Allowance for Loan Losses | 4 . 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 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 (Continued) Allowance for Loan Losses Metrics Year Ended December 31, 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 30 226 1 258 Net adjustment resulting from the change in the charge-off rate (1) — (21 ) — (21 ) Net charge-offs remaining (2) (42 ) (364 ) (2 ) (408 ) Total net charge-offs (42 ) (385 ) (2 ) (429 ) Reclassification of interest reserve (3) — 7 — 7 Loan sales — (1 ) (8 ) (9 ) Ending balance $ 64 $ 1,048 $ — $ 1,112 Allowance Ending Balance: Individually evaluated for impairment — TDR $ — $ 941 $ — $ 941 Collectively evaluated for impairment: Excluding Purchased Non-Credit Impaired Loans acquired at a discount and Purchased Credit Impaired Loans 64 107 — 171 Purchased Non-Credit Impaired Loans acquired at a discount (4) — — — — Purchased Credit Impaired Loans (4) — — — — Ending total allowance $ 64 $ 1,048 $ — $ 1,112 Loans Ending Balance: Individually evaluated for impairment — TDR $ — $ 9,617 $ — $ 9,617 Collectively evaluated for impairment: Excluding Purchased Non-Credit Impaired Loans acquired at a discount and Purchased Credit Impaired Loans 61,589 12,286 9 73,884 Purchased Non-Credit Impaired Loans acquired at a discount (4) 2,505 1,806 — 4,311 Purchased Credit Impaired Loans (4) — 201 — 201 Ending total loans (5) $ 64,094 $ 23,910 $ 9 $ 88,013 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) .07 % 1.67 % — % Net adjustment resulting from the change in charge-off rate as a percentage of average loans in repayment (1) — % .10 % — % Allowance coverage of charge-offs 1.5 2.7 — Allowance as a percentage of the ending total loan balance .10 % 4.38 % — % Allowance as a percentage of the ending loans in repayment .12 % 4.74 % — % Ending total loans (5) $ 64,094 $ 23,910 $ 9 Average loans in repayment $ 55,978 $ 21,859 $ 29 Ending loans in repayment $ 53,538 $ 22,089 $ 9 (1) In third-quarter 2019, the portion of the loan amount charged off at default on Private Education Loans increased from 80.5% to 81%. This charge resulted in a $21 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, 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 $33 million and $268 million, respectively, as of December 31, 2019 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, 2019. (5) Ending total loans for Private Education Loans includes the receivable for partially charged-off loans. 4. Allowance for Loan Losses (Continued) 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% to 80.5%. 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. Allowance for Loan Losses (Continued) 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. 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 December 31, 2019 December 31, 2018 December 31, 2017 (Dollars in millions) Balance % Balance % Balance % Loans in-school/grace/deferment (1) $ 3,114 $ 3,793 $ 4,711 Loans in forbearance (2) 7,442 8,386 8,533 Loans in repayment and percentage of each status: Loans current 47,255 88.3 % 53,500 89.8 % 59,264 87.3 % Loans delinquent 31-60 days (3) 2,094 3.9 1,964 3.4 2,638 3.9 Loans delinquent 61-90 days (3) 1,082 2.0 910 1.5 1,763 2.6 Loans delinquent greater than 90 days (3) 3,107 5.8 3,177 5.3 4,188 6.2 Total FFELP Loans in repayment 53,538 100 % 59,551 100 % 67,853 100 % Total FFELP Loans, gross 64,094 71,730 81,097 FFELP Loan unamortized premium 545 599 666 Total FFELP Loans 64,639 72,329 81,763 FFELP Loan allowance for losses (64 ) (76 ) (60 ) FFELP Loans, net $ 64,575 $ 72,253 $ 81,703 Percentage of FFELP Loans in repayment 83.5 % 83.0 % 83.7 % Delinquencies as a percentage of FFELP Loans in repayment 11.7 % 10.2 % 12.7 % FFELP Loans in forbearance as a percentage of loans in repayment and forbearance 12.2 % 12.3 % 11.2 % (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. 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 Loans Credit Quality Indicators TDRs December 31, 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 $ 8,493 92 % $ 9,133 92 % FICO below 640 777 8 836 8 Total $ 9,270 100 % $ 9,969 100 % School Type: Not-for-profit $ 7,387 80 % $ 7,888 79 % For-profit 1,883 20 2,081 21 Total $ 9,270 100 % $ 9,969 100 % Cosigners: With cosigner (1) $ 5,792 62 % $ 6,172 62 % Without cosigner 3,478 38 3,797 38 Total $ 9,270 100 % $ 9,969 100 % Seasoning (2) 1-12 payments $ 224 3 % $ 335 3 % 13-24 payments 301 3 436 4 25-36 payments 472 5 660 7 37-48 payments 662 7 934 10 More than 48 payments 7,262 78 7,178 72 Not yet in repayment 349 4 426 4 Total $ 9,270 100 % $ 9,969 100 % (1) Excluding Private Education Refinance Loans, which do not have a cosigner, the cosigner rate was 63% and 62% at December 31, 2019 and 2018, respectively. (2) Number of months in active repayment for which a scheduled payment was received. (3) Balance equals the gross Private Education Loans. 