Allowance for Loan Losses | 4. Our provisions for loan losses represent the periodic expense of maintaining an allowance sufficient to absorb incurred probable losses, net of expected recoveries, in the held-for-investment loan portfolios. The evaluation of the provisions for loan losses is inherently subjective, as it requires material estimates that may be susceptible to significant changes. We segregate our Private Education portfolio into two classes of loans in monitoring and assessing credit risk – Troubled Debt Restructurings (“TDRs”) and Non-TDRs. We believe that the allowance for loan losses is appropriate to cover probable losses incurred in the loan portfolios. Allowance for Loan Losses Metrics Year Ended December 31, 2017 (Dollars in millions) FFELP Loans Private Education Loans Other Loans Total Allowance for Loan Losses Beginning balance $ 67 $ 1,351 $ 15 $ 1,433 Total provision 42 382 2 426 Charge-offs (1) (49 ) (443 ) (7 ) (499 ) Reclassification of interest reserve (2) — 7 — 7 Ending balance $ 60 $ 1,297 $ 10 $ 1,367 Allowance Ending Balance: Individually evaluated for impairment - TDR $ — $ 1,171 $ 9 $ 1,180 Collectively evaluated for impairment: Excluding Purchased Non-Credit Impaired Loans acquired at a discount and Purchased Credit Impaired Loans 60 126 1 187 Purchased Non-Credit Impaired Loans acquired at a discount (3) — — — — Purchased Credit Impaired Loans (3) — — — — Ending total allowance $ 60 $ 1,297 $ 10 $ 1,367 Loans Ending Balance: Individually evaluated for impairment - TDR $ — $ 10,921 $ 30 $ 10,951 Collectively evaluated for impairment: Excluding Purchased Non-Credit Impaired Loans acquired at a discount and Purchased Credit Impaired Loans 77,860 11,861 40 89,761 Purchased Non-Credit Impaired Loans acquired at a discount (3) 3,237 2,610 — 5,847 Purchased Credit Impaired Loans (3) — 248 — 248 Ending total loans (4) $ 81,097 $ 25,640 $ 70 $ 106,807 Charge-offs as a percentage of average loans in repayment .07 % 1.98 % 5.39 % Allowance coverage of charge-offs 1.2 2.9 1.5 Allowance as a percentage of the ending total loan balance (3) .07 % 5.06 % 14.32 % Allowance as a percentage of the ending loans in repayment (3) .09 % 5.66 % 14.32 % Ending total loans (4) $ 81,097 $ 25,640 $ 70 Average loans in repayment $ 68,318 $ 22,342 $ 130 Ending loans in repayment $ 67,853 $ 22,924 $ 70 (1) Charge-offs are reported net of expected recoveries. For Private Education Loans, the expected recovery amount is transferred to the receivable for partially charged-off loan balance. Charge-offs include charge-offs against the receivable for partially charged-off loans which represents the difference between what was expected to be recovered and any shortfalls in what was actually recovered in the period. See “Receivable for Partially Charged-Off Private Education Loans” for further discussion. (2) Represents the additional allowance related to the amount of uncollectible interest reserved within interest income that is transferred in the period to the allowance for loan losses when interest is capitalized to a loan’s principal balance. (3) See “Note 2 — Significant Accounting Policies — Allowance for Loan Losses” for a description of our policy for the $6.5 billion of loans ($3.5 billion of FFELP and $3.0 billion of Private Education) purchased in 2017 accounted for as either Purchased Credit Impaired Loans or Purchased Non-Credit Impaired Loans. The Purchased Credit Impaired Loans’ losses are not provided for by the allowance for loan losses in the above table as these loans are separately reserved for, if needed. No allowance for loan losses has been established for these loans as of December 31, 2017. The losses of the Purchased Non-Credit Impaired Loans acquired at a discount are not provided for by the allowance for loan losses in the above table as the remaining purchased discount associated with the FFELP and Private Education Loans of $43 million and $392 million, respectively, as of December 31, 2017 is greater than the incurred losses and as a result no allowance for loan losses has been established for these loans as of December 31, 2017. As a result, excluding the $6.5 billion of loans acquired in 2017, the allowance as a percentage of the ending total loan balance and the allowance as a percentage of the ending loans in repayment would be 0.08 percent and 0.09 percent for FFELP Loans and 5.69 percent and 6.42 percent for Private Education Loans, respectively. (4) Ending total loans for Private Education Loans