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Asset Quality
6 Months Ended
Jun. 30, 2021
Credit Loss [Abstract]  
Asset Quality
4. Asset Quality

ALLL

We estimate the appropriate level of the ALLL on at least a quarterly basis. The methodology is described in Note 1 ("Summary of Significant Accounting Policies") under the heading "Allowance for Loan and Lease Losses" beginning on page 110 of our 2020 Form 10-K.

The ALLL at June 30, 2021, represents our current estimate of lifetime credit losses inherent in the loan portfolio at that date. The changes in the ALLL by loan category for the periods indicated are as follows:

Three months ended June 30, 2021:
in millionsMarch 31, 2021ProvisionCharge-offsRecoveriesJune 30, 2021
Commercial and Industrial $596 $(88)$(41)$32 $499 
Commercial real estate:
Real estate — commercial mortgage256 (31)(4)6 227 
Real estate — construction45 (10)  35 
Total commercial real estate loans301 (41)(4)6 262 
Commercial lease financing40 (6)  34 
Total commercial loans937 (135)(45)38 795 
Real estate — residential mortgage100 (13)(1) 86 
Home equity loans157 (18)(4)1 136 
Consumer direct loans126 (6)(7)2 115 
Credit cards80 (6)(9)3 68 
Consumer indirect loans38 (18)(5)5 20 
Total consumer loans501 (61)(26)11 425 
Total ALLL — continuing operations1,438 (196)
(a)
(71)49 1,220 
Discontinued operations33 (2)(1) 30 
Total ALLL — including discontinued operations$1,471 $(198)$(72)$49 $1,250 
(a)Excludes a credit for losses on lending-related commitments of $26 million.

Three months ended June 30, 2020:
in millionsMarch 31, 2020ProvisionCharge-offsRecoveriesJune 30, 2020
Commercial and Industrial $542 $249 $(71)$$725 
Commercial real estate:
Real estate — commercial mortgage207 87 (2)— 292 
Real estate — construction25 16 — — 41 
Total commercial real estate loans232 103 (2)— 333 
Commercial lease financing44 14 (4)55 
Total commercial loans818 366 (77)1,113 
Real estate — residential mortgage89 14 (2)— 101 
Home equity loans184 14 (2)197 
Consumer direct loans116 22 (10)130 
Credit cards104 13 (12)107 
Consumer indirect loans48 16 (7)60 
Total consumer loans541 79 (33)595 
Total ALLL — continuing operations1,359 445 
(a)
(110)14 1,708 
Discontinued operations43 — (2)43 
Total ALLL — including discontinued operations$1,402 $445 $(112)$16 $1,751 
(a)Excludes a provision for losses on lending-related commitments of $37 million.
Six months ended June 30, 2021
in millionsDecember 31, 2020ProvisionCharge-offsRecoveriesJune 30, 2021
Commercial and Industrial $678 $(105)$(114)$40 $499 
Commercial real estate:
Real estate — commercial mortgage327 (68)(39)7 227 
Real estate — construction47 (12)  35 
Total commercial real estate loans374 (80)  262 
Commercial lease financing47 (10)(4)1 34 
Total commercial loans1,099 (195)(157)48 795 
Real estate — residential mortgage102 (16)(1)1 86 
Home equity loans171 (31)(6)2 136 
Consumer direct loans128 (2)(15)4 115 
Credit cards87 (9)(15)5 68 
Consumer indirect loans39 (17)(12)10 20 
Total consumer loans527 (75)(49)22 425 
Total ALLL — continuing operations1,626 (270)
(a)
(206)70 1,220 
Discontinued operations36 (5)(2)1 30 
Total ALLL — including discontinued operations$1,662 $(275)$(208)$71 $1,250 
(a)Excludes a credit for losses on lending-related commitments of $45 million