4. Allowance for Loan Losses (Continued) Private Education Loans Credit Quality Indicators Non-TDRs December 31, 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 $ 13,687 97 % $ 13,087 96 % FICO below 640 365 3 475 4 Total $ 14,052 100 % $ 13,562 100 % School Type: Not-for-profit $ 12,614 90 % $ 11,953 88 % For-profit 1,438 10 1,609 12 Total $ 14,052 100 % $ 13,562 100 % Cosigners: With cosigner (1) $ 5,184 37 % $ 6,961 51 % Without cosigner 8,868 63 6,601 49 Total $ 14,052 100 % $ 13,562 100 % Seasoning (2) 1-12 payments $ 4,673 33 % $ 3,353 25 % 13-24 payments 1,570 11 486 3 25-36 payments 603 4 322 2 37-48 payments 251 2 383 3 More than 48 payments 6,675 48 8,626 64 Not yet in repayment 280 2 392 3 Total $ 14,052 100 % $ 13,562 100 % (1) Excluding Private Education Refinance Loans, which do not have a cosigner, the cosigner rate was 67% at December 31, 2019 and 2018. (2) Number of months in active repayment for which a scheduled payment was received. (3) 4. Allowance for Loan Losses (Continued) Private Education Loan Delinquencies TDRs December 31, 2019 December 31, 2018 December 31, 2017 (Dollars in millions) Balance % Balance % Balance % Loans in-school/grace/deferment (1) $ 349 $ 426 $ 477 Loans in forbearance (2) 479 518 681 Loans in repayment and percentage of each status: Loans current 7,557 89.5 % 7,890 87.4 % 8,333 88.9 % Loans delinquent 31-60 days (3) 296 3.5 344 3.8 351 3.7 Loans delinquent 61-90 days (3) 191 2.3 235 2.6 207 2.2 Loans delinquent greater than 90 days (3) 398 4.7 556 6.2 487 5.2 Total TDR loans in repayment 8,442 100 % 9,025 100 % 9,378 100 % Total TDR loans, gross 9,270 9,969 10,536 TDR loans unamortized discount (203 ) (212 ) (225 ) Total TDR loans 9,067 9,757 10,311 TDR loans receivable for partially charged-off loans 347 367 385 TDR loans allowance for losses (941 ) (1,100 ) (1,171 ) TDR loans, net $ 8,473 $ 9,024 $ 9,525 Percentage of TDR loans in repayment 91.1 % 90.5 % 89.0 % Delinquencies as a percentage of TDR loans in repayment 10.5 % 12.6 % 11.1 % Loans in forbearance as a percentage of TDR loans in repayment and forbearance 5.4 % 5.4 % 6.8 % (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. Allowance for Loan Losses (Continued) Private Education Loan Delinquencies Non-TDRs December 31, 2019 December 31, 2018 December 31, 2017 (Dollars in millions) Balance % Balance % Balance % Loans in-school/grace/deferment (1) $ 280 $ 392 $ 584 Loans in forbearance (2) 125 158 214 Loans in repayment and percentage of each status: Loans current 13,526 99.1 % 12,851 98.8 % 13,257 97.9 % Loans delinquent 31-60 days (3) 53 .4 71 .5 120 .9 Loans delinquent 61-90 days (3) 27 .2 32 .3 59 .4 Loans delinquent greater than 90 days (3) 41 .3 58 .4 110 .8 Total non-TDR loans in repayment 13,647 100 % 13,012 100 % 13,546 100 % Total non-TDR loans, gross 14,052 13,562 14,344 Non-TDR loans unamortized discount (414 ) (547 ) (699 ) Total non-TDR loans 13,638 13,015 13,645 Non-TDR loans receivable for partially charged-off loans 241 307 375 Non-TDR loans allowance for losses (107 ) (101 ) (126 ) Non-TDR loans, net $ 13,772 $ 13,221 $ 13,894 Percentage of non-TDR loans in repayment 97.1 % 95.9 % 94.4 % Delinquencies as a percentage of non-TDR loans in repayment .9 % 1.2 % 2.1 % Loans in forbearance as a percentage of non- TDR loans in repayment and forbearance .9 % 1.2 % 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) 2019 2018 2017 Receivable at beginning of period $ 674 $ 760 $ 815 Expected future recoveries of current period defaults (1) 74 89 110 Recoveries (2) (126 ) (139 ) (155 ) Charge-offs (3) (34 ) (36 ) (10 ) Receivable at end of period $ 588 $ 674 $ 760 (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-quarters of 2019 and 2018, the portion of the loan amount charged off at default increased from 80.5% to 81% and from 79% to 80.5%, respectively. This change resulted in a $21 million and $32 million reduction to the balance of the receivable for partially charged-off loans in 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 December 31, 2019 and 2018, respectively. The unpaid principal balance of TDR loans that were in an interest rate reduction plan as of December 31, 2019 and 2018 was $1.7 billion and $1.8 billion, respectively. At December 31, 2019 and 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) December 31, 2019 December 31, 2018 Recorded investment (1) $ 9,594 $ 10,326 Total ending loans (2) $ 9,617 $ 10,336 Related allowance $ 941 $ 1,100 (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) 2019 2018 2017 Average recorded investment $ 9,965 $ 10,637 $ 10,989 Interest income recognized $ 770 $ 764 $ 708 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) 2019 2018 2017 Modified loans (1) $ 475 $ 596 $ 816 Charge-offs (2) $ 324 $ 343 $ 346 Payment-default $ 109 $ 142 $ 181 (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, 2019 TDR $ 182 $ 18 $ 18 Non-TDR 115 2 4 Total $ 297 $ 20 $ 22 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 |