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Allowance for Credit Losses
9 Months Ended
Sep. 30, 2021
Credit Loss [Abstract]  
Allowance for Credit Losses Allowance for Credit Losses
We utilize a minimum of three forward-looking economic scenarios to calculate lifetime ECL when estimating the allowance for credit losses for in scope financial assets and the liability for off-balance sheet credit exposures. The three scenarios are termed the "Consensus Economic Scenarios" and represent a 'most likely outcome' (the "Central scenario") and two less likely 'outer' scenarios, referred to as the "Upside scenario" and the "Downside scenario". Each scenario is assigned a weighting deemed appropriate for the estimation of lifetime ECL, with the majority of the weighting typically placed on the Central Scenario. At management's discretion, changes may be made to the weighting assigned to the three scenarios or additional scenarios may be included in order to consider current economic conditions. As a result of the deterioration of economic conditions and significant economic uncertainty caused by the COVID-19 pandemic, beginning in the second quarter of 2020, we developed and utilized a fourth scenario for estimating lifetime ECL, referred to as the "Alternative Downside scenario", to reflect the possibility that the adverse impact associated with the deterioration in economic conditions could manifest itself over a far longer period of time.
Updates to Economic Scenarios and Other Changes During the Nine Months Ended September 30, 2021 Although economic conditions improved during the first half of 2021, the impact of the COVID-19 pandemic continued to create uncertainty about the future economic environment. As a result, we updated our three Consensus Economic Scenarios and our Alternative Downside scenario to reflect management's view of forecasted economic conditions and utilized the four updated scenarios for estimating lifetime ECL at March 31, 2021 and June 30, 2021. Each of the four scenarios were assigned weightings with the majority of the weighting placed on the Central scenario, the second most weighting placed on the Downside scenario and lower equal weights placed on the Upside and Alternative Downside scenarios. This weighting was deemed appropriate for the estimation of lifetime ECL at the time.
During the third quarter of 2021, economic conditions continued to improve, although at a slower pace than during the first half of the year. However, the impact of the COVID-19 pandemic continues to create uncertainty about the future economic environment. As a result, we updated our three Consensus Economic Scenarios and our Alternative Downside scenario to reflect management's current view of forecasted economic conditions and utilized the four updated scenarios for estimating lifetime ECL at September 30, 2021. Each of the four scenarios were assigned weightings with the majority of the weighting placed on the Central scenario, the second most weighting placed on the Downside scenario and lower equal weights placed on the Upside and Alternative Downside scenarios. This weighting was deemed appropriate for the estimation of lifetime ECL under current conditions. The following discussion summarizes the Central, Upside, Downside and Alternative Downside scenarios at September 30, 2021. The economic assumptions described in this section have been formed specifically for the purpose of calculating ECL.
In the Central scenario, Gross Domestic Product ("GDP") maintains its strong recovery path in 2021 and carries its expansion into 2022, under the assumption that economic activities continue to recover while impact from new COVID-19 infections subsides as more people are vaccinated, and high fiscal support boosts near-term economic growth. With a strong economic recovery, the unemployment rate continues on its downward trend, while demand for housing, combined with limited supply, continues to drive the residential housing market to carry its growth momentum into 2022. Commercial real estate prices also start to appreciate, after a period of sluggish growth driven by pandemic induced adjustments. In the financial markets, growth in financial asset prices remains moderate, the federal funds rate remains at the current near-zero level until the beginning of 2023, and the 10-year U.S. Treasury yield, which has experienced some increase since the start of 2021, continues to rise.
In the Upside scenario, the economy is assumed to grow at a faster pace than in the Central scenario. As a result, the unemployment rate falls faster than in the Central scenario and, with increasing mobility, commercial real estate prices start to accelerate. In this scenario, the equity price index climbs with strong momentum, and overall optimism allows the Federal Reserve Board ("FRB") to start normalizing monetary policy earlier than currently anticipated, which consequently drives the 10-year U.S. Treasury yield to a level that is significantly higher than in the Central Scenario.
In the Downside scenario, the economy drops into a mild recession, with the unemployment rate reversing its downward trend and remaining at a higher level. In this scenario, the residential housing market slowly loses its momentum in 2022 due to weakness in the labor market, and the commercial real estate market suffers a heavier blow than the residential housing market. The equity price index in this scenario loses about half of its value by the middle of 2023, driven by an overall erosion of consumer and business sentiments, which also results in a lower 10-year U.S. Treasury yield than in the Central Scenario, and the federal funds rate remains at the lowest level for the next two years.
