Loans Held-for-Investment | 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 LHFI totaled $38 million at September 30, 2021 and $43 million at December 31, 2020 and was reported in other assets on the Consolidated Statements of Financial Condition. The following table presents our LHFI: September 30, 2021 December 31, 2020 (Dollars in millions) Consumer loans Residential first mortgage $ 1,626 $ 2,266 Home equity 657 856 Other 1,203 1,004 Total consumer loans 3,486 4,126 Commercial loans Commercial real estate 3,216 3,061 Commercial and industrial 1,387 1,382 Warehouse lending 6,179 7,658 Total commercial loans 10,782 12,101 Total loans held-for-investment $ 14,268 $ 16,227 The following table presents the UPB of our loan sales and purchases in the LHFI portfolio: Nine Months Ended September 30, 2021 2020 (Dollars in millions) Loans Sold (1) Performing loans $ 92 $ 436 Total loans sold $ 92 $ 436 Net gain associated with loan sales (2) $ 3 Loans Purchased Home equity $ — $ — Other consumer — 63 Total loans purchased $ — $ 63 (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 LGG to collateralize lines of credit and/or borrowings with the FRB of Chicago and the FHLB of Indianapolis. At September 30, 2021 and December 31, 2020, we had pledged loans of $4.3 billion and $11.6 billion, respectively. Allowance for Credit Losses on Loans We determine the estimate of the ACL on at least a quarterly basis. The ACL represents Management's estimate of expected lifetime losses in our LHFI portfolio, excluding loans carried under the fair value option. In addition, we record a reserve for expected lifetime losses on our unfunded commitments - see Reserve for Unfunded Commitments section below. Therefore, we record ALLL on relevant financial assets and a reserve for unfunded commitments on our Consolidated Statements of Financial Condition, collectively referred to as the ACL. Expected credit losses are estimated over the contractual term of the loans, adjusted for expected prepayments when appropriate. The contractual terms exclude expected extensions, renewals, and modifications unless the following applies: Management has a reasonable expectation at the reporting date that a TDR will be executed with an individual borrower or the extension or renewal options are included in the original or modified contract at the reporting date and are not unconditionally cancellable by us. The ACL is impacted by changes in asset quality of the portfolio, including but not limited to increases in risk rating changes in our commercial portfolio, borrower delinquencies, changes in FICO scores or changes in LTVs in our consumer portfolio. In addition, while we have incorporated our forecasted impact of COVID-19 into our ACL, the ultimate impact of COVID-19 is still uncertain, including how long economic activity will be impacted by the pandemic and what effect the unprecedented levels of government fiscal and monetary actions will have on the economy and our credit losses. Specifically identified component . The specifically identified component of ACL related to performing TDR loans is generally measured as the difference between the recorded investment in the specific loan and the present value of the cash flows expected to be collected, discounted at the loan's original effective interest rate. Estimating the timing and amounts of future cash flow projections is highly judgmental and based upon assumptions including default rates, prepayment probability and loss severities. All of these estimates and assumptions require significant management judgment and certain assumptions are highly subjective. Specifically identified collateral dependent NPL loans are generally measured as the difference between the recorded investment in the impaired loan and the underlying collateral value less estimated costs to sell. These estimates are dependent on third-party property valuations which may be influenced by factors such as the current and future level of home prices, the duration of current overall economic conditions, and other macroeconomic and portfolio-specific factors. Model-based component . 