LOANS | NOTE 3 — LOANS The following tables and data as of June 30, 2020 include the loan balances acquired in the MOB Acquisition, which were recorded at fair value on the acquisition date. See Note 2 — Acquisition and Discontinued Operations Unless otherwise noted, loans held for sale are not included. Loans by Product (dollars in millions) June 30, 2020 December 31, 2019 Commercial loans $ 27,624.4 $ 22,765.1 Financing Leases and Leverage Leases 2,337.9 2,254.4 Total commercial 29,962.3 25,019.5 Consumer loans 7,556.0 5,979.4 Total loans $ 37,518.3 $ 30,998.9 The following table presents loans by segment, based on obligor location: Loans (dollars in millions) June 30, 2020 December 31, 2019 Domestic Foreign Total Domestic Foreign Total Commercial Banking $ 27,351.7 $ 1,621.2 $ 28,972.9 $ 22,866.0 $ 1,527.4 $ 24,393.4 Consumer Banking (1) 8,545.4 - 8,545.4 6,605.5 - 6,605.5 Total $ 35,897.1 $ 1,621.2 $ 37,518.3 $ 29,471.5 $ 1,527.4 $ 30,998.9 (1) The following table presents selected components of the net investment in loans: Components of Net Investment (dollars in millions) June 30, December 31, 2020 2019 Unearned income $ (425.3 ) $ (430.0 ) Unamortized (discounts) / premiums (530.9 ) 30.0 Accretable yield on PCI loans (1) — (745.4 ) Net unamortized deferred costs and (fees) 39.7 50.9 (1 ) Certain of the following tables present credit-related information at the “class” level. A class is generally a disaggregation of a portfolio segment. In determining the classes, CIT considered the loan characteristics and methods it applies in monitoring and assessing credit risk and performance. Credit Quality Indicators Management monitors credit quality of commercial loans and financing leases based upon risk rating classifications consistent with bank regulatory guidance and consumer loans based upon FICO scores and loan-to-value ratios (“LTV”). The definitions of the commercial loan ratings are as follows: • Pass — loans in this category do not meet the criteria for classification in one of the categories below. • Special mention —loans in this category exhibit potential weaknesses that deserve management's close attention. If left uncorrected, these potential weaknesses may, at some future date, result in the deterioration of a loan’s repayment prospects. • Classified — loans in this category range from: (1) loans that exhibit a well-defined weakness and are inadequately protected by the current sound worth and paying capacity of the borrower, and are characterized by the distinct possibility that some loss will be sustained if the deficiencies are not corrected to (2) loans with weaknesses that make collection or liquidation in full unlikely on the basis of current facts, conditions, and values. Classified loans can accrue interest or be placed on non-accrual depending on the Company’s evaluation of these factors. Criticized loans include loans with a rating of special mention or classified. For consumer loans, we monitor credit quality utilizing the borrower FICO scores to evaluate borrower’s credit payment history and current LTV of the underlying collateral to assess potential loss severity in the event of default. A loan to a borrower with a low FICO score (less than 660) is considered to be of higher risk than a loan to a borrower with a higher FICO score. The Company examines LTV migration and stratifies LTV into categories to monitor the risk in the loan classes. The Company periodically updates the property values of real estate collateral (for home equity and residential mortgages) to calculate current LTV ratios, adjusted based on home price indices compiled by the Case-Shiller Home Price Indices, or more often if events require (e.g., a loan secured by the collateral is placed on non-accrual). Further, a loan to a borrower with a high LTV