Allowance for Loan Losses | 2. Allowance for Loan Losses Allowance for Loan Losses Roll Forward Three Months Ended March 31, 2024 (Dollars in millions) FFELP Private Total Beginning balance $ 215 $ 617 $ 832 Total provision 1 11 12 Charge-offs: Gross charge-offs ( 10 ) ( 110 ) ( 120 ) Expected future recoveries on current period gross charge-offs — 11 11 Net charge-offs (1)(2) ( 10 ) ( 99 ) ( 109 ) Decrease in expected future recoveries on previously fully (3) — 9 9 Allowance at end of period $ 206 $ 538 $ 744 Net charge-offs as a percentage of average loans in repayment .13 % 2.40 % Ending total loans $ 36,085 $ 17,146 Average loans in repayment $ 29,736 $ 16,671 Ending loans in repayment $ 28,985 $ 16,480 (1) $ 28 million of Private Education Loan net charge-offs is in connection with the resolution of certain private legacy loans in bankruptcy. This was previously reserved for in 2023. (2) Charge-offs are reported net of expected recoveries. For Private Education Loans, we charge off the estimated loss of a defaulted loan balance by charging off the entire defaulted loan balance and estimating recoveries on a pool basis. These estimated recoveries are referred to as "expected future recoveries on previously fully charged-off loans." For FFELP Loans, the recovery is received at the time of charge-off. (3) At the end of each month, for Private Education Loans that are 212 days past due, we charge off the estimated loss of a defaulted loan balance by charging off the entire loan balance and estimating recoveries on a pool basis. These estimated recoveries are referred to as “expected future recoveries on previously fully charged-off loans.” If actual periodic recoveries are less than expected, the difference is immediately reflected as a reduction to expected future recoveries on previously fully charged-off loans. If actual periodic recoveries are greater than expected, they will be reflected as a recovery through the allowance for Private Education Loan losses once the cumulative recovery amount exceeds the cumulative amount originally expected to be recovered. The following table summarizes the activity in the expected future recoveries on previously fully charged-off loans: Three Months Ended March 31, (Dollars in millions) 2024 Beginning of period expected future recoveries on previously fully charged-off loans $ 226 Expected future recoveries of current period defaults 11 Recoveries (cash collected) ( 11 ) Charge-offs (as a result of lower recovery expectations) ( 9 ) End of period expected future recoveries on previously fully charged-off loans $ 217 Change in balance during period $ ( 9 ) 2. Allowance for Loan Losses (Continued) Three Months Ended March 31, 2023 (Dollars in millions) FFELP Loans Private Education Loans Total Beginning balance $ 222 $ 800 $ 1,022 Total provision 10 ( 24 ) ( 14 ) Charge-offs: Gross charge-offs ( 18 ) ( 88 ) ( 106 ) Expected future recoveries on current period gross charge-offs — 13 13 Net charge-offs (1) ( 18 ) ( 75 ) ( 93 ) Decrease in expected future recoveries on previously fully (2) — 5 5 Allowance at end of period $ 214 $ 706 $ 920 Net charge-offs as a percentage of average loans in repayment .22 % 1.63 % Ending total loans $ 42,362 $ 18,981 Average loans in repayment $ 34,305 $ 18,552 Ending loans in repayment $ 33,740 $ 18,258 (1) Charge-offs are reported net of expected recoveries. For Private Education Loans, we charge off the estimated loss of a defaulted loan balance by charging off the entire defaulted loan balance and estimating recoveries on a pool basis. These estimated recoveries are referred to as "expected future recoveries on previously fully charged-off loans." For FFELP Loans, the recovery is received at the time of charge-off. (2) At the end of each month, for Private Education Loans that are 212 days past due, we charge off the estimated loss of a defaulted loan balance by charging off the entire loan balance and estimating recoveries on a pool basis. These estimated recoveries are referred to as “expected future recoveries on previously fully charged-off loans.” If actual periodic recoveries are less than expected, the difference is immediately reflected as a reduction to