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 September 30, 2021, we utilized the Moody’s September 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 third quarter of 2021 was improved as compared to the scenario used in the second quarter 2021. Unemployment ends 2021 at 5 percent and will continue to recover in 2022. GDP continues to recover in the last quarter of 2021 and returns to pre-COVID levels in 2023. HPI decreases slightly through 2022, at a lower rate as compared to the scenario used in the second quarter of 2021. Qualitative adjustments . The specifically identified component analysis and the output of the model provide a reasonable starting point for our analysis, but do not, by themselves, form a sufficient basis to determine the appropriate level for the ACL. We therefore consider the qualitative factors that are likely to cause the ACL associated with our existing portfolio to differ from the output of the model. The most significant qualitative factors considered include changes in economic and business conditions, changes in nature and volume of portfolio and changes in the volume and severity of past due loans. The application of different inputs into the model calculation and the assumptions used by Management to adjust the model calculation are subject to significant management judgment and may result in actual credit losses that differ from the originally estimated amounts. The following table presents changes in the ALLL, by class of loan: Residential Home Equity Other Commercial Commercial Warehouse Total (Dollars in millions) Three Months Ended September 30, 2021 Beginning balance $ 48 $ 17 $ 38 $ 58 $ 38 $ 3 $ 202 (Benefit) provision (5) (3) (5) (23) 11 — (25) Charge-offs (1) — (1) — (6) — (8) Recoveries 1 1 — — — — 2 Ending allowance balance $ 43 $ 15 $ 32 $ 35 $ 43 $ 3 $ 171 Three Months Ended September 30, 2020 Beginning balance $ 60 $ 28 $ 34 $ 83 $ 23 $ 1 $ 229 Provision (6) 1 4 6 19 4 28 Charge-offs (2) (1) (1) — — — (4) Recoveries — 1 1 — — — 2 Ending allowance balance $ 52 $ 29 $ 38 $ 89 $ 42 $ 5 $ 255 Nine Months Ended September 30, 2021 Beginning balance $ 49 $ 25 $ 39 $ 84 $ 51 $ 4 $ 252 (Benefit) provision (4) (10) (6) (49) (17) (1) $ (87) Charge-offs (4) (1) (3) — (7) — $ (15) Recoveries 2 1 2 — 16 — $ 21 Ending allowance balance $ 43 $ 15 $ 32 $ 35 $ 43 $ 3 $ 171 Nine Months Ended September 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 10 3 24 65 26 4 $ 132 Charge-offs (5) (3) (4) — — — $ (12) Recoveries — 3 2 — — — $ 5 Ending allowance balance $ 52 $ 29 $ 38 $ 89 $ 42 $ 5 $ 255 (1) Includes LGG. The ALLL was $171 million at September 30, 2021 and $252 million at December 31, 2020. The decrease in the allowance is primarily reflective of improvements in our economic forecasts and our evaluation of the performance and stable credit quality of the LHFI portfolio as borrowers continue to recover from the economic stress caused by the 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. As these loans reach the end of their forbearance period, we have been working with each customer to modify or refinance the outstanding loan to fit their new circumstances. Refer to payment deferral information in the Credit Risk Section of the MD&A for additional details. 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 NPLs). 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 consider accrued interest receivable in our measurement of the ACL as accrued interest is written-off in a timely manner when the loan is placed on nonaccrual. 