Loans Held-for-Investment | 750 $ 87 $ 372 $ 172 $ 293 $ 278 $ 333 $ 61 $ 4 $ 1,600 700-750 45 234 128 112 83 165 31 4 802 <700 20 105 33 16 7 102 14 3 300 Home Equity >750 2 13 6 3 1 9 366 12 412 700-750 2 16 7 4 1 11 331 16 388 <700 2 13 6 2 1 9 132 11 176 Other Consumer >750 86 235 99 2 1 9 109 — 541 700-750 36 121 68 1 — 1 65 — 292 <700 4 12 18 1 1 1 28 — 65 Total Consumer Loans (1) $ 284 $ 1,121 $ 537 $ 434 $ 373 $ 640 $ 1,137 $ 50 $ 4,576 (1) Excludes loans carried under the fair value option Loan-to-value ratios primarily impact the allowance on mortgages within the consumer loan portfolio. The following table presents the amortized cost in residential first mortgages and home equity based on loan-to-value ratios: Revolving Loans Converted to Term Loans Amortized Cost Basis LTV Band Revolving Loans Amortized Cost Basis Total Amortized Cost Basis by Origination Year As of June 30, 2020 2020 2019 2018 2017 2016 Prior Consumer Loans (Dollars in millions) Residential first mortgage >90 $ 45 $ 303 $ 167 $ 45 $ 3 $ 23 $ — $ — $ 586 71-90 68 243 96 141 96 298 — — 942 55-70 27 95 33 119 139 167 — — 580 <55 12 70 37 116 130 112 106 11 594 Home Equity >90 — — — 1 2 14 1 — 18 71-90 4 32 14 6 1 11 648 25 741 <=70 2 10 5 2 — 4 180 14 217 Total (1) $ 158 $ 753 $ 352 $ 430 $ 371 $ 629 $ 935 $ 50 $ 3,678 (1) Excludes loans carried under the fair value option Commercial Loans Risk rating and average loan duration have the most significant impact on the ACL for commercial loans. Additional factors which impact the ACL are debt-service-coverage ratio, loan-to-value ratio, interest-coverage ratio and leverage ratio. Internal audit conducts periodic examinations which serve as an independent verification of the accuracy of the ratings assigned. All loans are examined on an at least annual basis. 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. Based on the most recent analysis performed, the amortized cost basis, by risk category for each class of loans within the commercial portfolio is as follows: Revolving Loans Converted to Term Loans Amortized Cost Basis Term Loans Revolving Loans Amortized Cost Basis Total December 31, 2019 Amortized Cost Basis by Origination Year As of June 30, 2020 2020 2019 2018 2017 2016 Prior Commercial Loans (Dollars in million) Commercial real estate Pass $ 184 $ 950 $ 477 $ 486 $ 353 $ 286 $ (1) $ — $ 2,735 $ 2,794 Watch 23 32 88 33 38 36 — — 250 24 Special mention — — 3 20 — — — — 23 5 Substandard — — 3 5 — — — — 8 5 Commercial and industrial Pass 119 580 248 317 113 110 22 — 1,509 1,533 Watch 1 2 10 — — — 1 — 14 72 Special mention 1 12 4 14 — 6 — — 37 24 Substandard 21 — 10 4 — — — — 35 5 Payroll protection program Pass 373 — — — — — — — 373 — Warehouse Pass — — — — — — 4,942 — 4,942 2,556 Watch — — — — — — 255 — 255 189 Special mention — — — — — — 35 — 35 15 Substandard — — — — — — — — — — Total commercial loans $ 722 $ 1,576 $ 843 $ 879 $ 504 $ 438 $ 5,254 $ — $ 10,216 $ 7,222 " id="sjs-B4" xml:space="preserve">Loans Held-for-Investment We classify loans that we have the intent and ability to hold for the foreseeable future or until maturity as LHFI. We report LHFI at their amortized cost, which includes the outstanding principal balance adjusted for any unamortized premiums, discounts, deferred fees and costs. The accrued interest receivable on loans held-for-investment totaled $38.8 million at June 30, 2020 and $36.9 million at December 31, 2019 and was reported in other assets on the Consolidated Statements of Financial Condition. The following table presents our loans held-for-investment: June 30, 2020 December 31, 2019 (Dollars in millions) Consumer loans Residential first mortgage $ 2,716 $ 3,154 Home equity 978 1,024 Other 898 729 Total consumer loans 4,592 4,907 Commercial loans Commercial real estate 3,016 2,828 Commercial and industrial 1,968 1,634 Warehouse lending 5,232 2,760 Total commercial loans 10,216 7,222 Total loans held-for-investment $ 14,808 $ 12,129 The following table presents the UPB of our loan sales and purchases in the loans held-for-investment portfolio: Six Months Ended June 30, 2020 2019 (Dollars in millions) Loans Sold (1) Performing loans $ 38 $ 139 Total loans sold $ 38 $ 139 Net gain associated with loan sales (2) $ — $ 2 Loans Purchased Home equity $ — $ 149 Other consumer 63 51 Total loans purchased $ 63 $ 200 Premium associated with loans