includes the receivable for partially charged-off loans. Year Ended December 31, 2016 (Dollars in millions) FFELP Loans Private Education Loans Other Loans Total Allowance for Loan Losses Beginning balance $ 78 $ 1,471 $ 15 $ 1,564 Total provision 43 383 3 429 Charge-offs (1) (54 ) (513 ) (3 ) (570 ) Reclassification of interest reserve (2) — 10 — 10 Ending balance $ 67 $ 1,351 $ 15 $ 1,433 Allowance Ending Balance: Individually evaluated for impairment - TDR $ — $ 1,190 $ 11 $ 1,201 Collectively evaluated for impairment 67 161 4 232 Ending total allowance $ 67 $ 1,351 $ 15 $ 1,433 Loans Ending Balance: Individually evaluated for impairment - TDR $ — $ 11,165 $ 32 $ 11,197 Collectively evaluated for impairment 86,918 13,983 132 101,033 Ending total loans (3) $ 86,918 $ 25,148 $ 164 $ 112,230 Charge-offs as a percentage of average loans in repayment .07 % 2.20 % 2.10 % Allowance coverage of charge-offs 1.2 2.6 7.0 Allowance as a percentage of the ending total loan balance .08 % 5.37 % 9.35 % Allowance as a percentage of the ending loans in repayment .09 % 6.10 % 9.35 % Ending total loans (3) $ 86,918 $ 25,148 $ 164 Average loans in repayment $ 72,714 $ 23,275 $ 104 Ending loans in repayment $ 70,557 $ 22,150 $ 164 (1) Charge-offs are reported net of expected recoveries. For Private Education Loans, the expected recovery amount is transferred to the receivable for partially charged-off loan balance. Charge-offs include charge-offs against the receivable for partially charged-off loans which represents the difference between what was expected to be recovered and any shortfalls in what was actually recovered in the period. See “Receivable for Partially Charged-Off Private Education Loans” for further discussion. (2) Represents the additional allowance related to the amount of uncollectible interest reserved within interest income that is transferred in the period to the allowance for loan losses when interest is capitalized to a loan’s principal balance. (3) Ending total loans for Private Education Loans includes the receivable for partially charged-off loans. Year Ended December 31, 2015 (Dollars in millions) FFELP Loans Private Education Loans Other Loans Total Allowance for Loan Losses Beginning balance $ 93 $ 1,916 $ 24 $ 2,033 Total provision 46 538 (3 ) 581 Net adjustment resulting from the change in the charge-off rate (1) — (330 ) — (330 ) Net charge-offs remaining (2) (61 ) (659 ) (6 ) (726 ) Total net charge-offs (61 ) (989 ) (6 ) (1,056 ) Reclassification of interest reserve (3) — 11 — 11 Loan sales — (5 ) — (5 ) Ending balance $ 78 $ 1,471 $ 15 $ 1,564 Allowance Ending Balance: Individually evaluated for impairment - TDR $ — $ 1,209 $ 12 $ 1,221 Collectively evaluated for impairment 78 262 3 343 Ending total allowance $ 78 $ 1,471 $ 15 $ 1,564 Loans Ending Balance: Individually evaluated for impairment - TDR $ — $ 10,965 $ 37 $ 11,002 Collectively evaluated for impairment 95,393 17,431 49 112,873 Ending total loans (4) $ 95,393 $ 28,396 $ 86 $ 123,875 Net charge-offs as a percentage of average loans in repayment, excluding the net adjustment resulting from the change in the charge-off rate (annualized) (1) .08 % 2.55 % 6.17 % Net adjustment resulting from the change in the charge-off rate as a percentage of average loans in repayment (annualized) (1) — % 1.28 % — % Allowance coverage of net charge-offs, excluding the net adjustment resulting from the change in the charge-off rate (annualized) (1) 1.3 2.2 2.5 Allowance as a percentage of the ending total loan balance .08 % 5.18 % 17.28 % Allowance as a percentage of the ending loans in repayment .11 % 6.00 % 17.28 % Ending total loans (4) $ 95,393 $ 28,396 $ 86 Average loans in repayment $ 75,925 $ 25,802 $ 97 Ending loans in repayment $ 73,838 $ 24,502 $ 86 (1) In 2015, the portion of the loan amount charged off at default on Private Education Loans increased from 73 percent to 79 percent. This did not impact the provision for loan losses as previously this had been reserved through the allowance for loan losses. This change resulted in a $330 million reduction to the balance of the receivable for partially charged-off loans. (2) Charge-offs are reported net of expected recoveries. For Private Education Loans, the expected recovery amount is transferred to the receivable for partially charged-off loan balance. Charge-offs include charge-offs against the receivable for partially charged-off loans which represents the difference between what was expected to be recovered and