Six months ended June 30, 2020


in millionsPre-ASC 326 Adoption December 31, 2019Impact of ASC 326 AdoptionJanuary 1, 2020ProvisionCharge-offsRecoveriesJune 30, 2020
Commercial and Industrial $551 $(141)$410 $436 $(131)$10 $725 
Commercial real estate:
Real estate — commercial mortgage143 16 159 137 (5)292 
Real estate — construction22 (7)15 26 — — 41 
Total commercial real estate loans165 174 163 (5)333 
Commercial lease financing35 43 17 (6)55 
Total commercial loans751 (124)627 616 (142)12 1,113 
Real estate — residential mortgage77 84 19 (2)— 101 
Home equity loans31 147 178 22 (6)197 
Consumer direct loans34 63 97 51 (22)130 
Credit cards47 35 82 44 (23)107 
Consumer indirect loans30 36 32 (16)60 
Total consumer loans149 328 477 168 (69)19 595 
Total ALLL — continuing operations900 204 1,104 784 
(a)
(211)31 1,708 
Discontinued operations10 31 41 (4)43 
Total ALLL — including discontinued operations$910 $235 $1,145 $787 $(215)$34 $1,751 
(a)Excludes a provision for losses on lending-related commitments of $57 million.


As described in Note 1 ("Summary of Significant Accounting Policies"), under the heading “Allowance for Loan and Lease Losses” beginning on page 110 of our 2020 Form 10-K, we estimate the ALLL using relevant available information, from internal and external sources, relating to past events, current conditions, and reasonable and supportable forecasts. In our estimation of expected credit losses, we use a two year reasonable and supportable period across all products. Following this two year period in which supportable forecasts can be generated, for all modeled loan portfolios, we revert expected credit losses to a level that is consistent with our historical information by reverting the macroeconomic variables (model inputs) to their long run average. We revert to historical loss rates for less complex estimation methods for smaller portfolios. A 20 year fixed length look back period is used to calculate the long run average of the macroeconomic variables. A four quarter reversion period is used where the macroeconomic variables linearly revert to their long run average following the two year reasonable and supportable period.

We develop our reasonable and supportable forecasts using relevant data including, but not limited to, changes in economic output, unemployment rates, property values, and other factors associated with the credit losses on financial assets. Some macroeconomic variables apply to all portfolio segments, while others are more portfolio specific. The following table discloses key macroeconomic variables for each loan portfolio.
SegmentPortfolio
Key Macroeconomic Variables (a)
CommercialCommercial and industrialBBB corporate bond rate (spread), GDP, industrial production, and unemployment rate
Commercial real estateBBB corporate bond rate (spread), property and real estate price indices, and unemployment rate
Commercial lease financingBBB corporate bond rate (spread), GDP, and unemployment rate
ConsumerReal estate — residential mortgageGDP, home price index, unemployment rate, and 30 year mortgage rate
Home equityHome price index, unemployment rate, and 30 year mortgage rate
Consumer directUnemployment rate and U.S. household income
Consumer indirectNew vehicle sales, used vehicle prices, and unemployment rate
Credit cardsUnemployment rate and U.S. household income
Discontinued operationsUnemployment rate
(a)Variables include all transformations and interactions with other risk drivers. Additionally, variables may have varying impacts at different points in the economic cycle.

In addition to macroeconomic drivers, portfolio attributes such as remaining term, outstanding balance, risk ratings, FICO, LTV, and delinquency also drive ALLL changes. Our ALLL models were designed to capture the correlation between economic and portfolio changes. As such, evaluating shifts in individual portfolio attributes and macroeconomic variables in isolation may not be indicative of past or future performance.

Economic Outlook

As of June 30, 2021, the economic prospects continue to improve at a more accelerated pace than in the first quarter of 2021, but the continuation of the COVID-19 pandemic and the wind-down of various governmental assistance programs still creates much uncertainty. We utilized the Moody’s May 2021 Consensus forecast to estimate our expected credit losses as of June 30, 2021. We determined such forecast to be a reasonable view of the outlook for the economy given all available information at quarter end.

