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 Loan portfolio in 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. 4. Allowance for Loan Losses Metrics Year Ended December 31, 2018 (Dollars in millions) FFELP Loans Private Education Loans Other Loans Total Allowance for Loan Losses Beginning balance $ 60 $ 1,297 $ 10 $ 1,367 Total provision 70 299 1 370 Net adjustment resulting from the change in the charge- off rate (1) — (32 ) — (32 ) Net charge-offs remaining (2) (54 ) (371 ) (2 ) (427 ) Total net charge-offs (54 ) (403 ) (2 ) (459 ) Reclassification of interest reserve (3) — 8 — 8 Ending balance $ 76 $ 1,201 $ 9 $ 1,286 Allowance Ending Balance: Individually evaluated for impairment — TDR $ — $ 1,100 $ 8 $ 1,108 Collectively evaluated for impairment: Excluding Purchased Non-Credit Impaired Loans acquired at a discount and Purchased Credit Impaired Loans 76 101 1 178 Purchased Non-Credit Impaired Loans acquired at a discount (4) — — — — Purchased Credit Impaired Loans (4) — — — — Ending total allowance $ 76 $ 1,201 $ 9 $ 1,286 Loans Ending Balance: Individually evaluated for impairment — TDR $ — $ 10,336 $ 28 $ 10,364 Collectively evaluated for impairment: Excluding Purchased Non-Credit Impaired Loans acquired at a discount and Purchased Credit Impaired Loans 68,880 11,464 51 80,395 Purchased Non-Credit Impaired Loans acquired at a discount (4) 2,850 2,180 — 5,030 Purchased Credit Impaired Loans (4) — 225 — 225 Ending total loans (5) $ 71,730 $ 24,205 $ 79 $ 96,014 Net charge-offs as a percentage of average loans in repayment, excluding the net adjustment resulting from the change in the charge-off rate (1) .09 % 1.66 % — % Net adjustment resulting from the change in charge-off rate as a percentage of average loans in repayment (1) — % .14 % — % Allowance coverage of charge-offs 1.4 3.0 — Allowance as a percentage of the ending total loan balance .11 % 4.96 % 11.52 % Allowance as a percentage of the ending loans in repayment .13 % 5.45 % 11.52 % Ending total loans (5) $ 71,730 $ 24,205 $ 79 Average loans in repayment $ 62,927 $ 22,312 $ 75 Ending loans in repayment $ 59,551 $ 22,037 $ 79 (1) In third-quarter 2018, the portion of the loan amount charged off at default on Private Education Loans increased from 79 percent to 80.5 percent. This charge resulted in a $32 million reduction to the balance of the receivable for partially charged-off loan balance. (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) 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, 2018. 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 $37 million and $326 million, respectively, as of December 31, 2018 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, 2018. (5) Ending total loans for Private Education Loans includes the receivable for partially charged-off loans. 4. 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 .07 % 5.06 % 14.32 % Allowance as a percentage of the ending loans in repayment .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) 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. (4) Ending total loans for Private Education Loans includes the receivable for partially charged-off loans. 4. 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. 4. Key Credit Quality Indicators FFELP Loans are substantially insured and guaranteed as to their principal and accrued interest in the event of default. 