Allowance for Loan Losses | 2. Allowance for Loan Losses 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 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. 2. Allowance for Loan Losses (Continued) Allowance for Loan Losses Metrics Three Months Ended September 30, 2019 (Dollars in millions) FFELP Loans Private Education Loans Other Loans Total Allowance for Loan Losses Beginning balance $ 67 $ 1,151 $ — $ 1,218 Total provision 8 56 — 64 Net adjustment resulting from the change in the charge-off rate (1) — (21 ) — (21 ) Net charge-offs remaining (2) (9 ) (87 ) — (96 ) Total net charge-offs (9 ) (108 ) — (117 ) Reclassification of interest reserve (3) — 2 — 2 Ending balance $ 65 $ 1,101 $ — $ 1,166 Allowance Ending Balance: Individually evaluated for impairment — TDR $ — $ 998 $ — $ 998 Collectively evaluated for impairment: Excluding Purchased Non-Credit Impaired Loans acquired at a discount and Purchased Credit Impaired Loans 65 103 — 168 Purchased Non-Credit Impaired Loans acquired at a discount (4) — — — — Purchased Credit Impaired Loans (4) — — — — Ending total allowance $ 65 $ 1,101 $ — $ 1,166 Loans Ending Balance: Individually evaluated for impairment — TDR $ — $ 9,810 $ — $ 9,810 Collectively evaluated for impairment: Excluding Purchased Non-Credit Impaired Loans acquired at a discount and Purchased Credit Impaired Loans 63,003 11,683 6 74,692 Purchased Non-Credit Impaired Loans acquired at a discount (4) 2,585 1,892 — 4,477 Purchased Credit Impaired Loans (4) — 208 — 208 Ending total loans (5) $ 65,588 $ 23,593 $ 6 $ 89,187 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) .06 % 1.60 % — % Net adjustment resulting from the change in charge-off rate as a percentage of average loans in repayment (1) — % .39 % — % Allowance coverage of charge-offs 1.9 2.6 — Allowance as a percentage of the ending total loan balance .10 % 4.67 % — % Allowance as a percentage of the ending loans in repayment .12 % 5.08 % — % Ending total loans (5) $ 65,588 $ 23,593 $ 6 Average loans in repayment $ 54,973 $ 21,549 $ 5 Ending loans in repayment $ 54,395 $ 21,655 $ 6 (1) (2) (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 September 30, 2019. 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 $34 million and $281 million, respectively, as of September 30, 2019 is greater than the incurred losses and as a result no allowance for loan losses has been established for these loans as of September 30, 2019. (5) Ending total loans for Private Education Loans includes the receivable for partially charged-off loans. 2. Allowance for Loan Losses (Continued) Three Months Ended September 30, 2018 (Dollars in millions) FFELP Loans Private Education Loans Other Loans Total Allowance for Loan Losses Beginning balance $ 82 $ 1,297 $ 10 $ 1,389 Total provision 10 75 — 85 Net adjustment resulting from the change in the charge-off rate (1) — (32 ) — (32 ) Net charge-offs remaining (2) (13 ) (116 ) — (129 ) Total net charge-offs (13 ) (148 ) — (161 ) Reclassification of interest reserve (3) — 2 — 2 Ending balance $ 79 $ 1,226 $ 10 $ 1,315 Allowance Ending Balance: Individually evaluated for impairment — TDR $ — $ 1,134 $ 9 $ 1,143 Collectively evaluated for impairment: Excluding Purchased Non-Credit Impaired Loans acquired at a discount and Purchased Credit Impaired Loans 79 92 1 172 Purchased Non-Credit Impaired Loans acquired at a discount (4) — — — — Purchased Credit Impaired Loans (4) — — — — Ending total allowance $ 79 $ 1,226 $ 10 $ 1,315 Loans Ending Balance: Individually evaluated for impairment — TDR $ — $ 10,497 $ 29 $ 10,526 Collectively