purchased $ — $ 7 (1) Upon a change in our intent, the loans were transferred to LHFS and subsequently sold. (2) 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 June 30, 2020 we had pledged loans of $11.6 billion, compared to $9.1 billion at December 31, 2019. Allowance for Loan Losses We determine the estimate of the allowance for loan losses on at least a quarterly basis. The allowance for loan losses represents management's estimate of lifetime losses in our LHFI portfolio, excluding loans carried under the fair value option. We establish an allowance using relevant available information, from internal and external sources, relating to past events, current conditions, and reasonable and supportable forecasts. The allowance uses a loan-level, model-based approach, to estimate the expected lifetime credit losses. For non-performing loans, we've elected to use the collateral dependent practical expedient. The reserve for collateral dependent loans is established as the difference between fair value of the collateral less cost to sell and the amortized cost of the loan. Management applies judgment and assigns qualitative factors to each loan portfolio segment or the portfolio as a whole based upon the consideration of the following factors: levels of and trends in delinquencies and performance of loans, levels of and trends in write-offs and recoveries collected, changes in the nature and volume of the portfolio, changes in reasonable and supportable economic forecasts, changes in lending policies and procedures, changes in economic and business conditions, changes in lending management, changes in credit quality statistics, changes in the quality of the loan review system, changes in prepayment expectations or other factors affecting assessments of loan contractual term, changes in concentrations of credit, industry conditions and other internal or external factor changes. A specific allowance is established on impaired loans when it is probable all amounts due will not be collected pursuant to the original contractual terms of the loan and the recorded investment in the loan exceeds its fair value. The required allowance is measured using either the present value of the expected future cash flows discounted at the loan's effective interest rate or the fair value of the collateral less estimated costs to sell if the loan is collateral dependent. A general allowance is established for lifetime losses inherent on non-impaired loans by segmenting the portfolio based upon common risk characteristics. Our consumer loan portfolio is segmented into Residential First Mortgage, Home Equity and Other Consumer. Loan characteristics impacting these segments include lien position, credit quality, and loan structure. At a high-level our commercial loans are segmented into Commercial Real Estate, Commercial and Industrial, and Warehouse Lending. Loan characteristics impacting these segments include credit quality and loan structure. We measure the allowance using the applicable dual risk rating model which measures probability of default, loss given default and exposure at default. As of June 30, 2020, we estimated losses over a two-year reasonable and supportable forecast period using macroeconomic scenarios before reverting economic variables over a one-year period to their long-term historical averages on a straight-line basis. As of June 30, 2020, we utilized the Moody’s June scenarios in our forecast: a growth forecast, weighted at 30 percent; a baseline forecast, weighted at 40 percent; and an adverse forecast, weighted at 30 percent. The resulting composite forecast for the second quarter of 2020 was worse than the scenario used in the first quarter 2020. Unemployment ends the year at 10 percent and recovers only slightly in 2021. GDP recovers only slightly by the end of the year from current levels and does not return to the pre-COVID level until mid-2022. HPI decreases 2 percent from early 2020 through 2021. The worsening of our economic forecast increased the ACL by $31 million from March 31, 2020. In addition to this increase, we judgmentally increased the qualitative reserves by $39 million primarily in our CRE and C&I portfolios, guided by the model output from Moody's adverse scenario and our judgment relating to industries and borrowers we believe could be more exposed to the stressful conditions in