Financing receivables are comprised of commercial loans, consumer loans, and the deposit receivable. See Note 2 for information regarding the Company’s accounting policies related to financing receivables and the allowance for credit losses.

The following tables present a rollforward of the allowance for credit losses for the three months ended March 31:



	Commercial Loans		Consumer Loans			Total
	(in millions)
Balance, December 31, 2019 ⁽¹⁾	$	51	$	—		$	51
Cumulative effect of adoption of current expected credit losses guidance	2		3			5
Balance, January 1, 2020	53		3			56
Provisions	10		2			12
Write-offs	—		(1		)	(1		)
Balance, March 31, 2020	$	63	$	4		$	67

⁽¹⁾Prior to January 1, 2020, the allowance for credit losses was based on an incurred loss model that did not require estimating expected credit losses over the expected life of the asset.

As of both March 31, 2020 and December 31, 2019, accrued interest on commercial loans was $14 million and is recorded in receivables on the Consolidated Balance Sheets and excluded from the amortized cost basis of commercial loans.

During the three months ended March 31, 2020 and 2019, the Company purchased $56 million and $33 million, respectively, of syndicated loans, and sold $7 million and $13 million, respectively, of syndicated loans.

Nonperforming loans were $31 million and $25 million as of March 31, 2020 and December 31, 2019, respectively. All other loans were considered to be performing.

The Company reviews the credit worthiness of the borrower and the performance of the underlying properties in order to determine the risk of loss on commercial mortgage loans. Loan-to-value ratio is the primary credit quality indicator included in this review. Total commercial mortgage loans past due were nil as of both March 31, 2020 and December 31, 2019.

Based on this review, the commercial mortgage loans are assigned an internal risk rating, which management updates as necessary. Commercial mortgage loans which management has assigned its highest risk rating were less than 1% of total commercial mortgage loans as of both March 31, 2020 and December 31, 2019. Loans with the highest risk rating represent distressed loans which the Company has identified as impaired or expects to become delinquent or enter into foreclosure within the next six months.

The table below presents the amortized cost basis of commercial mortgage loans as of March 31, 2020 by year of origination and loan-to-value ratio:



Loan-to-Value Ratio	2020		2019		2018		2017		2016		Prior		Total
Loan-to-Value Ratio	(in millions)
> 100%	$	—	$	—	$	—	$	—	$	1	$	11	$	12
80% - 100%	13		15		10		4		14		12		68
60% - 80%	33		182		85		44		61		129		534
40% - 60%	8		46		54		156		86		692		1,042
< 40%	5		24		51		96		75		898		1,149
Total	$	59	$	267	$	200	$	300	$	237	$	1,742	$	2,805

In addition, the Company reviews the concentrations of credit risk by region and property type. Concentrations of credit risk of commercial mortgage loans by U.S. region were as follows:



	Loans				Percentage
	March 31, 2020		December 31, 2019		March 31, 2020		December 31, 2019
	(in millions)
East North Central	$	234	$	239	8	%	9	%
East South Central	119		121		4		4
Middle Atlantic	185		182		7		6
Mountain	247		251		9		9
New England	56		54		2		2
Pacific	843		831		30		30
South Atlantic	730		723		26		26
West North Central	211		214		8		8
West South Central	180		182		6		6
	2,805		2,797		100	%	100	%
Less: allowance for credit losses	26		19
Total	$	2,779	$	2,778



	Loans				Percentage
	March 31, 2020		December 31, 2019		March 31, 2020		December 31, 2019
	(in millions)
Apartments	$	705	$	692	25	%	25	%
Hotel	50		51		2		2
Industrial	430		429		15		15
Mixed use	90		78		3		3
Office	407		419		15		15
Retail	918		931		33		33
Other	205		197		7		7
	2,805		2,797		100	%	100	%
Less: allowance for credit losses	26		19
Total	$	2,779	$	2,778

The recorded investment in syndicated loans as of March 31, 2020 and December 31, 2019 was $560 million and $543 million, respectively. The Company’s syndicated loan portfolio is diversified across industries and issuers, with limited exposure to the oil and gas industry. Total syndicated loans past due were nil and $1 million as of March 31, 2020 and December 31, 2019, respectively. The Company assigns an internal risk rating to each syndicated loan in its portfolio ranging from 1 through 5, with 5 reflecting the lowest quality.

The table below presents the amortized cost basis of syndicated loans as of March 31, 2020 by origination year and internal risk rating:



Internal Risk Rating	2020		2019		2018		2017		2016		Prior		Total
Internal Risk Rating	(in millions)
Risk 5	$	—	$	—	$	—	$	—	$	—	$	—	$	—
Risk 4	—		13		5		6		2		7		33
Risk 3	—		5		14		31		10		19		79
Risk 2	11		40		59		60		23		56		249
Risk 1	9		27		49		58		18		38		199
Total	$	20	$	85	$	127	$	155	$	53	$	120	$	560

The Company offers loans to financial advisors for transitional cost assistance. Repayment of the loan is highly dependent on the retention of the financial advisor. In the event a financial advisor is no longer affiliated with the Company, any unpaid balances become immediately due. Accordingly, the primary risk factor for advisor loans is termination status. The allowance for credit losses related to loans to advisors that have terminated their relationship with the Company was $9 million and $10 million as of March 31, 2020 and December 31, 2019, respectively.

The table below presents the amortized cost basis of advisor loans as of March 31, 2020 by origination year and termination status:



Termination Status	2020		2019		2018		2017		2016		Prior		Total
Termination Status	(in millions)
Active	$	46	$	153	$	109	$	134	$	91	$	111	$	644
Terminated	—		—		—		1		3		12		16
Total	$	46	$	153	$	109	$	135	$	94	$	123	$	660

The credit cards are co-branded with Ameriprise Financial, Inc. and issued to the Company’s customers by a third party. FICO scores and delinquency rates are the primary credit quality indicators for the credit card portfolio. Delinquency rates are measured as based on the number of days past due. Two percent of credit card receivables were over 30 days past due as of both March 31, 2020 and December 31, 2019.

Policy loans do not exceed the cash surrender value at origination. As there is minimal risk of loss related to policy loans, the Company does not record an allowance for credit losses.

The Company monitors collateral supporting margin loans and requests additional collateral when necessary in order to mitigate the risk of loss. As of both March 31, 2020 and December 31, 2019, the allowance for credit losses on margin loans was not material.

The deposit receivable was $1.5 billion as of both March 31, 2020 and December 31, 2019. The deposit receivable is fully collateralized by the fair value of the assets held in a trust. Based on management’s evaluation of the nature of the underlying assets and the potential for changes in the collateral value, the Company did not have an allowance for credit losses for the deposit receivable as of both March 31, 2020 and December 31, 2019.

The recorded investment in restructured loans was not material as of both March 31, 2020 and December 31, 2019. There were no loans restructured by the Company during both the three months ended March 31, 2020 and 2019. There are no commitments to lend additional funds to borrowers whose loans have been restructured.