expected future recoveries on previously fully charged-off loans. If actual periodic recoveries are greater than expected, they will be reflected as a recovery through the allowance for Private Education Loan losses once the cumulative recovery amount exceeds the cumulative amount originally expected to be recovered. The following table summarizes the activity in the expected future recoveries on previously fully charged-off loans: Three Months Ended March 31, (Dollars in millions) 2023 Beginning of period expected future recoveries on previously fully charged-off loans $ 274 Expected future recoveries of current period defaults 13 Recoveries (cash collected) ( 13 ) Charge-offs (as a result of lower recovery expectations) ( 6 ) End of period expected future recoveries on previously fully charged-off loans $ 268 Change in balance during period $ ( 5 ) 2. Allowance for Loan Losses (Continued) Key Credit Quality Indicators We assess and determine the collectability of our education loan portfolios by evaluating certain risk characteristics we refer to as key credit quality indicators. Key credit quality indicators are incorporated into the allowance for loan losses calculation. FFELP Loans FFELP Loans are substantially insured and guaranteed as to their principal and accrued interest in the event of default. The key credit quality indicators are loan status and loan type. FFELP Loan Delinquencies March 31, 2024 December 31, 2023 March 31, 2023 (Dollars in millions) Balance % Balance % Balance % Loans in-school/grace/deferment (1) $ 1,562 $ 1,557 $ 1,778 Loans in forbearance (2) 5,538 6,147 6,844 Loans in repayment and percentage of each status: Loans current 25,162 86.8 % 26,204 86.1 % 28,886 85.6 % Loans delinquent 31-60 days (3) 1,163 4.0 1,193 3.9 1,270 3.8 Loans delinquent 61-90 days (3) 747 2.6 746 2.5 902 2.7 Loans delinquent greater than 90 days (3) 1,913 6.6 2,293 7.5 2,682 7.9 Total FFELP Loans in repayment 28,985 100 % 30,436 100 % 33,740 100 % Total FFELP Loans 36,085 38,140 42,362 FFELP Loan allowance for losses ( 206 ) ( 215 ) ( 214 ) FFELP Loans, net $ 35,879 $ 37,925 $ 42,148 Percentage of FFELP Loans in repayment 80.3 % 79.8 % 79.6 % Delinquencies as a percentage of FFELP Loans in 13.2 % 13.9 % 14.4 % FFELP Loans in forbearance as a percentage of 16.0 % 16.8 % 16.9 % (1) Loans for customers who may still be attending school or engaging in other permitted educational activities and are not yet required to make payments on their loans, e.g., residency periods for medical students or a grace period for bar exam preparation, as well as loans for customers who have requested and qualify for other permitted program deferments such as military, unemployment, or economic hardships. (2) Loans for customers who have used their allowable deferment time or do not qualify for deferment, that need additional time to obtain employment or who have temporarily ceased making full payments due to hardship or other factors such as disaster relief, including COVID-19 relief programs, consistent with established loan program servicing policies and procedures. (3) The period of delinquency is based on the number of days scheduled payments are contractually past due. Loan type : (Dollars in millions) March 31, 2024 March 31, 2023 Change Stafford Loans $ 11,398 $ 13,592 $ ( 2,194 ) Consolidation Loans 21,177 24,697 ( 3,520 ) Rehab Loans 3,510 4,073 ( 563 ) Total loans, gross $ 36,085 $ 42,362 $ ( 6,277 ) 2. Allowance for Loan Losses (Continued) Private Education Loans The key credit quality indicators are credit scores (FICO scores), loan status, loan seasoning, certain loan modifications, the existence of a cosigner and school type. The FICO score is the higher of the borrower or co-borrower score and is updated at least every six months while school type is assessed at origination. The other Private Education Loan key quality indicators are updated quarterly. Private Education Loan Credit Quality Indicators by Origination Year March 31, 2024 (Dollars in millions) 2024 2023 2022 2021 2020 Prior Total % of Total Credit Quality FICO Scores: 640 and above $ 259 $ 877 $ 1,514 $ 3,744 $ 1,175 $ 7,827 $ 15,396 90 % Below 640 5 14 70 128 31 1,502 1,750 10 