LOANS | NOTE 3 — LOANS Unless otherwise noted, loans held for sale are not included in the amounts presented throughout this note. Loans by Product (dollars in millions) September 30, 2021 December 31, 2020 Commercial Loans $ 26,055.9 $ 27,410.9 Financing Leases and Leverage Leases 2,119.4 2,318.0 Total commercial 28,175.3 29,728.9 Consumer Loans 5,285.7 6,415.7 Total loans $ 33,461.0 $ 36,144.6 The following table presents loans by segment, based on obligor location: Loans (dollars in millions) September 30, 2021 December 31, 2020 Domestic International Total Domestic International Total Commercial Banking $ 25,851.9 $ 1,365.2 $ 27,217.1 $ 27,323.4 $ 1,313.1 $ 28,636.5 Consumer Banking (1) 6,243.9 — 6,243.9 7,508.1 — 7,508.1 Total $ 32,095.8 $ 1,365.2 $ 33,461.0 $ 34,831.5 $ 1,313.1 $ 36,144.6 (1) The Consumer Banking segment includes certain commercial loans, primarily consisting of a portfolio of Small Business Administration ("SBA") loans and Community Development Lending loans. These loans are excluded from the Consumer loan balances and included in the Commercial loan balances in product related tables in this note. The following table presents selected components of the net investment in loans: Components of Net Investment (dollars in millions) September 30, December 31, 2021 2020 Unearned income $ (353.8 ) $ (373.9 ) Unamortized (discounts) premiums (284.4 ) (434.4 ) Net unamortized deferred costs 39.8 35.8 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. Commercial criticized loans include loans with a rating of special mention or classified. For consumer loans, we monitor credit quality utilizing current LTV of the underlying collateral to assess potential loss severity in the event of default and the borrower FICO scores to evaluate borrowers’ credit payment history. The Company examines LTV migration and stratifies LTV into categories to monitor 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 the Case-Shiller Home Price Indices. 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. Generally, 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, while the consumer loan LTV ratios and FICO scores tables summarize loans by year of origination. These tables reflect the amortized cost basis of the respective commercial and consumer loans. Accrued interest receivable is not reported with the loan’s amortized cost basis and is reported in other assets. Commercial Loans — Risk Rating by Class (1) (dollars in millions) Term Loans by Origination Year Revolving Loans Converted Grade 2021 2020 2019 2018 2017 2016 & Prior Revolving Loans to Term Loans Total September 30, 2021 Commercial Finance Pass $ 4,518.2 $ 2,426.7 $ 1,984.6 $ 1,414.5 $ 460.9 $ 943.5 $ 2,486.0 $ 60.6 $ 14,295.0 Special Mention 22.3 69.4 185.8 146.7 3.0 72.4 147.7 0.5 647.8 Classified-accrual 35.7 71.2 237.0 132.7 108.4 184.5 158.8 2.8 931.1 Classified-non-accrual — — 1.3 24.4 10.8 112.5 76.3 — 225.3 Total Commercial Finance 4,576.2 2,567.3 2,408.7 1,718.3 583.1 1,312.9 2,868.8 63.9 16,099.2 Real Estate Finance Pass 457.0 1,112.9 1,824.6 666.9 335.6 797.6 2.8 — 5,197.4 Special Mention — 87.1 100.3 79.5 58.9 13.3 — — 339.1 Classified-accrual — 0.3 411.5 240.7 96.4 82.0 — — 830.9 Classified-non-accrual — — — 0.2 1.9 61.3 — — 63.4 Total Real Estate Finance 457.0 1,200.3 2,336.4 987.3 492.8 954.2 2.8 — 6,430.8 Business Capital Pass 1,437.9 1,263.1 957.1 465.2 154.5 33.0 7.8 — 4,318.6 Special Mention 12.7 25.2 36.9 18.7 10.7 2.9 — — 107.1 Classified-accrual 21.7 33.3 58.9 31.4 10.2 1.4 — — 156.9 Classified-non-accrual 2.6 9.5 12.5 10.5 2.9 2.8 — — 40.8 Total Business Capital 1,474.9 1,331.1 1,065.4 525.8 178.3 40.1 7.8 — 4,623.4 Rail Pass — — 0.6 — — 63.1 — — 63.7 Total Rail — — 0.6 — — 63.1 — — 63.7 Commercial Banking Pass 6,413.1 4,802.7 4,766.9 2,546.6 951.0 1,837.2 2,496.6 60.6 23,874.7 Special Mention 35.0 181.7 323.0 244.9 72.6 88.6 147.7 0.5 1,094.0 Classified-accrual 57.4 104.8 707.4 404.8 215.0 267.9 158.8 2.8 1,918.9 Classified-non-accrual 2.6 9.5 13.8 35.1 15.6 176.6 76.3 — 329.5 Total Commercial Banking 6,508.1 5,098.7 5,811.1 3,231.4 1,254.2 2,370.3 2,879.4 63.9 27,217.1 Consumer Banking - Consumer and Community Banking (2) Pass 166.1 274.1 145.3 97.7 47.0 82.0 2.4 — 814.6 Special Mention — — 10.0 3.2 4.4 3.7 — — 21.3 Classified-accrual — 7.4 27.3 26.9 12.0 16.8 — — 90.4 Classified-non-accrual — — 17.0 3.6 4.2 7.1 — — 31.9 Total Consumer Banking 166.1 281.5 199.6 131.4 67.6 109.6 2.4 — 958.2 Commercial Loans Pass 6,579.2 5,076.8 4,912.2 2,644.3 998.0 1,919.2 2,499.0 60.6 24,689.3 Special Mention 35.0 181.7 333.0 248.1 77.0 92.3 147.7 0.5 1,115.3 Classified-accrual 57.4 112.2 734.7 431.7 227.0 284.7 158.8 2.8 2,009.3 Classified-non-accrual 2.6 9.5 30.8 38.7 19.8 183.7 76.3 — 361.4 Total Commercial Loans $ 6,674.2 $ 5,380.2 $ 6,010.7 $ 3,362.8 $ 1,321.8 $ 2,479.9 $ 2,881.8 $ 63.9 $ 28,175.3 (1), (2) See footnotes below table on the next page. Commercial Loans — Risk Rating by Class (1) (dollars in millions) (continued) Term Loans by Origination Year Revolving Loans Converted Grade 2020 2019 2018 2017 2016 2015 & Prior Revolving Loans to Term Loans Total December 31, 2020 Commercial Finance Pass $ 4,819.9 $ 2,132.5 $ 2,000.1 $ 678.0 $ 181.1 $ 745.6 $ 3,329.4 $ 61.1 $ 13,947.7 Special Mention 81.2 206.4 210.8 18.4 30.8 119.9 313.3 2.8 983.6 Classified-accrual 82.4 161.7 49.8 169.2 107.2 183.1 314.2 5.6 1,073.2 Classified-non-accrual 0.5 9.0 53.9 9.6 22.1 60.7 83.6 — 239.4 Total Commercial Finance 4,984.0 2,509.6 2,314.6 875.2 341.2 1,109.3 4,040.5 69.5 16,243.9 Real Estate Finance Pass 1,075.9 2,089.2 1,212.3 663.5 480.3 493.0 28.1 — 6,042.3 Special Mention 65.9 333.7 126.4 225.5 93.5 46.3 — — 891.3 Classified-accrual 0.3 184.4 124.2 74.6 78.0 75.8 — — 537.3 Classified-non-accrual — 33.3 0.2 15.3 0.2 28.0 6.2 — 83.2 Total Real Estate Finance 1,142.1 2,640.6 1,463.1 978.9 652.0 643.1 34.3 — 7,554.1 Business Capital Pass 1,678.9 1,371.4 809.5 299.3 106.3 15.6 14.4 0.8 4,296.2 Special Mention 29.6 67.2 42.4 32.4 12.3 0.3 — — 184.2 Classified-accrual 34.3 80.8 71.5 25.9 11.2 0.9 — — 224.6 Classified-non-accrual 8.0 33.0 17.1 10.9 2.8 1.0 — — 72.8 Total Business Capital 1,750.8 1,552.4 940.5 368.5 132.6 17.8 14.4 0.8 4,777.8 Rail Pass — 0.8 — 0.1 3.1 56.7 — — 60.7 Total Rail — 0.8 — 0.1 3.1 56.7 — — 60.7 Commercial Banking Pass 7,574.7 5,593.9 4,021.9 1,640.9 770.8 1,310.9 3,371.9 61.9 24,346.9 Special Mention 176.7 607.3 379.6 276.3 136.6 166.5 313.3 2.8 2,059.1 