Receivables [Abstract]  
Loans, Notes, Trade and Other Receivables, Excluding Allowance for Credit Losses [Text Block]
NOTE 6 - LOANS
Composition of Loan Portfolio
(Dollars in millions)
June 30, 2019
 
December 31, 2018
Commercial loans:
 
 
 
C&I 1

$72,971

 

$71,137

CRE
8,655

 
7,265

Commercial construction
2,365

 
2,538

Total commercial LHFI
83,991

 
80,940

Consumer loans:
 
 
 
Residential mortgages - guaranteed
439

 
459

Residential mortgages - nonguaranteed 2
28,794

 
28,836

Residential home equity products
8,902

 
9,468

Residential construction
156

 
184

Guaranteed student
7,202

 
7,229

Other direct
11,817

 
10,615

Indirect
13,598

 
12,419

Credit cards
1,690

 
1,689

Total consumer LHFI
72,598

 
70,899

LHFI

$156,589

 

$151,839

LHFS 3

$2,229

 

$1,468

1 Includes $4.1 billion of sales-type, direct financing, and leveraged leases at both June 30, 2019 and December 31, 2018. Includes $862 million and $796 million of installment loans at June 30, 2019 and December 31, 2018, respectively.
2 Includes $127 million and $163 million of LHFI measured at fair value at June 30, 2019 and December 31, 2018, respectively.
3 Includes $1.7 billion and $1.2 billion of LHFS measured at fair value at June 30, 2019 and December 31, 2018, respectively.

LHFI Purchases, Sales, and Transfers
 
Three Months Ended June 30
 
Six Months Ended June 30
(Dollars in millions)
2019
 
2018
 
2019
 
2018
Non-routine LHFI purchases 1, 2:
 
 
 
 
 
 
Consumer loans

$85

 

$—

 

$258

 

$—

Routine LHFI purchases 2, 3:
 
 
 
 
 
 
Consumer loans
471

 
548

 
916

 
1,023

LHFI sales 4, 5:
 
 
 
 
 
 
 
Commercial loans
177

 
37

 
217

 
72

Consumer loans
432

 
100

 
432

 
100

Transfers from:
 
 
 
 
 
 
 
LHFI to LHFS
 
 
 
 
713

 
327

LHFS to LHFI
 
 
 
 
12

 
18

LHFI to OREO
 
 
 
 
23

 
33

1 Purchases are episodic in nature and are conducted based on specific business strategies.
2 Represents UPB of loans purchased.
3 Purchases are routine in nature and are conducted in the normal course of business.
4 Excludes sales of loans originated for sale and loans recorded at fair value conducted in the normal course of business.
5 Net gain on loan sales totaled $45 million for both the three and six months ended June 30, 2019, and was immaterial for the three and six months ended June 30, 2018.