The baseline scenario reflects moderate economic growth over the next two years in markets in which we operate. U.S. GDP continues to rebound with a projected 10.6% annualized growth rate in the second quarter of 2021 and an overall growth rate of approximately 7% expected for the year. The national unemployment rate forecast is 5.9% in the second quarter of 2021, and is expected to decline to 4.7% by the fourth quarter of 2021.

To the extent we identified credit risk considerations that were not captured by the third-party economic forecast, we addressed the risk through management’s qualitative adjustments to the ALLL.

As a result of the unprecedented economic uncertainty caused by the COVID-19 pandemic, our future loss estimates may vary considerably from our June 30, 2021 assumptions.

Commercial Loan Portfolio

The ALLL from continuing operations for the commercial segment decreased by $142 million, or 15.2%, from March 31, 2021. The overall decrease in the allowance is driven by improvements in economic forecasts, a slight decline in loan balances, and improving asset quality.

The changes to the economic forecast primarily reflect improvements in economic drivers used in our models. The unemployment and GDP positive growth outlook contributes to the overall commercial segment reserve decrease. Expected improvements in real estate price indices lead to a reduction in reserve in our commercial real estate book. Risk rating migrations are driving a modest decrease in ALLL levels for the commercial and industrial portfolio. The ALLL results also reflect incremental credit risk considerations as a result of the future economic uncertainties which are addressed through qualitative adjustments.

As of June 30, 2021, we concluded that no ALLL is necessary for $5.7 billion in outstanding PPP loans as they are 100% guaranteed by the SBA.

Consumer Loan Portfolio

The ALLL from continuing operations for the consumer segment decreased by $76 million, or 15.2%, from March 31, 2021. The overall decrease in the allowance is driven by updated economic forecasts that capture an improving outlook for several drivers and strong portfolio performance, partially offset by growth in consumer real estate.
The most meaningful changes to the economic forecast contributing to the reduction in reserves include improvement in the unemployment rate outlook, which impacts all consumer portfolios. In addition, the housing market and HPI outlook continue to display strength, which impacts the residential mortgage and home equity segments. The unprecedented increase in used vehicle prices and favorable outlook are the main driver for the reserve reduction in the indirect auto loan portfolio. As it relates to the decline in the ALLL due to portfolio factors, shifts are largely driven by attrition activity, targeted portfolio growth and overall strong credit drivers. The ALLL results also reflect incremental credit risk considerations as a result of the economic stress and related borrower assistance programs, which are addressed through qualitative adjustments.

Credit Risk Profile

The prevalent risk characteristic for both commercial and consumer loans is the risk of loss arising from an obligor’s inability or failure to meet contractual payment or performance terms. Evaluation of this risk is stratified and monitored by the loan risk rating grades assigned for the commercial loan portfolios and the refreshed FICO score assigned for the consumer loan portfolios. The internal risk grades assigned to loans follow our definitions of Pass and Criticized, which are consistent with published definitions of regulatory risk classifications. Loans with a pass rating represent those loans not classified on our rating scale for problem credits, as minimal credit risk has been identified. Criticized loans are those loans that either have a potential weakness deserving management's close attention or have a well-defined weakness that may put full collection of contractual cash flows at risk. Borrower FICO scores provide information about the credit quality of our consumer loan portfolio as they provide an indication as to the likelihood that a debtor will repay its debts. The scores are obtained from a nationally recognized consumer rating agency and are presented in the tables below at the dates indicated.