our forecast. In addition, we reviewed our loans in deferral status and proactively downgraded loans totaling approximately $180 million UPB from "pass" status during the quarter, resulting in an increase of $24 million to the ACL. This resulted in an increase to our reserves of approximately $98 million during the second quarter, which includes an increase in our reserves for unfunded commitments of $1 million. The following table presents changes in the allowance for loan losses, by class of loan: Residential Home Equity Other Commercial Commercial Warehouse Total (Dollars in millions) Three Months Ended June 30, 2020 Beginning balance $ 46 $ 23 $ 16 $ 28 $ 18 $ 1 $ 132 Provision 16 5 19 55 5 — 100 Charge-offs (2) (1) (2) — — — (5) Recoveries — 1 1 — — — 2 Ending allowance balance $ 60 $ 28 $ 34 $ 83 $ 23 $ 1 $ 229 Three Months Ended June 30, 2019 Beginning balance $ 35 $ 16 $ 4 $ 36 $ 30 $ 6 $ 127 Provision (benefit) (8) — 3 (1) 24 (1) 17 Charge-offs (1) — (3) — (31) — (35) Recoveries — — 1 — — — 1 Ending allowance balance $ 26 $ 16 $ 5 $ 35 $ 23 $ 5 $ 110 Six Months Ended June 30, 2020 Beginning balance, prior to adoption of ASC 326 $ 22 $ 14 $ 6 $ 38 $ 22 $ 5 $ 107 Impact of adopting ASC 326 25 12 10 (14) (6) (4) 23 Provision 16 2 20 59 7 — 104 Charge-offs (3) (2) (3) — — — (8) Recoveries — 2 1 — — — 3 Ending allowance balance $ 60 $ 28 $ 34 $ 83 $ 23 $ 1 $ 229 Six Months Ended June 30, 2019 Beginning balance $ 38 $ 15 $ 3 $ 48 $ 18 $ 6 $ 128 Provision (benefit) (10) — 5 (13) 36 (1) 17 Charge-offs (2) — (4) — (31) — (37) Recoveries — 1 1 — — — 2 Ending allowance balance $ 26 $ 16 $ 5 $ 35 $ 23 $ 5 $ 110 (1) Includes loans with government guarantees. The allowance for loan losses was $229 million at June 30, 2020 and $110 million at June 30, 2019. The increase in the allowance is reflective of the adoption of CECL and changes in the economic forecast used in the ACL models as a result of the ongoing COVID-19 pandemic. 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. Beginning in March 2020, as a response to COVID-19, customers facing COVID-19 related difficulties were offered forbearance in an effort to help our borrowers get to the other side of the health crisis when we believe they will be able to fulfill all of their contractual commitments. 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. We do not measure an allowance for credit losses for accrued interest receivables as accrued interest is written off in a timely manner. We are not aging receivables for customers who have been granted a payment deferral in response to COVID-19 which remain in the aging category they were in at the time of payment deferral. We continue to accrue interest on these loans, consistent with our forbearance programs. The following table sets forth the LHFI aging analysis of past due and current loans: 30-59 Days 60-89 Days 90 Days or Total Current Total LHFI (3) (4) (Dollars in millions) June 30, 2020 Consumer loans Residential first mortgage $ 6 $ 5 $ 27 $ 38 $ 2,678 $ 2,716 Home equity 1 — 5 6 972 978 Other 2 1 1 4 894 898 Total consumer loans 9 6 33 48 4,544 4,592 Commercial loans Commercial real estate — — — — 3,016 3,016 Commercial and industrial (1) — — — — 1,968 1,968 Warehouse lending — — — — 5,232 5,232 Total commercial loans — — — — 10,216 10,216 Total loans (2) $ 9 $ 6 $ 33 $ 48 $ 14,760 $ 14,808 December 31, 2019 Consumer loans Residential first mortgage $ 5 $ 4 $ 21 $ 30 $ 3,124 $ 3,154 Home Equity 1 — 4 5 1,019 1,024 Other 3 1 1 5 724 729 Total consumer loans 9 5 26 40 4,867 4,907 Commercial loans Commercial real estate — — — — 2,828 2,828 Commercial and industrial — — — — 1,634 1,634 Warehouse lending — — — — 2,760 2,760 Total commercial loans — — — — 7,222 7,222 Total loans (2) $ 9 $ 5 $ 26 $ 40 $ 12,089 $ 12,129 (1) Includes less than 90 day past due performing loans which are deemed nonaccrual. Interest is not being accrued on these loans. (2) Includes $5 million and $4 million of past due loans accounted for under the fair value option as of June 30, 2020 and December 31, 2019, respectively. (3) Collateral dependent loans totaled $63 million at June 30, 2020 and $54 million at December 31, 2019, respectively. The majority of these loans are secured by real estate. (4) The interest income recognized on impaired loans was $1 million and less than $1 million at June 30, 2020 and December 31, 