At June 30, 2019 and December 31, 2018, the Company had $32.2 billion and $28.1 billion of net eligible loan collateral pledged to the Federal Reserve discount window to support $24.1 billion and $21.3 billion of available, unused borrowing capacity, respectively.
At June 30, 2019 and December 31, 2018, the Company had $39.4 billion and $39.2 billion of net eligible loan collateral pledged to the FHLB of Atlanta to support $31.9 billion and $31.0 billion of available borrowing capacity, respectively. The available FHLB borrowing capacity at June 30, 2019 was used to support $9.8 billion of advances and $4.2 billion of letters of credit issued on the Company's behalf. At December 31, 2018, the available FHLB borrowing capacity was used to support $5.0 billion of advances and $5.8 billion of letters of credit issued on the Company's behalf.
Credit Quality Evaluation
The Company evaluates the credit quality of its LHFI portfolio by employing a dual internal risk rating system, which assigns both PD and LGD ratings to derive expected losses. Assignment of these ratings are predicated upon numerous factors, including consumer credit risk scores, rating agency information, borrower/guarantor financial capacity, LTV ratios, collateral type, debt service coverage ratios, collection experience, other internal metrics/analyses, and/or qualitative assessments.
For the commercial portfolio, the Company believes that the most appropriate credit quality indicator is an individual loan’s risk assessment expressed according to the broad regulatory agency classifications of Pass or Criticized. The Company conforms to the following regulatory classifications for Criticized assets: Other Assets Especially Mentioned (or Special Mention), Substandard, Doubtful, and Loss. However, for the purposes of disclosure, management believes the most meaningful distinction within the Criticized categories is between Criticized accruing (which includes Special Mention and a portion of Substandard) and Criticized nonaccruing (which includes a portion of Substandard as well as Doubtful and Loss). This distinction identifies those relatively higher risk loans for which there is a basis to believe that the Company will not collect all amounts due under those loan agreements. The Company's risk rating system is more granular, with multiple risk ratings in both the Pass and Criticized categories. Pass ratings reflect relatively low PDs; whereas, Criticized assets have higher PDs. The granularity in Pass ratings assists in establishing pricing, loan structures, approval requirements, reserves, and ongoing credit management requirements. Commercial risk ratings are refreshed at least annually, or more frequently as appropriate, based upon considerations such as market conditions, borrower characteristics, and portfolio trends. Additionally, management routinely reviews portfolio risk ratings, trends, and concentrations to support risk identification and mitigation activities. As reflected in the following risk rating table, the increases in Pass and Criticized accruing C&I loans at June 30, 2019 compared to December 31, 2018, were due to loan growth and normal variability in the portfolio. Criticized nonaccruing C&I loans remained low relative to accruing loans.
For consumer loans, the Company monitors credit risk based on indicators such as delinquencies and FICO scores. The Company believes that consumer credit risk, as assessed by the industry-wide FICO scoring method, is a relevant credit quality indicator. Borrower-specific FICO scores are obtained at origination as part of the Company’s formal underwriting process, and refreshed FICO scores are obtained by the Company at least quarterly.
For guaranteed loans, the Company monitors the credit quality based primarily on delinquency status, as it is a more relevant indicator of credit quality due to the government guarantee. At June 30, 2019 and December 31, 2018, 28% and 27%, respectively, of guaranteed residential mortgages were current with respect to payments. At June 30, 2019 and December 31, 2018, 76% and 72%, respectively, of guaranteed student loans were current with respect to payments. The Company's loss exposure on guaranteed residential mortgages and student loans is mitigated by the government guarantee.

LHFI by credit quality indicator are presented in the following tables:
 
Commercial Loans
 
C&I
 
CRE
 
Commercial Construction
(Dollars in millions)
June 30, 2019
 
December 31, 2018
 
June 30, 2019
 
December 31, 2018
 
June 30, 2019
 
December 31, 2018
Risk rating:
 
 
 
 
 
 
 
 
 
 
 
Pass

$70,532

 

$69,095

 

$8,526

 

$7,165

 

$2,311

 

$2,459

Criticized accruing
2,181

 
1,885

 
127

 
98

 
54

 
79

Criticized nonaccruing
258

 
157

 
2

 
2

 

 

Total

$72,971

 

$71,137

 

$8,655

 

$7,265

 

$2,365

 

$2,538



 
 Consumer Loans 1
 
Residential Mortgages -
Nonguaranteed
 
Residential Home Equity Products
 
Residential Construction
(Dollars in millions)
June 30, 2019
 
December 31, 2018
 
June 30, 2019
 
December 31, 2018
 
June 30, 2019
 
December 31, 2018
Current FICO score range:
 
 
 
 
 
 
 
 
 
 
 
700 and above

$25,895

 

$25,764

 

$7,573

 

$8,060

 

$125

 

$151

620 - 699
2,278

 
2,367

 
952

 
1,015

 
26

 
27

Below 620 2
621

 
705

 
377

 
393

 
5

 
6

Total

$28,794

 

$28,836

 

$8,902

 

$9,468

 

$156

 

$184


 
Other Direct
 
Indirect
 
Credit Cards
(Dollars in millions)
June 30, 2019
 
December 31, 2018
 
June 30, 2019
 
December 31, 2018
 
June 30, 2019
 
December 31, 2018
Current FICO score range:
 
 
 
 
 
 
 
 
 
 
 
700 and above

$10,220

 

$9,296

 

$10,506

 

$9,315

 

$1,147

 

$1,142

620 - 699
1,428

 
1,175

 
2,326

 
2,395

 
416

 
420

Below 620 2
169

 
144

 
766

 
709

 
127

 
127

Total

$11,817

 

$10,615

 

$13,598

 

$12,419

 

$1,690

 

$1,689


1 Excludes $7.2 billion of guaranteed student loans at both June 30, 2019 and December 31, 2018, and $439 million and $459 million of guaranteed residential mortgages at June 30, 2019 and December 31, 2018, respectively, for which there was nominal risk of principal loss due to the government guarantee.
2  For substantially all loans with refreshed FICO scores below 620, the borrower’s FICO score at the time of origination exceeded 620 but has since deteriorated as the loan has seasoned.