ratio and a low FICO score is at greater risk of default than a loan to a borrower that has both a high LTV ratio and a high FICO score. The following table summarizes commercial loans disaggregated by year of origination and by risk rating. The consumer loan LTV ratios and FICO scores by year of origination are also presented below. Following the Company’s adoption of CECL, prior period risk rating disclosures were not conformed to current disclosure requirements and will continue to be reported under previously applicable accounting guidance. The tables reflect the amortized cost basis of the loans. Accrued interest is reported separately from the loan’s amortized cost basis as accrued interest receivable (within other assets). Commercial Loans — Risk Rating by Class (dollars in millions) Term Loans by Origination Year Revolving Loans Converted Grade June 30, 2020 2020 2019 2018 2017 2016 2015 & Prior Revolving Loans to Term Loans Total (1) Commercial Finance Pass $ 2,397.8 $ 2,449.9 $ 2,470.7 $ 844.6 $ 365.4 $ 897.5 $ 4,425.3 $ 67.6 $ 13,918.8 Special Mention 110.7 75.0 76.2 32.4 8.7 73.9 453.9 — 830.8 Classified-accrual 57.3 114.0 53.7 174.7 64.8 186.5 471.1 3.0 1,125.1 Classified-non-accrual — 87.9 35.8 10.9 27.8 78.2 79.0 — 319.6 Total Commercial Finance 2,565.8 2,726.8 2,636.4 1,062.6 466.7 1,236.1 5,429.3 70.6 16,194.3 Real Estate Finance Pass 664.1 1,714.2 1,005.9 558.3 388.7 523.7 1,347.1 — 6,202.0 Special Mention 29.8 264.4 228.5 167.7 62.5 60.2 247.9 — 1,061.0 Classified-accrual — 69.1 38.8 43.3 32.8 55.9 158.2 — 398.1 Classified-non-accrual — 30.4 0.2 — — 8.1 13.6 — 52.3 Total Real Estate Finance 693.9 2,078.1 1,273.4 769.3 484.0 647.9 1,766.8 — 7,713.4 Business Capital Pass 964.8 1,608.4 1,026.5 443.9 179.3 45.9 20.5 0.6 4,289.9 Special Mention 33.8 95.3 73.2 36.8 21.9 2.3 — — 263.3 Classified-accrual 30.4 156.8 114.1 47.2 20.4 4.8 — — 373.7 Classified-non-accrual 2.8 24.4 23.5 16.5 8.3 3.2 0.1 — 78.8 Total Business Capital 1,031.8 1,884.9 1,237.3 544.4 229.9 56.2 20.6 0.6 5,005.7 Rail Pass — 1.0 — — 3.1 55.4 — — 59.5 Total Rail — 1.0 — — 3.1 55.4 — — 59.5 Total Commercial Banking Pass 4,026.7 5,773.5 4,503.1 1,846.8 936.5 1,522.5 5,792.9 68.2 24,470.2 Special Mention 174.3 434.7 377.9 236.9 93.1 136.4 701.8 — 2,155.1 Classified-accrual 87.7 339.9 206.6 265.2 118.0 247.2 629.3 3.0 1,896.9 Classified-non-accrual 2.8 142.7 59.5 27.4 36.1 89.5 92.7 — 450.7 Total Commercial Banking 4,291.5 6,690.8 5,147.1 2,376.3 1,183.7 1,995.6 7,216.7 71.2 28,972.9 Consumer and Community Banking (2) Pass 347.4 198.8 114.6 82.5 55.4 83.5 11.1 — 893.3 Special Mention 0.8 9.6 2.0 0.5 — 2.0 — — 14.9 Classified-accrual 24.8 1.4 9.2 13.7 13.0 17.5 0.3 — 79.9 Classified-non-accrual — — 0.6 — — 0.7 — — 1.3 Total Consumer Banking 373.0 209.8 126.4 96.7 68.4 103.7 11.4 — 989.4 Commercial Loans Pass 4,374.1 5,972.3 4,617.7 1,929.3 991.9 1,606.0 5,804.0 68.2 25,363.5 Special Mention 175.1 444.3 379.9 237.4 93.1 138.4 701.8 — 2,170.0 Classified-accrual 112.5 341.3 215.8 278.9 131.0 264.7 629.6 3.0 1,976.8 Classified-non-accrual 2.8 142.7 60.1 27.4 36.1 90.2 92.7 — 452.0 Total Commercial Loans $ 4,664.5 $ 6,900.6 $ 5,273.5 $ 2,473.0 $ 1,252.1 $ 2,099.3 $ 7,228.1 $ 71.2 $ 29,962.3 (1) (2) Commercial Loan s — Risk Rating by Clas s (dollars in millions) Grade: Pass Special Mention Classified- accrual Classified- non-accrual PCI Loans (1) Total December 31, 2019 Commercial Banking Commercial Finance $ 12,601.1 $ 450.7 $ 614.3 $ 246.7 $ — $ 13,912.8 Real Estate Finance 5,007.0 341.0 6.3 0.4 27.8 5,382.5 Business Capital 4,527.5 233.1 217.0 60.9 — 5,038.5 Rail 59.6 — — — — 59.6 Total Commercial Banking 22,195.2 1,024.8 837.6 308.0 27.8 24,393.4 Consumer Banking Consumer and Community Banking - Primarily SBA Loans 589.6 2.4 33.9 0.2 — 626.1 Total Consumer Banking 589.6 2.4 