evaluated for impairment: Excluding Purchased Non-Credit Impaired Loans acquired at a discount and Purchased Credit Impaired Loans 70,778 11,459 49 82,286 Purchased Non-Credit Impaired Loans acquired at a discount (4) 2,941 2,282 — 5,223 Purchased Credit Impaired Loans (4) — 231 — 231 Ending total loans (5) $ 73,719 $ 24,469 $ 78 $ 98,266 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 % 2.08 % — % Net adjustment resulting from the change in charge-off rate as a percentage of average loans in repayment (1) — % .57 % — % Allowance coverage of charge-offs 1.5 2.1 — Allowance as a percentage of the ending total loan balance .11 % 5.01 % 12.71 % Allowance as a percentage of the ending loans in repayment .13 % 5.57 % 12.71 % Ending total loans (5) $ 73,719 $ 24,469 $ 78 Average loans in repayment $ 61,956 $ 22,158 $ 77 Ending loans in repayment $ 60,959 $ 21,997 $ 78 (1) (2) (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 September 30, 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 $38 million and $343 million, respectively, as of September 30, 2018 is greater than the incurred losses and as a result no allowance for loan losses has been established for these loans as of September 30, 2018. (5) Ending total loans for Private Education Loans includes the receivable for partially charged-off loans. 2. Allowance for Loan Losses (Continued) Nine Months Ended September 30, 2019 (Dollars in millions) FFELP Loans Private Education Loans Other Loans Total Allowance for Loan Losses Beginning balance $ 76 $ 1,201 $ 9 $ 1,286 Total provision 23 185 1 208 Net adjustment resulting from the change in the charge-off rate (1) — (21 ) — (21 ) Net charge-offs remaining (2) (33 ) (267 ) (2 ) (302 ) Total net charge-offs (33 ) (288 ) (2 ) (323 ) Reclassification of interest reserve (3) — 5 — 5 Loan sales and other transactions — (1 ) (8 ) (9 ) Ending balance $ 65 $ 1,101 $ — $ 1,166 Allowance Ending Balance: Individually evaluated for impairment - TDR $ — $ 998 $ — $ 998 Collectively evaluated for impairment: Excluding Purchased Non-Credit Impaired Loans acquired at a discount and Purchased Credit Impaired Loans 65 103 — 168 Purchased Non-Credit Impaired Loans acquired at a discount (4) — — — — Purchased Credit Impaired Loans (4) — — — — Ending total allowance $ 65 $ 1,101 $ — $ 1,166 Loans Ending Balance: Individually evaluated for impairment - TDR $ — $ 9,810 $ — $ 9,810 Collectively evaluated for impairment: Excluding Purchased Non-Credit Impaired Loans acquired at a discount and Purchased Credit Impaired Loans 63,003 11,683 6 74,692 Purchased Non-Credit Impaired Loans acquired at a discount (4) 2,585 1,892 — 4,477 Purchased Credit Impaired Loans (4) — 208 — 208 Ending total loans (5) $ 65,588 $ 23,593 $ 6 $ 89,187 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) .08 % 1.64 % — % Net adjustment resulting from the change in charge-off rate as a percentage of average loans in repayment (1) — % .13 % — % Allowance coverage of charge-offs 1.5 2.9 — Allowance as a percentage of the ending total loan balance .10 % 4.67 % — % Allowance as a percentage of the ending loans in repayment .12 % 5.08 % — % Ending total loans (5) $ 65,588 $ 23,593 $ 6 Average loans in repayment $ 56,605 $ 21,819 $ 36 Ending loans in repayment $ 54,395 $ 21,655 $ 6 (1) (2) (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 September 30, 2019. 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 $34 million and $281 million, respectively, as of September 30, 2019 is greater than the incurred losses and as a result no allowance for loan losses has been established for these loans as of September 30, 2019. (5) Ending total loans for Private Education Loans includes the receivable for partially charged-off loans. 