Most extensions of credit are subject to loan grading or scoring. Loan grades are assigned at the time of origination, verified by credit risk management, and periodically re-evaluated thereafter. This risk rating methodology blends our judgment with quantitative modeling. Commercial loans generally are assigned two internal risk ratings. The first rating reflects the probability that the borrower will default on an obligation; the second rating reflects expected recovery rates on the credit facility. Default probability is determined based on, among other factors, the financial strength of the borrower, an assessment of the borrower’s management, the borrower’s competitive position within its industry sector, and our view of industry risk in the context of the general economic outlook. Types of exposure, transaction structure, and collateral, including credit risk mitigants, affect the expected recovery assessment.
Commercial Credit Exposure
Credit Risk Profile by Creditworthiness Category and Vintage (a)
As of June 30, 2021Term LoansRevolving Loans Amortized Cost BasisRevolving Loans Converted to Term Loans Amortized Cost Basis
Amortized Cost Basis by Origination Year and Internal Risk Rating
in millions20212020201920182017PriorTotal
Commercial and Industrial
Risk Rating:
Pass$6,763 $8,185 $4,542 $3,382 $2,124 $3,974 $19,061 $104 $48,135 
Criticized (Accruing)30 118 232 242 208 236 1,086 30 2,182 
Criticized (Nonaccruing)17 52 48 221 355 
Total commercial and industrial6,794 8,310 4,791 3,676 2,339 4,258 20,368 136 50,672 
Real estate — commercial mortgage
Risk Rating:
Pass1,678 1,415 2,703 1,371 786 3,254 716 46 11,969 
Criticized (Accruing)12 25 156 152 142 330 111 930 
Criticized (Nonaccruing)— — 16 41 — 66 
Total real estate — commercial mortgage
1,690 1,440 2,863 1,524 944 3,625 831 48 12,965 
Real estate — construction
Risk Rating:
Pass177 555 700 365 152 36 28 2,022 
Criticized (Accruing)— 14 54 22 14 — 110 
Criticized (Nonaccruing)— — — — — — — — — 
Total real estate — construction177 559 714 419 174 50 30 2,132 
Commercial lease financing
Risk Rating:
Pass409 880 825 416 380 1,037 — — 3,947 
Criticized (Accruing)— 19 40 17 23 — — 107 
Criticized (Nonaccruing)— — — — 
Total commercial lease financing409 899 867 434 405 1,047 — 4,061 
Total commercial loans$9,070 $11,208 $9,235 $6,053 $3,862 $8,980 $21,229 $193 $69,830 