Classified-accrual 117.0 426.9 245.5 269.7 196.4 259.8 314.2 5.6 1,835.1 Classified-non-accrual 8.5 75.3 71.2 35.8 25.1 89.7 89.8 — 395.4 Total Commercial Banking 7,876.9 6,703.4 4,718.2 2,222.7 1,128.9 1,826.9 4,089.2 70.3 28,636.5 Consumer Banking - Consumer and Community Banking (2) Pass 507.6 157.1 104.5 62.3 50.0 67.3 0.1 — 948.9 Special Mention — 13.1 4.3 2.8 2.6 0.9 — — 23.7 Classified-accrual 21.0 19.3 17.0 11.0 13.8 17.6 0.3 — 100.0 Classified-non-accrual — 11.8 3.0 3.2 1.0 0.8 — — 19.8 Total Consumer Banking 528.6 201.3 128.8 79.3 67.4 86.6 0.4 — 1,092.4 Commercial Loans Pass 8,082.3 5,751.0 4,126.4 1,703.2 820.8 1,378.2 3,372.0 61.9 25,295.8 Special Mention 176.7 620.4 383.9 279.1 139.2 167.4 313.3 2.8 2,082.8 Classified-accrual 138.0 446.2 262.5 280.7 210.2 277.4 314.5 5.6 1,935.1 Classified-non-accrual 8.5 87.1 74.2 39.0 26.1 90.5 89.8 — 415.2 Total Commercial Loans $ 8,405.5 $ 6,904.7 $ 4,847.0 $ 2,302.0 $ 1,196.3 $ 1,913.5 $ 4,089.6 $ 70.3 $ 29,728.9 (1) Amortized cost excludes accrued intere (2) Primarily SBA loans. The following table provides a summary of the consumer loan LTV distribution for primarily single-family residential (“SFR”) mortgage loans. The average LTV was 53% and 58% for the total consumer loans included below at September 30, 2021 and December 31, 2020, respectively. Consumer Loans LTV Distribution (1) (dollars in millions) Term Loans Amortized Cost Basis by Origination Year Revolving Loans Converted LTV Range 2021 2020 2019 2018 2017 2016 & Prior Revolving Loans to Term Loans Total September 30, 2021 Legacy Consumer Mortgages Greater than 125% $ — $ — $ — $ — $ — $ 16.1 $ — $ 0.1 $ 16.2 101% – 125% — — — — — 22.6 — 0.3 22.9 80% – 100% — — — — — 64.5 — 1.1 65.6 Less than 80% — — — — — 1,051.1 — 25.5 1,076.6 Government-guaranteed ( 2 ) — — — — — 19.4 — — 19.4 No LTV available ( 3 ) — — — — — 0.1 — 1.2 1.3 Total Legacy Consumer Mortgages — — — — — 1,173.8 — 28.2 1,202.0 Consumer and Community Banking Greater than 125% — — — — — — — — — 101% – 125% — — — — — — — — — 80% – 100% 11.5 — 0.9 0.8 — 0.8 — — 14.0 Less than 80% 1,247.4 946.0 453.6 226.8 287.7 757.0 25.4 — 3,943.9 Government-guaranteed ( 2 ) — 10.0 22.5 10.3 46.6 13.0 — — 102.4 No LTV available ( 3 ) — 0.1 0.1 0.1 0.1 1.0 1.3 — 2.7 No LTV required ( 4 ) 0.8 2.2 1.0 0.8 0.7 13.0 2.2 — 20.7 Total Consumer and Community Banking 1,259.7 958.3 478.1 238.8 335.1 784.8 28.9 — 4,083.7 Total Consumer Loans $ 1,259.7 $ 958.3 $ 478.1 $ 238.8 $ 335.1 $ 1,958.6 $ 28.9 $ 28.2 $ 5,285.7 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 December 31, 2020 Legacy Consumer Mortgages Greater than 125% $ — $ — $ — $ — $ — $ 37.5 $ — $ 0.4 $ 37.9 101% – 125% — — — — — 60.5 — 1.1 61.6 80% – 100% — — — — — 189.2 — 3.4 192.6 Less than 80% — — — — — 1,344.3 — 34.7 1,379.0 Government-guaranteed ( 2 ) — — — — — 20.8 — — 20.8 No LTV available ( 3 ) — — — — — 0.1 — 1.7 1.8 Total Legacy Consumer Mortgages — — — — — 1,652.4 — 41.3 1,693.7 Consumer and Community Banking Greater than 125% — — — — — — — — — 101% – 125% — — — — — — — — — 80% – 100% 21.3 17.1 3.5 — — 1.7 2.4 — 46.0 Less than 80% 1,328.4 1,022.7 445.8 507.2 380.1 778.8 41.5 — 4,504.5 Government-guaranteed ( 2 ) 12.0 33.7 15.7 68.2 9.5 7.8 — — 146.9 