33.9 0.2 — 626.1 Total $ 22,784.8 $ 1,027.2 $ 871.5 $ 308.2 $ 27.8 $ 25,019.5 (1) PCI Loans had $20.7 million of non-criticized loans and $7.1 million of criticized loans (special mention or classified). The following table provides a summary of the consumer loan LTV distribution for primarily single-family residential (“SFR”) mortgage loans. The average LTV was 60% and 63% for the total consumer loans included below at June 30, 2020 and December 31, 2019, respectively. For loans granted payment deferral due to COVID-19, the average LTV was 64% at June 30, 2020. Following the Company’s adoption of CECL, the comparative prior period financial information was not adjusted for the Consumer Loan LTV Distribution and will continue to be reported under previously applicable accounting guidance. Consumer Loans LTV Distribution (dollars in millions) Term Loans Amortized Cost Basis by Origination Year Revolving Loans Converted LTV Range 2020 2019 2018 2017 2016 2015 & Prior Revolving Loans to Term Loans Total (4) June 30, 2020 Legacy Consumer Mortgages Greater than 125% $ — $ — $ — $ — $ — $ 53.6 $ — $ 0.5 $ 54.1 101% – 125% — — — — — 85.2 — 1.8 87.0 80% – 100% — — — — — 275.5 — 5.9 281.4 Less than 80% — — — — — 1,533.2 — 40.9 1,574.1 Government-guaranteed (1) — — — — — 23.7 — — 23.7 No LTV available (2) — — — — — 0.1 — 2.2 2.3 Total Legacy Consumer Mortgages — — — — — 1,971.3 — 51.3 2,022.6 Consumer and Community Banking Greater than 125% — — — — — — 0.1 — 0.1 101% – 125% — — — — — — — — — 80% – 100% 27.6 60.9 18.6 1.8 0.3 1.7 4.2 — 115.1 Less than 80% 748.6 1,470.9 710.3 732.4 465.2 1,038.7 50.9 — 5,217.0 Government-guaranteed (1) 5.3 43.2 21.7 87.4 10.6 8.4 — — 176.6 No LTV available (2) 0.1 0.1 0.3 0.4 0.2 1.0 1.8 — 3.9 No LTV required (3) 0.1 1.1 0.7 0.4 0.7 14.4 3.3 — 20.7 Total Consumer and Community Banking 781.7 1,576.2 751.6 822.4 477.0 1,064.2 60.3 — 5,533.4 Total Consumer Loans (4) $ 781.7 $ 1,576.2 $ 751.6 $ 822.4 $ 477.0 $ 3,035.5 $ 60.3 $ 51.3 $ 7,556.0 (1) (2) (3) (4) Consumer Loans LTV Distribution (dollars in millions) Covered Loans (2) Non-covered Loans Total Consumer LTV Range Non-PCI PCI Non-PCI PCI Loans December 31, 2019 Greater than 125% $ — $ 2.8 $ 5.2 $ 53.2 $ 61.2 101% – 125% — 8.5 6.6 93.0 108.1 80% – 100% 0.3 48.1 183.4 239.3 471.1 Less than 80% 307.5 234.3 4,225.5 570.6 5,337.9 Not Applicable (1) — — 1.1 — 1.1 Total $ 307.8 $ 293.7 $ 4,421.8 $ 956.1 $ 5,979.4 (1) (2) The SFR amounts represent the carrying value, which differ from unpaid principal balances, and include the unamortized premiums or discounts. Prior to March 31, 2020, certain consumer SFR loans were “covered loans” for which the Company was eligible for reimbursement for a portion of certain future losses with indemnifications provided by the FDIC under LSAs. At December 31, 2019, the covered loans related to the FDIC-assisted transactions of First Federal Bank of California in December 2009 (“First Federal Transaction”) and La Jolla Bank, FSB in February 2010 (“La Jolla Transaction”) for which the indemnification period ended in December 2019 and February 2020, respectively. As of June 30, 2020, all of the LSAs have expired and there are no covered loans. The average FICO score was 753 and 751 for the total consumer loans included below at June 30, 2020 and December 31, 2019, respectively. For loans granted forbearance arrangements due to COVID-19, the average FICO score of the borrowers (prior to entering the forbearance period) was 703 at June 30, 2020. The borrower’s FICO score is not impacted during the payment deferral period as a result of a loan modification made in response to the COVID-19 pandemic. The following table provides a summary of the FICO score distribution for consumer loans by origination year and revolving loans . Current FICO Score