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) (5) (Dollars in millions) September 30, 2021 Consumer loans Residential first mortgage $ 6 $ 1 $ 47 $ 54 $ 1,572 $ 1,626 Home equity 3 — 8 11 646 657 Other 3 1 3 7 1,196 1,203 Total consumer loans 12 2 58 72 3,414 3,486 Commercial loans Commercial real estate — — — — 3,216 3,216 Commercial and industrial — — 35 35 1,352 1,387 Warehouse lending — — — — 6,179 6,179 Total commercial loans — — 35 35 10,747 10,782 Total loans (2) $ 12 $ 2 $ 93 $ 107 $ 14,161 $ 14,268 December 31, 2020 Consumer loans Residential first mortgage $ 4 $ 4 $ 31 $ 39 $ 2,227 $ 2,266 Home equity 1 1 5 7 849 856 Other 4 1 2 7 997 1,004 Total consumer loans 9 6 38 53 4,073 4,126 Commercial loans Commercial real estate 20 — 3 23 3,038 3,061 Commercial and industrial 1 — 15 16 1,366 1,382 Warehouse lending — — — — 7,658 7,658 Total commercial loans 21 — 18 39 12,062 12,101 Total loans (2) $ 30 $ 6 $ 56 $ 92 $ 16,135 $ 16,227 (1) Includes less than 90 days past due performing loans which are deemed nonaccrual. Interest is not being accrued on these loans. (2) Includes $9 million and $8 million of past due loans accounted for under the fair value option as of September 30, 2021 and December 31, 2020, respectively. (3) Collateral dependent loans totaled $120 million and $80 million at September 30, 2021 and December 31, 2020, respectively. The majority of these loans are secured by real estate. (4) The interest income recognized on impaired loans was less than a million and $2 million for the three months ended September 30, 2021 and December 31, 2020, respectively. (5) The delinquency status for loans in forbearance is frozen for loans at inception of the forbearance period and will resume when the borrower's forbearance period ends. Interest income is recognized on nonaccrual loans using a cash basis method. The interest on nonaccrual loans that would have been accrued for the three months ended September 30, 2021 was $1 million. At September 30, 2021 and December 31, 2020, we had no loans 90 days or greater 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 $19 million as of September 30, 2021, compared to $28 million as of December 31, 2020. The decrease in the reserve is due to improvements in the economic forecasts as a result of the continued vaccine rollout and the lifting of most COVID-19 restrictions. 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, 2020 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 borrowers principal and interest payment deferrals, forbearance and/or extensions up to a maximum period of 18 months. 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 loan forbearance, modifications, deferrals and extensions made under these COVID-19 programs are not TDRs. The following table provides a summary of TDRs by type and performing status: TDRs Performing Nonperforming Total (Dollars in millions) September 30, 2021 Consumer loans Residential first mortgage $ 25 $ 9 $ 34 Home equity 9 3 12 Total consumer TDR loans 34 12 46 Commercial loans Commercial real estate — — — Commercial and industrial $ — $ 2 2 Total TDRs (1)(2) $ 34 $ 14 $ 48 December 31, 2020 Consumer loans Residential first mortgage $ 19 $ 8 $ 27 Home equity 12 2 14 Total consumer TDR loans 31 10 41 Commercial loans Commercial real estate 5 — 5 Total TDRs (1)(2) $ 36 $ 10 $ 46 (1) ALLL on TDR loans totaled $4 million and $5 million at September 30, 2021 and December 31, 2020. (2) Includes $1 million and $3 million of TDR loans accounted for under the fair value option at September 30, 2021 and December 31, 2020. 