2. Allowance for Loan Losses (Continued) Nine Months Ended September 30, 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 60 224 — 284 Net adjustment resulting from the change in the charge-off rate (1) — (32 ) — (32 ) Net charge-offs remaining (2) (41 ) (269 ) — (310 ) Total net charge-offs (41 ) (301 ) — (342 ) Reclassification of interest reserve (3) — 6 — 6 Ending balance $ 79 $ 1,226 $ 10 $ 1,315 Allowance Ending Balance: Individually evaluated for impairment - TDR $ — $ 1,134 $ 9 $ 1,143 Collectively evaluated for impairment: Excluding Purchased Non-Credit Impaired Loans acquired at a discount and Purchased Credit Impaired Loans 79 92 1 172 Purchased Non-Credit Impaired Loans acquired at a discount (4) — — — — Purchased Credit Impaired Loans (4) — — — — Ending total allowance $ 79 $ 1,226 $ 10 $ 1,315 Loans Ending Balance: Individually evaluated for impairment - TDR $ — $ 10,497 $ 29 $ 10,526 Collectively evaluated for impairment: Excluding Purchased Non-Credit Impaired Loans acquired at a discount and Purchased Credit Impaired Loans 70,778 11,459 49 82,286 Purchased Non-Credit Impaired Loans acquired at a discount (4) 2,941 2,282 — 5,223 Purchased Credit Impaired Loans (4) — 231 — 231 Ending total loans (5) $ 73,719 $ 24,469 $ 78 $ 98,266 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 % 1.61 % — % Net adjustment resulting from the change in charge-off rate as a percentage of average loans in repayment (1) — % .19 % — % Allowance coverage of charge-offs 1.4 3.0 — Allowance as a percentage of the ending total loan balance .11 % 5.01 % 13.02 % Allowance as a percentage of the ending loans in repayment .13 % 5.57 % 13.02 % Ending total loans (5) $ 73,719 $ 24,469 $ 78 Average loans in repayment $ 63,934 $ 22,367 $ 74 Ending loans in repayment $ 60,959 $ 21,997 $ 78 (1) (2) (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 September 30, 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 $38 million and $343 million, respectively, as of September 30, 2018 is greater than the incurred losses and as a result no allowance for loan losses has been established for these loans as of September 30, 2018. (5) Ending total loans for Private Education Loans includes the receivable for partially charged-off loans. 2. Allowance for Loan Losses (Continued) 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 September 30, 2019 December 31, 2018 (Dollars in millions) Balance % Balance % Loans in-school/grace/deferment (1) $ 3,383 $ 3,793 Loans in forbearance (2) 7,810 8,386 Loans in repayment and percentage of each status: Loans current 48,785 89.7 % 53,500 89.8 % Loans delinquent 31-60 days (3) 1,656 3.0 1,964 3.4 Loans delinquent 61-90 days (3) 827 1.5 910 1.5 Loans delinquent greater than 90 days (3) 3,127 5.8 3,177 5.3 Total FFELP Loans in repayment 54,395 100 % 59,551 100 % Total FFELP Loans, gross 65,588 71,730 FFELP Loan unamortized premium 564 599 Total FFELP Loans 66,152 72,329 FFELP Loan allowance for losses (65 ) (76 ) FFELP Loans, net $ 66,087 $ 72,253 Percentage of FFELP Loans in repayment 82.9 % 83.0 % Delinquencies as a percentage of FFELP Loans in repayment 10.3 % 10.2 % FFELP Loans in forbearance as a percentage of loans in repayment and forbearance 12.6 % 12.3 % (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. 