As of December 31, 2020Term LoansRevolving Loans Amortized Cost BasisRevolving Loans Converted to Term Loans Amortized Cost Basis
Amortized Cost Basis by Origination Year and Internal Risk Rating
in millions20202019201820172016PriorTotal
Commercial and Industrial
Risk Rating:
Pass$13,100 $5,487 $4,040 $2,617 $1,967 $2,709 $19,832 $118 $49,870 
Criticized (Accruing)66 198 174 236 150 279 1,527 22 2,652 
Criticized (Nonaccruing)27 71 28 17 226 385 
Total commercial and industrial13,174 5,712 4,285 2,881 2,134 2,995 21,585 141 52,907 
Real estate — commercial mortgage
Risk Rating:
Pass1,591 2,937 1,737 867 765 3,027 885 43 11,852 
Criticized (Accruing)12 142 81 145 72 255 22 731 
Criticized (Nonaccruing)— 88 — 104 
Total real estate — commercial mortgage
1,603 3,080 1,822 1,016 839 3,370 912 45 12,687 
Real estate — construction
Risk Rating:
Pass367 764 510 188 27 22 31 1,914 
Criticized (Accruing)— 14 38 18 — — 73 
Criticized (Nonaccruing)— — — — — — — — — 
Total real estate — construction367 778 548 206 27 24 32 1,987 
Commercial lease financing
Risk Rating:
Pass1,076 1,050 534 504 228 901 — — 4,293 
Criticized (Accruing)10 35 15 26 — — 97 
Criticized (Nonaccruing)— — — 
Total commercial lease financing1,086 1,087 551 532 237 906 — — 4,399 
Total commercial loans$16,230 $10,657 $7,206 $4,635 $3,237 $7,295 $22,529 $191 $71,980 
(a)Accrued interest of $127 million and $140 million as of June 30, 2021 and December 31, 2020, respectively, presented in Other Assets on the Consolidated Balance Sheets, was excluded from the amortized cost basis disclosed in these tables.
Consumer Credit Exposure
Credit Risk Profile by FICO Score and Vintage (a)
As of June 30, 2021Term LoansRevolving Loans Amortized Cost BasisRevolving Loans Converted to Term Loans Amortized Cost Basis
Amortized Cost Basis by Origination Year and FICO Score
in millions20212020201920182017PriorTotal
Real estate — residential mortgage
FICO Score:
750 and above$3,871 $3,348 $1,106 $129 $173 $1,353 — — $9,980 
660 to 749743 462 201 54 37 363 — — 1,860 
Less than 66010 14 17 18 157 — — 225 
No Score18 39 — — 66 
Total real estate — residential mortgage4,642 3,825 1,326 203 223 1,912 — — 12,131 
Home equity loans
FICO Score:
750 and above799 911 321 128 160 818 $2,426 $508 6,071 
660 to 749262 335 147 56 55 247 1,087 172 2,361 
Less than 66014 28 21 15 15 106 353 51 603 
No Score— — 12 
Total home equity loans1,075 1,276 491 200 230 1,173 3,870 732 9,047 
Consumer direct loans
FICO Score:
750 and above867 1,457 688 90 24 120 112 — 3,358 
660 to 749251 383 220 58 15 48 224 — 1,199 
Less than 66010 20 28 14 12 64 — 152 
No Score31 44 36 14 12 22 181 — 340 
Total consumer direct loans1,159 1,904 972 176 55 202 581 — 5,049 
Credit cards
FICO Score:
750 and above— — — — — — 472 — 472 
660 to 749— — — — — — 372 — 372 
Less than 660— — — — — — 77 — 77 
No Score— — — — — — — 
Total credit cards— — — — — — 923 — 923 
Consumer indirect loans
FICO Score:
750 and above115 821 770 286 130 81 — — 2,203 
660 to 749— 496 416 163 63 54 — — 1,192 
Less than 660— 102 116 70 35 32 — — 355 
No Score— — — — — — — — — 
Total consumer indirect loans115 1,419 1,302 519 228 167 — — 3,750 
Total consumer loans$6,991 $8,424 $4,091 $1,098 $736 $3,454 $5,374 $732 $30,900 
As of December 31, 2020Term LoansRevolving Loans Amortized Cost BasisRevolving Loans Converted to Term Loans Amortized Cost Basis
Amortized Cost Basis by Origination Year and FICO Score
in millions20202019201820172016PriorTotal
Real estate — residential mortgage
FICO Score:
750 and above$3,595 $1,620 $194 $254 $537 $1,211 — — $7,411 
660 to 749710 284 76 48 100 332 — — 1,550 
Less than 66016 28 21 10 26 170 — — 271 
No Score52 — — 66 
Total real estate — residential mortgage4,322 1,934 293 319 665 1,765 — — 9,298 
Home equity loans
FICO Score:
750 and above1,043 404 168 202 190 839 $2,689 $590 6,125 
660 to 749385 198 82 77 69 253 1,237 206 2,507 
Less than 66027 30 18 20 20 113 426 61 715 
No Score— — 13 
Total home equity loans1,457 634 269 299 279 1,207 4,357 858 9,360 
Consumer direct loans
FICO Score:
750 and above1,840 883 115 32 16 57 119 — 3,062 
660 to 749479 268 80 22 14 33 254 1,151 
Less than 66023 37 21 10 81 — 185 
No Score65 35 21 21 10 11 153 — 316 
Total consumer direct loans2,407 1,223 237 83 45 111 607 4,714 
Credit cards
FICO Score:
750 and above— — — — — — 488 — 488 
660 to 749— — — — — — 407 — 407 
Less than 660— — — — — — 93 — 93 
No Score— — — — — — — 
Total credit cards— — — — — — 989 — 989 
Consumer indirect loans
FICO Score:
750 and above1,092 924 369 188 69 66 — — 2,708 
660 to 749653 558 232 97 36 47 — — 1,623 
Less than 660143 163 99 54 25 28 — — 512 
No Score— — — — — — — 
Total consumer indirect loans1,889 1,645 700 339 130 141 — — 4,844 
Total consumer loans$10,075 $5,436 $1,499 $1,040 $1,119 $3,224 $5,953 $859 $29,205 
(a)Accrued interest of $97 million and $101 million as of June 30, 2021 and December 31, 2020, respectively, presented in Other Assets on the Consolidated Balance Sheets, was excluded from the amortized cost basis disclosed in this table.


