| Financing Receivables | Loans and Allowance for Credit Losses Major classifications within the Company’s held for investment loan portfolio at September 30, 2021 and December 31, 2020 are as follows: (In thousands) September 30, 2021 December 31, 2020 Commercial: Business $ 5,277,850 $ 6,546,087 Real estate – construction and land 1,257,836 1,021,595 Real estate – business 2,937,852 3,026,117 Personal Banking: Real estate – personal 2,769,292 2,820,030 Consumer 2,049,559 1,950,502 Revolving home equity 281,442 307,083 Consumer credit card 569,976 655,078 Overdrafts 4,583 3,149 Total loans $ 15,148,390 $ 16,329,641 Accrued interest receivable totaled $33.0 million and $41.9 million at September 30, 2021 and December 31, 2020, respectively, and was included within other assets on the consolidated balance sheets. For the three months ended September 30, 2021, the Company wrote-off accrued interest by reversing interest income of $27 thousand and $781 thousand in the Commercial and Personal Banking portfolios, respectively. Similarly, for the nine months ended September 30, 2021, the Company wrote-off accrued interest of $188 thousand and $3.9 million in the Commercial and Personal Banking portfolios, respectively. At September 30, 2021, loans of $3.5 billion were pledged at the Federal Home Loan Bank as collateral for borrowings and letters of credit obtained to secure public deposits. Additional loans of $1.3 billion were pledged at the Federal Reserve Bank as collateral for discount window borrowings. Allowance for credit losses The allowance for credit losses is measured using an average historical loss model which incorporates relevant information about past events (including historical credit loss experience on loans with similar risk characteristics), current conditions, and reasonable and supportable forecasts that affect the collectability of the remaining cash flows over the contractual term of the loans. The allowance for credit losses is measured on a collective (pool) basis. Loans are aggregated into pools based on similar risk characteristics including borrower type, collateral type and expected credit loss patterns. Loans that do not share similar risk characteristics, primarily large loans on non-accrual status, are evaluated on an individual basis. For loans evaluated for credit losses on a collective basis, average historical loss rates are calculated for each pool using the Company’s historical net charge-offs (combined charge-offs and recoveries by observable historical reporting period) and outstanding loan balances during a lookback period. Lookback periods can be different based on the individual pool and represent management’s credit expectations for the pool of loans over the remaining contractual life. In certain loan pools, if the Company’s own historical loss rate is not reflective of the loss expectations, the historical loss rate is augmented by industry and peer data. The calculated average net charge-off rate is then adjusted for current conditions and reasonable and supportable forecasts. These adjustments increase or decrease the average historical loss rate to reflect expectations of future losses given a single path economic forecast of key macroeconomic variables including GDP, disposable income, unemployment rate, various interest rates, CPI inflation rate, HPI, CREPI and market volatility. The adjustments are based on results from various regression models projecting the impact of the macroeconomic variables to loss rates. The forecast is used for a reasonable and supportable period before reverting back to historical averages using a straight-line method. The forecast adjusted loss rate is applied to the amortized cost of loans over the remaining contractual lives, adjusted for expected prepayments. The contractual term excludes expected extensions (except for contractual extensions at the option of the customer), renewals and modifications unless there is a reasonable expectation that a troubled debt restructuring will be executed. Credit cards and certain similar consumer lines of