2019, respectively. Interest income is recognized on nonaccrual loans using a cash basis method. The interest income recognized on impaired loans was $1 million and less than $1 million at June 30, 2020 and December 31, 2019, respectively. At June 30, 2020 and December 31, 2019, we had no loans 90 days past due and still accruing interest. Reserve for Unfunded Commitments We estimated expected credit losses over the contractual period in which we are exposed to credit risk via a contractual obligation to extend credit, unless that obligation is unconditionally cancellable by us. The reserve for unfunded commitments is adjusted as a provision for credit loss expense. The estimate includes consideration of the likelihood that funding will occur and an estimate of expected credit losses on commitments expected to be funded over its estimated life. The reserve for unfunded commitments is reflected in other liabilities on the Consolidated Statements of Financial Condition and was $21 million as of June 30, 2020, compared to $3 million as of June 30, 2019. The increase in the reserve is reflective of the adoption of CECL which required us to record an allowance for our estimate of lifetime losses and an increase due to changes in the economic forecast used in the ACL models as a result of the ongoing COVID-19 pandemic. The following categories of off-balance sheet credit exposures have been identified: unfunded loans with available balances, new commitments to lend that are not yet funded, and standby and commercial letters of credit. For further information, see Note 15 - Legal Proceedings, Contingencies and Commitments. 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. 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, 2019 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. Beginning in March 2020, as a response to COVID-19, we offered our consumer and commercial customers principal and interest payment deferrals and extensions. We considered these programs in the context of whether or not the short-term modifications of these loans would constitute a TDR. We considered the CARES Act, interagency guidance and related guidance from the FASB, which provided that short-term modifications made on a good faith basis in response to COVID-19 to borrowers who were current prior to any relief are not required to be accounted for as TDRs. As a result, we have determined that these loans are not TDRs. The following table provides a summary of TDRs by type and performing status: TDRs Performing Nonperforming Total (Dollars in millions) June 30, 2020 Consumer loans Residential first mortgage $ 20 $ 8 $ 28 Home equity 15 2 17 Commercial Real Estate 5 — 5 Total TDRs (1)(2) $ 40 $ 10 $ 50 December 31, 2019 Consumer loans Residential first mortgage $ 20 $ 8 $ 28 Home Equity 18 2 20 Total TDRs (1)(2) $ 38 $ 10 $ 48 (1) Allowance for loan losses on TDR loans totaled $4 million and $8 million at June 30, 2020 and December 31, 2019, respectively. (2) Includes $2 million of TDR loans accounted for under the fair value option at June 30, 2020 and December 31, 2019. 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) (Dollars in millions) Three Months Ended June 30, 2020 Commercial Real Estate 1 $ 5 $ 5 Total TDR loans 1 $ 5 $ 5 Three Months Ended June 30, 2019 Home equity (2)(3) 2 — — Total TDR loans 2 $ — $ — Six Months Ended June 30, 2020 Residential first mortgages 5 $ 1 $ 1 Home equity (2)(3) 2 — — Consumer 1 — — Commercial Real Estate 1 $ 5 $ 5 Total TDR loans 9 6 6 Six Months Ended June 30, 2019 Residential first mortgages 2 $ — $ — Home equity (2)(3) 4 1 1 Total TDR loans 6 $ 1 $ 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 was one residential first mortgage loan modified in the previous 12 months that subsequently defaulted during the three and six months ended June 30, 2020. There were no residential first mortgage loans modified in the previous 12 months that subsequently defaulted during the three and six months ended June 30, 2019. The increase in allowance at modification was less than $1 million for the three months ended June 30, 2020 and June 30, 2019. All TDR classes within the consumer and commercial portfolios are considered subsequently defaulted when they are greater than 90 days past due within 12 months of the restructuring date. 