Loans Held-for-Investment | Loans Held-for-Investment The following table presents our loans held-for-investment: March 31, 2019 December 31, 2018 (Dollars in millions) Consumer loans Residential first mortgage $ 3,100 $ 2,999 Home equity 796 731 Other 433 314 Total consumer loans 4,329 4,044 Commercial loans Commercial real estate 2,324 2,152 Commercial and industrial 1,651 1,433 Warehouse lending 1,632 1,459 Total commercial loans 5,607 5,044 Total loans held-for-investment $ 9,936 $ 9,088 The following table presents the UPB of our loan sales and purchases in the loans held-for-investment portfolio: Three Months Ended March 31, 2019 2018 (Dollars in millions) Loans Sold (1) Performing loans (2) $ 102 $ — Total loans sold $ 102 $ — Net gain associated with loan sales (3) $ 2 $ — Loans Purchased Home equity $ 49 $ — Other consumer 51 — Total loans purchased $ 100 $ — Premium associated with loans purchased $ 3 $ — (1) Upon a change in our intent, the loans were transferred to LHFS and subsequently sold. (2) During the three months ended December 31, 2018, we entered into an agreement to sell these loans, which we subsequently settled on during the three months ended March 31, 2019 . (3) Recorded in net gain on loan sales on Consolidated Statements of Operations. We have pledged certain LHFI, LHFS, and loans with government guarantees to collateralize lines of credit and/or borrowings with the FHLB of Indianapolis and the FRB of Chicago. At March 31, 2019 we had pledged loans of $6.5 billion , compared to $6.8 billion of pledged loans at December 31, 2018 . Allowance for Loan Losses We determine the estimate of the ALLL on at least a quarterly basis. Refer to Note 1- Description of Business, Basis of Presentation, and Summary of Significant Accounting Standards to the consolidated financial statements in the Annual Report on Form 10-K for the year ended December 31, 2018 for a description of the methodology. The ALLL, other than for loans that have been identified for individual evaluation for impairment, is determined on a loan pool basis by grouping loan types with common risk characteristics to determine our best estimate of incurred losses. The following table presents changes in ALLL, by class of loan: Residential First Mortgage (1) Home Equity Other Consumer Commercial Real Estate Commercial and Industrial Warehouse Lending Total (Dollars in millions) Three Months Ended March 31, 2019 Beginning balance ALLL $ 38 $ 15 $ 3 $ 48 $ 18 $ 6 $ 128 Charge-offs (1 ) — (1 ) — — — (2 ) Recoveries — 1 — — — — 1 Provision (benefit) (2 ) — 2 (12 ) 12 — — Ending balance ALLL $ 35 $ 16 $ 4 $ 36 $ 30 $ 6 $ 127 Three Months Ended March 31, 2018 Beginning balance ALLL $ 47 $ 22 $ 1 $ 45 $ 19 $ 6 $ 140 Charge-offs (1 ) (1 ) — — — — (2 ) Recoveries — 1 — — — — 1 Provision (benefit) 1 (1 ) — (1 ) 1 — — Ending balance ALLL $ 47 $ 21 $ 1 $ 44 $ 20 $ 6 $ 139 (1) Includes loans with government guarantees. The following table sets forth the method of evaluation, by class of loan: Residential First Mortgage (1) Home Equity Other Consumer Commercial Real Estate Commercial and Industrial Warehouse Lending Total (Dollars in millions) March 31, 2019 Loans held-for-investment (2) Individually evaluated $ 33 $ 23 $ 1 $ — $ — $ — $ 57 Collectively evaluated 3,059 771 432 2,324 1,651 1,632 9,869 Total loans $ 3,092 $ 794 $ 433 $ 2,324 $ 1,651 $ 1,632 $ 9,926 Allowance for loan losses (2) Individually evaluated $ 4 $ 7 $ — $ — $ — $ — $ 11 Collectively evaluated 31 9 4 36 30 6 116 Total allowance for loan losses $ 35 $ 16 $ 4 $ 36 $ 30 $ 6 $ 127 December 31, 2018 Loans held-for-investment (2) Individually evaluated $ 32 $ 23 $ — $ — $ — $ — $ 55 Collectively evaluated 2,959 706 314 2,152 1,433 1,459 9,023 Total loans $ 2,991 $ 729 $ 314 $ 2,152 $ 1,433 $ 1,459 $ 9,078 Allowance for loan losses (2) Individually evaluated $ 4 $ 7 $ — $ — $ — $ — $ 11 Collectively evaluated 34 8 3 48 18 6 117 Total allowance for loan losses $ 38 $ 15 $ 3 $ 48 $ 18 $ 6 $ 128 (1) Includes allowance related to loans with government guarantees. (2) Excludes loans carried under the fair value option. Loans are considered to be past due when any payment of principal or interest is 30 days past the scheduled payment date. While it is the goal of management to collect on loans, we attempt to work out a satisfactory repayment