credit do not have stated maturities and therefore, for these loan classes, remaining contractual lives are determined by estimating future cash flows expected to be received from customers until payments have been fully allocated to outstanding balances. Additionally, the allowance for credit losses considers other qualitative factors not included in historical loss rates or macroeconomic forecast such as changes in portfolio composition, underwriting practices, or significant unique events or conditions. Key model assumptions in the Company’s allowance for credit loss model include the economic forecast, the reasonable and supportable period, prepayment assumptions and qualitative factors applied for portfolio composition changes, underwriting practices, or significant unique events or conditions. The assumptions utilized in estimating the Company’s allowance for credit losses at September 30, 2021 and June 30, 2021 are discussed below. Key Assumption September 30, 2021 June 30, 2021 Overall economic forecast • An optimistic recovery from the Global Coronavirus Recession (GCR) continues • Assumes improving health conditions • Assumes gradual easing of supply constraints • Continued uncertainty regarding the assumptions related to the health crisis • Uncertainty regarding rising inflation • An optimistic recovery from the GCR continues • Assumes improving health conditions and expanding vaccine distribution • Further fiscal stimulus assumed • Continued uncertainty regarding the assumptions related to the health crisis • Uncertainty regarding rising inflation Reasonable and supportable period and related reversion period • One year for commercial and personal banking loans • Reversion to historical average loss rates within two quarters using straight-line method • One year for commercial and personal banking loans • Reversion to historical average loss rates within two quarters using straight-line method Forecasted macro-economic variables • Unemployment rate ranging from 4.5% to 4.0% during the supportable forecast period • Real GDP growth ranging from 5.7% to 3.6% • Prime rate of 3.25% • Unemployment rate ranging from 4.6% to 4.0% during the supportable forecast period • Real GDP growth ranging from 10.7% to 1.7% • Prime rate of 3.25% Prepayment assumptions Commercial loans • 5% for most loan pools Personal banking loans • Ranging from 26.9% to 16.5% for most loan pools • 62.2% for consumer credit cards Commercial loans • 5% for most loan pools Personal banking loans • Ranging from 25.4% to 16.5% for most loan pools • 60.1% for consumer credit cards Qualitative factors Added net reserves using qualitative processes related to: • Loans originated in our expansion markets, loans that are designated as shared national credits, and certain portfolios considered to be COVID-19 impacted • Changes in the composition of the loan portfolios • Loans downgraded to special mention, substandard, or non-accrual status Added net reserves using qualitative processes related to: • Loans originated in our expansion markets, loans that are designated as shared national credits, and certain portfolios considered to be COVID-19 impacted • Changes in the composition of the loan portfolios • Loans downgraded to special mention, substandard, or non-accrual status The liability for unfunded lending commitments utilizes the same model as the allowance for credit losses on loans, however, the liability for unfunded lending commitments incorporates an assumption for the portion of unfunded commitments that are expected to be funded. Sensitivity in the Allowance for Credit Loss model The allowance for credit losses is an estimate that requires significant judgment including projections of the macro-economic environment. The forecasted macro-economic environment continuously changes which can cause fluctuations in estimated expected losses. The current forecast projects a continued recovery of the COVID-19 pandemic induced recession. This pandemic is unprecedented and information that could be used in the estimation of the allowance for credit losses