Allowance for Credit Losses

3 Months Ended

Mar. 31, 2022

We utilize a minimum of four 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. Three of the 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". The fourth scenario, referred to as the "Alternative Downside Scenario", is designed to consider severe downside risks with more extreme economic outcomes than those captured by the Consensus Economic Scenarios. 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 four scenarios or additional scenarios may be included in order to consider current economic conditions.

Updates to Economic Scenarios and Other Changes During the Three Months Ended March 31, 2022 During the first quarter of 2022, in addition to the continued economic uncertainty caused by the coronavirus ("COVID-19") pandemic, the impact of the Russia-Ukraine war created further uncertainty about the future economic environment. As a result, in addition to updating our three Consensus Economic Scenarios and our Alternative Downside scenario, we developed and utilized a fifth scenario for estimating lifetime ECL at March 31, 2022, referred to as the "Alternative Downside 2 scenario" to reflect the possibility that the war could last for a prolonged period of time. Each of the five scenarios were assigned weightings with the majority of the weighting placed on the Central scenario, the second most weighting placed on the Alternative Downside 2 scenario, lower equal weights placed on the Downside and Alternative Downside scenarios, and the lowest weighting placed on the Upside scenario. This weighting was deemed appropriate for the estimation of lifetime ECL under current conditions. The following discussion summarizes the Central, Upside, Downside, Alternative Downside and Alternative Downside 2 scenarios at March 31, 2022. The economic assumptions described in this section have been formed specifically for the purpose of calculating ECL.

In the Central scenario, U.S. Gross Domestic Product ("GDP") maintains its strong growth path in 2022, under the assumption that economic activities continue to grow while impacts from newly emerging risks, including those from new COVID-19 infections, subside. With strong economic growth, 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 forward, and commercial real estate prices also continue the recent trend of appreciation. In the financial markets, growth in financial asset prices remains moderate, the Federal Reserve Board ("FRB") raises its policy rate, and the 10-year U.S. Treasury yield 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 both commercial and residential real estate prices grow at faster rates than in the Central Scenario. In this scenario, the equity price index climbs with strong momentum, and overall optimism allows the FRB to raise its policy rate faster than currently anticipated, which consequently drives the 10-year U.S. Treasury yield to a level that is higher than in the Central Scenario.

In the Downside scenario, the economy stagnates, with the unemployment rate reversing its downward trend and remaining at a higher level. The residential housing market slowly loses its momentum due to weakness in the labor market, and the commercial real estate market suffers a heavier deceleration than the residential housing market. In this scenario, the equity price index goes through a moderate price correction 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 2022 and stays in until late 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 moderately, 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.

In the Alternative Downside 2 scenario, the war in Ukraine turns into a protracted crisis, which results in high economic costs with surging inflation, largely due to high energy and commodity prices and a squeeze on disposable income, leading to a period of economic stagnation. In this scenario, unemployment rises modestly through 2022, reversing its downward trend, and corrections in risky asset prices lead to a flight to quality in global asset markets. The FRB, however, remains committed to tackling inflation and embarks on a more aggressive rate hiking cycle, which eventually helps to control inflation by late 2023.

The following table presents the forecasted key macroeconomic variables in our Central scenarios used for estimating lifetime ECL at March 31, 2022 and December 31, 2021:


	For the Quarter Ended
	June 30, 2022		December 31, 2022		June 30, 2023		December 31, 2023
Unemployment rate (quarterly average):
Forecast at March 31, 2022	3.8	%	3.6	%	3.5	%	3.6	%

Forecast at December 31, 2021	4.3		4.0		3.8		3.7
GDP growth rate (year-over-year):
Forecast at March 31, 2022	3.8		2.8		2.6		2.4

Forecast at December 31, 2021	4.1		2.8		2.3		2.5

In addition to the updates to the economic scenarios, we increased the management judgment allowance on our commercial loan portfolio for risk factors associated with economic uncertainty, including higher risk industry exposures and supply chain disruptions, that are not fully captured in the models. We also increased the management judgment allowance on our consumer loan portfolio for risk factors associated with economic uncertainty that are not fully captured in the models.

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 COVID-19 pandemic and subsequent significant recovery 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 both the Russia-Ukraine war and the COVID-19 pandemic will continue to evolve and impact our business and our allowance for credit losses in future periods, the extent of which remains uncertain. We will continue to monitor these situations closely and will continue to adapt our 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:


	March 31, 2022		December 31, 2021
	(in millions)
Allowance for credit losses:
Loans	$	467	$	447
Securities held-to-maturity(1)	1		1
Other financial assets measured at amortized cost(2)	1		1
Securities available-for-sale(1)	—		1
Total allowance for credit losses	$	469	$	450

Liability for off-balance sheet credit exposures	$	84	$	103

(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 months ended March 31, 2022 and 2021:


	Commercial Loans								Consumer Loans
	Real Estate, including Construction		Business and Corporate Banking		Global Banking		Other Comm'l		Residential Mortgages		Home Equity Mortgages		Credit Cards		Other Consumer		Total Loans
	(in millions)


















Three Months Ended March 31, 2022
Allowance for credit losses – beginning of period	$	73	$	243	$	100	$	4	$	8	$	5	$	14	$	—	$	447


Provision charged (credited) to income	49		(40)		29		(2)		(4)		—		(1)		—		31
Charge-offs	—		(8)		(9)		—		(1)		(1)		—		—		(19)
Recoveries	—		2		—		—		2		2		2		—		8
Net (charge-offs) recoveries	—		(6)		(9)		—		1		1		2		—		(11)

Allowance for credit losses – end of period	$	122	$	197	$	120	$	2	$	5	$	6	$	15	$	—	$	467

Three Months Ended March 31, 2021
Allowance for credit losses – beginning of period	$	145	$	375	$	287	$	7	$	(9)	$	22	$	161	$	27	$	1,015


Provision charged (credited) to income	(25)		(53)		(65)		—		(2)		(3)		(1)		4		(145)
Charge-offs	—		(2)		—		—		(1)		—		(18)		(4)		(25)
Recoveries	—		1		—		—		3		2		2		—		8
Net (charge-offs) recoveries	—		(1)		—		—		2		2		(16)		(4)		(17)

Allowance for credit losses – end of period	$	120	$	321	$	222	$	7	$	(9)	$	21	$	144	$	27	$	853

The following table summarizes the changes in the liability for off-balance sheet credit exposures during the three months ended March 31, 2022 and 2021:



Three Months Ended March 31,	2022		2021
	(in millions)
Balance at beginning of period	$	103	$	237


Provision credited to income	(19)		(82)
Balance at end of period	$	84	$	155

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."


	March 31, 2022		December 31, 2021
	(in millions)
Accrued interest receivables:
Loans	$	103	$	109
Securities held-to-maturity	12		13
Other financial assets measured at amortized cost	5		1
Securities available-for-sale	78		82
Total accrued interest receivables	198		205
Allowance for credit losses	—		1
Accrued interest receivables, net	$	198	$	204

During both the three months ended March 31, 2022 and 2021, charged-off accrued interest receivables were immaterial.