Allowance for Loan Losses | 4. Allowance for Loan Losses Metrics Year Ended December 31, 2021 (Dollars in millions) FFELP Loans Private Education Loans Total Beginning balance $ 288 $ 1,089 $ 1,377 Provision: Reversal of allowance related to loan sales (1) — (107 ) (107 ) Remaining provision — 46 46 Total provision — (61 ) (61 ) Charge-offs: Net adjustment resulting from the change in the charge-off rate (2) — (16 ) (16 ) Net charge-offs remaining (3) (26 ) (153 ) (179 ) Total charge-offs (3) (26 ) (169 ) (195 ) Decrease in expected future recoveries on charged-off loans (4) — 150 150 Allowance at end of period 262 1,009 1,271 Plus: expected future recoveries on charged-off loans (4) — 329 329 Allowance at end of period excluding expected future recoveries on charged-off loans (5) $ 262 $ 1,338 $ 1,600 Net charge-offs as a percentage of average loans in repayment, excluding the net adjustment resulting from the change in the charge-off rate (2) .06 % .76 % Net adjustment resulting from the change in charge-off rate as a percentage of average loans in repayment (2) — % .08 % Allowance coverage of charge-offs (6) 10.0 7.9 Allowance as a percentage of the ending total loan balance (6) .5 % 6.3 % Allowance as a percentage of the ending loans in repayment (6) .6 % 6.6 % Ending total loans $ 52,903 $ 21,180 Average loans in repayment $ 45,781 $ 20,150 Ending loans in repayment $ 44,390 $ 20,284 (1) In connection with the sale of approximately $1.6 billion of Private Education Loans in 2021. (2) In 2021, the portion of the loan amount charged off at default on Private Education Loans increased from 81.4% to 81.7%. This change resulted in a $16 million reduction to the balance of the expected future recoveries on charged-off loans in 2021. (3) Charge-offs are reported net of expected recoveries. For Private Education Loans, at the time of charge-off, the expected recovery amount is transferred from the education loan balance to the allowance for loan loss and is referred to as the expected future recoveries on charged-off loans. For FFELP Loans, the recovery is received at the time of charge-off. (4) At the end of each month, for Private Education 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 as the “expected future recoveries on 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 expected future recoveries for charged-off loans. If actual periodic recoveries are greater than expected, they will be reflected as a recovery through the allowance for Private Education Loan losses once the cumulative recovery amount exceeds the cumulative amount originally expected to be recovered. The following table summarizes the activity in the expected future recoveries on charged-off loans: Year Ended December 31, (Dollars in millions) 2021 Beginning of period expected recoveries $ 479 Expected future recoveries of current period defaults 22 Recoveries (87 ) Charge-offs (35 ) Reduction in expected recoveries related to regulatory settlement (5) (50 ) End of period expected recoveries $ 329 Change in balance during period $ (150 ) (5) See “Note 12 – Commitments, Contingencies and Guarantees” for further discussion. (6) The allowance used for these metrics excludes the expected future recoveries on charged-off loans to better reflect the current expected credit losses remaining in the portfolio. 4. See “Note 2 – Significant Accounting Policies” for discussion of the adoption of CECL on January 1, 2020. Year Ended December 31, 2020 (Dollars in millions) FFELP Loans Private Education Loans Total Allowance at beginning of period $ 64 $ 1,048 $ 1,112 Transition adjustment made under CECL on January 1, 2020 (1) 260 (3 ) 257 Allowance at beginning of period after transition adjustment to CECL 324 1,045 1,369 Total provision 13 142 155 Charge-offs: Net adjustment resulting from the change in the charge-off rate (2) — (23 ) (23 ) Net charge-offs remaining (3) (49 ) (184 ) (233 ) Total charge-offs (3) (49 ) (207 ) (256 ) Decrease in expected future recoveries on charged-off loans (4) — 109 109 Allowance at end of period 288 1,089 1,377 Plus: expected future recoveries on charged-off loans (4) — 479 479 Allowance at end of period excluding expected future recoveries on charged-off loans (5) $ 288 $ 1,568 $ 1,856 Net charge-offs as a percentage of average loans in repayment, excluding the net adjustment resulting from the change in the charge-off rate (2) .10 % .88 % Net adjustment resulting from the change in charge-off rate as a percentage of average loans in repayment (2) — % .11 % Allowance coverage of charge-offs (5) 5.9 7.6 Allowance as a percentage of the ending total loan balance (5) .5 % 7.1 % Allowance as a percentage of the ending loans in repayment (5) .6 % 7.5 % Ending total loans $ 58,572 $ 22,168 Average loans in repayment $ 48,130 $ 20,790 Ending loans in repayment $ 48,057 $ 20,841 (1) For a further discussion of our adoption of CECL, see “Note 2 – Significant Accounting Policies.” ( 2 ) In 2020, the portion of the loan amount charged off at default on Private Education Loans increased from 81% to 81.4%. This charge resulted in a $23 million reduction to the balance of the receivable for partially charged-off loan balance. ( 3 ) Charge-offs are reported net of expected recoveries. For Private Education Loans, at the time of charge-off, the expected recovery amount is transferred from the education loan balance to the allowance for loan loss and is referred to as the expected future recoveries on charged-off loans. For FFELP Loans, the recovery is received at the time of charge-off. ( 4 ) At the end of each month, for Private Education 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 as the “expected future recoveries on 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 expected future recoveries for charged-off loans. If actual periodic recoveries are greater than expected, they will be reflected as a recovery through the allowance for Private Education Loan losses once the cumulative recovery amount exceeds the cumulative amount originally expected to be recovered. The following table summarizes the activity in the expected future recoveries on charged-off loans. Year Ended December 31, (Dollars in millions) 2020 Beginning of period expected recoveries $ 588 Expected future recoveries of current period defaults 32 Recoveries (107 ) Charge-offs (34 ) End of period expected recoveries $ 479 Change in balance during period $ (109 ) ( 5 ) The allowance used for these metrics excludes the expected future recoveries on charged-off loans to better reflect the current expected credit losses remaining in the portfolio. 4. Year Ended December 31, 2019 (Dollars in millions) FFELP Loans Private Education Loans Other Loans Total Beginning balance $ 76 $ 1,201 $ 9 $ 1,286 Total provision 30 226 1 258 Charge-offs: Net adjustment resulting from the change in the charge-off rate (1) — (21 ) — (21 ) Net charge-offs remaining (2) (42 ) (364 ) (2 ) (408 ) Total charge-offs (2) (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 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. For FFELP Loans, the recovery is received at the time of charge-off. (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. Troubled Debt Restructurings (TDRs) We sometimes modify the terms of loans 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 75% and 72% of the loans granted forbearance have qualified as a TDR loan at December 31, 2021 and 2020, respectively. The unpaid principal balance of TDR loans that were in an interest rate reduction program as of December 31, 2021 and 2020 was $831 million and $948 million, respectively. 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) 2021 2020 2019 Modified loans (1) $ 149 $ 264 $ 475 Charge-offs (2) $ 124 $ 157 $ 324 Payment default $ 21 $ 47 $ 109 (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 4. Key Credit Quality Indicators We assess and determine the collectability of our education loan portfolios by evaluating certain risk characteristics we refer to as key credit quality indicators. Key credit quality indicators are incorporated into the allowance for loan losses calculation. FFELP Loans FFELP Loans are substantially insured and guaranteed as to their principal and accrued interest in the event of default. The key credit quality indicators are loan status and loan type. FFELP Loan Delinquencies December 31, 2021 December 31, 2020 (Dollars in millions) Balance % Balance % Loans in-school/grace/deferment (1) $ 2,220 $ 2,791 Loans in forbearance (2) 6,292 7,725 Loans in repayment and percentage of each status: Loans current 39,679 89.4 % 43,623 90.8 % Loans delinquent 31-60 days (3) 1,696 3.8 1,374 2.9 Loans delinquent 61-90 days (3) 904 2.0 836 1.7 Loans delinquent greater than 90 days (3) 2,112 4.8 2,223 4.6 Total FFELP Loans in repayment 