changes frequently. Trends in health conditions and vaccine distribution could significantly modify economic projections used in the estimation of the allowance for credit losses. A summary of the activity in the allowance for credit losses on loans and the liability for unfunded lending commitments during the three and nine months ended September 30, 2021 and 2020, respectively, follows: For the Three Months Ended September 30, 2021 For the Nine Months Ended September 30, 2021 (In thousands) Commercial Personal Banking Total Commercial Personal Banking Total ALLOWANCE FOR CREDIT LOSSES ON LOANS Balance at beginning of period $ 98,038 $ 74,357 $ 172,395 $ 121,549 $ 99,285 $ 220,834 Provision for credit losses on loans 186 (6,147) (5,961) (28,302) (15,447) (43,749) Deductions: Loans charged off 190 6,387 6,577 692 27,694 28,386 Less recoveries on loans 130 2,788 2,918 5,609 8,467 14,076 Net loan charge-offs (recoveries) 60 3,599 3,659 (4,917) 19,227 14,310 Balance September 30, 2021 $ 98,164 $ 64,611 $ 162,775 $ 98,164 $ 64,611 $ 162,775 LIABILITY FOR UNFUNDED LENDING COMMITMENTS Balance at beginning of period $ 23,350 $ 858 $ 24,208 $ 37,259 $ 1,048 $ 38,307 Provision for credit losses on unfunded lending commitments (1,564) 140 (1,424) (15,473) (50) (15,523) Balance September 30, 2021 $ 21,786 $ 998 $ 22,784 $ 21,786 $ 998 $ 22,784 ALLOWANCE FOR CREDIT LOSSES ON LOANS AND LIABILITY FOR UNFUNDED LENDING COMMITMENTS $ 119,950 $ 65,609 $ 185,559 $ 119,950 $ 65,609 $ 185,559 For the Three Months Ended September 30, 2020 For the Nine Months Ended September 30, 2020 (In thousands) Commercial Personal Banking Total Commercial Personal Banking Total ALLOWANCE FOR CREDIT LOSSES ON LOANS Balance at end of prior period $ 130,553 $ 110,191 $ 240,744 $ 91,760 $ 68,922 $ 160,682 Adoption of ASU 2016-13 — — — (29,711) 8,672 (21,039) Balance at beginning of period $ 130,553 $ 110,191 $ 240,744 $ 62,049 $ 77,594 $ 139,643 Provision for credit losses on loans (1,935) 5,135 3,200 69,418 54,141 123,559 Deductions: Loans charged off 357 10,292 10,649 4,159 32,127 36,286 Less recoveries on loans 163 2,902 3,065 1,116 8,328 9,444 Net loan charge-offs 194 7,390 7,584 3,043 23,799 26,842 Balance September 30, 2020 $ 128,424 $ 107,936 $ 236,360 $ 128,424 $ 107,936 $ 236,360 LIABILITY FOR UNFUNDED LENDING COMMITMENTS Balance at end of prior period $ 34,052 $ 1,247 $ 35,299 $ 399 $ 676 $ 1,075 Adoption of ASU 2016-13 — — — 16,057 33 16,090 Balance at beginning of period $ 34,052 $ 1,247 $ 35,299 $ 16,456 $ 709 $ 17,165 Provision for credit losses on unfunded lending commitments (60) (39) (99) 17,536 499 18,035 Balance September 30, 2020 $ 33,992 $ 1,208 $ 35,200 $ 33,992 $ 1,208 $ 35,200 ALLOWANCE FOR CREDIT LOSSES ON LOANS AND LIABILITY FOR UNFUNDED LENDING COMMITMENTS $ 162,416 $ 109,144 $ 271,560 $ 162,416 $ 109,144 $ 271,560 Delinquent and non-accrual loans The Company considers loans past due on the day following the contractual repayment date, if the contractual repayment was not received by the Company as of the end of the business day. The following table provides aging information on the Company’s past due and accruing loans, in addition to the balances of loans on non-accrual status, at September 30, 2021 and December 31, 2020. (In thousands) Current or Less Than 30 Days Past Due 30 – 89 Days Past Due 90 Days Past Due and Still Accruing Non-accrual Total September 30, 2021 Commercial: Business $ 5,266,174 $ 3,029 $ 354 $ 8,293 $ 5,277,850 Real estate – construction and land 1,257,836 — — — 1,257,836 Real estate – business 2,935,233 2,042 — 577 2,937,852 Personal Banking: Real estate – personal 2,762,146 3,029 2,566 1,551 2,769,292 Consumer 2,029,109 18,147 2,303 — 2,049,559 Revolving home equity 279,410 1,202 830 — 281,442 Consumer credit card 560,685 4,848 4,443 — 569,976 Overdrafts 4,294 289 — — 4,583 Total $ 15,094,887 $ 32,586 $ 10,496 $ 10,421 $ 15,148,390 December 31, 2020 Commercial: Business $ 6,517,838 $ 2,252 $ 3,473 $ 22,524 $ 6,546,087 Real estate – construction and land 1,021,592 — 3 — 1,021,595 Real estate – business 3,016,215 