No LTV available ( 3 ) — — 0.2 0.2 0.2 0.7 1.3 — 2.6 No LTV required ( 4 ) 2.0 1.0 1.0 0.6 1.0 13.4 3.0 — 22.0 Total Consumer and Community Banking 1,363.7 1,074.5 466.2 576.2 390.8 802.4 48.2 — 4,722.0 Total Consumer Loans $ 1,363.7 $ 1,074.5 $ 466.2 $ 576.2 $ 390.8 $ 2,454.8 $ 48.2 $ 41.3 $ 6,415.7 (1) Amortized cost excludes accrued interest (2) Represents loans with principal repayments insured by the FHA and U.S. Department of Veterans Affairs (“VA”). (3) Represents primarily junior lien loans for which LTV is not available. (4) Represents overdrafts, personal lines of credit, unsecured loans and third-party guaranteed loans with servicer recourse option for which LTV is not required. The following table provides a summary of the most current FICO score distribution for consumer loans by origination year and revolving loans. The average FICO score was 764 and 755 for the total c onsumer l oans included below at September 30, 2021 and December 31, 2020 , respectively. FICO Score Distribution (1) (dollars in millions) Term Loans Amortized Cost Basis by Origination Year Revolving Loans Converted Current FICO 2021 2020 2019 2018 2017 2016 & Prior Revolving Loans to Term Loans Total September 30, 2021 Legacy Consumer Mortgages Greater than or equal to 730 $ — $ — $ — $ — $ — $ 607.6 $ — $ 13.2 $ 620.8 Greater than or equal to 660 and less than 730 — — — — — 347.5 — 8.1 355.6 Less than 660 — — — — — 173.4 — 6.2 179.6 Government-guaranteed (2) — — — — — 19.4 — — 19.4 No FICO score available (3) — — — — — 25.9 — 0.7 26.6 FICO score not required (4) — — — — — — — — — Total Legacy Consumer Mortgages — — — — — 1,173.8 — 28.2 1,202.0 Consumer and Community Banking Greater than or equal to 730 1,068.6 810.8 392.2 188.1 260.4 614.0 19.3 — 3,353.4 Greater than or equal to 660 and less than 730 182.2 122.8 58.9 33.0 22.4 101.2 6.2 — 526.7 Less than 660 8.1 12.3 3.7 5.6 4.8 30.4 2.8 — 67.7 Government-guaranteed (2) — 10.0 22.5 10.3 46.6 13.0 — — 102.4 No FICO score available (3) — 0.2 — 1.0 0.2 13.6 0.2 — 15.2 FICO score not required (4) 0.8 2.2 0.8 0.8 0.7 12.6 0.4 — 18.3 Total Consumer and Community Banking 1,259.7 958.3 478.1 238.8 335.1 784.8 28.9 — 4,083.7 Total Consumer Loans $ 1,259.7 $ 958.3 $ 478.1 $ 238.8 $ 335.1 $ 1,958.6 $ 28.9 $ 28.2 $ 5,285.7 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 December 31, 2020 Legacy Consumer Mortgages Greater than or equal to 730 $ — $ — $ — $ — $ — $ 729.1 $ — $ 17.9 $ 747.0 Greater than or equal to 660 and less than 730 — — — — — 499.3 — 13.0 512.3 Less than 660 — — — — — 369.4 — 9.4 378.8 Government-guaranteed ( 2 ) — — — — — 20.8 — — 20.8 No FICO score available ( 3 ) — — — — — 33.8 — 1.0 34.8 Total Legacy Consumer Mortgages — — — — — 1,652.4 — 41.3 1,693.7 Consumer and Community Banking Greater than or equal to 730 1,152.3 923.7 372.3 453.5 339.7 596.7 34.2 — 3,872.4 Greater than or equal to 660 and less than 730 186.3 104.7 68.7 46.3 34.5 125.6 10.0 — 576.1 Less than 660 11.0 11.2 8.4 7.3 5.5 40.8 3.1 — 87.3 Government-guaranteed ( 2 ) 12.0 33.7 15.7 68.2 9.5 7.8 — — 146.9 No FICO score available ( 3 ) 0.1 0.5 0.1 0.3 0.6 18.2 0.2 — 20.0 FICO score not required ( 4 ) 2.0 0.7 1.0 0.6 1.0 13.3 0.7 — 19.3 Total Consumer and Community