any shortfalls in what was actually recovered in the period. See “Receivable for Partially Charged-Off Private Education Loans” for further discussion. (3) Represents the additional allowance related to the amount of uncollectible interest reserved within interest income that is transferred in the period to the allowance for loan losses when interest is capitalized to a loan’s principal balance. (4) Ending total loans for Private Education Loans includes the receivable for partially charged-off loans. Key Credit Quality Indicators FFELP Loans are substantially insured and guaranteed as to their principal and accrued interest in the event of default; therefore, the key credit quality indicator for this portfolio is loan status. The impact of changes in loan status is incorporated quarterly into the allowance for loan losses calculation. FFELP Loan Delinquencies December 31, 2017 2016 2015 (Dollars in millions) Balance % Balance % Balance % Loans in-school/grace/deferment (1) $ 4,711 $ 5,871 $ 8,257 Loans in forbearance (2) 8,533 10,490 13,298 Loans in repayment and percentage of each status: Loans current 59,264 87.3 % 61,977 87.8 % 62,651 84.8 % Loans delinquent 31-60 days (3) 2,638 3.9 2,820 4.0 3,285 4.5 Loans delinquent 61-90 days (3) 1,763 2.6 1,325 1.9 1,856 2.5 Loans delinquent greater than 90 days (3) 4,188 6.2 4,435 6.3 6,046 8.2 Total FFELP Loans in repayment 67,853 100 % 70,557 100 % 73,838 100 % Total FFELP Loans, gross 81,097 86,918 95,393 FFELP Loan unamortized premium 666 879 1,087 Total FFELP Loans 81,763 87,797 96,480 FFELP Loan allowance for losses (60 ) (67 ) (78 ) FFELP Loans, net $ 81,703 $ 87,730 $ 96,402 Percentage of FFELP Loans in repayment 83.7 % 81.2 % 77.4 % Delinquencies as a percentage of FFELP Loans in repayment 12.7 % 12.2 % 15.2 % FFELP Loans in forbearance as a percentage of loans in repayment and forbearance 11.2 % 12.9 % 15.3 % (1) Loans for customers who may still be attending school or engaging in other permitted educational activities and are not required to make payments on the 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. (3) The period of delinquency is based on the number of days scheduled payments are contractually past due. For Private Education Loans, the key credit quality indicators are FICO scores, school type, the existence of a cosigner, the loan status and loan seasoning. The FICO scores/school type are assessed at origination. The other Private Education Loan key quality indicators can change and are incorporated quarterly into the allowance for loan losses calculation. The following table highlights the principal balance (excluding the receivable for partially charged-off loans) of our Private Education Loan portfolio stratified by the key credit quality indicators. Private Education Loans Credit Quality Indicators TDR December 31, 2017 December 31, 2016 (Dollars in millions) Balance (2) % of Balance Balance (2) % of Balance Credit Quality Indicators Original Winning FICO Scores: FICO 640 and above $ 9,647 92 % $ 9,863 91 % FICO below 640 889 8 942 9 Total $ 10,536 100 % $ 10,805 100 % School Type: Not-for-profit $ 8,247 78 % $ 8,346 77 % For-profit 2,289 22 2,459 23 Total $ 10,536 100 % $ 10,805 100 % Cosigners: With cosigner $ 6,441 61 % $ 6,486 60 % Without cosigner 4,095 39 4,319 40 Total $ 10,536 100 % $ 10,805 100 % Seasoning (1) 1-12 payments $ 506 5 % $ 754 7 % 13-24 payments 644 6 927 9 25-36 payments 947 9 1,289 12 37-48 payments 1,271 12 1,620 15 More than 48 payments 6,691 63 5,636 52 Not yet in repayment 477 5 579 5 Total $ 10,536 100 % $ 10,805 100 % (1) Number of months in active repayment for which a scheduled payment was received. (2) Balance equals the gross Private Education Loans. Private Education Loans Credit Quality Indicators Non-TDR December 31, 2017 December 31, 2016 (Dollars in millions) Balance (2) % of Balance Balance (2) % of Balance Credit Quality Indicators Original Winning FICO Scores: FICO 640 and above $ 13,752 96 % $ 13,120 97 % FICO below 640 592 4 408 3 Total $ 14,344 100 % $ 13,528 100 % School Type: Not-for-profit $ 12,431 87 % $ 11,338 84 % For-profit 1,913 13 2,190 16 Total $ 14,344 100 % $ 13,528 100 % Cosigners: With cosigner $ 9,193 64 % $ 9,124 67 % Without cosigner 5,151 36 4,404 33 Total $ 14,344 100 % $ 13,528 100 % Seasoning (1) 1-12 payments $ 1,424 10 % $ 586 4 % 13-24 payments 437 3 344 3 25-36 payments 466 3 619 5 37-48 payments 867 6 1,103 8 More than 48 payments 10,566 74 10,062 74 Not yet in repayment 584 4 814 6 