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 September 30, 2021 Residential first mortgages 21 $ 8 $ 8 Home equity(2)(3) 1 $ — $ — Commercial Real Estate — $ — $ — Total TDR loans 22 $ 8 $ 8 Three Months Ended September 30, 2020 Residential first mortgages 1 $ — $ — Home equity(2)(3) 1 — — Consumer 1 $ — $ — Total TDR loans 3 $ — $ — Nine Months Ended September 30, 2021 Residential first mortgages 32 $ 14 $ 14 Home equity(2)(3) 2 $ — $ — Consumer — $ — $ — Commercial Real Estate 1 $ 2 $ 2 Total TDR loans 35 $ 16 $ 16 Nine Months Ended September 30, 2020 Residential first mortgages 6 $ 1 $ 1 Home equity(2)(3) 3 $ — $ — Consumer 2 $ — $ — Commercial Real Estate 1 $ 5 $ 5 Total TDR loans 12 $ 6 $ 6 (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 loans modified in the previous 12 months that subsequently defaulted during the three months ended September 30, 2021. All TDR classes within the consumer and commercial loan 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 a combination of internal and external risk rating systems which are applied to all consumer and commercial loans which are used as loan-level inputs to our ACL models. Descriptions of our 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. Substandard assets are characterized by the distinct possibility that we will sustain some loss if the deficiencies are not corrected. For HELOANs 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 nonaccrual 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 nonaccrual. 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, 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. Consumer loans includes other consumer product 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 as Substandard. Payment activity, credit rating and LTVs 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 Amortized Cost Basis Revolving Loans Converted to Term Loans Amortized Cost Basis Total December 31, 2020 Term Loans Amortized Cost Basis by Closing Year As of September 30, 2021 2021 2020 2019 2018 2017 Prior Consumer Loans (Dollars in millions) Residential First Mortgage Pass $ 272 $ 218 $ 291 $ 123 $ 147 $ 419 $ 82 $ 15 $ 1,567 $ 2,205 Watch — — — — 1 2 — — 3 21 Substandard — 1 7 7 2 23 — 1 41 25 Home Equity Pass 3 5 18 7 4 15 544 52 648 838 Watch — — — — — — — — — 13 Substandard — — — — — 2 2 3 7 3 Other Consumer Pass 326 244 246 111 2 4 261 6 1,200 1,000 Watch — — 1 — — — — — 1 1 Substandard — 1 1 1 — — — — 3 3 Total Consumer Loans (1)(2) $ 601 $ 469 $ 564 $ 249 $ 156 $ 465 $ 889 $ 77 $ 3,470 $ 4,109 (1) Excludes loans carried under the fair value option. (2) The delinquency status for loans in forbearance are frozen for loans at inception of the forbearance period and will resume when the borrower's forbearance period ends. Revolving Loans Amortized Cost Basis Revolving Loans Converted to Term Loans Amortized Cost Basis Total December 31, 2019 Term Loans Amortized Cost Basis by Closing Year As of December 31, 2020 2020 2019 2018 2017 2016 Prior Consumer Loans (Dollars in millions) Residential First Mortgage Pass $ 362 $ 544 $ 231 $ 289 $ 252 $ 420 $ 92 $ 15 $ 2,205 $ 3,107 Watch — 1 1 1 — 17 1 — 21 23 Substandard — 3 5 2 — 15 — — 25 15 Home Equity Pass 7 31 13 6 2 11 720 48 838 1,002 Watch — — — — — 11 2 — 13 16 Substandard — — — — — 1 1 1 3 3 Other Consumer Pass 292 321 145 3 1 6 227 5 1,000 727 Watch — — — — — — — 1 1 1 Substandard 1 1 1 — — — — — 3 1 Total Consumer Loans (1)(2) $ 662 $ 901 $ 396 $ 301 $ 255 $ 481 $ 1,043 $ 70 $ 4,109 $ 4,895 (1) Excludes loans carried under the fair value option. (2) The delinquency status for loans in forbearance are frozen for loans at inception of the forbearance period and will resume when the borrower's forbearance period ends. 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 Closing Year As of September 30, 2021 2021 2020 2019 2018 2017 Prior Consumer Loans (Dollars in millions) Residential First Mortgage >750 $ 118 $ 109 $ 126 $ 54 $ 95 $ 238 $ 50 $ 7 $ 797 700-750 97 60 91 50 45 $ 132 22 6 503 <700 57 50 81 26 10 $ 74 10 3 311 Home Equity >750 1 2 5 2 2 $ 5 257 15 289 700-750 2 2 7 3 1 $ 6 218 22 261 <700 — 1 6 2 1 $ 6 71 18 105 Other Consumer >750 326 245 248 98 2 $ 4 250 4 1,177 700-750 — — — 12 — $ — 7 — 19 <700 — — — 2 — $ — 4 2 8 Total Consumer Loans (1) $ 601 $ 469 $ 564 $ 249 $ 156 $ 465 $ 889 $ 