Banking 1,363.7 1,074.5 466.2 576.2 390.8 802.4 48.2 — 4,722.0 Total Consumer Loans $ 1,363.7 $ 1,074.5 $ 466.2 $ 576.2 $ 390.8 $ 2,454.8 $ 48.2 $ 41.3 $ 6,415.7 (1) Amortized cost excludes accrued interest receivable. See footnote 1 to the LTV table above. (2) Represents loans with principal repayments insured by the FHA and VA. (3) Represents loans with no FICO score available due to borrower bankruptcy or limited credit history. (4) FICO sores not required for these overdrafts, personal lines of credit or third-party guaranteed loans with servicer recourse option. Past Due and Non-accrual Loans Additional information on reporting of past due and non-accrual loans is provided in the 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 or non-accrual classification: Loans - Delinquency Status (dollars in millions) Past Due Total 30-59 60-89 90 or more Past Due Current Total September 30, 2021 Commercial Banking Commercial Finance $ 37.2 $ 8.9 $ 29.8 $ 75.9 $ 16,023.3 $ 16,099.2 Real Estate Finance 0.2 10.6 9.2 20.0 6,410.8 6,430.8 Business Capital 58.5 26.4 17.3 102.2 4,521.2 4,623.4 Rail — — — — 63.7 63.7 Total Commercial Banking 95.9 45.9 56.3 198.1 27,019.0 27,217.1 Consumer Banking Legacy Consumer Mortgage 24.1 4.7 25.2 54.0 1,148.1 1,202.1 Consumer and Community Banking 42.7 26.7 20.2 89.6 4,952.2 5,041.8 Total Consumer Banking 66.8 31.4 45.4 143.6 6,100.3 6,243.9 Total $ 162.7 $ 77.3 $ 101.7 $ 341.7 $ 33,119.3 $ 33,461.0 December 31, 2020 Commercial Banking Commercial Finance $ 59.9 $ 2.8 $ 122.0 $ 184.7 $ 16,059.2 $ 16,243.9 Real Estate Finance 71.7 38.3 82.4 192.4 7,361.7 7,554.1 Business Capital 113.6 40.2 16.6 170.4 4,607.4 4,777.8 Rail — — — — 60.7 60.7 Total Commercial Banking 245.2 81.3 221.0 547.5 28,089.0 28,636.5 Consumer Banking Legacy Consumer Mortgage 61.0 17.6 79.7 158.3 1,535.5 1,693.8 Consumer and Community Banking 173.1 10.6 34.0 217.7 5,596.6 5,814.3 Total Consumer Banking 234.1 28.2 113.7 376.0 7,132.1 7,508.1 Total $ 479.3 $ 109.5 $ 334.7 $ 923.5 $ 35,221.1 $ 36,144.6 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 that are 90 days or more past due and are guaranteed by government agencies are not placed on non-accrual status. See Note 1 – Business and Summary of Significant Accounting Policies Loans on Non-Accrual Status (dollars in millions) ( 1 ) September 30, 2021 December 31, 2020 Non-Accrual Loans With No Allowance Recorded (2) Non-Accrual Loans With No Allowance Recorded (2) Commercial Banking Commercial Finance (3) $ 225.3 $ 13.4 $ 239.4 $ 8.0 Business Capital 40.8 3.1 72.8 1.5 Real Estate Finance 63.4 2.6 83.2 16.0 Total Commercial Banking 329.5 19.1 395.4 25.5 Consumer Banking Consumer and Community Banking 52.1 29.5 53.4 38.2 Legacy Consumer Mortgages 23.3 5.9 139.3 30.0 Total Consumer Banking 75.4 35.4 192.7 68.2 Total $ 404.9 $ 54.5 $ 588.1 $ 93.7 Repossessed assets and OREO (4) 10.5 7.9 Total non-performing assets $ 415.4 $ 596.0 Commercial loans past due 90 days or more accruing $ 14.7 $ 92.5 Consumer loans past due 90 days or more accruing (5) 13.2 11.3 Total accruing loans past due 90 days or more $ 27.9 $ 103.8 (1) Accrued interest that was reversed when the loan went to non-accrual status was $0.5 million and $1.1 million