schedule or modification with past due borrowers and will undertake foreclosure proceedings if the delinquency is not satisfactorily resolved. Our practices regarding past due loans are designed to both assist borrowers in meeting their contractual obligations and minimize losses incurred by the Bank. We cease the accrual of interest on all classes of consumer and commercial loans upon the earlier of, becoming 90 days past due, or when doubt exists as to the ultimate collection of principal or interest (classified as nonaccrual or nonperforming loans). When a loan is placed on nonaccrual status, the accrued interest income is reversed and the loan may only return to accrual status when principal and interest become current and are anticipated to be fully collectible. The following table sets forth the LHFI aging analysis of past due and current loans: 30-59 Days Past Due 60-89 Days Past Due 90 Days or Greater Past Due (1) Total Past Due Current Total LHFI (Dollars in millions) March 31, 2019 Consumer loans Residential first mortgage $ 3 $ 1 $ 20 $ 24 $ 3,076 $ 3,100 Home equity 1 — 3 4 792 796 Other 2 1 1 4 429 433 Total consumer loans 6 2 24 32 4,297 4,329 Commercial loans Commercial real estate — — — — 2,324 2,324 Commercial and industrial — 1 — 1 1,650 1,651 Warehouse lending — — — — 1,632 1,632 Total commercial loans — 1 — 1 5,606 5,607 Total loans (2) $ 6 $ 3 $ 24 $ 33 $ 9,903 $ 9,936 December 31, 2018 Consumer loans Residential first mortgage $ 4 $ 2 $ 19 $ 25 $ 2,974 $ 2,999 Home Equity 1 — 3 4 727 731 Other — — — — 314 314 Total consumer loans 5 2 22 29 4,015 4,044 Commercial loans Commercial real estate — — — — 2,152 2,152 Commercial and industrial — — — — 1,433 1,433 Warehouse lending — — — — 1,459 1,459 Total commercial loans — — — — 5,044 5,044 Total loans (2) $ 5 $ 2 $ 22 $ 29 $ 9,059 $ 9,088 (1) Includes less than 90 day past due performing loans which are deemed nonaccrual. Interest is not being accrued on these loans. (2) Includes $3 million of loans accounted for under the fair value option at both March 31, 2019 and December 31, 2018 . Interest income is recognized on nonaccrual loans using a cash basis method. Interest that would have been accrued on impaired loans was less than $1 million at both the three months ended March 31, 2019 and the three months ended March 31, 2018 . At March 31, 2019 and December 31, 2018 , we had no loans 90 days past due and still accruing interest. Troubled Debt Restructurings We may modify certain loans in both our consumer and commercial loan portfolios to retain customers or to maximize collection of the outstanding loan balance. Troubled debt restructurings ("TDRs") are modified loans in which a borrower demonstrates financial difficulties and for which a concession has been granted as a result. Nonperforming TDRs are included in nonaccrual loans. TDRs remain in nonperforming status until a borrower has made payments and is current for at least six consecutive months. Performing TDRs are not considered to be nonaccrual so long as we believe that all contractual principal and interest due under the restructured terms will be collected. Performing and nonperforming TDRs remain impaired as interest and principal will not be received in accordance with the original contractual terms of the loan agreement. Refer to Note 1- Description of Business, Basis of Presentation, and Summary of Significant Accounting Standards to the consolidated financial statements in the Annual Report on Form 10-K for the year ended December 31, 2018 for a description of the methodology used to determine TDRs. Some loan modifications classified as TDRs may not ultimately result in the full collection of principal and interest, as modified, but may give rise to potential incremental losses. We measure impairments using a discounted cash flow method for performing TDRs and measure impairment based on collateral values for nonperforming TDRs. The following table provides a summary of TDRs by type and performing status: TDRs Performing Nonperforming Total (Dollars in millions) March 31, 2019 Consumer loans Residential first mortgage $ 22 $ 8 $ 30 Home equity 21 2 23 Total TDRs (1)(2) $ 43 $ 10 $ 53 December 31, 2018 Consumer loans Residential first mortgage $ 22 $ 8 $ 30 Home Equity 22 2 24 Total TDRs (1)(2) $ 44 $ 10 $ 54 (1) The ALLL on TDR loans totaled $10 million at both March 31, 2019 and December 31, 2018 . (2) Includes $3 million of TDR loans accounted for under the fair value option at both March 31, 2019 and December 31, 2018 . The following table provides a summary of newly modified TDRs: New TDRs Number of Accounts Pre-Modification Unpaid Principal Balance Post-Modification Unpaid Principal Balance (1) Increase in Allowance at Modification (Dollars in millions) Three Months Ended March 31, 2019 Residential first mortgages 2 $ — $ — $ — Home equity (2)(3) 2 — — — Total TDR loans 4 $ — $ — $ — Three Months Ended March 31, 2018 Residential first mortgages 6 $ 1 $ 1 $ — Home equity (2)(3) 5 1 1 — Commercial and industrial 1 5 5 1 Total TDR loans 12 $ 7 $ 7 $ 1 (1) Post-modification balances include past due amounts that are capitalized at modification date. (2) Home equity post-modification UPB reflects write downs. (3) Includes loans carried at the fair value option. There were no residential first mortgage loans modified in the previous 12 months that subsequently defaulted during the three months ended March 31, 2019 , compared to two residential first mortgage loans with UPB of $1 million modified in the previous 12 months that subsequently defaulted during the three months ended March 31, 2018. There was no change in the allowance associated with these TDRs at subsequent default. All TDR classes within the consumer and commercial portfolios are considered subsequently defaulted when greater than 90 days past due within 12 months of the restructuring date. Impaired Loans The following table presents individually evaluated impaired loans and the associated allowance: March 31, 2019 December 31, 2018 Recorded Investment Net Unpaid Principal Balance Related Allowance Recorded Investment Net Unpaid Principal Balance Related Allowance (Dollars in millions) With no related allowance recorded Consumer loans Residential first mortgage $ 16 $ 20 $ — $ 13 $ 16 $ — Home equity — 3 — 1 4 — Other consumer 1 1 — — — — Total loans with no related allowance recorded $ 17 $ 24 $ — $ 14 $ 20 $ — With an allowance recorded Consumer loans Residential first mortgage $ 18 $ 18 $ 4 $ 19 $ 20 $ 4 Home equity 22 23 7 22 23 7 Total loans with an allowance recorded $ 40 $ 41 $ 11 $ 41 $ 43 $ 11 Total Impaired loans Consumer Loans Residential first mortgage $ 34 $ 38 $ 4 $ 32 $ 36 $ 4 Home equity 22 26 7 23 27 7 Other consumer 1 1 — — — — Total impaired loans $ 57 $ 65 $ 11 $ 55 $ 63 $ 11 The following table presents average impaired loans and the interest income recognized: Three Months Ended March 31, 2019 2018 Average Recorded Investment Interest Income Recognized Average Recorded Investment Interest Income Recognized (Dollars in millions) Consumer loans Residential first mortgage $ 34 $ — $ 33 $ — Home equity 22 — 27 1 Other consumer 1 — — — Commercial loans Commercial and industrial — — 3 — Total impaired loans $ 57 $ — $ 63 $ 1 Credit Quality We utilize an internal risk rating system which is applied to all consumer and commercial loans. Descriptions of our internal risk ratings as they relate to credit quality follow the ratings used by the U.S. bank regulatory agencies as listed below. Pass. Pass assets are not impaired nor do they have any known deficiencies that could impact the quality of the asset. Watch. Watch assets are defined as pass rated assets that exhibit elevated risk characteristics or other factors that deserve management’s close attention and increased monitoring. However, the asset does not exhibit a potential or well-defined weakness that would warrant a downgrade to criticized or adverse classification. Special mention. Assets identified as special mention possess credit deficiencies or potential weaknesses deserving management's close attention. Special mention assets have a potential weakness or pose an unwarranted financial risk that, if not corrected, could weaken the assets and increase risk in the future. Special mention assets are criticized, but do not expose an institution to sufficient risk to warrant adverse classification. Substandard . Assets identified as substandard are inadequately protected by the current net worth and paying capacity of the obligor or of the collateral pledged, if any. Assets so classified must have a well-defined weakness or weaknesses that jeopardize the full collection or