Total $ 264 $ 891 $ 1,584 $ 3,872 $ 1,206 $ 9,329 $ 17,146 100 % Loan Status: In-school/grace/ $ 12 $ 65 $ 66 $ 84 $ 21 $ 418 $ 666 4 % Current/90 days or 252 824 1,508 3,772 1,182 8,591 16,129 94 Greater than 90 days — 2 10 16 3 320 351 2 Total $ 264 $ 891 $ 1,584 $ 3,872 $ 1,206 $ 9,329 $ 17,146 100 % Seasoning (1) : 1-12 payments $ 252 $ 782 $ 50 $ 28 $ 5 $ 48 $ 1,165 7 % 13-24 payments — 51 1,188 124 12 64 1,439 8 25-36 payments — — 299 3,478 38 126 3,941 23 37-48 payments — — — 196 1,020 267 1,483 9 More than 48 — — — — 121 8,628 8,749 51 Loans in-school/ 12 58 47 46 10 196 369 2 Total $ 264 $ 891 $ 1,584 $ 3,872 $ 1,206 $ 9,329 $ 17,146 100 % Certain Loan (2) : Modified $ — $ 1 $ 52 $ 144 $ 51 $ 5,680 $ 5,928 35 % Non-Modified 264 890 1,532 3,728 1,155 3,649 11,218 65 Total $ 264 $ 891 $ 1,584 $ 3,872 $ 1,206 $ 9,329 $ 17,146 100 % Cosigners: With cosigner (3) $ 45 $ 268 $ 174 $ 90 $ 22 $ 4,993 $ 5,592 33 % Without cosigner 219 623 1,410 3,782 1,184 4,336 11,554 67 Total $ 264 $ 891 $ 1,584 $ 3,872 $ 1,206 $ 9,329 $ 17,146 100 % School Type: Not-for-profit $ 239 $ 844 $ 1,500 $ 3,647 $ 1,153 $ 7,984 $ 15,367 90 % For-profit 25 47 84 225 53 1,345 1,779 10 Total $ 264 $ 891 $ 1,584 $ 3,872 $ 1,206 $ 9,329 $ 17,146 100 % Allowance for loan ( 538 ) Total loans, net $ 16,608 Charge-Offs $ — $ ( 1 ) $ ( 2 ) $ ( 4 ) $ ( 1 ) $ ( 91 ) $ ( 99 ) 100 % (1) Number of months in active repayment for which a scheduled payment was received. (2) Loan Modifications represents the historical definition of a troubled debt restructuring (TDR) prior to the implementation of ASU No. 2022-02 on January 1, 2023. Any loan that meets the historical definition of a TDR retains that classification for the life of the loan (including loans that meet that definition in 2023). This includes loans given rate modifications, term extensions or forbearance greater than 3 months in the prior 24-month period. This classification is not intended to reconcile in any way to the modification disclosures required under ASU No. 2022-02. (3) Excluding Private Education Refinance Loans, which do not have a cosigner, the cosigner rate was 66 % for total loans at March 31, 2024. 2. Allowance for Loan Losses (Continued) Private Education Loan Credit Quality Indicators by Origination Year March 31, 2023 (Dollars in millions) 2023 2022 2021 2020 2019 Prior Total % of Total Credit Quality FICO Scores: 640 and above $ 167 $ 1,761 $ 4,368 $ 1,438 $ 1,353 $ 8,133 $ 17,220 91 % Below 640 3 40 92 24 43 1,559 1,761 9 Total $ 170 $ 1,801 $ 4,460 $ 1,462 $ 1,396 $ 9,692 $ 18,981 100 % Loan Status: In-school/grace/ $ 9 $ 67 $ 91 $ 27 $ 31 $ 498 $ 723 4 % Current/90 days or 161 1,729 4,360 1,432 1,359 8,853 17,894 94 Greater than 90 days — 5 9 3 6 341 364 2 Total $ 170 $ 1,801 $ 4,460 $ 1,462 $ 1,396 $ 9,692 $ 18,981 100 % Seasoning (1) : 1-12 payments $ 161 $ 1,386 $ 80 $ 9 $ 8 $ 71 $ 1,715 9 % 13-24 payments — 362 4,084 32 23 86 4,587 24 25-36 payments — — 242 1,251 106 157 1,756 9 37-48 payments — — — 155 1,190 272 1,617 9 More than 48 — — — — 53 8,884 8,937 47 Loans in-school/ 9 53 54 15 16 222 369 2 Total $ 170 $ 1,801 $ 4,460 $ 1,462 $ 1,396 $ 9,692 $ 18,981 100 % Certain Loan (2) : Modified $ — $ 14 $ 89 $ 38 $ 72 $ 6,279 $ 6,492 34 % Non-Modified 170 1,787 4,371 1,424 1,324 3,413 12,489 66 Total $ 170 $ 1,801 $ 4,460 $ 1,462 $ 1,396 $ 9,692 $ 18,981 100 % Cosigners: With cosigner (3) $ 35 $ 189 $ 103 $ 26 $ 9 $ 5,894 $ 6,256 33 % Without cosigner 135 1,612 4,357 1,436 1,387 3,798 12,725 67 Total $ 170 $ 1,801 $ 4,460 $ 1,462 $ 1,396 $ 9,692 $ 18,981 100 % School Type: Not-for-profit $ 158 $ 1,704 $ 4,202 $ 1,397 $ 1,300 $ 8,150 $ 16,911 89 % For-profit 12 97 258 65 96 1,542 2,070 11 Total $ 170 $ 1,801 $ 4,460 $ 1,462 $ 1,396 $ 9,692 $ 18,981 100 % Allowance for loan ( 706 ) Total loans, net $ 18,275 Charge-Offs $ — $ ( 2 ) $ ( 2 ) $ ( 1 ) $ ( 2 ) $ ( 68 ) $ ( 75 ) 100 % (1) Number of months in active repayment for which a scheduled payment was received. (2) Loan Modifications represents the historical definition of a troubled debt restructuring (TDR) prior to the implementation of ASU No. 2022-02 on January 1, 2023. Any loan that meets the historical definition of a TDR retains that classification for the life of the loan (including loans that meet that definition in 2023). This includes loans given rate modifications, term extensions or forbearance greater than 3 months in the prior 24-month period. This classification is not intended to reconcile in any way to the modification disclosures required under ASU No. 2022-02. (3) Excluding Private Education Refinance Loans, which do not have a cosigner, the cosigner rate was 65 % for total loans at March 31, 2023 . 