
Dollars in millions	June 30, 2021		Provision		Charge-offs		Recoveries		September 30, 2021
Commercial and Industrial	$	499	$	(30)	$	(27)	$	20	$	462
Commercial real estate:
Real estate — commercial mortgage	227		(44)		—		1		184
Real estate — construction	35		(8)		—		—		27
Total commercial real estate loans	262		(52)		—		1		211
Commercial lease financing	34		(7)		(1)		6		32
Total commercial loans	795		(89)		(28)		27		705
Real estate — residential mortgage	86		(1)		2		1		88
Home equity loans	136		(13)		(1)		2		124
Consumer direct loans	115		(5)		(7)		2		105
Credit cards	68		(4)		(6)		1		59
Consumer indirect loans	20		5		(26)		4		3
Total consumer loans	425		(18)		(38)		10		379
Total ALLL — continuing operations	1,220		(107)		(66)		37		1,084
Discontinued operations	30		(1)		(1)		1		29
Total ALLL — including discontinued operations	$	1,250	$	(108)	$	(67)	$	38	$	1,113


Dollars in millions	June 30, 2020		Provision			Charge-offs		Recoveries		September 30, 2020
Commercial and Industrial	$	725	$	177		$	(101)	$	9	$	810
Commercial real estate:
Real estate — commercial mortgage	292		(2)			(13)		2		279
Real estate — construction	41		(7)			—		—		34
Total commercial real estate loans	333		(9)			(13)		2		313
Commercial lease financing	55		13			(10)		—		58
Total commercial loans	1,113		181			(124)		11		1,181
Real estate — residential mortgage	101		2			—		1		104
Home equity loans	197		(13)			(4)		3		183
Consumer direct loans	130		1			(8)		2		125
Credit cards	107		(5)			(9)		2		95
Consumer indirect loans	60		(16)			(6)		4		42
Total consumer loans	595		(31)			(27)		12		549
Total ALLL — continuing operations	1,708		150		(a)	(151)		23		1,730
Discontinued operations	43		(1)			—		—		42
Total ALLL — including discontinued operations	$	1,751	$	149		$	(151)	$	23	$	1,772


Dollars in millions	December 31, 2020		Provision			Charge-offs		Recoveries		September 30, 2021
Commercial and Industrial	$	678	$	(135)		$	(141)	$	60	$	462
Commercial real estate:
Real estate — commercial mortgage	327		(112)			(39)		8		184
Real estate — construction	47		(20)			—		—		27
Total commercial real estate loans	374		(132)			—		—		211
Commercial lease financing	47		(17)			(5)		7		32
Total commercial loans	1,099		(284)			(185)		75		705
Real estate — residential mortgage	102		(17)			1		2		88
Home equity loans	171		(44)			(7)		4		124
Consumer direct loans	128		(7)			(22)		6		105
Credit cards	87		(13)			(21)		6		59
Consumer indirect loans	39		(12)			(38)		14		3
Total consumer loans	527		(93)			(87)		32		379
Total ALLL — continuing operations	1,626		(377)		(a)	(272)		107		1,084
Discontinued operations	36		(6)			(3)		2		29
Total ALLL — including discontinued operations	$	1,662	$	(383)		$	(275)	$	109	$	1,113


Dollars in millions	December 31, 2019		Impact of ASC 326 Adoption		January 1, 2020		Provision			Charge-offs		Recoveries		September 30, 2020
Commercial and Industrial	$	551	$	(141)	$	410	$	613		$	(232)	$	19	$	810
Commercial real estate:
Real estate — commercial mortgage	143		16		159		135			(18)		3		279
Real estate — construction	22		(7)		15		19			—		—		34
Total commercial real estate loans	165		9		174		154			(18)		3		313
Commercial lease financing	35		8		43		30			(16)		1		58
Total commercial loans	751		(124)		627		797			(266)		23		1,181
Real estate — residential mortgage	7		77		84		21			(2)		1		104
Home equity loans	31		147		178		9			(10)		6		183
Consumer direct loans	34		63		97		52			(30)		6		125
Credit cards	47		35		82		39			(32)		6		95
Consumer indirect loans	30		6		36		16			(22)		12		42
Total consumer loans	149		328		477		137			(96)		31		549
Total ALLL — continuing operations	900		204		1,104		934		(a)	(362)		54		1,730
Discontinued operations	10		31		41		2			(4)		3		42
Total ALLL — including discontinued operations	$	910	$	235	$	1,145	$	936		$	(366)	$	57	$	1,772

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.