Distribution (dollars in millions) Term Loans Amortized Cost Basis by Origination Year Revolving Loans Converted Current FICO 2020 2019 2018 2017 2016 2015 & Prior Revolving Loans to Term Loans Total (4) June 30, 2020 Legacy Consumer Mortgages Greater than or equal to 730 $ — $ — $ — $ — $ — $ 775.3 $ — $ 22.2 $ 797.5 Greater than or equal to 660 and less than 730 — — — — — 608.8 — 16.4 625.2 Less than 660 — — — — — 519.7 — 12.0 531.7 Government-guaranteed (1) — — — — — 23.7 — — 23.7 No FICO score available (2) — — — — — 43.8 — 0.7 44.5 Total Legacy Consumer Mortgages — — — — — 1,971.3 — 51.3 2,022.6 Consumer and Community Banking Greater than or equal to 730 669.3 1,334.2 630.1 671.3 404.2 824.3 41.6 — 4,575.0 Greater than or equal to 660 and less than 730 101.1 185.1 87.9 55.9 52.6 137.8 13.7 — 634.1 Less than 660 4.4 13.0 10.5 5.5 7.9 59.4 4.0 — 104.7 Government-guaranteed (1) 5.3 43.2 21.7 87.4 10.6 8.3 — — 176.5 No FICO score available (2) 1.5 — 0.7 1.9 1.0 20.2 0.2 — 25.5 FICO score not required (3) 0.1 0.7 0.7 0.4 0.7 14.2 0.8 — 17.6 Total Consumer and Community Banking 781.7 1,576.2 751.6 822.4 477.0 1,064.2 60.3 — 5,533.4 Total Consumer Loans (4) $ 781.7 $ 1,576.2 $ 751.6 $ 822.4 $ 477.0 $ 3,035.5 $ 60.3 $ 51.3 $ 7,556.0 (1) (2) (3) (4) Current FICO Score Distribution (dollars in millions) Covered Loans (3) Non-covered Loans Total Consumer FICO Range Non-PCI PCI Non-PCI PCI Loans December 31, 2019 Legacy Consumer Mortgages Greater than or equal to 730 $ 202.2 $ 98.6 $ 320.0 $ 252.5 $ 873.3 Greater than or equal to 660 and less than 730 71.3 98.8 123.2 324.7 618.0 Less than 660 16.8 89.8 51.0 370.5 528.1 Government-guaranteed (1) — — 24.5 — 24.5 No FICO score available (2) 17.5 6.5 5.2 8.4 37.6 Total Legacy Consumer Mortgages 307.8 293.7 523.9 956.1 2,081.5 Consumer and Community Banking Greater than or equal to 730 — — 3,319.0 — 3,319.0 Greater than or equal to 660 and less than 730 — — 332.6 — 332.6 Less than 660 — — 29.6 — 29.6 Government-guaranteed (1) — — 193.8 — 193.8 No FICO score available — — 21.8 — 21.8 FICO score not required (2) — — 1.1 — 1.1 Total Consumer and Community Banking — — 3,897.9 — 3,897.9 Total Consumer Banking $ 307.8 $ 293.7 $ 4,421.8 $ 956.1 $ 5,979.4 (1) (2) (3) As of June 30, 2020 and December 31, 2019, there was no remaining amount of negative amortization contractually permitted on consumer loans with terms that permitted negative amortization. Past Due and Non-accrual Loans— For additional information on reporting of past due and non-accrual loans, see discussion of the CARES Act and Interagency Statement in Note 1 – Business and Summary of Significant Accounting Policies The table that follows presents portfolio delinquency status, regardless of accrual/non-accrual classification: Loans - Delinquency Status (dollars in millions) Past Due 30-59 60-89 90 or more Total Past Due Current (1) PCI Loans Total (2) June 30, 2020 Commercial Banking Commercial Finance $ 96.6 $ 79.2 $ 140.9 $ 316.7 $ 15,877.6 $ — $ 16,194.3 Real Estate Finance 51.9 78.0 32.5 162.4 7,551.0 — 7,713.4 Business Capital 91.4 102.9 46.2 240.5 4,765.2 — 5,005.7 Rail — — — — 59.5 — 59.5 Total Commercial Banking 239.9 260.1 219.6 719.6 28,253.3 — 28,972.9 Consumer Banking Legacy Consumer Mortgages 98.5 32.4 75.3 206.2 1,816.4 — 2,022.6 Consumer and Community Banking 47.0 7.9 13.3 68.2 6,454.6 — 6,522.8 Total Consumer Banking 145.5 40.3 88.6 274.4 8,271.0 — 8,545.4 Total $ 385.4 $ 300.4 $ 308.2 $ 994.0 $ 36,524.3 $ — $ 37,518.3 December 31, 2019 Commercial Banking Commercial Finance $ 58.7 $ 27.8 $ 49.0 $ 135.5 $ 13,777.3 $ — $ 13,912.8 Real Estate Finance 0.6 46.6 — 47.2 5,307.5 27.8 5,382.5 Business Capital 113.8 35.0 22.0 170.8 4,867.7 — 5,038.5 Rail — — — — 59.6 — 59.6 Total Commercial Banking 173.1 109.4 71.0 353.5 24,012.1 27.8 24,393.4 Consumer