2. Allowance for Loan Losses (Continued) 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 Loan Credit Quality Indicators TDRs September 30, 2019 December 31, 2018 (Dollars in millions) Balance (3) % of Balance Balance (3) % of Balance Credit Quality Indicators Original Winning FICO Scores: FICO 640 and above $ 8,670 92 % $ 9,133 92 % FICO below 640 792 8 836 8 Total $ 9,462 100 % $ 9,969 100 % School Type: Not-for-profit $ 7,524 80 % $ 7,888 79 % For-profit 1,938 20 2,081 21 Total $ 9,462 100 % $ 9,969 100 % Cosigners: With cosigner (1) $ 5,904 62 % $ 6,172 62 % Without cosigner 3,558 38 3,797 38 Total $ 9,462 100 % $ 9,969 100 % Seasoning (2) 1-12 payments $ 247 3 % $ 335 3 % 13-24 payments 332 3 436 4 25-36 payments 515 5 660 7 37-48 payments 718 8 934 10 More than 48 payments 7,280 77 7,178 72 Not yet in repayment 370 4 426 4 Total $ 9,462 100 % $ 9,969 100 % (1) Excluding Private Education Refinance Loans, which do not have a cosigner, the cosigner rate was 62% at September 30, 2019 and December 31, 2018. (2) Number of months in active repayment for which a scheduled payment was received. (3) Balance equals the gross Private Education Loans. 2. Allowance for Loan Losses (Continued) Private Education Loan Credit Quality Indicators Non-TDRs September 30, 2019 December 31, 2018 (Dollars in millions) Balance (3) % of Balance Balance (3) % of Balance Credit Quality Indicators Original Winning FICO Scores: FICO 640 and above $ 13,138 97 % $ 13,087 96 % FICO below 640 390 3 475 4 Total $ 13,528 100 % $ 13,562 100 % School Type: Not-for-profit $ 12,073 89 % $ 11,953 88 % For-profit 1,455 11 1,609 12 Total $ 13,528 100 % $ 13,562 100 % Cosigners: With cosigner (1) $ 5,558 41 % $ 6,961 51 % Without cosigner 7,970 59 6,601 49 Total $ 13,528 100 % $ 13,562 100 % Seasoning (2) 1-12 payments $ 3,828 28 % $ 3,353 25 % 13-24 payments 1,508 11 486 3 25-36 payments 517 4 322 2 37-48 payments 258 2 383 3 More than 48 payments 7,112 53 8,626 64 Not yet in repayment 305 2 392 3 Total $ 13,528 100 % $ 13,562 100 % (1) Excluding Private Education Refinance Loans, which do not have a cosigner, the cosigner rate was 67% at September 30, 2019 and December 31, 2018. (2) Number of months in active repayment for which a scheduled payment was received. (3) Balance equals the gross Private Education Loans. 2. Allowance for Loan Losses (Continued) Private Education Loan Delinquencies TDRs September 30, 2019 December 31, 2018 (Dollars in millions) Balance % Balance % Loans in-school/grace/deferment (1) $ 370 $ 426 Loans in forbearance (2) 513 518 Loans in repayment and percentage of each status: Loans current 7,668 89.4 % 7,890 87.4 % Loans delinquent 31-60 days (3) 291 3.4 344 3.8 Loans delinquent 61-90 days (3) 179 2.1 235 2.6 Loans delinquent greater than 90 days (3) 441 5.1 556 6.2 Total TDR loans in repayment 8,579 100 % 9,025 100 % Total TDR loans, gross 9,462 9,969 TDR loans unamortized discount (209 ) (212 ) Total TDR loans 9,253 9,757 TDR loans receivable for partially charged-off loans 348 367 TDR loans allowance for losses (998 ) (1,100 ) TDR loans, net $ 8,603 $ 9,024 Percentage of TDR loans in repayment 90.7 % 90.5 % Delinquencies as a percentage of TDR loans in repayment 10.6 % 12.6 % Loans in forbearance as a percentage of TDR loans in repayment and forbearance 5.6 % 5.4 % (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. 