In the Alternative Downside scenario, the U.S. economy re-enters into a recession in early 2022 and stays in until early 2023, followed by a very anemic recovery thereafter. An extended period of economic contraction keeps the unemployment rate at a very high level, which pressures residential housing prices to fall, while at the same time, contracting corporate activities and rising unemployment pushes the commercial real estate market into a severe downturn. In this scenario, financial markets experience a major sell-off and volatility in the financial markets remains extremely high over the next year, widening corporate credit spreads substantially, and flight to safe haven assets pushes the 10-year U.S. Treasury yield lower.
The following table presents the forecasted key macroeconomic variables in our Central scenarios used for estimating lifetime ECL at September 30, 2021, June 30, 2021 and December 31, 2020:
For the Quarter Ended
December 31, 2021June 30, 2022December 31, 2022
Unemployment rate (quarterly average):
Forecast at September 30, 20214.7 %4.3 %4.2 %
Forecast at June 30, 20214.8 4.4 4.1 
Forecast at December 31, 20206.2 5.9 5.4 
GDP growth rate (year-over-year):
Forecast at September 30, 20216.8 4.9 2.3 
Forecast at June 30, 20216.3 4.7 2.3 
Forecast at December 31, 20205.3 3.1 1.8 
In addition to the updates to the economic scenarios, during the three and nine months ended September 30, 2021, we decreased the management judgment allowance on our commercial loan portfolio for risk factors associated with higher risk client and industry exposures and, in the year-to-date period, economic uncertainty relating to the impact of COVID-19 that are not fully captured in the models. The decrease for risk factors associated with higher risk industry exposures reflects the transfer of certain commercial real estate loans to held for sale during the third quarter of 2021, which resulted in the reversal of the existing allowance for credit losses on these loans totaling $24 million. During the three and nine months ended September 30, 2021, we also decreased the management judgment allowance on our consumer loan portfolio for risk factors associated with economic uncertainty and, in the year-to-date period, forbearance accounts that are not fully captured in the models. The decrease in the management judgment allowance on our consumer loan portfolio in the year-to-date period reflects the transfer of certain loans to held for sale. As previously disclosed, during the second quarter of 2021, we made the decision to exit our mass market retail banking business as well as our remaining retail credit card portfolio which resulted in the transfer of certain loans to held for sale and the reversal or charge-off of the existing allowances for credit losses on these loans which collectively totaled $157 million.
While we believe that the assumptions used in our credit loss models are reasonable within the parameters for which the models have been built and calibrated to operate, the severe projections of macro-economic variables during the current COVID-19 pandemic represent events outside the parameters for which the models have been built. As a result, adjustments to model outputs to reflect consideration of management judgment are used with stringent governance in place to ensure an appropriate lifetime ECL estimate.
The circumstances around the COVID-19 pandemic are evolving and will continue to impact our business and our allowance for credit losses in future periods. The details of how various U.S. Government actions will impact our customers and therefore the impact on our allowance for credit losses remains uncertain. We will continue to monitor the COVID-19 situation closely and will continue to adapt our Consensus Economic Scenarios approach as necessary to reflect management's current view of forecasted economic conditions.

Allowance for Credit Losses / Liability for Off-Balance Sheet Credit Exposures The following table summarizes our allowance for credit losses and the liability for off-balance sheet credit exposures:
September 30, 2021December 31, 2020
 (in millions)
Allowance for credit losses:
Loans$475 $1,015 
Securities held-to-maturity(1)
1 
Other financial assets measured at amortized cost(2)
2 
Securities available-for-sale(1)
1 
Total allowance for credit losses$479 $1,020 
Liability for off-balance sheet credit exposures$110 $237 
(1)See Note 5, "Securities," for additional information regarding the allowance for credit losses associated with our security portfolios.
(2)Primarily includes accrued interest receivables and customer acceptances.