Segment	Portfolio	Key Macroeconomic Variables (a)
Commercial	Commercial and industrial	BBB corporate bond rate (spread), GDP, industrial production, and unemployment rate
	Commercial real estate	BBB corporate bond rate (spread), property and real estate price indices, and unemployment rate
	Commercial lease financing	BBB corporate bond rate (spread), GDP, and unemployment rate
Consumer	Real estate — residential mortgage	GDP, home price index, unemployment rate, and 30 year mortgage rate
	Home equity	Home price index, unemployment rate, and 30 year mortgage rate
	Consumer direct	Unemployment rate and U.S. household income
	Consumer indirect	New vehicle sales, used vehicle prices, and unemployment rate
	Credit cards	Unemployment rate and U.S. household income
	Discontinued operations	Unemployment rate

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.

As of September 30, 2021, the economic outlook continues to be strong, but the emergence of the Delta variant of the COVID-19 virus negatively impacted supply chains and consumer confidence. We utilized the Moody’s August 2021 Consensus forecast as our baseline forecast to estimate our expected credit losses as of September 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 continues to reflect moderate economic growth over the next two years in markets in which we operate. U.S. GDP continues to increase at an 8.2% annualized rate in the third quarter of 2021 and at an annual rate of approximately 6% and 5% for 2021 and 2022, respectively. The national unemployment rate forecast is 5.3% in the third quarter of 2021, and is expected to decline to 4.7% by the fourth quarter of 2021 and 4.0% by the fourth quarter of 2022.

The changes to the economic forecast primarily reflect improvements in economic drivers used in our models. The favorable unemployment and GDP outlook contributes to the overall commercial segment reserve decrease. Expected improvements in real estate price indices lead to a reduction in reserve for our commercial real estate book. Positive 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.

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 home price index outlook continue to display strength, which impacts the residential mortgage and home equity segments. 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 uncertainty and related borrower assistance programs, which are addressed through qualitative adjustments.

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.


As of September 30, 2021	Term Loans												Revolving Loans Amortized Cost Basis		Revolving Loans Converted to Term Loans Amortized Cost Basis
	Amortized Cost Basis by Origination Year and Internal Risk Rating
Dollars in millions	2021		2020		2019		2018		2017		Prior						Total
Commercial and Industrial
Risk Rating:
Pass	$	9,315	$	5,420	$	4,491	$	3,186	$	2,016	$	3,884	$	18,950	$	102	$	47,364
Criticized (Accruing)	40		115		193		192		236		208		925		27		1,936
Criticized (Nonaccruing)	—		9		18		41		6		16		160		3		253
Total commercial and industrial	9,355		5,544		4,702		3,419		2,258		4,108		20,035		132		49,553
Real estate — commercial mortgage
Risk Rating:
Pass	3,219		1,357		2,589		1,338		687		3,073		690		64		13,017
Criticized (Accruing)	15		20		87		85		123		228		48		2		608
Criticized (Nonaccruing)	—		1		1		5		1		37		4		—		49
Total real estate — commercial mortgage	3,234		1,378		2,677		1,428		811		3,338		742		66		13,674
Real estate — construction
Risk Rating:
Pass	318		619		610		292		104		49		29		6		2,027
Criticized (Accruing)	—		4		13		52		22		1		1		—		93
Criticized (Nonaccruing)	—		—		—		—		—		—		—		—		—
Total real estate — construction	318		623		623		344		126		50		30		6		2,120
Commercial lease financing
Risk Rating:
Pass	655		815		744		348		347		997		—		—		3,906
Criticized (Accruing)	—		4		35		14		13		5		—		—		71
Criticized (Nonaccruing)	—		—		1		1		1		2		—		—		5
Total commercial lease financing	655		819		780		363		361		1,004				—		3,982
Total commercial loans	$	13,562	$	8,364	$	8,782	$	5,554	$	3,556	$	8,500	$	20,807	$	204	$	69,329