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, 2018 December 31, 2017 December 31, 2016 (Dollars in millions) Balance % Balance % Balance % Loans in-school/grace/deferment (1) $ 3,793 $ 4,711 $ 5,871 Loans in forbearance (2) 8,386 8,533 10,490 Loans in repayment and percentage of each status: Loans current 53,500 89.8 % 59,264 87.3 % 61,977 87.8 % Loans delinquent 31-60 days (3) 1,964 3.4 2,638 3.9 2,820 4.0 Loans delinquent 61-90 days (3) 910 1.5 1,763 2.6 1,325 1.9 Loans delinquent greater than 90 days (3) 3,177 5.3 4,188 6.2 4,435 6.3 Total FFELP Loans in repayment 59,551 100 % 67,853 100 % 70,557 100 % Total FFELP Loans, gross 71,730 81,097 86,918 FFELP Loan unamortized premium 599 666 879 Total FFELP Loans 72,329 81,763 87,797 FFELP Loan allowance for losses (76 ) (60 ) (67 ) FFELP Loans, net $ 72,253 $ 81,703 $ 87,730 Percentage of FFELP Loans in repayment 83.0 % 83.7 % 81.2 % Delinquencies as a percentage of FFELP Loans in repayment 10.2 % 12.7 % 12.2 % FFELP Loans in forbearance as a percentage of loans in repayment and forbearance 12.3 % 11.2 % 12.9 % (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. (3) The period of delinquency is based on the number of days scheduled payments are contractually past due. 4. 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 and 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 TDRs December 31, 2018 December 31, 2017 (Dollars in millions) Balance (2) % of Balance Balance (2) % of Balance Credit Quality Indicators Original Winning FICO Scores: FICO 640 and above $ 9,133 92 % $ 9,647 92 % FICO below 640 836 8 889 8 Total $ 9,969 100 % $ 10,536 100 % School Type: Not-for-profit $ 7,888 79 % $ 8,247 78 % For-profit 2,081 21 2,289 22 Total $ 9,969 100 % $ 10,536 100 % Cosigners: With cosigner $ 6,172 62 % $ 6,441 61 % Without cosigner 3,797 38 4,095 39 Total $ 9,969 100 % $ 10,536 100 % Seasoning (1) 1-12 payments $ 335 3 % $ 506 5 % 13-24 payments 436 4 644 6 25-36 payments 660 7 947 9 37-48 payments 934 10 1,271 12 More than 48 payments 7,178 72 6,691 63 Not yet in repayment 426 4 477 5 Total $ 9,969 100 % $ 10,536 100 % (1) Number of months in active repayment for which a scheduled payment was received. (2) Balance equals the gross Private Education Loans. 4. Private Education Loans Credit Quality Indicators Non-TDRs December 31, 2018 December 31, 2017 (Dollars in millions) Balance (2) % of Balance Balance (2) % of Balance Credit Quality Indicators Original Winning FICO Scores: FICO 640 and above $ 13,087 96 % $ 13,752 96 % FICO below 640 475 4 592 4 Total $ 13,562 100 % $ 14,344 100 % School Type: Not-for-profit $ 11,953 88 % $ 12,431 87 % For-profit 1,609 12 1,913 13 Total $ 13,562 100 % $ 14,344 100 % Cosigners: With cosigner $ 6,961 51 % $ 9,193 64 % Without cosigner 6,601 49 5,151 36 Total $ 13,562 100 % $ 14,344 100 % Seasoning (1) 1-12 payments $ 3,353 25 % $ 1,424 10 % 13-24 payments 486 3 437 3 25-36 payments 322 2 466 3 37-48 payments 383 3 867 6 More than 48 payments 8,626 64 10,566 74 Not yet in repayment 392 3 584 4 Total $ 13,562 100 % $ 14,344 100 % (1) Number of months in active repayment for which a scheduled payment was received. (2) 4. Private Education Loan Delinquencies TDRs December 31, 2018 December 31, 2017 December 31, 2016 (Dollars in millions) Balance % Balance % Balance % Loans in-school/grace/deferment (1) $ 426 $ 477 $ 579 Loans in forbearance (2) 518 681 588 Loans in repayment and percentage of each status: Loans current 7,890 87.4 % 8,333 88.9 % 8,273 85.8 % Loans delinquent 31-60 days (3) 344 3.8 351 3.7 412 4.3 Loans delinquent 61-90 days (3) 235 2.6 207 2.2 267 2.8 Loans delinquent greater than 90 days (3) 556 6.2 487 5.2 686 7.1 Total TDR loans in repayment 9,025 100 % 9,378 100 % 9,638 100 % Total TDR loans, gross 9,969 10,536 10,805 TDR loans unamortized discount (212 ) (225 ) (237 ) Total TDR loans 9,757 10,311 10,568 TDR loans receivable for partially charged-off loans 367 385 360 TDR loans allowance for losses (1,100 ) (1,171 ) (1,190 ) TDR loans, net $ 9,024 $ 9,525 $ 9,738 Percentage of TDR loans in repayment 90.5 % 89.0 % 89.2 % Delinquencies as a percentage of TDR loans in repayment 12.6 % 11.1 % 14.2 % Loans in forbearance as a percentage of TDR loans in repayment and forbearance 5.4 % 6.8 % 5.7 % (1) Deferment includes customers who have returned to school or are engaged 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. (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. 