The LHFI portfolio by payment status is presented in the following tables:

 
June 30, 2019
 
Accruing
 
 
 
 
(Dollars in millions)
Current
 
30-89 Days
Past Due
 
90+ Days
Past Due
 
 Nonaccruing 1
 
Total
Commercial loans:
 
 
 
 
 
 
 
 
 
C&I

$72,650

 

$49

 

$14

 

$258

 

$72,971

CRE
8,650

 
3

 

 
2

 
8,655

Commercial construction
2,365

 

 

 

 
2,365

Total commercial LHFI
83,665

 
52

 
14

 
260

 
83,991

Consumer loans:
 
 
 
 
 
 
 
 
 
Residential mortgages - guaranteed
125

 
25

 
289

 

3 
439

Residential mortgages - nonguaranteed 2
28,589

 
53

 
8

 
144

 
28,794

Residential home equity products
8,731

 
62

 

 
109

 
8,902

Residential construction
147

 
1

 

 
8

 
156

Guaranteed student
5,498

 
562

 
1,142

 

3 
7,202

Other direct
11,753

 
50

 
4

 
10

 
11,817

Indirect
13,493

 
99

 
1

 
5

 
13,598

Credit cards
1,655

 
17

 
18

 

 
1,690

Total consumer LHFI
69,991

 
869

 
1,462

 
276

 
72,598

Total LHFI

$153,656

 

$921

 

$1,476

 

$536

 

$156,589

1 Includes nonaccruing LHFI past due 90 days or more of $301 million. Nonaccruing LHFI past due fewer than 90 days include nonaccrual LHFI modified in TDRs, performing second lien LHFI where the first lien loan is nonperforming, and certain energy-related commercial LHFI.
2 Includes $127 million of LHFI measured at fair value, the majority of which were accruing current.
3 Guaranteed LHFI are not placed on nonaccrual status regardless of delinquency because collection of principal and interest is reasonably assured by the government. 


 
December 31, 2018
 
Accruing
 
 
 
 
(Dollars in millions)
Current
 
30-89 Days
Past Due
 
90+ Days
Past Due
 
 Nonaccruing 1
 
Total
Commercial loans:
 
 
 
 
 
 
 
 
 
C&I

$70,901

 

$64

 

$15

 

$157

 

$71,137

CRE
7,259

 
3

 
1

 
2

 
7,265

Commercial construction
2,538

 

 

 

 
2,538

Total commercial LHFI
80,698

 
67

 
16

 
159

 
80,940

Consumer loans:
 
 
 
 
 
 
 
 
 
Residential mortgages - guaranteed
125

 
39

 
295

 

3 
459

Residential mortgages - nonguaranteed 2
28,552

 
70

 
10

 
204

 
28,836

Residential home equity products
9,268

 
62

 

 
138

 
9,468

Residential construction
170

 
3

 

 
11

 
184

Guaranteed student
5,236

 
685

 
1,308

 

3 
7,229

Other direct
10,559

 
45

 
4

 
7

 
10,615

Indirect
12,286

 
125

 
1

 
7

 
12,419

Credit cards
1,654

 
17

 
18

 

 
1,689

Total consumer LHFI
67,850

 
1,046

 
1,636

 
367

 
70,899

Total LHFI

$148,548

 

$1,113

 

$1,652

 

$526

 

$151,839

1 Includes nonaccruing LHFI past due 90 days or more of $306 million. Nonaccruing LHFI past due fewer than 90 days include nonaccrual LHFI modified in TDRs, performing second lien LHFI where the first lien loan is nonperforming, and certain energy-related commercial LHFI.
2 Includes $163 million of LHFI measured at fair value, the majority of which were accruing current.
3 Guaranteed LHFI are not placed on nonaccrual status regardless of delinquency because collection of principal and interest is reasonably assured by the government.