Banking Legacy Consumer Mortgages 15.5 3.3 17.7 36.5 795.2 1,249.8 2,081.5 Consumer and Community Banking 16.4 3.3 7.6 27.3 4,496.7 — 4,524.0 Total Consumer Banking 31.9 6.6 25.3 63.8 5,291.9 1,249.8 6,605.5 Total $ 205.0 $ 116.0 $ 96.3 $ 417.3 $ 29,304.0 $ 1,277.6 $ 30,998.9 (1) (2) The following table sets forth non-accrual loans, assets received in satisfaction of loans (OREO and repossessed assets) and loans 90 days or more past due and still accruing. Loans on Non-Accrual Status (dollars in millions) ( 1 )( 2 ) December 31, 2019 CECL Adoption ( 3 ) MOB Acquisition January 1, 2020 June 30, 2020 With No Allowance Recorded ( 4 ) Commercial Banking Commercial Finance ( 5 ) $ 246.7 $ — $ 61.1 $ 307.8 $ 319.6 $ 66.8 Business Capital 60.9 — — 60.9 78.8 2.0 Real Estate Finance 0.4 0.6 — 1.0 52.3 13.6 Total Commercial Banking 308.0 0.6 61.1 369.7 450.7 82.4 Consumer Banking Consumer and Community Banking 4.0 — 7.2 11.2 9.7 2.1 Legacy Consumer Mortgages ( 6 ) 14.3 81.6 — 95.9 96.0 9.4 Total Consumer Banking 18.3 81.6 7.2 107.1 105.7 11.5 Total $ 326.3 $ 82.2 $ 68.3 $ 476.8 $ 556.4 $ 93.9 Repossessed assets and OREO (7) 20.1 15.3 Total non-performing assets $ 346.4 $ 571.7 Commercial loans past due 90 days or more accruing $ 25.6 $ 74.2 Consumer loans past due 90 days or more accruing 11.3 10.5 Total accruing loans past due 90 days or more $ 36.9 $ 84.7 (1) (2) (3) is before the MOB Acquisition, detail of which is separately disclosed. (4) (5) (6) (7) Payments received on non-accrual loans are generally applied first against outstanding principal, though in certain instances where the remaining recorded investment is deemed fully collectible, interest income is recognized on a cash basis. Loans are in the process of foreclosure when repayment is expected to be provided substantially through the sale of the underlying real estate and the borrower is experiencing financial difficulty. The table below summarizes the residential mortgage loans in the process of foreclosure. Consistent with the government agency guidance, CIT has suspended residential property foreclosures and evictions until at least August 31, 2020 to single family homeowners due to the COVID-19 pandemic. Loans in Process of Foreclosure (dollars in millions) June 30, December 31, 2020 2019 Loans in process of foreclosure (1) $ 28.3 $ 38.9 (1) Impaired Loans The following table contains prior period information about impaired loans and the related allowance for loan losses by class, pre-adoption of CECL. CECL did not carry forward the concept of impaired loans, therefore only the prior period is presented. PCI loans, which were excluded from impaired loan balances, included loans that were identified as impaired at the date of the OneWest Transaction (the “Acquisition Date”) for which the Company is applying the income recognition and disclosure guidance in ASC 310-30 ( Loans and Debt Securities Acquired with Deteriorated Credit Quality Loans Acquired with Deteriorated Credit Quality Impaired Loans (dollars in millions) Average Recorded Investment December 31, 2019 Recorded Investment Unpaid Principal Balance Related Allowance Year Ended December 31, 2019 With no related allowance recorded: Commercial Banking Commercial Finance $ 46.5 $ 69.0 $ — $ 68.0 Business Capital 4.8 5.5 — 6.0 Real Estate Finance — — — 1.6 Consumer Banking Consumer and Community Banking 4.0 4.0 — 4.9 Legacy Consumer Mortgages 20.6 22.4 — 24.7 With an allowance recorded: Commercial Banking Commercial Finance 223.9 267.3 86.0 166.6 Business Capital 19.4 19.4 10.0 11.6 Real Estate Finance — — — 0.8 Consumer Banking Consumer and Community Banking 0.1 0.2 — — Legacy Consumer Mortgages 1.4 1.4 0.2 0.4 Total Impaired Loans (1) 320.7 389.2 96.2 284.6 Total Loans Impaired at Acquisition Date 1,277.6 1,936.1 17.4 1,504.4 Total $ 1,598.3 $ 2,325.3 $ 113.6 $ 1,789.0 (1) Loans Acquired with Deteriorated Credit Quality Effective with the adoption of CECL, PCD loans are recorded at an initial amortized cost comprised of the sum of 1) the purchase price and 2) the estimate of credit losses which is recorded in the ACL. Subsequent to the initial recognition, PCD loans are accounted for under the same methodology as non-PCD loans. The following table provides a reconciliation of the purchase price and the unpaid principal balance / contractual cash flows owed to CIT as of the acquisition date for loans acquired during the respective period. For the period ended June 30, 2020, the PCD loans acquired related to the MOB Acquisition. PCD Loans acquired during the period ended June 30, 2020 (dollars in millions) Commercial Banking Consumer Banking Total Par Value (UPB) $ 347.8 $ 58.4 $ 406.2 Allowance for Credit Losses (1) (56.1 ) (2.7 ) (58.8 ) (Discount) Premium (9.0 ) 2.4 (6.6 ) Purchase Price $ 282.7 $ 58.1 $ 340.8 (1) Pre-adoption of CECL, the Company applied the income recognition and disclosure guidance in ASC 310-30 to loans that were identified as PCI as of the Acquisition Date. PCI loans were initially recorded at estimated fair value with no allowance for loan losses carried over, since the initial fair values reflected credit losses expected to be incurred over the remaining lives of the loans. The acquired loans are subject to the Company’s internal credit review. See Note 4 — Allowance for Credit Losses. PCI Loans (dollars in millions) December 31, 2019 Carrying Value Unpaid Principal Balance Allowance for Loan Losses Commercial Banking Real Estate Finance $ 27.8 $ 30.4 $ 9.8 Consumer Banking Legacy Consumer Mortgages 1,249.8 1,905.7 7.6 Total $ 1,277.6 $ 1,936.1 $ 17.4 Accretable Yield See the Company’s 2019 Form 10-K, Note 1 — Business and Summary of Significant Accounting Policies Change in Accretable Yield (dollars in millions) Quarter Ended June 30, Six Months Ended June 30, 2019 2019 Balance, beginning of period $ 863.6 $ 903.8 Accretion into interest income (39.6 ) (80.3 ) Reclassification from non-accretable difference 4.3 6.7 Disposals and Other (1.3 ) (3.2 ) Balance, end of period $ 827.0 $ 827.0 Troubled Debt Restructuring The Company periodically modifies the terms of loans in response to borrowers’ difficulties. Modifications that include a financial concession to the borrower are accounted for as TDRs. A restructuring of a debt constitutes a TDR for purposes of ASC 310-40 when CIT, for economic or legal reasons related to the debtor’s financial difficulties, grants a concession to the debtor that it would not otherwise consider. A concession may be either by agreement between CIT and the debtor or imposed by law or a court of law. See the Company's 2019 Form 10-K for discussion of policies on TDRs. The Interagency Statement and CARES Act offer some practical expedients for evaluating whether loan modifications that occur in response to the COVID-19 pandemic are TDRs. The CARES Act provides that financial institutions are not expected to designate a loan with payment accommodations granted due to COVID-19 as past due or non-accrual if the accommodation meets certain requirements and the loan was current on the date used to determine the borrower’s delinquency status for the purpose of providing the deferment. The Interagency Statement indicates that a lender can conclude that a borrower is not experiencing financial difficulty in accordance with regulatory guidance, if either (1) short-term (e.g., six months or less) modifications are made in response to the COVID-19 pandemic, such as payment deferrals, fee waivers, extensions of repayment terms, or other delays in payment that are insignificant related to loans in which the borrower is less than 30 days