As of December 31, 2020	Term Loans												Revolving Loans Amortized Cost Basis		Revolving Loans Converted to Term Loans Amortized Cost Basis
	Amortized Cost Basis by Origination Year and Internal Risk Rating
Dollars in millions	2020		2019		2018		2017		2016		Prior						Total
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)	8		27		71		28		17		7		226		1		385
Total commercial and industrial	13,174		5,712		4,285		2,881		2,134		2,995		21,585		141		52,907
Real estate — commercial mortgage
Risk Rating:
Pass	1,591		2,937		1,737		867		765		3,027		885		43		11,852
Criticized (Accruing)	12		142		81		145		72		255		22		2		731
Criticized (Nonaccruing)	—		1		4		4		2		88		5		—		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:
Pass	367		764		510		188		27		22		31		5		1,914
Criticized (Accruing)	—		14		38		18		—		2		1		—		73
Criticized (Nonaccruing)	—		—		—		—		—		—		—		—		—
Total real estate — construction	367		778		548		206		27		24		32		5		1,987
Commercial lease financing
Risk Rating:
Pass	1,076		1,050		534		504		228		901		—		—		4,293
Criticized (Accruing)	10		35		15		26		7		4		—		—		97
Criticized (Nonaccruing)	—		2		2		2		2		1		—		—		9
Total commercial lease financing	1,086		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


As of September 30, 2021	Term Loans												Revolving Loans Amortized Cost Basis		Revolving Loans Converted to Term Loans Amortized Cost Basis
	Amortized Cost Basis by Origination Year and FICO Score
Dollars in millions	2021		2020		2019		2018		2017		Prior						Total
Real estate — residential mortgage
FICO Score:
750 and above	$	6,071	$	3,150	$	933	$	104	$	141	$	1,218	—		—		$	11,617
660 to 749	1,300		407		186		47		31		323		—		—		2,294
Less than 660	23		12		19		16		10		151		—		—		231
No Score	19		1		1		2		4		34		1		—		62
Total real estate — residential mortgage	7,413		3,570		1,139		169		186		1,726		1		—		14,204
Home equity loans
FICO Score:
750 and above	919		885		285		113		139		739		$	2,333	$	462	5,875
660 to 749	345		295		130		49		47		222		1,037		158		2,283
Less than 660	20		26		20		14		15		99		336		48		578
No Score	—		2		—		1		—		2		5		1		11
Total home equity loans	1,284		1,208		435		177		201		1,062		3,711		669		8,747
Consumer direct loans
FICO Score:
750 and above	1,287		1,271		594		76		20		137		109		—		3,494
660 to 749	413		350		200		51		13		48		217		—		1,292
Less than 660	19		22		29		12		3		14		61		—		160
No Score	47		45		32		16		9		21		208		—		378
Total consumer direct loans	1,766		1,688		855		155		45		220		595		—		5,324
Credit cards
FICO Score:
750 and above	—		—		—		—		—		—		472		—		472
660 to 749	—		—		—		—		—		—		375		—		375
Less than 660	—		—		—		—		—		—		72		—		72
No Score	—		—		—		—		—		—		9		—		9
Total credit cards	—		—		—		—		—		—		928		—		928
Consumer indirect loans
FICO Score:
750 and above	4		—		—		—		—		36		—		—		40
660 to 749	—		—		—		—		—		26		—		—		26
Less than 660	—		—		—		—		—		11		—		—		11
No Score	—		—		—		—		—		—		—		—		—
Total consumer indirect loans	4		—		—		—		—		73		—		—		77
Total consumer loans	$	10,467	$	6,466	$	2,429	$	501	$	432	$	3,081	$	5,235	$	669	$	29,280