Impaired Loans
A loan is considered impaired when it is probable that the Company will be unable to collect all amounts due, including principal and interest, according to the contractual terms of the agreement. Commercial nonaccrual loans greater than $3 million and certain commercial and consumer LHFI whose terms have been modified in a TDR are individually evaluated for
impairment. Smaller-balance homogeneous LHFI that are collectively evaluated for impairment and LHFI measured at fair value are not included in the following tables. Additionally, the following tables exclude guaranteed student loans and guaranteed residential mortgages for which there was nominal risk of principal loss due to the government guarantee.

 
June 30, 2019
 
December 31, 2018
(Dollars in millions)
Unpaid
Principal
Balance
 
 Carrying 1
Value
 
Related
ALLL
 
Unpaid
Principal
Balance
 
 Carrying 1
Value
 
Related
ALLL
Impaired LHFI with no ALLL recorded:
 
 
 
 
 
 
 
 
 
 
Commercial loans:
 
 
 
 
 
 
 
 
 
 
 
C&I

$73

 

$69

 

$—

 

$132

 

$79

 

$—

CRE

 

 

 
10

 

 

Total commercial LHFI with no ALLL recorded
73

 
69

 

 
142

 
79

 

Consumer loans:
 
 
 
 
 
 
 
 
 
 
 
Residential mortgages - nonguaranteed
378

 
300

 

 
501

 
397

 

Residential construction
7

 
4

 

 
12

 
7

 

Total consumer LHFI with no ALLL recorded
385

 
304

 

 
513

 
404

 

 
 
 
 
 
 
 
 
 
 
 
 
Impaired LHFI with an ALLL recorded:
 
 
 
 
 
 
 
 
 
 
 
Commercial loans:
 
 
 
 
 
 
 
 
 
 
 
C&I
253

 
233

 
49

 
81

 
70

 
13

Total commercial LHFI with an ALLL recorded
253

 
233

 
49

 
81

 
70

 
13

Consumer loans:
 
 
 
 
 
 
 
 
 
 
 
Residential mortgages - nonguaranteed
580

 
580

 
58

 
1,006

 
984

 
96

Residential home equity products
785

 
753

 
46

 
849

 
799

 
44

Residential construction
72

 
70

 
5

 
79

 
76

 
6

Other direct
57

 
57

 
1

 
57

 
57

 
1

Indirect
134

 
133

 
4

 
133

 
133

 
5

Credit cards
11

 
11

 
2

 
30

 
9

 
2

Total consumer LHFI with an ALLL recorded
1,639

 
1,604

 
116

 
2,154

 
2,058

 
154

Total impaired LHFI

$2,350

 

$2,210

 

$165

 

$2,890

 

$2,611

 

$167

1 Carrying value reflects charge-offs that have been recognized plus other amounts that have been applied to adjust the net book balance.


Included in the impaired LHFI carrying values above at June 30, 2019 and December 31, 2018 were $1.8 billion and $2.3 billion, respectively, of accruing TDRs held for investment, of which 97% were current. See Note 1, “Significant Accounting
Policies,” to the Company's 2018 Annual Report on Form 10-K, for further information regarding the Company’s loan impairment policy.



 
Three Months Ended June 30
 
Six Months Ended June 30
 
2019
 
2018
 
2019
 
2018
(Dollars in millions)
Average
Carrying Value
 
 Interest 1
Income
Recognized
 
Average
Carrying Value
 
 Interest 1
Income
Recognized
 
Average
Carrying
Value
 
 Interest 1
Income
Recognized
 
Average
Carrying
Value
 
 Interest 1
Income
Recognized
Impaired LHFI with no ALLL recorded:
 
 
 
 
 
 
Commercial loans:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
C&I

$70

 

$1

 

$46

 

$1

 

$69

 

$2

 

$47

 

$1

CRE

 

 
42

 

 

 

 
44

 

Total commercial LHFI with no ALLL recorded
70

 
1

 
88

 
1

 
69

 
2

 
91

 
1

Consumer loans:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Residential mortgages - nonguaranteed
301

 
4

 
383

 
4

 
303

 
8

 
378

 
7

Residential construction
4

 