7,666 6 2,230 3,026,117 Personal Banking: Real estate – personal 2,808,886 6,521 2,837 1,786 2,820,030 Consumer 1,921,822 25,417 3,263 — 1,950,502 Revolving home equity 305,037 1,656 390 — 307,083 Consumer credit card 635,770 7,090 12,218 — 655,078 Overdrafts 2,896 253 — — 3,149 Total $ 16,230,056 $ 50,855 $ 22,190 $ 26,540 $ 16,329,641 At September 30, 2021, the Company had $5.5 million in non-accrual business loans that had no allowance for credit loss. At December 31, 2020, the Company had $9.4 million in non-accrual business loans that had no allowance for credit loss. The Company did not record any interest income on non-accrual loans during the three and nine months ended September 30, 2021 and 2020, respectively. Credit quality indicators The following table provides information about the credit quality of the Commercial loan portfolio. The Company utilizes an internal risk rating system comprised of a series of grades to categorize loans according to perceived risk associated with the expectation of debt repayment based on borrower specific information including but not limited to current financial information, historical payment experience, industry information, collateral levels and collateral types. The “pass” category consists of a range of loan grades that reflect increasing, though still acceptable, risk. A loan is assigned the risk rating at origination and then monitored throughout the contractual term for possible risk rating changes. Movement of risk through the various grade levels in the “pass” category is monitored for early identification of credit deterioration. The “special mention” rating is applied to loans where the borrower exhibits negative financial trends due to borrower specific or systemic conditions that, if left uncorrected, threaten its capacity to meet its debt obligations. The borrower is believed to have sufficient financial flexibility to react to and resolve its negative financial situation. It is a transitional grade that is closely monitored for improvement or deterioration. The “substandard” rating is applied to loans where the borrower exhibits well-defined weaknesses that jeopardize its continued performance and are of a severity that the distinct possibility of default exists. Loans are placed on “non-accrual” when management does not expect to collect payments consistent with acceptable and agreed upon terms of repayment. All loans are analyzed for risk rating updates annually. For larger loans, rating assessments may be more frequent if relevant information is obtained earlier through debt covenant monitoring or overall relationship management. Smaller loans are monitored as identified by the loan officer based on the risk profile of the individual borrower or if the loan becomes past due related to credit issues. Loans rated Special Mention, Substandard or Non-accrual are subject to quarterly review and monitoring processes. In addition to the regular monitoring performed by the lending personnel and credit committees, loans are subject to review by a credit review department which verifies the appropriateness of the risk ratings for the loans chosen as part of its risk-based review plan. The risk category of loans in the Commercial portfolio as of September 30, 2021 and December 31, 2020 are as follows: Term Loans Amortized Cost Basis by Origination Year (In thousands) 2021 2020 2019 2018 2017 Prior Revolving Loans Amortized Cost Basis Total September 30, 2021 Business Risk Rating: Pass $ 1,134,349 $ 857,499 $ 719,076 $ 287,921 $ 184,147 $ 316,405 $ 1,662,395 $ 5,161,792 Special mention 1,360 742 22,078 19,893 612 3,430 13,958 62,073 Substandard 3,489 9,371 7,961 4,124 5 11,444 9,298 45,692 Non-accrual 446 — 1 2,057 110 5,655 24 8,293 Total Business: $ 1,139,644 $ 867,612 $ 749,116 $ 313,995 $ 184,874 $ 336,934 $ 1,685,675 $ 5,277,850 Real estate-construction Risk Rating: Pass $ 448,441 $ 465,051 $ 141,423 $ 43,814 $ 2,691 $ 24,807 $ 27,175 $ 1,153,402 Special mention 15,474 28,037 — 995 19,499 — — 64,005 Substandard 239 11,767 — 15,226 13,197 — — 40,429 Total Real estate-construction: $ 464,154 $ 504,855 $ 141,423 $ 60,035 $ 35,387 $ 24,807 $ 27,175 $ 1,257,836 Real estate-business Risk Rating: Pass $ 424,347 $ 749,037 $ 577,966 $ 272,536 $ 209,234 $ 324,869 $ 57,801 $ 2,615,790 Special mention 1,080 29,998 10,980 22,751 2,117 5,853 2 72,781 Substandard 17,021 64,197 11,834 30,993 68,664 52,183 3,812 248,704 Non-accrual 198 65 76 205 — 33 — 577 Total Real estate-business: $ 442,646 $ 843,297 $ 600,856 $ 326,485 $ 280,015 $ 382,938 $ 61,615 $ 2,937,852 Commercial loans Risk Rating: Pass $ 2,007,137 $ 2,071,587 $ 1,438,465 $ 604,271 $ 396,072 $ 666,081 $ 1,747,371 $ 8,930,984 Special mention 17,914 58,777 33,058 43,639 22,228 9,283 13,960 198,859 Substandard 20,749 85,335 19,795 50,343 81,866 63,627 13,110 334,825 Non-accrual 644 65 77 2,262 110 5,688 24 8,870 Total Commercial loans: $ 2,046,444 $ 2,215,764 $ 1,491,395 $ 700,515 $ 500,276 $ 744,679 $ 1,774,465 $ 9,473,538 Term Loans Amortized Cost Basis by Origination Year (In thousands) 2020 2019 2018 2017 2016 Prior Revolving Loans Amortized Cost Basis Total December 31, 2020 Business Risk Rating: Pass $ 2,472,419 $ 966,068 $ 438,557 $ 329,207 $ 163,357 $ 281,604 $ 1,619,680 $ 6,270,892 Special mention 28,612 26,746 14,102 1,781 5,091 1,664 41,749 119,745 Substandard 17,246 21,985 5,076 2,675 3,578 13,390 68,976 132,926 Non-accrual 12,619 1 5,327 391 502 3,659 25 22,524 Total Business: $ 2,530,896 $ 1,014,800 $ 463,062 $ 334,054 $ 172,528 $ 300,317 $ 1,730,430 $ 6,546,087 Real estate-construction Risk Rating: Pass $ 483,302 $ 330,480 $ 56,747 $ 3,021 $ 24,426 $ 1,692 $ 27,356 $ 927,024 Special mention 29,692 — 1,022 34,532 — — — 65,246 Substandard 1,154 — 14,989 13,182 — — — 29,325 Total Real estate-construction: $ 514,148 $ 330,480 $ 72,758 $ 50,735 $ 24,426 $ 1,692 $ 27,356 $ 1,021,595 Real estate- business Risk Rating: Pass $ 890,740 $ 666,399 $ 336,850 $ 241,656 $ 313,691 $ 199,534 $ 67,796 $ 2,716,666 Special mention 8,936 21,734 49,580 6,597 17,504 1,309 3,002 108,662 Substandard 46,882 1,037 4,061 81,435 17,538 45,014 2,592 198,559 Non-accrual 478 188 1,480 — — 84 — 2,230 Total Real-estate business: $ 947,036 $ 689,358 $ 391,971 $ 329,688 $ 348,733 $ 245,941 $ 73,390 $ 3,026,117 Commercial loans Risk Rating: Pass $ 3,846,461 $ 1,962,947 $ 832,154 $ 573,884 $ 501,474 $ 482,830 $ 1,714,832 $ 9,914,582 Special mention 67,240 48,480 64,704 42,910 22,595 2,973 44,751 293,653 Substandard 65,282 23,022 24,126 97,292 21,116 58,404 71,568 360,810 Non-accrual 13,097 189 6,807 391 502 3,743 25 24,754 Total Commercial loans: $ 3,992,080 $ 2,034,638 $ 927,791 $ 714,477 $ 545,687 $ 547,950 $ 1,831,176 $ 10,593,799 The credit quality of Personal Banking loans is monitored primarily on the basis of aging/delinquency, and this information is provided as of September 30, 2021 and December 31, 2020 below: Term Loans Amortized Cost Basis by Origination Year (In thousands) 2021 2020 2019 2018 2017 Prior Revolving Loans Amortized Cost Basis Total September 30, 2021 Real estate-personal Current to 90 days past due $ 509,080 $ 941,728 $ 379,912 $ 170,651 $ 158,655 $ 595,786 $ 9,363 $ 2,765,175 Over 90 days past due 86 663 — 188 167 1,462 — 2,566 Non-accrual — — 185 111 — 1,255 — 1,551 Total Real estate-personal: $ 509,166 $ 942,391 $ 380,097 $ 170,950 $ 158,822 $ 598,503 $ 9,363 $ 2,769,292 Consumer Current to 90 days past due $ 441,146 $ 391,312 $ 221,490 $ 96,086 $ 59,935 $ 93,205 $ 744,082 $ 2,047,256 Over 90 days past due 54 310 250 230 27 253 1,179 2,303 Total Consumer: $ 441,200 $ 391,622 $ 221,740 $ 96,316 $ 59,962 $ 93,458 $ 745,261 $ 2,049,559 Revolving home equity Current to 90 days past due $ — $ — $ — $ — $ — $ — $ 280,612 $ 280,612 Over 90 days past due — — — — — — 830 830 Total Revolving home equity: $ — $ — $ — $ — $ — $ — $ 281,442 $ 281,442 Consumer credit card Current to 90 days past due $ — $ — $ — $ — $ — $ — $ 565,533 $ 565,533 Over 90 days past due — — — — — — 4,443 4,443 Total Consumer credit card: $ — $ — $ — $ — $ — $ — $ 569,976 $ 569,976 Overdrafts Current to 90 days past due $ 4,583 $ — $ — $ — $ — $ — $ — $ 4,583 Total Overdrafts: $ 