Total $ 14,344 100 % $ 13,528 100 % (1) Number of months in active repayment for which a scheduled payment was received. (2) TDR Private Education Loan Delinquencies December 31, 2017 2016 2015 (Dollars in millions) Balance % Balance % Balance % Loans in-school/grace/deferment (1) $ 477 $ 579 $ 706 Loans in forbearance (2) 681 588 694 Loans in repayment and percentage of each status: Loans current 8,333 88.9 % 8,273 85.8 % 7,887 85.3 % Loans delinquent 31-60 days (3) 351 3.7 412 4.3 414 4.5 Loans delinquent 61-90 days (3) 207 2.2 267 2.8 263 2.9 Loans delinquent greater than 90 days (3) 487 5.2 686 7.1 678 7.3 Total TDR loans in repayment 9,378 100 % 9,638 100 % 9,242 100 % Total TDR loans, gross 10,536 10,805 10,642 TDR loans unamortized discount (225 ) (237 ) (243 ) Total TDR loans 10,311 10,568 10,399 TDR loans receivable for partially charged-off loans 385 360 323 TDR loans allowance for losses (1,171 ) (1,190 ) (1,209 ) TDR loans, net $ 9,525 $ 9,738 $ 9,513 Percentage of TDR loans in repayment 89.0 % 89.2 % 86.8 % Delinquencies as a percentage of TDR loans in repayment 11.1 % 14.2 % 14.7 % Loans in forbearance as a percentage of TDR loans in repayment and forbearance 6.8 % 5.7 % 7.0 % (1) Deferment includes customers who have returned to school or are engaged in other permitted educational activities and are not required to make payments on the loans, e.g., residency periods for medical students or a grace period for bar exam preparation. (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, 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. Non-TDR Private Education Loan Delinquencies December 31, 2017 2016 2015 (Dollars in millions) Balance % Balance % Balance % Loans in-school/grace/deferment (1) $ 584 $ 814 $ 1,334 Loans in forbearance (2) 214 202 279 Loans in repayment and percentage of each status: Loans current 13,257 97.9 % 12,233 97.8 % 14,844 97.3 % Loans delinquent 31-60 days (3) 120 .9 110 .9 163 1.1 Loans delinquent 61-90 days (3) 59 .4 54 .4 85 .6 Loans delinquent greater than 90 days (3) 110 .8 115 .9 168 1.0 Total non-TDR loans in repayment 13,546 100 % 12,512 100 % 15,260 100 % Total non-TDR loans, gross 14,344 13,528 16,873 Non-TDR loans unamortized discount (699 ) (220 ) (288 ) Total non-TDR loans 13,645 13,308 16,585 Non-TDR loans receivable for partially charged-off loans 375 455 558 Non-TDR loans allowance for losses (126 ) (161 ) (262 ) Non-TDR loans, net $ 13,894 $ 13,602 $ 16,881 Percentage of non-TDR loans in repayment 94.4 % 92.5 % 90.4 % Delinquencies as a percentage of non-TDR loans in repayment 2.1 % 2.2 % 2.7 % Loans in forbearance as a percentage of non- TDR loans in repayment and forbearance 1.6 % 1.6 % 1.8 % (1) Deferment includes customers who have returned to school or are engaged in other permitted educational activities and are not required to make payments on the loans, e.g., residency periods for medical students or a grace period for bar exam preparation. (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, 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. Receivable for Partially Charged-Off Private Education Loans At the end of each month, for loans that are 212 or more days past due, we charge off the estimated loss of a defaulted loan balance. Actual recoveries are applied against the remaining loan balance that was not charged off. We refer to this remaining loan balance as the “receivable for partially charged-off loans.” If actual periodic recoveries are less than expected, the difference is immediately charged off through the allowance for Private Education Loan losses with an offsetting reduction in the receivable for partially charged-off Private Education 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 financial crisis, which began in 2007, impacted our collections on defaulted loans and as a result, Private Education Loans which defaulted from 2007 through March 31, 2015, experienced collection performance below our pre-financial crisis experience. For that reason, until we gained enough data and experience to determine the long-term, post-default recovery rate of 21 percent in second-quarter 2015, we established a reserve for potential shortfalls in recoveries. In the second quarter of 2015, the portion of the loan amount charged off at default increased from 73 percent to 79 percent. This did not impact the provision for loan losses as previously this had been reserved through the allowance for loan losses. This change resulted in a $330 million reduction