 
7

 

 
4

 

 
7

 

Total consumer LHFI with no ALLL recorded
305

 
4

 
390

 
4

 
307

 
8

 
385

 
7

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Impaired LHFI with an ALLL recorded:
 
 
 
 
 
 
 
 
 
 
 
 
Commercial loans:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
C&I
237

 
1

 
184

 
1

 
237

 
2

 
185

 
2

Total commercial LHFI with an ALLL recorded
237

 
1

 
184

 
1

 
237

 
2

 
185

 
2

Consumer loans:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Residential mortgages - nonguaranteed
583

 
8

 
1,053

 
13

 
584

 
20

 
1,064

 
26

Residential home equity products
755

 
9

 
849

 
9

 
760

 
17

 
854

 
18

Residential construction
71

 
1

 
84

 
1

 
71

 
2

 
85

 
3

Other direct
57

 
1

 
58

 
1

 
57

 
2

 
58

 
2

Indirect
137

 
2

 
133

 
2

 
141

 
3

 
137

 
3

Credit cards
11

 

 
8

 

 
10

 
1

 
7

 

Total consumer LHFI with an ALLL recorded
1,614

 
21

 
2,185

 
26

 
1,623

 
45

 
2,205

 
52

Total impaired LHFI

$2,226

 

$27

 

$2,847

 

$32

 

$2,236

 

$57

 

$2,866

 

$62

1 Of the interest income recognized during the three and six months ended June 30, 2019 and 2018, cash basis interest income was immaterial.


NPAs are presented in the following table:

(Dollars in millions)
June 30, 2019
 
December 31, 2018
NPAs:
 
 
 
Commercial NPLs:
 
 
 
C&I

$258

 

$157

CRE
2

 
2

Consumer NPLs:
 
 
 
Residential mortgages - nonguaranteed
144

 
204

Residential home equity products
109

 
138

Residential construction
8

 
11

Other direct
10

 
7

Indirect
5

 
7

Total nonaccrual LHFI/NPLs 1
536

 
526

OREO 2
55

 
54

Other repossessed assets
7

 
9

Total NPAs

$598

 

$589

1 Nonaccruing restructured LHFI are included in total nonaccrual LHFI/NPLs.
2 Does not include foreclosed real estate related to loans insured by the FHA or guaranteed by the VA. Proceeds due from the FHA and the VA are recorded as a receivable in Other assets in the Consolidated Balance Sheets until the property is conveyed and the funds are received. The receivable related to proceeds due from the FHA and the VA totaled $51 million and $50 million at June 30, 2019 and December 31, 2018, respectively.



The Company's recorded investment of nonaccruing LHFI secured by residential real estate properties for which formal foreclosure proceedings were in process at June 30, 2019 and December 31, 2018 was $82 million and $93 million, respectively. The Company's recorded investment of accruing LHFI secured by residential real estate properties for which formal foreclosure proceedings were in process at June 30, 2019 and December 31, 2018 was $102 million and $110 million, of which $95 million and $103 million were insured by the FHA or guaranteed by the VA, respectively.
At June 30, 2019, OREO included $53 million of foreclosed residential real estate properties and $1 million of foreclosed commercial real estate properties, with the remaining $1 million related to land.
At December 31, 2018, OREO included $50 million of foreclosed residential real estate properties and $2 million of foreclosed commercial real estate properties, with the remaining $2 million related to land.


Restructured Loans
A TDR is a loan for which the Company has granted an economic concession to a borrower in response to financial difficulty experienced by the borrower, which the Company would not have considered otherwise. When a loan is modified under the terms of a TDR, the Company typically offers the borrower an extension of the loan maturity date and/or a reduction in the original contractual interest rate. In limited situations, the Company may offer to restructure a loan in a manner that
ultimately results in the forgiveness of a contractually specified principal balance.
At both June 30, 2019 and December 31, 2018, the Company had an immaterial amount of commitments to lend additional funds to debtors whose terms have been modified in a TDR. The number and carrying value of loans modified under the terms of a TDR, by type of modification, are presented in the following tables:

 
Three Months Ended June 30, 2019 1
(Dollars in millions)
Number of Loans Modified
 