4. Private Education Loan Delinquencies Non-TDRs December 31, 2018 December 31, 2017 December 31, 2016 (Dollars in millions) Balance % Balance % Balance % Loans in-school/grace/deferment (1) $ 392 $ 584 $ 814 Loans in forbearance (2) 158 214 202 Loans in repayment and percentage of each status: Loans current 12,851 98.8 % 13,257 97.9 % 12,233 97.8 % Loans delinquent 31-60 days (3) 71 .5 120 .9 110 .9 Loans delinquent 61-90 days (3) 32 .3 59 .4 54 .4 Loans delinquent greater than 90 days (3) 58 .4 110 .8 115 .9 Total non-TDR loans in repayment 13,012 100 % 13,546 100 % 12,512 100 % Total non-TDR loans, gross 13,562 14,344 13,528 Non-TDR loans unamortized discount (547 ) (699 ) (220 ) Total non-TDR loans 13,015 13,645 13,308 Non-TDR loans receivable for partially charged-off loans 307 375 455 Non-TDR loans allowance for losses (101 ) (126 ) (161 ) Non-TDR loans, net $ 13,221 $ 13,894 $ 13,602 Percentage of non-TDR loans in repayment 95.9 % 94.4 % 92.5 % Delinquencies as a percentage of non-TDR loans in repayment 1.2 % 2.1 % 2.2 % Loans in forbearance as a percentage of non- TDR loans in repayment and forbearance 1.2 % 1.6 % 1.6 % (1) Deferment includes customers who have returned to school or are engaged 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. (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. 4. The following table summarizes the activity in the receivable for partially charged-off loans. Years Ended December 31, (Dollars in millions) 2018 2017 2016 Receivable at beginning of period $ 760 $ 815 $ 881 Expected future recoveries of current period defaults (1) 89 110 128 Recoveries (2) (139 ) (155 ) (181 ) Charge-offs (3) (36 ) (10 ) (13 ) Receivable at end of period $ 674 $ 760 $ 815 (1) Represents our estimate of the amount to be collected in the future. (2) Current period cash collections. (3) Represents the current period recovery shortfall — the difference between what was expected to be collected and what was actually collected. Additionally, in third-quarter 2018, the portion of the loan amount charged off at default increased from 79 percent to 80.5 percent. This change resulted in a $32 million reduction to the balance of the receivable for partially charged-off loans. 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 customers experiencing financial difficulty. Where we have granted either a forbearance of greater than three months, an interest rate reduction or an extended repayment plan, these are classified as TDRs. Approximately 65 percent and 61 percent of the loans granted forbearance have qualified as a TDR loan at December 31, 2018, and 2017, respectively. The unpaid principal balance of TDR loans that were in an interest rate reduction plan as of December 31, 2018 and 2017 was $1.8 billion and $2.7 billion, respectively. At December 31, 2018 and 2017, 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. TDRs (Dollars in millions) December 31, 2018 December 31, 2017 Recorded investment (1) $ 10,326 $ 10,890 Total ending loans (2) $ 10,336 $ 10,921 Related allowance $ 1,100 $ 1,171 (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. 4. The following table provides the average recorded investment and interest income recognized for our TDR loans. Years Ended December 31, (Dollars in millions) 2018 2017 2016 Average recorded investment $ 10,637 $ 10,989 $ 11,078 Interest income recognized $ 764 $ 708 $ 667 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, (Dollars in millions) 2018 2017 2016 Modified loans (1) $ 596 $ 816 $ 1,169 Charge-offs (2) $ 343 $ 346 $ 382 Payment-default $ 142 $ 181 $ 265 (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. (Dollars in millions) Total Greater Than 90 Days Past Due Allowance for Uncollectible Interest December 31, 2018 TDR $ 205 $ 26 $ 23 Non-TDR 149 3 4 Total $ 354 $ 29 $ 27 December 31, 2017 TDR $ 196 $ 20 $ 20 Non-TDR 187 4 6 Total $ 383 $ 24 $ 26 December 31, 2016 TDR $ 192 $ 28 $ 23 Non-TDR 199 5 7 Total $ 391 $ 33 $ 30 |