4,583 $ — $ — $ — $ — $ — $ — $ 4,583 Personal banking loans Current to 90 days past due $ 954,809 $ 1,333,040 $ 601,402 $ 266,737 $ 218,590 $ 688,991 $ 1,599,590 $ 5,663,159 Over 90 days past due 140 973 250 418 194 1,715 6,452 10,142 Non-accrual — — 185 111 — 1,255 — 1,551 Total Personal banking loans: $ 954,949 $ 1,334,013 $ 601,837 $ 267,266 $ 218,784 $ 691,961 $ 1,606,042 $ 5,674,852 Term Loans Amortized Cost Basis by Origination Year (In thousands) 2020 2019 2018 2017 2016 Prior Revolving Loans Amortized Cost Basis Total December 31, 2020 Real estate-personal Current to 90 days past due $ 1,123,918 $ 488,379 $ 218,390 $ 201,971 $ 227,265 $ 544,008 $ 11,476 $ 2,815,407 Over 90 days past due 534 375 281 411 388 848 — 2,837 Non-accrual 29 191 116 45 65 1,340 — 1,786 Total Real estate-personal: $ 1,124,481 $ 488,945 $ 218,787 $ 202,427 $ 227,718 $ 546,196 $ 11,476 $ 2,820,030 Consumer Current to 90 days past due $ 536,799 $ 337,431 $ 161,337 $ 115,886 $ 75,769 $ 86,831 $ 633,186 $ 1,947,239 Over 90 days past due 212 358 328 220 174 397 1,574 3,263 Total Consumer: $ 537,011 $ 337,789 $ 161,665 $ 116,106 $ 75,943 $ 87,228 $ 634,760 $ 1,950,502 Revolving home equity Current to 90 days past due $ — $ — $ — $ — $ — $ — $ 306,693 $ 306,693 Over 90 days past due — — — — — — 390 390 Total Revolving home equity: $ — $ — $ — $ — $ — $ — $ 307,083 $ 307,083 Consumer credit card Current to 90 days past due $ — $ — $ — $ — $ — $ — $ 642,860 $ 642,860 Over 90 days past due — — — — — — 12,218 12,218 Total Consumer credit card: $ — $ — $ — $ — $ — $ — $ 655,078 $ 655,078 Overdrafts Current to 90 days past due $ 3,149 $ — $ — $ — $ — $ — $ — $ 3,149 Total Overdrafts: $ 3,149 $ — $ — $ — $ — $ — $ — $ 3,149 Personal banking loans Current to 90 days past due $ 1,663,866 $ 825,810 $ 379,727 $ 317,857 $ 303,034 $ 630,839 $ 1,594,215 $ 5,715,348 Over 90 days past due 746 733 609 631 562 1,245 14,182 18,708 Non-accrual 29 191 116 45 65 1,340 — 1,786 Total Personal banking loans: $ 1,664,641 $ 826,734 $ 380,452 $ 318,533 $ 303,661 $ 633,424 $ 1,608,397 $ 5,735,842 Collateral-dependent loans The Company's collateral-dependent loans are comprised of large loans on non-accrual status. The Company requires that collateral-dependent loans are either over-collateralized or carry collateral equal to the amortized cost of the loan. The following table presents the amortized cost basis of collateral-dependent loans as of September 30, 2021 and December 31, 2020. (In thousands) Business Assets Business Real Estate Oil & Gas Assets Total September 30, 2021 Commercial: Business $ 2,056 $ — $ 2,518 $ 4,574 Total $ 2,056 $ — $ 2,518 $ 4,574 December 31, 2020 Commercial: Business $ 13,109 $ — $ 2,695 $ 15,804 Real estate - business — 986 — 986 Total $ 13,109 $ 986 $ 2,695 $ 16,790 Other Personal Banking loan information As noted above, the credit quality of Personal Banking loans is monitored primarily on the basis of aging/delinquency, and this information is provided in the table in the above section on "Credit quality indicators." In addition, FICO scores are obtained and updated on a quarterly basis for most of the loans in the Personal Banking portfolio. This is a published credit score designed to measure the risk of default by taking into account various factors from a borrower's financial history and is considered supplementary information utilized by the Company, as management does not consider this information in evaluating the allowance for credit losses on loans. The Bank normally obtains a FICO score at the loan's origination and renewal dates, and updates are obtained on a quarterly basis. Excluded from the table below are certain personal real estate loans for which FICO scores are not obtained because the loans generally pertain to commercial customer activities and are often underwritten with other collateral considerations. These loans totaled $186.0 million at September 30, 2021 and $191.1 million at December 31, 2020. The table also excludes consumer loans related to the Company's patient healthcare loan program, which totaled $189.6 million