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 based 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. Payment activity, credit rating and loan-to-value ratios have the most significant impact on the ACL for consumer loans. The following table presents the amortized cost in residential and consumer loans based on payment activity: Revolving Loans Converted to Term Loans Amortized Cost Basis Revolving Loans Amortized Cost Basis Total December 31, 2019 Term Loans Amortized Cost Basis by Origination Year As of June 30, 2020 2020 2019 2018 2017 2016 Prior Consumer Loans (Dollars in millions) Residential First Mortgage Pass $ 152 $ 709 $ 325 $ 418 $ 367 $ 568 $ 105 $ 11 $ 2,655 $ 3,107 Watch — 1 2 1 1 19 1 — 25 23 Substandard — 1 6 2 — 13 — — 22 15 Home Equity Pass 6 42 19 9 3 15 827 38 959 1,002 Watch — — — — — 13 1 — 14 16 Substandard — — — — — 1 1 1 3 3 Other Consumer Pass 126 368 183 4 2 11 202 — 896 727 Watch — — 1 — — — — — 1 1 Substandard — — 1 — — — — — 1 1 Total Consumer Loans (1) $ 284 $ 1,121 $ 537 $ 434 $ 373 $ 640 $ 1,137 $ 50 $ 4,576 $ 4,895 (1) Excludes loans carried under the fair value option The following table presents the amortized cost in residential and consumer loans based on credit scores: Revolving Loans Converted to Term Loans Amortized Cost Basis FICO Band Revolving Loans Amortized Cost Basis Total Amortized Cost Basis by Origination Year As of June 30, 2020 2020 2019 2018 2017 2016 Prior Consumer Loans (Dollars in millions) Residential First Mortgage >750 $ 87 $ 372 $ 172 $ 293 $ 278 $ 333 $ 61 $ 4 $ 1,600 700-750 45 234 128 112 83 165 31 4 802 <700 20 105 33 16 7 102 14 3 300 Home Equity >750 2 13 6 3 1 9 366 12 412 700-750 2 16 7 4 1 11 331 16 388 <700 2 13 6 2 1 9 132 11 176 Other Consumer >750 86 235 99 2 1 9 109 — 541 700-750 36 121 68 1 — 1 65 — 292 <700 4 12 18 1 1 1 28 — 65 Total Consumer Loans (1) $ 284 $ 1,121 $ 537 $ 434 $ 373 $ 640 $ 1,137 $ 50 $ 4,576 (1) Excludes loans carried under the fair value option Loan-to-value ratios primarily impact the allowance on mortgages within the consumer loan portfolio. The following table presents the amortized cost in residential first mortgages and home equity based on loan-to-value ratios: Revolving Loans Converted to Term Loans Amortized Cost Basis LTV Band Revolving Loans Amortized Cost Basis Total Amortized Cost Basis by Origination Year As of June 30, 2020 2020 2019 2018 2017 2016 Prior Consumer Loans (Dollars in millions) Residential first mortgage >90 $ 45 $ 303 $ 167 $ 45 $ 3 $ 23 $ — $ — $ 586 71-90 68 243 96 141 96 298 — — 942 55-70 27 95 33 119 139 167 — — 580 <55 12 70 37 116 130 112 106 11 594 Home Equity >90 — — — 1 2 14 1 — 18 71-90 4 32 14 6 1 11 648 25 741 <=70 2 10 5 2 — 4 180 14 217 Total (1) $ 158 $ 753 $ 352 $ 430 $ 371 $ 629 $ 935 $ 50 $ 3,678 (1) Excludes loans carried under the fair value option Commercial Loans Risk rating and average loan duration have the most significant impact on the ACL for commercial loans. Additional factors which impact the ACL are debt-service-coverage ratio, loan-to-value ratio, interest-coverage ratio and leverage ratio. Internal audit conducts periodic examinations which serve as an independent verification of the accuracy of the ratings assigned. All loans are examined on an at least annual basis. 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. Based on the most recent analysis performed, the amortized cost basis, by risk category for each class of loans within the commercial portfolio is as follows: Revolving Loans Converted to Term Loans Amortized Cost Basis Term Loans Revolving Loans Amortized Cost Basis Total December 31, 2019 Amortized Cost Basis by Origination Year As of June 30, 2020 2020 2019 2018 2017 2016 Prior Commercial Loans (Dollars in million) Commercial real estate Pass $ 184 $ 950 $ 477 $ 486 $ 353 $ 286 $ (1) $ — $ 2,735 $ 2,794 Watch 23 32 88 33 38 36 — — 250 24 Special mention — — 3 20 — — — — 23 5 Substandard — — 3 5 — — — — 8 5 Commercial and industrial Pass 119 580 248 317 113 110 22 — 1,509 1,533 Watch 1 2 10 — — — 1 — 14 72 Special mention 1 12 4 14 — 6 — — 37 24 Substandard 21 — 10 4 — — — — 35 5 Payroll protection program Pass 373 — — — — — — — 373 — Warehouse Pass — — — — — — 4,942 — 4,942 2,556 Watch — — — — — — 255 — 255 189 Special mention — — — — — — 35 — 35 15 Substandard — — — — — — — — — — Total commercial loans $ 722 $ 1,576 $ 843 $ 879 $ 504 $ 438 $ 5,254 $ — $ 10,216 $ 7,222 |