to the balance of the receivable for partially charged-off loans. The following table summarizes the activity in the receivable for partially charged-off loans. Years Ended December 31, (Dollars in millions) 2017 2016 2015 Receivable at beginning of period $ 815 $ 881 $ 1,245 Expected future recoveries of current period defaults (1) 110 128 183 Recoveries (2) (155 ) (181 ) (191 ) Net adjustment resulting from the change in the charge-off rate (3) — — (330 ) Net charge-offs remaining (4) (10 ) (13 ) (26 ) Total net charge-offs (5) (10 ) (13 ) (356 ) Receivable at end of period $ 760 $ 815 $ 881 (1) Represents our estimate of the amount to be collected in the future. (2) Current period cash collections. (3) In 2015, the portion of the loan amount charged off at default increased from 73 percent to 79 percent. This change resulted in a $330 million reduction to the balance of the receivable for partially charged-off loans. (4) Represents the current period recovery shortfall — the difference between what was expected to be collected and what was actually collected. (5) These amounts are included in total charge-offs as reported in the “Allowance for Private Education Loan Losses” table. Troubled Debt Restructurings (“TDRs”) We sometimes modify the terms of loans for certain customers when we believe such modifications may increase the ability and willingness of a customer to make payments and thus increase the ultimate overall amount collected on a loan. These modifications generally take the form of a forbearance, a temporary interest rate reduction or an extended repayment plan. For customers experiencing financial difficulty, certain Private Education Loans for which we have granted either a forbearance of greater than three months, an interest rate reduction or an extended repayment plan are classified as TDRs. Approximately 61 percent and 61 percent of the loans granted forbearance have qualified as a TDR loan at December 31, 2017, and 2016, respectively. The unpaid principal balance of TDR loans that were in an interest rate reduction plan as of December 31, 2017 and 2016 was $2.7 billion and $2.6 billion, respectively. At December 31, 2017 and 2016, all of our TDR loans had a related allowance recorded. The following table provides the recorded investment, unpaid principal balance and related allowance for our TDR loans. TDR Loans (Dollars in millions) Recorded Investment (1) Total Ending Loans (2) Related Allowance December 31, 2017 $ 10,890 $ 10,921 $ 1,171 December 31, 2016 11,119 11,165 1,190 (1) Recorded investment is equal to the unpaid principal balance (which includes the receivable for partially charged-off loans), accrued interest and unamortized discount. (2) Total ending loans includes the receivable for partially charged-off loans. The following table provides the average recorded investment and interest income recognized for our TDR loans. Years Ended December 31, 2017 2016 2015 (Dollars in millions) Average Recorded Investment Interest Income Recognized Average Recorded Investment Interest Income Recognized Average Recorded Investment Interest Income Recognized Total $ 10,989 $ 708 $ 11,078 $ 667 $ 10,770 $ 653 The following table provides the amount of loans modified in the periods presented that resulted in a TDR. Additionally, the table summarizes charge-offs occurring in the TDR portfolio, as well as TDRs for which a payment default occurred in the current period within 12 months of the loan first being designated as a TDR. We define payment default as 60 days past due for this disclosure. Years Ended December 31, 2017 2016 2015 (Dollars in millions) Modified Loans (1) Charge- Offs (2) Payment- Default Modified Loans (1) Charge- Offs (2) Payment- Default Modified Loans (1) Charge- Offs (2) Payment- Default Total $ 816 $ 346 $ 181 $ 1,169 $ 382 $ 265 $ 1,604 $ 459 $ 403 (1) Represents period ending balance of loans that have been modified during the period and resulted in a TDR. (2) Represents loans that charged off that were classified as TDRs. Accrued Interest Receivable The following table provides information regarding accrued interest receivable on our Private Education Loans. Accrued Interest Receivable As of December 31, (Dollars in millions) Total Greater Than 90 Days Past Due Allowance for Uncollectible Interest 2017 TDR $ 196 $ 20 $ 20 Non-TDR 187 4 6 Total $ 383 $ 24 $ 26 2016 TDR $ 192 $ 28 $ 23 Non-TDR 199 5 7 Total $ 391 $ 33 $ 30 2015 TDR $ 201 $ 28 $ 26 Non-TDR 289 7 9 Total $ 490 $ 35 $ 35 |