at September 30, 2021 and $188.1 million at December 31, 2020. As the healthcare loans are guaranteed by the hospital, customer FICO scores are not obtained for these loans. The personal real estate loans and consumer loans excluded below totaled less than 7% of the Personal Banking portfolio. For the remainder of loans in the Personal Banking portfolio, the table below shows the percentage of balances outstanding at September 30, 2021 and December 31, 2020 by FICO score. Personal Banking Loans % of Loan Category Real Estate - Personal Consumer Revolving Home Equity Consumer Credit Card September 30, 2021 FICO score: Under 600 .9 % 1.7 % 0.9 % 3.3 % 600 - 659 2.0 3.8 2.3 11.3 660 - 719 7.8 14.2 9.2 30.8 720 - 779 24.4 25.0 21.0 28.5 780 and over 64.9 55.3 66.6 26.1 Total 100.0 % 100.0 % 100.0 % 100.0 % December 31, 2020 FICO score: Under 600 .8 % 2.3 % 1.3 % 5.0 % 600 - 659 1.9 4.2 2.4 12.3 660 - 719 8.8 14.1 8.6 31.2 720 - 779 24.5 23.9 22.2 28.0 780 and over 64.0 55.5 65.5 23.5 Total 100.0 % 100.0 % 100.0 % 100.0 % Troubled debt restructurings Restructured loans are those extended to borrowers who are experiencing financial difficulty and who have been granted a concession. Restructured loans are placed on non-accrual status if the Company does not believe it probable that amounts due under the contractual terms will be collected. Commercial performing restructured loans are primarily comprised of certain business, construction and business real estate loans classified as substandard but renewed at rates judged to be non-market. These loans are performing in accordance with their modified terms, and because the Company believes it probable that all amounts due under the modified terms of the agreements will be collected, interest on these loans is being recognized on an accrual basis. Troubled debt restructurings also include certain credit card and other small consumer loans under various debt management and assistance programs. Modifications to these loans generally involve removing the available line of credit, placing loans on amortizing status, and lowering the contractual interest rate. Certain personal real estate, revolving home equity, and consumer loans were classified as consumer bankruptcy troubled debt restructurings because they were not reaffirmed by the borrower in bankruptcy proceedings. Interest on these loans is being recognized on an accrual basis, as the borrowers are continuing to make payments. Other consumer loans classified as troubled debt restructurings consist of various other workout arrangements with consumer customers. (In thousands) September 30, 2021 December 31, 2020 Accruing restructured loans: Commercial $ 110,583 $ 117,740 Assistance programs 6,789 7,804 Consumer bankruptcy 2,327 2,841 Other consumer 2,293 2,353 Non-accrual loans 7,866 9,889 Total troubled debt restructurings $ 129,858 $ 140,627 Section 4013 of the CARES Act was signed into law on March 27, 2020, and includes a provision that short-term modifications are not troubled debt restructurings, if made on a good-faith basis in response to COVID-19 to borrowers who were current prior to December 31, 2019. The Company follows the guidance under the CARES Act when determining if a customer’s modification is subject to troubled debt restructuring classification. If it is deemed the modification is not short-term, not COVID-19 related or the customer does not meet the criteria under the guidance to be scoped out of troubled debt restructuring classification, the Company will evaluate the loan modifications under its existing framework which requires modifications that result in a concession to a borrower experiencing financial difficulty be accounted for as a troubled debt restructuring. The initial guidance issued under the CARES Act was due to expire on December 31, 2020. During January 2021, the Consolidated Appropriations Act, 2021 was enacted and extended through the end of 2021 the relief offered under the CARES Act related to the accounting and disclosure requirements for troubled debt restructurings as a result of