44,391 100 % 48,056 100 % Total FFELP Loans 52,903 58,572 FFELP Loan allowance for losses (262 ) (288 ) FFELP Loans, net $ 52,641 $ 58,284 Percentage of FFELP Loans in repayment 83.9 % 82.0 % Delinquencies as a percentage of FFELP Loans in repayment 10.6 % 9.2 % FFELP Loans in forbearance as a percentage of loans in repayment and forbearance 12.4 % 13.8 % (1) Loans for customers who may still be attending school or engaging in other permitted educational activities and are not yet required to make payments on their loans, e.g., residency periods for medical students or a grace period for bar exam preparation, as well as loans for customers who have requested and qualify for other permitted program deferments such as military, unemployment, or economic hardships. (2) Loans for customers who have used their allowable deferment time or do not qualify for deferment, that need additional time to obtain employment or who have temporarily ceased making full payments due to hardship or other factors such as disaster relief, including COVID-19 relief programs, consistent with established loan program servicing policies and procedures. (3) The period of delinquency is based on the number of days scheduled payments are contractually past due. Loan type : (Dollars in millions) December 31, 2021 December 31, 2020 Change Stafford Loans $ 16,329 $ 17,686 $ (1,357 ) Consolidation Loans 31,873 35,968 (4,095 ) Rehab Loans 4,701 4,918 (217 ) Total loans, gross $ 52,903 $ 58,572 $ (5,669 ) 4. Private Education Loans The key credit quality indicators are credit scores (FICO scores), loan status, loan seasoning, whether a loan is a TDR, the existence of a cosigner and school type. The FICO score is the higher of the borrower or co-borrower score and is updated at least every six months while school type is assessed at origination. The other Private Education Loan key quality indicators are updated quarterly. Private Education Loan Credit Quality Indicators by Origination Year (Dollars in millions) 2021 2020 2019 2018 2017 Prior Total % of Total Credit Quality Indicators FICO Scores: 640 and above $ 5,185 $ 1,990 $ 1,862 $ 695 $ 209 $ 9,606 $ 19,547 92 % Below 640 42 15 37 21 8 1,510 1,633 8 Total $ 5,227 $ 2,005 $ 1,899 $ 716 $ 217 $ 11,116 $ 21,180 100 % Loan Status: In-school/grace/ deferment/forbearance $ 41 $ 30 $ 34 $ 17 $ 6 $ 768 $ 896 4 % Current/90 days or less delinquent 5,184 1,973 1,860 697 211 10,062 19,987 94 Greater than 90 days delinquent 2 2 5 2 — 286 297 2 Total $ 5,227 $ 2,005 $ 1,899 $ 716 $ 217 $ 11,116 $ 21,180 100 % Seasoning (1) 1-12 payments $ 5,208 $ 161 $ 27 $ 5 $ 1 $ 133 $ 5,535 26 % 13-24 payments — 1,824 568 14 3 150 2,559 12 25-36 payments — — 1,283 165 9 248 1,705 8 37-48 payments — — — 524 61 380 965 5 More than 48 payments — — — — 141 9,914 10,055 47 Loans in-school/ grace/deferment 19 20 21 8 2 291 361 2 Total $ 5,227 $ 2,005 $ 1,899 $ 716 $ 217 $ 11,116 $ 21,180 100 % TDR Status: TDR $ 2 $ 8 $ 31 $ 28 $ 29 $ 7,158 $ 7,256 34 % Non-TDR 5,225 1,997 1,868 688 188 3,958 13,924 66 Total $ 5,227 $ 2,005 $ 1,899 $ 716 $ 217 $ 11,116 $ 21,180 100 % Cosigners: With cosigner (2) $ 17 $ 33 $ 12 $ — $ 34 $ 7,266 $ 7,362 35 % Without cosigner 5,210 1,972 1,887 716 183 3,850 13,818 65 Total $ 5,227 $ 2,005 $ 1,899 $ 716 $ 217 $ 11,116 $ 21,180 100 % School Type: Not-for-profit $ 4,918 $ 1,916 $ 1,771 $ 659 $ 208 $ 9,241 $ 18,713 88 % For-profit 309 89 128 57 9 1,875 2,467 12 Total $ 5,227 $ 2,005 $ 1,899 $ 716 $ 217 $ 11,116 $ 21,180 100 % Allowance for loan losses (1,009 ) Total loans, net $ 20,171 ( 1 ) Number of months in active repayment for which a scheduled payment was received. (2) Excluding Private Education Refinance Loans, which do not have a cosigner, the cosigner rate was 65% for total loans at December 31, 2021. 