2. Allowance for Loan Losses (Continued) Private Education Loan Delinquencies Non-TDRs September 30, 2019 December 31, 2018 (Dollars in millions) Balance % Balance % Loans in-school/grace/deferment (1) $ 305 $ 392 Loans in forbearance (2) 147 158 Loans in repayment and percentage of each status: Loans current 12,958 99.1 % 12,851 98.8 % Loans delinquent 31-60 days (3) 48 .4 71 .5 Loans delinquent 61-90 days (3) 23 .2 32 .3 Loans delinquent greater than 90 days (3) 47 .3 58 .4 Total non-TDR loans in repayment 13,076 100 % 13,012 100 % Total non-TDR loans, gross 13,528 13,562 Non-TDR loans unamortized discount (437 ) (547 ) Total non-TDR loans 13,091 13,015 Non-TDR loans receivable for partially charged-off loans 255 307 Non-TDR loans allowance for losses (103 ) (101 ) Non-TDR loans, net $ 13,243 $ 13,221 Percentage of non-TDR loans in repayment 96.7 % 95.9 % Delinquencies as a percentage of non-TDR loans in repayment .9 % 1.2 % Loans in forbearance as a percentage of non- TDR loans in repayment and forbearance 1.1 % 1.2 % (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. 2. Allowance for Loan Losses (Continued) 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. We refer to the remaining loan balance as the “receivable for partially charged-off loans.” Actual recoveries are applied against this receivable balance. If actual periodic recoveries are less than expected, the difference is immediately charged off through the allowance for Private Education Loan losses. The following table summarizes the activity in the receivable for partially charged-off Private Education Loans. Three Months Ended September 30, Nine Months Ended September 30, (Dollars in millions) 2019 2018 2019 2018 Receivable at beginning of period $ 640 $ 724 $ 674 $ 760 Expected future recoveries of current period defaults (1) 18 29 56 68 Recoveries (2) (31 ) (33 ) (98 ) (107 ) Charge-offs (3) (24 ) (32 ) (29 ) (33 ) Receivable at end of period $ 603 $ 688 $ 603 $ 688 (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% to 80.5%, and in third-quarter 2019, it increased from 80.5% to 81%. These changes resulted in a $21 and $32 million reduction to the balance of the receivable for partially charged-off loans in the three months ended September 30, 2019 and 2018, respectively. 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 69% and 65% of the loans granted forbearance have qualified as a TDR loan at September 30, 2019 and December 31, 2018, respectively. The unpaid principal balance of TDR loans that were in an interest rate reduction program as of September 30, 2019 and December 31, 2018 was $1.9 billion and $1.8 billion, respectively. 2. Allowance for Loan Losses (Continued) At September 30, 2019 and December 31, 2018, 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) September 30, 2019 December 31, 2018 Recorded investment (1) $ 9,789 $ 10,326 Total ending loans (2) $ 9,810 $ 10,336 Related allowance $ 998 $ 1,100 (1) (2) Total ending loans includes the receivable for partially charged-off loans. The following tables provide the average recorded investment and interest income recognized for our TDR loans. Three Months Ended September 30, Nine Months Ended September 30, (Dollars in millions) 2019 2018 2019 2018 Average recorded investment $ 9,887 $ 10,568 $ 10,059 $ 10,717 Interest income recognized $ 194 $ 196 $ 586 $ 563 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. Three Months Ended September 30, Nine Months Ended September 30, (Dollars in millions) 2019 2018 2019 2018 Modified loans (1) $ 113 $ 163 $ 369 $ 470 Charge-offs (2) $ 88 $ 123 $ 242 $ 243 Payment default $ 25 $ 35 $ 83 $ 105 (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. 2. Allowance for Loan Losses (Continued) 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 September 30, 2019 TDR $ 189 $ 26 $ 22 Non-TDR 122 3 6 Total $ 311 $ 29 $ 28 December 31, 2018 TDR $ 205 $ 26 $ 23 Non-TDR 149 3 4 Total $ 354 $ 29 $ 27 |