Nonperforming and Past Due Loans

Our policies for determining past due loans, placing loans on nonaccrual, applying payments on nonaccrual loans, and resuming accrual of interest for our commercial and consumer loan portfolios are disclosed in Note 1 (“Summary of Significant Accounting Policies”) under the heading “Nonperforming Loans” beginning on page 108 of our 2020 Form 10-K.

Under the CARES Act as well as banking regulator interagency guidance, certain loan modifications to borrowers experiencing financial distress as a result of the economic impacts created by the COVID-19 pandemic may not be required to be reported as past due. For COVID-19 related loan modifications which occurred from March 1, 2020, through June 30, 2021, and met the loan modification criteria under either the CARES Act or the criteria specified by the regulatory agencies, we have elected to re-age to current status all commercial loans and consumer loans that are not secured by real-estate and freeze the delinquency status of consumer real estate secured loans as of the modification or forbearance grant date. At June 30, 2021, the portfolio loans and leases in active deferral or forebearance as part of our COVID-19 hardship relief programs totaled $259 million, of which $209 million of loan modifications and forbearances made under the criteria of either the CARES Act, banking regulator interagency guidance, or short-term forbearance policies were not reported as nonperforming.
The following aging analysis of past due and current loans as of June 30, 2021, and December 31, 2020, provides further information regarding Key’s credit exposure.

Aging Analysis of Loan Portfolio(a)
June 30, 2021Current
30-59
Days Past
Due (b)
60-89
Days Past
Due (b)
90 and
Greater
Days Past
Due (b)
Non-performing
Loans
Total Past
Due and
Non-performing
Loans
Total
Loans (c)
in millions
LOAN TYPE
Commercial and industrial$50,188 $71 $19 $39 $355 $484 $50,672 
Commercial real estate:
Commercial mortgage12,865 12 15 66 100 12,965 
Construction2,131 — — — 2,132 
Total commercial real estate loans14,996 12 15 66 101 15,097 
Commercial lease financing4,043 18 4,061 
Total commercial loans$69,227 $90 $28 $57 $428 $603 $69,830 
Real estate — residential mortgage$12,023 $$$— $99 $108 $12,131 
Home equity loans8,861 23 10 146 186 9,047 
Consumer direct loans5,035 14 5,049 
Credit cards909 14 923 
Consumer indirect loans3,717 14 14 33 3,750 
Total consumer loans$30,545 $52 $20 $17 $266 $355 $30,900 
Total loans$99,772 $142 $48 $74 $694 $958 $100,730 
(a)Amounts in table represent amortized cost and exclude loans held for sale.
(b)Accrued interest of $225 million presented in Other Assets on the Consolidated Balance Sheets is excluded from the amortized cost basis disclosed in this table.
(c)Net of unearned income, net of deferred fees and costs, and unamortized discounts and premiums.

December 31, 2020Current
30-59
Days Past
Due (b)
60-89
Days Past
Due (b)
90 and
Greater
Days Past
Due (b)
Non-performing
Loans
Total Past
Due and
Non-performing
Loans
Total
Loans (c)
in millions
LOAN TYPE
Commercial and industrial$52,396 $36 $50 $40 $385 $511 $52,907 
Commercial real estate:
Commercial mortgage12,548 21 104 139 12,687 
Construction1,986 — — — 1,987 
Total commercial real estate loans14,534 22 104 140 14,674 
Commercial lease financing4,369 21 — 30 4,399 
Total commercial loans$71,299 $66 $56 $62 $497 $681 $71,980 
Real estate — residential mortgage$9,173 $11 $$$110 $125 $9,298 
Home equity loans9,143 34 20 154 217 9,360 
Consumer direct loans4,694 20 4,714 
Credit cards972 17 989 
Consumer indirect loans4,792 25 17 52 4,844 
Total consumer loans$28,774 $82 $37 $24 $288 $431 $29,205 
Total loans$100,073 $148 $93 $86 $785 $1,112 $101,185 