4. Private Education Loan Credit Quality Indicators by Origination Year (Dollars in millions) 2020 2019 2018 2017 2016 Prior Total % of Total Credit Quality Indicators FICO Scores: 640 and above $ 4,008 $ 2,964 $ 1,079 $ 340 $ 72 $ 11,746 $ 20,209 91 % Below 640 15 34 23 9 2 1,876 1,959 9 Total $ 4,023 $ 2,998 $ 1,102 $ 349 $ 74 $ 13,622 $ 22,168 100 % Loan Status: In-school/grace/ deferment/forbearance $ 23 $ 43 $ 25 $ 10 $ 2 $ 1,224 $ 1,327 6 % Current/90 days or less delinquent 3,999 2,953 1,075 338 72 12,187 20,624 93 Greater than 90 days delinquent 1 2 2 1 — 211 217 1 Total $ 4,023 $ 2,998 $ 1,102 $ 349 $ 74 $ 13,622 $ 22,168 100 % Seasoning (1) 1-12 payments $ 4,014 $ 879 $ 7 $ 2 $ — $ 180 $ 5,082 23 % 13-24 payments — 2,098 243 7 1 234 2,583 12 25-36 payments — — 839 101 3 380 1,323 6 37-48 payments — — — 236 38 584 858 4 More than 48 payments — — — — 31 11,808 11,839 53 Loans in-school/ grace/deferment 9 21 13 3 1 436 483 2 Total $ 4,023 $ 2,998 $ 1,102 $ 349 $ 74 $ 13,622 $ 22,168 100 % TDR Status: TDR $ 1 $ 14 $ 23 $ 31 $ 11 $ 8,351 $ 8,431 38 % Non-TDR 4,022 2,984 1,079 318 63 5,271 13,737 62 Total $ 4,023 $ 2,998 $ 1,102 $ 349 $ 74 $ 13,622 $ 22,168 100 % Cosigners: With cosigner (2) $ 5 $ 13 $ 1 $ 49 $ 21 $ 8,911 $ 9,000 41 % Without cosigner 4,018 2,985 1,101 300 53 4,711 13,168 59 Total $ 4,023 $ 2,998 $ 1,102 $ 349 $ 74 $ 13,622 $ 22,168 100 % School Type: Not-for-profit $ 3,844 $ 2,801 $ 1,019 $ 333 $ 74 $ 11,255 $ 19,326 87 % For-profit 179 197 83 16 — 2,367 2,842 13 Total $ 4,023 $ 2,998 $ 1,102 $ 349 $ 74 $ 13,622 $ 22,168 100 % Allowance for loan losses (1,089 ) Total loans, net $ 21,079 (1) Number of months in active repayment for which a scheduled payment was received. (2) Excluding Private Education Refinance Loans, which do not have a cosigner, the cosigner rate was 65% for total loans at December 31, 2020. 4. Private Education Loan Delinquencies TDRs December 31, 2021 December 31, 2020 (Dollars in millions) Balance % Balance % Loans in-school/grace/deferment (1) $ 194 $ 280 Loans in forbearance (2) 446 703 Loans in repayment and percentage of each status: Loans current 6,023 91.0 % 6,952 93.4 % Loans delinquent 31-60 days (3) 199 3.0 185 2.5 Loans delinquent 61-90 days (3) 120 1.8 114 1.5 Loans delinquent greater than 90 days (3) 274 4.2 197 2.6 Total TDR loans in repayment 6,616 100 % 7,448 100 % Total TDR loans 7,256 8,431 TDR loans allowance for losses (829 ) (929 ) TDR loans, net $ 6,427 $ 7,502 Percentage of TDR loans in repayment 91.2 % 88.3 % Delinquencies as a percentage of TDR loans in repayment 9.0 % 6.6 % Loans in forbearance as a percentage of TDR loans in repayment and forbearance 6.3 % 8.6 % (1) Loans for customers who are attending school or are in other permitted educational activities and are not yet required to make payments on their loans, e.g., internship periods, as well as loans for customers who have requested and qualify for other permitted program deferments such as various military eligible deferments. (2) Loans for customers who have requested extension of grace period generally during employment transition or who have temporarily ceased making full payments due to hardship or other factors such as disaster relief, including COVID-19 relief programs, consistent with established loan program servicing policies and procedures. (3) The period of delinquency is based on the number of days scheduled payments are contractually past due. 4. Private Education Loan Delinquencies Non-TDRs December 31, 2021 December 31, 2020 (Dollars in millions) Balance % Balance % Loans in-school/grace/deferment (1) $ 167 $ 203 Loans in forbearance (2) 89 141 Loans in repayment and percentage of each status: Loans current 13,611 99.6 % 13,335 99.6 % Loans delinquent 31-60 days (3) 23 .2 26 .2 Loans delinquent 61-90 days (3) 11 .1 12 .1 Loans delinquent greater than 90 days (3) 23 .1 20 .1 Total non-TDR loans in repayment 13,668 100 % 13,393 100 % Total non-TDR loans 13,924 13,737 Non-TDR loans allowance for losses (180 ) (160 ) Non-TDR loans, net $ 13,744 $ 13,577 Percentage of non-TDR loans in repayment 98.2 % 97.5 % Delinquencies as a percentage of non-TDR loans in repayment .4 % .4 % Loans in forbearance as a percentage of non-TDR loans in repayment and forbearance .6 % 1.0 % (1) Loans for customers who are attending school or are in other permitted educational activities and are not yet required to make payments on their loans, e.g., internship periods, as well as loans for customers who have requested and qualify for other permitted program deferments such as various military eligible deferments. (2) Loans for customers who have requested extension of grace period generally during employment transition or who have temporarily ceased making full payments due to hardship or other factors such as disaster relief, including COVID-19 relief programs, consistent with established loan program servicing policies and procedures. (3) The period of delinquency is based on the number of days scheduled payments are contractually past due. |