2. Allowance for Loan Losses (Continued) Private Education Loan Delinquencies March 31, 2024 December 31, 2023 March 31, 2023 (Dollars in millions) Balance % Balance % Balance % Loans in-school/grace/deferment (1) $ 369 $ 360 $ 369 Loans in forbearance (2) 297 363 354 Loans in repayment and percentage of each status: Loans current 15,661 95.0 % 15,935 94.9 % 17,439 95.5 % Loans delinquent 31-60 days (3) 303 1.9 308 1.8 290 1.6 Loans delinquent 61-90 days (3) 165 1.0 173 1.0 165 .9 Loans delinquent greater than 90 days (3) 351 2.1 380 2.3 364 2.0 Total loans in repayment 16,480 100 % 16,796 100 % 18,258 100 % Total loans 17,146 17,519 18,981 Allowance for losses ( 538 ) ( 617 ) ( 706 ) Loans, net $ 16,608 $ 16,902 $ 18,275 Percentage of loans in repayment 96.1 % 95.9 % 96.2 % Delinquencies as a percentage of loans in 5.0 % 5.1 % 4.5 % Loans in forbearance as a percentage of 1.8 % 2.1 % 1.9 % (1) Loans for customers who are attending school or are in other permitted educational activities and are not yet required to make payments on their loans, e.g., internship periods, as well as loans for customers who have requested and qualify for other permitted program deferments such as various military eligible deferments. (2) Loans for customers who have requested extension of grace period generally during employment transition or who have temporarily ceased making full payments due to hardship or other factors such as disaster relief, including COVID-19 relief programs, consistent with established loan program servicing policies and procedures. (3) The period of delinquency is based on the number of days scheduled payments are contractually past due . 2. Allowance for Loan Losses (Continued) Loan Modifications to Borrowers Experiencing Financial Difficulty We adjust the terms of Private Education Loans for certain borrowers when we believe such changes will help our customers better manage their student loan obligations, achieve better outcomes and increase the collectability of the loans. These changes generally take the form of a temporary interest rate reduction, a temporary forbearance of payments, a temporary interest only payment, and a temporary interest rate reduction with a permanent extension of the loan term. The effect of modifications of loans made to borrowers who are experiencing financial difficulty is already included in the allowance for credit losses because of the measurement methodologies used to estimate the allowance. The model design predicts borrowers that will have financial difficulty in the future and require loan modification and increased life of loan default risk. Under our current forbearance practices, temporary hardship forbearance of payments generally cannot exceed 12 months over the life of the loan. However, exceptions can be made in cases where borrowers have shown the ability to make a substantial number of monthly principal and interest payments and in those cases borrowers can be granted up to 24 months of hardship forbearance over the life of the loan. We offer other administrative forbearances (e.g., death and disability, bankruptcy, military service, and disaster forbearance) that are either required by law (such as the Service members Civil Relief Act) or are considered separate from our active loss mitigation programs and therefore are not considered to be loan modifications requiring disclosure under ASU No. 2022-02. FFELP Loans are at least 97 percent guaranteed as to their principal and accrued interest by the federal government in the event of default and, therefore, we do not deem FFELP Loans as nonperforming from a credit risk perspective at any point in their life cycle prior to claim payment and continue to accrue