for the quarters ended September 30, 2021 and 2020, respectively, and $2.8 million and $6.0 million for the nine months ended September 30, 2021 and 2020, respectively. (2) Includes loans that have been charged-off to their net realizable value and loans where the collateral or enterprise value exceeds the expected pay off value. (3) Factored receivables within our Commercial Finance division do not accrue interest and therefore are not considered within non-accrual loan balances; however factored receivables are considered for credit provisioning purposes. (4) Balances consist mostly of single-family residential OREO. (5) Consists of loans guaranteed by government agencies. 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. Interest . 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 suspended residential property foreclosures and evictions through July 31, 2021 related to single family homeowners due to the COVID-19 pandemic. Loans in Process of Foreclosure (dollars in millions) September 30, December 31, 2021 2020 Loans in process of foreclosure $ 11.8 $ 22.9 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 Note 1 – Business and Summary of Significant Accounting Policies The CARES Act and Interagency Statement offer some practical expedients for evaluating whether loan modifications that occur in response to the COVID-19 pandemic are TDRs. See Note 1 – Business and Summary of Significant Accounting Policies 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 $0.1 million at September 30, 2021 and $4.5 million at December 31, 2020: TDRs (dollars in millions) September 30, 2021 December 31, 2020 Recorded Investment % Total TDR Recorded Investment % Total TDR Commercial Banking $ 96.1 74 % $ 109.8 82 % Consumer Banking 33.4 26 % 24.6 18 % Total $ 129.5 100 % $ 134.4 100 % Percent non-accrual 51 % 73 % Modifications (dollars in millions) Quarters Ended September 30, Nine Months Ended September 30, 2021 2020 2021 2020 Recorded investment related to modifications qualifying as TDRs that occurred during the periods $ 31.3 $ 10.0 $ 48.8 $ 62.4 Recorded investment at the time of default of TDRs that experienced a payment default (payment default is one missed payment) during the periods and for which the payment default occurred within one year of the modification $ 2.9 $ 13.6 12.9 19.9 There were $9.3 million and $28.3 million of commitments to lend additional funds to borrowers whose loan terms have been modified in TDRs as of September 30, 2021 and December 31, 2020, respectively. Modifications qualifying as TDRs based upon recorded investment at September 30, 2021, were comprised of payment deferrals (55%) and covenant relief and/or other (45%). At December 31, 2020, TDR recorded investment was comprised of payment deferrals (40%) and covenant relief and/or other (60%). 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 was 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 September 30, 2021 and 2020 were 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 September 30, 2021 and 2020 was not significant, as debt forgiveness is a relatively small component of the Company’s modification programs. 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. |