liquidation of the debt. They are characterized by the distinct possibility that we will sustain some loss if the deficiencies are not corrected. For home equity loans and other consumer loans, we evaluate credit quality based on the aging and status of payment activity and any other known credit characteristics that call into question full repayment of the asset. Substandard loans may be placed on either accrual or non-accrual status. Doubtful . An asset classified as doubtful has all the weaknesses inherent in one classified substandard, with the added characteristic that the weaknesses make collection or liquidation in full, on the basis of currently existing facts, conditions and values, highly questionable and improbable. A doubtful asset has a high probability of total or substantial loss, but because of specific pending events that may strengthen the asset, its classification as loss is deferred. Doubtful borrowers are usually in default, lack adequate liquidity or capital, and lack the resources necessary to remain an operating entity. Pending events can include mergers, acquisitions, liquidations, capital injections, the perfection of liens on additional collateral, the valuation of collateral, and refinancing. Generally, pending events should be resolved within a relatively short period and the ratings will be adjusted based on the new information. Due to the high probability of loss, doubtful assets are placed on non-accrual. Loss. An asset classified as loss is considered uncollectible and of such little value that the continuance as a bankable asset is not warranted. This classification does not mean that an asset has absolutely no recovery or salvage value, but, rather that it is not practical or desirable to defer writing off the asset even though partial recovery may be affected in the future. Consumer Loans Consumer loans consist of open and closed end loans extended to individuals for household, family, and other personal expenditures, and includes consumer loans, and loans to individuals secured by their personal residence, including first mortgage, home equity, and home improvement loans. Because consumer loans are usually relatively small-balance, homogeneous exposures, consumer loans are rated primarily on payment performance. Payment performance is a proxy for the strength of repayment capacity and loans are generally classified based on their payment status rather than by an individual review of each loan. In accordance with regulatory guidance, we assign risk ratings to consumer loans in the following manner: • Consumer loans are classified as Watch once the loan becomes 60 days past due. • Open and closed-end consumer loans 90 days or more past due are classified Substandard. Commercial Loans Management conducts periodic examinations which serve as an independent verification of the accuracy of the ratings assigned. Loan grades are based on different factors within the borrowing relationship: entity sales, debt service coverage, debt/total net worth, liquidity, balance sheet and income statement trends, management experience, business stability, financing structure, and financial reporting requirements. The underlying collateral is also rated based on the specific type of collateral and corresponding LTV. The combination of the borrower and collateral risk ratings results in the final rating for the borrowing relationship. March 31, 2019 Pass Watch Special Mention Substandard Total Loans (Dollars in millions) Consumer Loans Residential first mortgage $ 3,053 $ 25 $ — $ 22 $ 3,100 Home equity 771 22 — 3 796 Other consumer 431 1 — 1 433 Total consumer loans $ 4,255 $ 48 $ — $ 26 $ 4,329 Commercial Loans Commercial real estate $ 2,297 $ 20 $ 5 $ 2 $ 2,324 Commercial and industrial 1,568 19 32 32 1,651 Warehouse 1,385 232 15 — 1,632 Total commercial loans $ 5,250 $ 271 $ 52 $ 34 $ 5,607 December 31, 2018 Pass Watch Special Mention Substandard Total Loans (Dollars in millions) Consumer Loans Residential first mortgage $ 2,952 $ 28 $ — $ 19 $ 2,999 Home equity 705 23 — 3 731 Other consumer 314 — — — 314 Total consumer loans $ 3,971 $ 51 $ — $ 22 $ 4,044 Commercial Loans Commercial real estate $ 2,132 $ 14 $ 5 $ 1 $ 2,152 Commercial and industrial 1,351 53 29 — 1,433 Warehouse 1,324 120 15 — 1,459 Total commercial loans $ 4,807 $ 187 $ 49 $ 1 $ 5,044 |