(a)Amounts in table represent amortized cost and exclude loans held for sale.
(b)Accrued interest of $241 million presented in Other Assets on the Consolidated Balance Sheets is excluded from the amortized cost basis disclosed in this table.
(c)Net of unearned income, net of deferred fees and costs, and unamortized discounts and premiums.


At June 30, 2021, the approximate carrying amount of our commercial nonperforming loans outstanding represented 69% of their original contractual amount owed, total nonperforming loans outstanding represented 76% of their original contractual amount owed, and nonperforming assets in total were carried at 81% of their original contractual amount owed.

Nonperforming loans reduced expected interest income by $7 million and $14 million for the three and six months ended June 30, 2021,respectively, and $7 million and $13 million for the three and six months ended June 30, 2020, respectively.

The amortized cost basis of nonperforming loans on nonaccrual status for which there is no related allowance for credit losses was $474 million at June 30, 2021.
Collateral-dependent Financial Assets

We classify financial assets as collateral-dependent when our borrower is experiencing financial difficulty, and we expect repayment to be provided substantially through the operation or sale of the collateral. Our commercial loans have collateral that includes commercial machinery, commercial properties, and commercial real estate construction projects. Our consumer loans have collateral that includes residential real estate, automobiles, boats, and RVs.

There were no significant changes in the extent to which collateral secures our collateral-dependent financial assets during the three months ended June 30, 2021.

TDRs

We classify loan modifications as TDRs when a borrower is experiencing financial difficulties and we have granted a concession without commensurate financial, structural, or legal consideration. Our loan modifications are handled on a case-by-case basis and are negotiated to achieve mutually agreeable terms that maximize loan collectability and meet the borrower’s financial needs. Under the CARES Act as well as banking regulator interagency guidance, certain loan modifications to borrowers experiencing financial distress as a result of the economic impacts created by the COVID-19 pandemic may not be required to be treated as TDRs under U.S. GAAP.  As of June 30, 2021, the outstanding balance of loans that underwent COVID-19 related loan modifications for which we elected to suspend TDR accounting as such loan modifications met the criteria under either the CARES Act or banking regulator interagency guidance totaled $209 million

Commitments outstanding to lend additional funds to borrowers whose loan terms have been modified in TDRs were $30 million and $1 million at June 30, 2021, and December 31, 2020, respectively.

The consumer TDR other concession category in the table below primarily includes those borrowers’ debts that are discharged through Chapter 7 bankruptcy and have not been formally re-affirmed. At June 30, 2021, and December 31, 2020, the recorded investment of consumer residential mortgage loans in the process of foreclosure was approximately $78 million and $92 million, respectively.

The following table shows the post-modification outstanding recorded investment by concession type for our commercial and consumer accruing and nonaccruing TDRs that occurred during the periods indicated:
Three Months Ended June 30,Six Months Ended June 30,
in millions2021202020212020
Commercial loans:
Extension of Maturity Date— $$26 $
Payment or Covenant Modification/Deferment$16 — 23 — 
Bankruptcy Plan Modification— — — — 
Increase in new commitment or new money— — 
Total$16 $12 $49 $12 
Consumer loans:
Interest rate reduction$$$$
Other13 
Total$$$11 $22 
Total TDRs$22 $18 $60 $34 