past due on its contractual payments at the time a modification program is implemented under the Interagency Statement, or 30 days past-due or less as of December 31, 2019 under the CARES Act, if elected, or (2) the modification or deferral program is related to COVID-19 and mandated by the federal government or a state government (e.g., a state program that requires all institutions within that state to suspend mortgage payments for a specified period). Accordingly, any loan modification that meets either of these practical expedients would not automatically be considered a TDR because the borrower is presumed not to be experiencing financial difficulty at the time of the loan modification. Modified loans that meet the definition of a TDR are subject to the Company's individually reviewed loans policy. The following table presents recorded investment of TDRs, excluding those within a trial modification period of $1.9 million at June 30, 2020 and $5.5 million at December 31, 2019, and those previously classified as PCI at December 31, 2019: TDRs (dollars in millions) June 30, 2020 December 31, 2019 Recorded Investment % Total TDR Recorded Investment % Total TDR Commercial Banking $ 106.2 83 % $ 129.5 87 % Consumer Banking 22.3 17 % 19.3 13 % Total $ 128.5 100 % $ 148.8 100 % Percent non-accrual 68 % 71 % Modifications that are TDRs (dollars in millions) Quarters Ended June 30, Six Months Ended June 30, 2020 2019 2020 2019 Recorded investment related to modifications qualifying as TDRs that occurred during the quarters and the six months ended $ 15.4 $ 76.9 $ 55.4 $ 79.4 Recorded investment at the time of default of TDRs that experienced a payment default (payment default is one missed payment) during the quarters and six months ended and for which the payment default occurred within one year of the modification $ 6.6 $ 15.9 $ 7.3 $ 16.5 There were $23.6 million of commitments to lend additional funds to borrowers whose loan terms have been modified in TDRs as of June 30, 2020 and December 31, 2019. Modifications qualifying as TDRs based upon recorded investment at June 30, 2020 and December 31, 2019, were comprised of payment deferrals (52%) and covenant relief and/or other (48%). The financial impact of the various modification strategies that the Company employs in response to borrower difficulties is presented below. The overall nature of modification programs were comparable in the prior periods. ▪ Payment deferrals result in lower net present value of cash flows, if not accompanied by additional interest or fees, and increased provision for credit losses to the extent applicable. The financial impact of these modifications is not significant given the moderate length of deferral periods. ▪ Interest rate reductions result in lower amounts of interest being charged to the customer but are a relatively small part of the Company’s restructuring programs. The weighted average change in interest rates for all TDRs occurring during the quarters ended June 30, 2020 and 2019 was not significant. ▪ Debt forgiveness, or the reduction in amount owed by borrower, results in incremental provision for credit losses, in the form of higher charge-offs. While these types of modifications have the greatest individual impact on the allowance, the amounts of principal forgiveness for TDRs occurring during quarters ended June 30, 2020 and 2019 was not significant, as debt forgiveness is a relatively small component of the Company’s modification programs. Except as it related to the modifications made for COVID-19 impacted borrowers, the other elements of the Company’s modification programs that are not TDRs do not have a significant impact on financial results given their relative size, or do not have a direct financial impact, as in the case of covenant changes. |