As of December 31, 2020	Term Loans												Revolving Loans Amortized Cost Basis		Revolving Loans Converted to Term Loans Amortized Cost Basis
	Amortized Cost Basis by Origination Year and FICO Score
Dollars in millions	2020		2019		2018		2017		2016		Prior						Total
Real estate — residential mortgage
FICO Score:
750 and above	$	3,595	$	1,620	$	194	$	254	$	537	$	1,211	—		—		$	7,411
660 to 749	710		284		76		48		100		332		—		—		1,550
Less than 660	16		28		21		10		26		170		—		—		271
No Score	1		2		2		7		2		52		—		—		66
Total real estate — residential mortgage	4,322		1,934		293		319		665		1,765		—		—		9,298
Home equity loans
FICO Score:
750 and above	1,043		404		168		202		190		839		$	2,689	$	590	6,125
660 to 749	385		198		82		77		69		253		1,237		206		2,507
Less than 660	27		30		18		20		20		113		426		61		715
No Score	2		2		1		—		—		2		5		1		13
Total home equity loans	1,457		634		269		299		279		1,207		4,357		858		9,360
Consumer direct loans
FICO Score:
750 and above	1,840		883		115		32		16		57		119		—		3,062
660 to 749	479		268		80		22		14		33		254		1		1,151
Less than 660	23		37		21		8		5		10		81		—		185
No Score	65		35		21		21		10		11		153		—		316
Total consumer direct loans	2,407		1,223		237		83		45		111		607		1		4,714
Credit cards
FICO Score:
750 and above	—		—		—		—		—		—		488		—		488
660 to 749	—		—		—		—		—		—		407		—		407
Less than 660	—		—		—		—		—		—		93		—		93
No Score	—		—		—		—		—		—		1		—		1
Total credit cards	—		—		—		—		—		—		989		—		989
Consumer indirect loans
FICO Score:
750 and above	1,092		924		369		188		69		66		—		—		2,708
660 to 749	653		558		232		97		36		47		—		—		1,623
Less than 660	143		163		99		54		25		28		—		—		512
No Score	1		—		—		—		—		—		—		—		1
Total consumer indirect loans	1,889		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

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 September 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 September 30, 2021, the portfolio loans and leases in active deferral or forebearance as part of our COVID-19 hardship relief programs totaled $174 million, of which $124 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.


September 30, 2021	Current		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)
Dollars in millions
LOAN TYPE
Commercial and industrial	$	49,161	$	56	$	33	$	50	$	253	$	392	$	49,553
Commercial real estate:
Commercial mortgage	13,606		12		2		5		49		68		13,674
Construction	2,118		1		—		1		—		2		2,120
Total commercial real estate loans	15,724		13		2		6		49		70		15,794
Commercial lease financing	3,973		2		1		1		5		9		3,982
Total commercial loans	$	68,858	$	71	$	36	$	57	$	307	$	471	$	69,329
Real estate — residential mortgage	$	14,096	$	6	$	3	$	6	$	93	$	108	$	14,204
Home equity loans	8,559		22		10		10		146		188		8,747
Consumer direct loans	5,307		6		3		4		4		17		5,324
Credit cards	914		3		3		5		3		14		928
Consumer indirect loans	75		1		—		—		1		2		77
Total consumer loans	$	28,951	$	38	$	19	$	25	$	247	$	329	$	29,280
Total loans	$	97,809	$	109	$	55	$	82	$	554	$	800	$	98,609


December 31, 2020	Current		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)
Dollars in millions
LOAN TYPE
Commercial and industrial	$	52,396	$	36	$	50	$	40	$	385	$	511	$	52,907
Commercial real estate:
Commercial mortgage	12,548		9		5		21		104		139		12,687
Construction	1,986		—		—		1		—		1		1,987
Total commercial real estate loans	14,534		9		5		22		104		140		14,674
Commercial lease financing	4,369		21		1		—		8		30		4,399
Total commercial loans	$	71,299	$	66	$	56	$	62	$	497	$	681	$	71,980
Real estate — residential mortgage	$	9,173	$	11	$	3	$	1	$	110	$	125	$	9,298
Home equity loans	9,143		34		20		9		154		217		9,360
Consumer direct loans	4,694		7		4		4		5		20		4,714
Credit cards	972		5		3		7		2		17		989
Consumer indirect loans	4,792		25		7		3		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