The following table summarizes the change in the post-modification outstanding recorded investment of our accruing and nonaccruing TDRs during the periods indicated:
Three Months Ended June 30,Six Months Ended June 30,
in millions2021202020212020
Balance at beginning of the period$376 $340 $363 $347 
Additions22 22 81 39 
Payments(60)(35)(81)(53)
Charge-offs(4)(17)(29)(23)
Balance at end of period$334 $310 $334 $310 
A further breakdown of TDRs included in nonperforming loans by loan category for the periods indicated are as follows:
June 30, 2021December 31, 2020
Number of
Loans
Pre-modification
Outstanding
Recorded
Investment
Post-modification
Outstanding
Recorded
Investment
Number of
Loans
Pre-modification
Outstanding
Recorded
Investment
Post-modification
Outstanding
Recorded
Investment
dollars in millions
LOAN TYPE
Nonperforming:
Commercial and industrial41 $112 $65 66 $136 $92 
Commercial real estate:
Commercial mortgage66 45 62 50 
Total commercial real estate loans66 45 62 50 
Total commercial loans45 178 110 73 198 142 
Real estate — residential mortgage214 25 23 258 35 34 
Home equity loans532 35 30 630 41 37 
Consumer direct loans200 212 
Credit cards291 356 
Consumer indirect loans735 13 861 15 11 
Total consumer loans1,972 78 67 2,317 96 87 
Total nonperforming TDRs2,017 256 177 2,390 294 229 
Prior-year accruing:(a)
Commercial and industrial13 26 25 — 
Commercial real estate
Commercial mortgage— — — — — — 
Total commercial real estate loans— — — — — — 
Total commercial loans13 26 25 — 
Real estate — residential mortgage480 40 34 485 37 31 
Home equity loans1,717 103 81 1,781 106 83 
Consumer direct loans200 163 
Credit cards598 536 
Consumer indirect loans705 26 14 775 29 16 
Total consumer loans3,700 178 132 3,740 179 134 
Total prior-year accruing TDRs3,713 204 157 3,743 184 134 
Total TDRs5,730 $460 $334 6,133 $478 $363 
(a)All TDRs that were restructured prior to January 1, 2021, and January 1, 2020, are fully accruing.

Commercial loan TDRs are considered defaulted when principal and interest payments are 90 days past due. Consumer loan TDRs are considered defaulted when principal and interest payments are more than 60 days past due. During the three months ended June 30, 2021, there was one commercial loan TDR and 29 consumer loan TDRs with a combined recorded investment of $1 million that experienced payment defaults after modifications resulting in TDR status during 2020. During the three months ended June 30, 2020, there were no commercial loan TDRs and 43 consumer loan TDRs with a combined recorded investment of $1 million that experienced payment defaults after modifications resulting in TDR status during 2019.

During the six months ended June 30, 2021, there were three commercial loan TDRs and 65 consumer loan TDRs with a combined recorded investment of $2 million that experienced payment defaults after modifications resulting in TDR status during 2020. During the six months ended June 30, 2020, there were no commercial loan TDRs and 127 consumer loan TDRs with a combined recorded investment of $3 million that experienced payment defaults after modifications resulting in TDR status during 2019.

Liability for Credit Losses on Off Balance Sheet Exposures

The liability for credit losses inherent in unfunded lending-related commitments, such as letters of credit and unfunded loan commitments, and certain financial guarantees is included in “accrued expense and other liabilities” on the balance sheet.

Changes in the liability for credit losses on off balance sheet exposures are summarized as follows:
 Three months ended June 30,Six months ended June 30,
in millions2021202020212020
Balance at the end of the prior period$178 $161 $197 $68 
Liability for credit losses on contingent guarantees at the end of the prior period —  
Cumulative effect from change in accounting principle (a), (b)
 —  66 
Balance at beginning of period178 161 197 141 
Provision (credit) for losses on off balance sheet exposures(26)37 (45)57 
Balance at end of period$152 $198 $152 $198 
(a)The cumulative effect from change in accounting principle relates to the January 1, 2020, adoption of ASU 2016-13.
(b)The six months ended June 30, 2020, amount excludes $4 million related to the provision for other financial assets.