77 $ 3,470 (1) Excludes loans carried under the fair value option. Revolving Loans Converted to Term Loans Amortized Cost Basis FICO Band Revolving Loans Amortized Cost Basis Total Amortized Cost Basis by Closing Year As of December 31, 2020 2020 2019 2018 2017 2016 Prior Consumer Loans (Dollars in millions) Residential First Mortgage >750 $ 195 $ 272 $ 118 $ 193 $ 181 $ 231 $ 55 $ 6 $ 1,251 700-750 119 180 90 85 64 130 25 7 700 <700 48 96 29 14 7 91 13 2 300 Home Equity >750 2 9 6 2 1 7 324 13 364 700-750 3 12 4 3 1 8 289 20 340 <700 2 10 3 1 — 8 110 16 150 Other Consumer >750 209 205 80 2 1 5 213 6 721 700-750 79 107 55 1 — 1 9 — 252 <700 5 10 11 — — — 5 — 31 Total Consumer Loans (1) $ 662 $ 901 $ 396 $ 301 $ 255 $ 481 $ 1,043 $ 70 $ 4,109 (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 Closing Year As of September 30, 2021 2021 2020 2019 2018 2017 Prior Consumer Loans (Dollars in millions) Residential First Mortgage >90 $ 82 $ 76 $ 160 $ 67 $ 19 $ 19 $ — $ — $ 423 71-90 104 89 76 32 44 207 — — 552 55-70 56 32 33 14 48 135 — — 318 <55 30 22 29 17 39 83 82 16 318 Home Equity >90 — — — — 1 7 — — 8 71-90 2 3 14 5 2 7 395 37 465 <=70 1 2 4 2 1 3 151 18 182 Total (1) $ 275 $ 224 $ 316 $ 137 $ 154 $ 461 $ 628 $ 71 $ 2,266 (1) Excludes loans carried under the fair value option. Revolving Loans Converted to Term Loans Amortized Cost Basis LTV Band Revolving Loans Amortized Cost Basis Total Amortized Cost Basis by Closing Year As of December 31, 2020 2020 2019 2018 2017 2016 Prior Consumer Loans (Dollars in millions) Residential first mortgage >90 $ 84 $ 260 $ 123 $ 35 $ 3 $ 19 $ — $ — $ 524 71-90 169 180 66 99 72 238 — — 824 55-70 83 60 22 82 96 122 — — 465 <55 26 48 26 76 81 73 93 15 438 Home Equity >90 — — — 1 1 10 — — 12 71-90 5 24 10 4 1 9 548 33 634 <=70 2 7 3 1 — 4 175 16 208 Total (1) $ 369 $ 579 $ 250 $ 298 $ 254 $ 475 $ 816 $ 64 $ 3,105 (1) Excludes loans carried under the fair value option. Commercial Loans Risk rating and the 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 at least an 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 risk rating for the borrowing relationship. Based on the most recent credit 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 December 31, 2020 Term Loans Revolving Loans Amortized Cost Basis Total Amortized Cost Basis by Closing Year As of September 30, 2021 2021 2020 2019 2018 2017 Prior Commercial Loans (Dollars in million) Commercial real estate Pass $ 330 $ 294 $ 621 $ 335 $ 252 $ 372 $ 826 $ — $ 3,030 $ 2,805 Watch — 5 8 23 72 52 — — 160 166 Special mention — — 3 — — — 1 — 4 53 Substandard — — — — 22 — — — 22 37 Commercial and industrial Pass 122 87 176 77 96 14 682 — 1,254 1,200 Watch — 2 11 5 — — 43 — 61 106 Special mention — — — — — — — — — 24 Substandard — — 17 19 4 — 32 — 72 52 Warehouse Pass 6,039 — — — — — — — 6,039 7,398 Watch 140 — — — — — — — 140 260 Special mention — — — — — — — — — — Substandard — — — — — — — — — — Total commercial loans $ 6,631 $ 388 $ 836 $ 459 $ 446 $ 438 $ 1,584 $ — $ 10,782 $ 12,101 Revolving Loans Converted to Term Loans Amortized Cost Basis December 31, 2019 Term Loans Revolving Loans Amortized Cost Basis Total Amortized Cost Basis by Closing Year As of December 31, 2020 2020 2019 2018 2017 2016 Prior Commercial Loans (Dollars in million) Commercial real estate Pass $ 347 $ 993 $ 439 $ 438 $ 308 $ 280 $ — $ — $ 2,805 $ 2,794 Watch 21 19 35 51 21 19 — — 166 24 Special mention 5 1 16 — 17 14 — — 53 5 Substandard — 11 1 25 — — — — 37 5 Commercial and industrial Pass 319 425 163 149 54 71 19 — 1,200 1,533 Watch 3 48 28 25 — 2 — — 106 72 Special mention 1 — 14 9 — — — — 24 24 Substandard 22 11 15 4 — — — — 52 5 Warehouse Pass 7,398 — — — — — — — 7,398 2,556 Watch 260 — — — — — — — 260 189 Special mention — — — — — — — — — 15 Substandard — — — — — — — — — — Total commercial loans $ 8,376 $ 1,508 $ 711 $ 701 $ 400 $ 386 $ 19 $ — $ 12,101 $ 7,222 |