At September 30, 2021, the approximate carrying amount of our commercial nonperforming loans outstanding represented 62% of their original contractual amount owed, total nonperforming loans outstanding represented 72% of their original contractual amount owed, and nonperforming assets in total were carried at 77% of their original contractual amount owed.

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.

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 September 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 $124 million.

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 September 30, 2021, and December 31, 2020, the recorded investment of consumer residential mortgage loans in the process of foreclosure was approximately $70 million and $92 million, respectively.


	Three Months Ended September 30,				Nine Months Ended September 30,
Dollars in millions	2021		2020		2021		2020
Commercial loans:


Extension of Maturity Date	$	—	$	—	$	5	$	8
Payment or Covenant Modification/Deferment	—		—		7		—
Bankruptcy Plan Modification	—		—		—		—
Increase in new commitment or new money	—		—		—		—
Total	$	—	$	—	$	12	$	8
Consumer loans:
Interest rate reduction	$	3	$	13	$	6	$	22

Other	12		6		18		18
Total	$	15	$	19	$	24	$	40
Total TDRs	$	15	$	19	$	36	$	48

A further breakdown of TDRs included in nonperforming loans by loan category for the periods indicated are as follows:


	September 30, 2021					December 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 industrial	35	$	92	$	53	66	$	136	$	92
Commercial real estate:
Commercial mortgage	3	50		29		7	62		50
Total commercial real estate loans	3	50		29		7	62		50
Total commercial loans	38	142		82		73	198		142
Real estate — residential mortgage	218	26		25		258	35		34
Home equity loans	569	38		33		630	41		37
Consumer direct loans	201	3		3		212	3		3
Credit cards	328	2		2		356	2		2
Consumer indirect loans	23	1		1		861	15		11
Total consumer loans	1,339	70		64		2,317	96		87
Total nonperforming TDRs	1,377	212		146		2,390	294		229
Prior-year accruing:(a)
Commercial and industrial	7	49		26		3	5		—
Commercial real estate
Commercial mortgage	1	—		—		—	—		—
Total commercial real estate loans	1	—		—		—	—		—
Total commercial loans	8	49		26		3	5		—
Real estate — residential mortgage	464	39		34		485	37		31
Home equity loans	1,648	100		78		1,781	106		83
Consumer direct loans	206	5		3		163	4		3
Credit cards	564	4		1		536	3		1
Consumer indirect loans	150	16		8		775	29		16
Total consumer loans	3,032	164		124		3,740	179		134
Total prior-year accruing TDRs	3,040	163		124		3,743	184		134
Total TDRs	4,417	$	375	$	270	6,133	$	478	$	363

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 September 30, 2021, there were two commercial loan TDRs and 33 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 three months ended September 30, 2020, there were no commercial loan TDRs and 33 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 nine months ended September 30, 2021, there were five commercial loan TDRs and 98 consumer loan TDRs with a combined recorded investment of $4 million that experienced payment defaults after modifications resulting in TDR status during 2020. During the nine months ended September 30, 2020, there were no commercial loan TDRs and 160 consumer loan TDRs with a combined recorded investment of $4 million that experienced payment defaults after modifications resulting in TDR status during 2019.


	Three months ended September 30,				Nine months ended September 30,
Dollars in millions	2021		2020		2021		2020
Balance at the end of the prior period	$	152	$	198	$	197	$	68
Liability for credit losses on contingent guarantees at the end of the prior period	—		—		—		7
Cumulative effect from change in accounting principle (a), (b)	—		—		—		66
Balance at beginning of period	152		198		197		141
Provision (credit) for losses on off balance sheet exposures	—		10		(45)		67
Balance at end of period	$	152	$	208	$	152	$	208