interest on those loans through the date of claim. Further, FFELP loan modification events are either legal entitlements subject to regulatory-driven eligibility criteria or addressed in the promissory note terms, so we do not consider these events as a component of our loan modification programs. The following tables show the amortized cost basis as of March 31, 2024 and 2023 of the loans to borrowers experiencing financial difficulty that were modified during the respective period. Three Months Ended March 31, 2024 Loan Modifications Made to Borrowers Experiencing Financial Difficulty (Dollars in millions) Interest Rate Reductions (1) More Than an Insignificant Payment Delay (2) Combination Rate Reduction and Term Extension Loan Type Amortized Cost % of Loan Type Amortized Cost % of Loan Type Amortized Cost % of Loan Type Private Education $ 545 3.2 % $ 337 2.0 % $ 39 .2 % Three Months Ended March 31, 2023 Loan Modifications Made to Borrowers Experiencing Financial Difficulty (Dollars in millions) Interest Rate Reductions (1) More Than an Insignificant Payment Delay (2) Combination Rate Reduction and Term Extension Loan Type Amortized Cost % of Loan Type Amortized Cost % of Loan Type Amortized Cost % of Loan Type Private Education $ 611 3.2 % $ 275 1.4 % $ 46 .2 % (1) As of March 31, 2024 and 2023, there was $ 1.1 billion and $ 1.1 billion, respectively, of loans in the interest rate reduction program. (2) More Than an Insignificant Payment Delay includes loans granted more than 3 months of short-term interest only payments or hardship forbearance. 2. Allowance for Loan Losses (Continued) For those loans modified in the three months ended March 31, 2024 and 2023, the following tables show the impact of such modification. Three Months Ended March 31, 2024 Loan Type Interest Rate Reductions More Than an Insignificant Payment Delay Combination Rate Reduction and Term Extension Private Education Loans Reduced the weighted average contractual rate from 13.3 % to 5.4 % Added an average 5 months to the remaining life of the loans Added an average 7 years to the remaining life of the loans and reduced the weighted average contractual rate from 12.9 % to 5.3 %. Three Months Ended March 31, 2023 Loan Type Interest Rate Reductions More Than an Insignificant Payment Delay Combination Rate Reduction and Term Extension Private Education Loans Reduced the weighted average contractual rate from 12.9 % to 4.9 % Added an average 6 months to the remaining life of the loans Added an average 8 years to the remaining life of the loans and reduced the weighted average contractual rate from 12.5 % to 5.1 %. The following table provides the amount of loan modifications for which a charge-off or payment default occurred in the respective period and within 12 months of the loan receiving a loan modification. We define payment default as 60 days or more past due for purposes of this disclosure. We closely monitor performance of the loans to borrowers experiencing financial difficulty that are modified to understand the effectiveness of the modification efforts. Three Months Ended March 31, (Dollars in millions) 2024 2023 Modified loans (amortized cost) (1) $ 179 $ 2 Payment default (par) $ 183 $ 2 Charge-offs (par) $ 11 $ — (1) For the three months ended March 31, 2024 , the modified loans include $ 123 million of Interest Rate Reduction, $ 12 million of Combination Rate Reduction and Term Extension, and $ 44 million of More Than Insignificant Payment Delay . For the three months ended March 31, 2023, the modified loans include $ 1.6 million of Interest Rate Reduction and $ 0.1 million of Combination Rate Reduction and Term Extension. The following table provides the performance and related loan status of Private Education Loans that have been modified during the respective reporting periods. (Dollars in millions) Payment Status (Amortized Cost) Loan Status March 31, 2024 December 31, 2023 March 31, 2023 Loans in school/deferment $ 1 $ 22 $ 2 Loans in forbearance 33 93 22 Loans current 872 2,199 891 Loans delinquent 31 - 60 days 9 160 8 Loans delinquent 61 - 90 days 2 96 2 Loans delinquent greater than 90 days 4 159 7 Total modified loans $ 921 $ 2,729 $ 932 |