COVID-19. The Company elected to adopt the extension of this guidance. The table below shows the balance of troubled debt restructurings by loan classification at September 30, 2021, in addition to the outstanding balances of these restructured loans which the Company considers to have been in default at any time during the past twelve months. For purposes of this disclosure, the Company considers "default" to mean 90 days or more past due as to interest or principal. (In thousands) September 30, 2021 Balance 90 days past due at any time during previous 12 months Commercial: Business $ 53,850 $ 347 Real estate - construction and land 10,104 — Real estate - business 53,240 198 Personal Banking: Real estate - personal 3,131 483 Consumer 2,865 177 Revolving home equity 23 — Consumer credit card 6,645 368 Total troubled debt restructurings $ 129,858 $ 1,573 For those loans on non-accrual status also classified as restructured, the modification did not create any further financial effect on the Company as those loans were already recorded at net realizable value. For those performing commercial loans classified as restructured, there were no concessions involving forgiveness of principal or interest and, therefore, there was no financial impact to the Company as a result of modification to these loans. No financial impact resulted from those performing loans where the debt was not reaffirmed in bankruptcy, as no changes to loan terms occurred in that process. However, the effects of modifications to loans under various debt management and assistance programs were estimated to decrease interest income by approximately $815 thousand on an annual, pre-tax basis, compared to amounts contractually owed. Other modifications to consumer loans mainly involve extensions and other small modifications that did not include the forgiveness of principal or interest. The allowance for credit losses related to troubled debt restructurings on non-accrual status is determined by individual evaluation, including collateral adequacy, using the same process as loans on non-accrual status which are not classified as troubled debt restructurings. Those performing loans classified as troubled debt restructurings are accruing loans which management expects to collect under contractual terms. Performing commercial loans having no other concessions granted other than being renewed at non-market interest rates are judged to have similar risk characteristics as non-troubled debt commercial loans and are collectively evaluated based on internal risk rating, loan type, delinquency, historical experience and current economic factors. Performing personal banking loans classified as troubled debt restructurings resulted from the borrower not reaffirming the debt during bankruptcy and have had no other concession granted, other than the Bank's future limitations on collecting payment deficiencies or in pursuing foreclosure actions. As such, they have similar risk characteristics as non-troubled debt personal banking loans and are evaluated collectively based on loan type, delinquency, historical experience and current economic factors. If a troubled debt restructuring defaults and is already on non-accrual status, the allowance for credit losses continues to be based on individual evaluation, using discounted expected cash flows or the fair value of collateral. If an accruing troubled debt restructuring defaults, the loan's risk rating is downgraded to non-accrual status and the loan's related allowance for credit losses is determined based on individual evaluation, or if necessary, the loan is charged off and collection efforts begin. The Company had commitments of $245 thousand at September 30, 2021 to lend additional funds to borrowers with restructured loans. Additionally, the Company had commitments at September 30, 2021 of $24.0 million related to letters of credit with an internal risk rating below substandard. Loans held for sale The Company designates certain long-term fixed rate personal real estate loans as held for sale, and the Company has elected the fa |