Rate Modification
 
Term Extension and/or Other Concessions
 
Total
Commercial loans:
 
 
 
 
 
 
 
C&I
22

 

$—

 

$2

 

$2

Consumer loans:
 
 
 
 
 
 
 
Residential mortgages - nonguaranteed
27

 
1

 
2

 
3

Residential home equity products
77

 

 
5

 
5

Other direct
268

 

 
5

 
5

Indirect
553

 

 
14

 
14

Credit cards
555

 
3

 

 
3

Total TDR additions
1,502

 

$4



$28

 

$32

1 Includes loans modified under the terms of a TDR that were charged-off during the period.

 
Six Months Ended June 30, 2019 1
(Dollars in millions)
Number of Loans Modified
 
Rate Modification
 
Term Extension and/or Other Concessions
 
Total
Commercial loans:
 
 
 
 
 
 
 
C&I
56

 

$1

 

$5

 

$6

Consumer loans:
 
 
 
 
 
 
 
Residential mortgages - nonguaranteed
58

 
3

 
5

 
8

Residential home equity products
161

 
2

 
10

 
12

Other direct
408

 

 
7

 
7

Indirect
1,121

 

 
29

 
29

Credit cards
994

 
5

 

 
5

Total TDR additions
2,798

 

$11

 

$56

 

$67


1 Includes loans modified under the terms of a TDR that were charged-off during the period.

 
Three Months Ended June 30, 2018 1
(Dollars in millions)
Number of Loans Modified
 
Rate Modification
 
Term Extension and/or Other Concessions
 
Total
Commercial loans:
 
 
 
 
 
 
 
C&I
29

 

$—

 

$29

 

$29

Consumer loans:
 
 
 
 
 
 
 
Residential mortgages - nonguaranteed
159

 
8

 
32

 
40

Residential home equity products
144

 

 
12

 
12

Residential construction
3

 

 

 

Other direct
214

 

 
3

 
3

Indirect
617

 

 
16

 
16

Credit cards
426

 
2

 

 
2

Total TDR additions
1,592

 

$10

 

$92

 

$102

1 Includes loans modified under the terms of a TDR that were charged-off during the period.
 
Six Months Ended June 30, 2018 1
(Dollars in millions)
Number of Loans Modified
 
Rate Modification
 
Term Extension and/or Other Concessions
 
Total
Commercial loans:
 
 
 
 
 
 
 
C&I
75

 

$—

 

$84

 

$84

Consumer loans:
 
 
 
 
 
 
 
Residential mortgages - nonguaranteed
219

 
17

 
38

 
55

Residential home equity products
280

 

 
24

 
24

Residential construction
4

 

 

 

Other direct
328

 

 
5

 
5

Indirect
1,395

 

 
35

 
35

Credit cards
734

 
3

 

 
3

Total TDR additions
3,035

 

$20

 

$186

 

$206

1 Includes loans modified under the terms of a TDR that were charged-off during the period.

TDRs that defaulted during the three and six months ended June 30, 2019 and 2018, which were first modified within the previous twelve months, were immaterial. The majority of loans that were modified under the terms of a TDR and subsequently became 90 days or more delinquent have remained on nonaccrual status since the time of delinquency.

Concentrations of Credit Risk
The Company does not have a significant concentration of credit risk to any individual client except for the U.S. government and its agencies. However, a geographic concentration arises because the majority of the Company's LHFI portfolio represents borrowers that reside in Florida, Georgia, Virginia, Maryland, and North Carolina. The Company’s cross-border outstanding loans totaled $1.8 billion at both June 30, 2019 and December 31, 2018.
With respect to collateral concentration, the Company's recorded investment in residential real estate secured LHFI totaled $38.3 billion at June 30, 2019 and represented 24% of total LHFI. At December 31, 2018, the Company's recorded investment in residential real estate secured LHFI totaled $38.9 billion and represented 26% of total LHFI. Additionally, at June 30, 2019 and December 31, 2018, the Company had commitments to extend credit on home equity lines of $10.6 billion and $10.3 billion, and had residential mortgage commitments outstanding of $5.3 billion and $2.7 billion, respectively. At both June 30, 2019 and December 31, 2018, 1% of the Company's LHFI secured by residential real estate was insured by the FHA or guaranteed by the VA.