The following table summarizes the changes in the allowance for credit losses on loans by product or line of business during the three and nine months ended September 30, 2021 and 2020:
 Commercial LoansConsumer Loans 
Real Estate, including ConstructionBusiness
and Corporate Banking
Global
Banking
Other
Comm'l
Residential
Mortgages
Home
Equity
Mortgages
Credit
Cards
Other
Consumer
Total Loans
 (in millions)
Three Months Ended September 30, 2021
Allowance for credit losses – beginning of period
$117 $284 $131 $6 $(6)$15 $ $ $547 
Provision charged (credited) to income(1)
(2)(38)(9)(2)(9)(2)(1)(1)(64)
Charge-offs(1)
 (13)   (3)  (16)
Recoveries 1   4 1 1 1 8 
Net (charge-offs) recoveries (12)  4 (2)1 1 (8)
Allowance for credit losses – end of period
$115 $234 $122 $4 $(11)$11 $ $ $475 
Three Months Ended September 30, 2020
Allowance for credit losses – beginning of period
$120 $434 $424 $$(19)$16 $190 $22 $1,192 
Provision charged (credited) to income43 (36)(103)12 (1)(2)(75)
Charge-offs(12)(2)(1)— (1)(1)(23)(4)(44)
Recoveries— — — — 11 
Net (charge-offs) recoveries(12)(1)— — (21)(4)(33)
Allowance for credit losses – end of period
$151 $401 $320 $$(5)$15 $167 $27 $1,084 
Nine Months Ended September 30, 2021
Allowance for credit losses – beginning of period
$145 $375 $287 $7 $(9)$22 $161 $27 $1,015 
Provision charged (credited) to income(1)
(30)(115)(153)(3)(3)(10)(78)(18)(410)
Charge-offs(1)
 (29)(12) (10)(5)(88)(11)(155)
Recoveries 3   11 4 5 2 25 
Net (charge-offs) recoveries (26)(12) 1 (1)(83)(9)(130)
Allowance for credit losses – end of period
$115 $234 $122 $4 $(11)$11 $ $ $475 
Nine Months Ended September 30, 2020
Allowance for credit losses – beginning of period
$153 $239 $106 $$12 $$105 $$637 
Cumulative effect adjustment to initially apply new accounting guidance for measuring credit losses(2)
(112)(60)51 (5)(86)32 (170)
Allowance for credit losses – beginning of period, adjusted
41 179 157 (74)13 137 10 467 
Provision charged (credited) to income122 283 183 62 96 24 774 
Charge-offs(12)(69)(20)— (1)(3)(71)(8)(184)
Recoveries— — 27 
Net (charge-offs) recoveries(12)(61)(20)(66)(7)(157)
Allowance for credit losses – end of period
$151 $401 $320 $$(5)$15 $167 $27 $1,084 
(1)For loans that are transferred to held for sale, the existing allowance for credit losses at the time of transfer are recognized as a charge-off to the extent fair value is less than amortized cost and attributable to credit. Any remaining allowance for credit losses is released as a reduction to the provision for credit losses.
During the third quarter of 2021, we transferred certain commercial real estate loans to held for sale and, as a result, we released $24 million of the existing allowance for credit losses as a reduction to the provision for credit losses.
During the second quarter of 2021, we made the decision to exit our mass market retail banking business as well as our remaining retail credit card portfolio which resulted in the transfer of certain loans to held for sale. As a result of transferring these loans to held for sale, during the nine months ended September 30, 2021, we recognized $56 million of the existing allowance for credit losses on consumer loans as charge-offs, primarily related to non-performing credit cards, and released $100 million of the existing allowance for credit losses on consumer loans as reductions to the provision for credit losses, primarily related to credit cards. The existing commercial allowance for credit losses on the retail business banking loan portfolio transferred to held for sale was not material. See Note 3, "Branch Assets and Liabilities Held for Sale."
(2)See Note 2, "Summary of Significant Accounting Policies and New Accounting Pronouncements," in our 2020 Form 10-K for additional discussion.
The following table summarizes the changes in the liability for off-balance sheet credit exposures during the three and nine months ended September 30, 2021 and 2020:
Three Months Ended September 30,Nine Months Ended September 30,
2021202020212020
 (in millions)
Balance at beginning of period$128 $253 $237 $104 
Cumulative effect adjustment to initially apply new accounting guidance for measuring credit losses(1)
 —  54 
Balance at beginning of period, adjusted128 253 237 158 
Provision charged (credited) to income(18)(28)(127)67 
Balance at end of period$110 $225 $110 $225 
(1)See Note 2, "Summary of Significant Accounting Policies and New Accounting Pronouncements," in our 2020 Form 10-K for additional discussion.
Accrued Interest Receivables The following table summarizes accrued interest receivables associated with financial assets carried at amortized cost and securities available-for-sale along with the related allowance for credit losses, which are reported net in other assets on the consolidated balance sheet. These accrued interest receivables are excluded from the amortized cost basis disclosures presented elsewhere in these financial statements, including Note 5, "Securities," and Note 6, "Loans."
September 30, 2021December 31, 2020
 (in millions)
Accrued interest receivables:
Loans$125 $140 
Securities held-to-maturity15 23 
Other financial assets measured at amortized cost2 
Securities available-for-sale87 100 
Total accrued interest receivables229 264 
Allowance for credit losses  
Accrued interest receivables, net$229 $262 
During the three and nine months ended September 30, 2021, we charged-off accrued interest receivables by reversing interest income for loans of $1 million and $3 million, respectively, compared with $1 million and $5 million during the three and nine months ended September 30, 2020, respectively.