Loans and Allowance for Credit Losses | Note 4 Loans and Allowance for Credit Losses The composition of the loan portfolio, disaggregated by class and underlying specific portfolio type, was as follows: June 30, 2015 December 31, 2014 (Dollars in Millions) Amount Percent Amount Percent Commercial Commercial $ 79,323 31.9 % $ 74,996 30.2 % Lease financing 5,297 2.1 5,381 2.2 Total commercial 84,620 34.0 80,377 32.4 Commercial Real Estate Commercial mortgages 32,060 12.9 33,360 13.5 Construction and development 10,198 4.1 9,435 3.8 Total commercial real estate 42,258 17.0 42,795 17.3 Residential Mortgages Residential mortgages 38,310 15.4 38,598 15.6 Home equity loans, first liens 13,027 5.2 13,021 5.2 Total residential mortgages 51,337 20.6 51,619 20.8 Credit Card 17,788 7.2 18,515 7.5 Other Retail Retail leasing 5,616 2.3 5,871 2.4 Home equity and second mortgages 16,071 6.5 15,916 6.4 Revolving credit 3,289 1.3 3,309 1.3 Installment 6,741 2.7 6,242 2.5 Automobile 15,935 6.4 14,822 6.0 Student (a) – – 3,104 1.3 Total other retail 47,652 19.2 49,264 19.9 Total loans, excluding covered loans 243,655 98.0 242,570 97.9 Covered Loans 4,984 2.0 5,281 2.1 Total loans $ 248,639 100.0 % $ 247,851 100.0 % (a) The Company transferred all of its student loans to loans held for sale at the end of the first quarter of 2015. The Company had loans of $79.4 billion at June 30, 2015, and $79.8 billion at December 31, 2014, pledged at the Federal Home Loan Bank (“FHLB”), and loans of $64.8 billion at June 30, 2015, and $61.8 billion at December 31, 2014, pledged at the Federal Reserve Bank. Originated loans are reported at the principal amount outstanding, net of unearned interest and deferred fees and costs. Net unearned interest and deferred fees and costs amounted to $509 million at June 30, 2015, and $574 million at December 31, 2014. All purchased loans and related indemnification assets are recorded at fair value at the date of purchase. The Company evaluates purchased loans for impairment at the date of purchase in accordance with applicable authoritative accounting guidance. Purchased loans with evidence of credit deterioration since origination for which it is probable that all contractually required payments will not be collected are considered “purchased impaired loans.” All other purchased loans are considered “purchased nonimpaired loans.” Changes in the accretable balance for purchased impaired loans were as follows: Three Months Ended Six Months Ended (Dollars in Millions) 2015 2014 2015 2014 Balance at beginning of period $ 1,187 $ 1,584 $ 1,309 $ 1,655 Accretion (100 ) (120 ) (198 ) (231 ) Disposals (43 ) (29 ) (70 ) (69 ) Reclassifications from nonaccretable difference (a) 32 53 37 134 Other – (1 ) (2 ) (2 ) Balance at end of period $ 1,076 $ 1,487 $ 1,076 $ 1,487 (a) Primarily relates to changes in expected credit performance. Allowance for Credit Losses The allowance for credit losses reserves for probable and estimable losses incurred in the Company’s loan and lease portfolio, including unfunded credit commitments, and includes certain amounts that do not represent loss exposure to the Company because those losses are recoverable under loss sharing agreements with the Federal Deposit Insurance Corporation (“FDIC”). The allowance for credit losses is increased through provisions charged to operating earnings and reduced by net charge-offs. Management evaluates the allowance each quarter to ensure it appropriately reserves for incurred losses. The allowance recorded for loans in the commercial lending segment is based on reviews of individual credit relationships and considers the migration analysis of commercial lending segment loans and actual loss experience. In the migration analysis applied to risk rated loan portfolios, the Company currently examines up to a 14-year period of loss experience. For each loan type, this historical loss experience is adjusted as necessary to consider any relevant changes in portfolio composition, lending policies, underwriting standards, risk management practices or economic conditions. The results of the analysis are evaluated quarterly to confirm an appropriate historical time frame is selected for each commercial loan type. The allowance recorded for impaired loans greater than $5 million in the commercial lending segment is based on an individual loan analysis utilizing expected cash flows discounted using the original effective interest rate, the observable market price of the loan, or the fair value of the collateral for collateral-dependent loans, rather than the migration analysis. The allowance recorded for all other commercial lending segment loans is determined on a homogenous pool basis and includes consideration of product mix, risk characteristics of the portfolio, bankruptcy experience, portfolio growth and historical losses, adjusted for current trends. The Company also considers the impacts of any loan modifications made to commercial lending segment loans and any subsequent payment defaults to its expectations of cash flows, principal balance, and current expectations about the borrower’s ability to pay in determining the allowance for credit losses. The allowance recorded for Troubled Debt Restructuring (“TDR”) loans and purchased impaired loans in the consumer lending segment is determined on a homogenous pool basis utilizing expected cash flows discounted using the original effective interest rate of the pool, or the prior quarter effective rate, respectively. The allowance for collateral-dependent loans in the consumer lending segment is determined based on the fair value of the collateral less costs to sell. The allowance recorded for all other consumer lending segment loans is determined on a homogenous pool basis and includes consideration of product mix, risk characteristics of the portfolio, bankruptcy experience, delinquency status, refreshed loan-to-value ratios when possible, portfolio growth and historical losses, adjusted for current trends. The Company also considers any modifications made to consumer lending segment loans including the impacts of any subsequent payment defaults since modification in determining the allowance for credit losses, such as the borrower’s ability to pay under the restructured terms, and the timing and amount of payments. The allowance for the covered loan segment is evaluated each quarter in a manner similar to that described for non-covered loans and reflects decreases in expected cash flows of those loans after the acquisition date. The provision for credit losses for covered loans considers the indemnification provided by the FDIC. In addition, subsequent payment defaults on loan modifications considered TDRs are considered in the underlying factors used in the determination of the appropriateness of the allowance for credit losses. For each loan segment, the Company estimates future loan charge-offs through a variety of analysis, trends and underlying assumptions. With respect to the commercial lending segment, TDRs may be collectively evaluated for impairment where observed performance history, including defaults, is a primary driver of the loss allocation. For commercial TDRs individually evaluated for impairment, attributes of the borrower are the primary factors in determining the allowance for credit losses. However, historical loss experience is also incorporated into the allowance methodology applied to this category of loans. With respect to the consumer lending segment, performance of the portfolio, including defaults on TDRs, is considered when estimating future cash flows. The Company’s methodology for determining the appropriate allowance for credit losses for all the loan segments also considers the imprecision inherent in the methodologies used. As a result, in addition to the amounts determined under the methodologies described above, management also considers the potential impact of other qualitative factors which include, but are not limited to, economic factors; geographic and other concentration risks; delinquency and nonaccrual trends; current business conditions; changes in lending policy, underwriting standards, internal review and other relevant business practices; and the regulatory environment. The consideration of these items results in adjustments to allowance amounts included in the Company’s allowance for credit losses for each of the above loan segments. The Company also assesses the credit risk associated with off-balance sheet loan commitments, letters of credit, and derivatives. Credit risk associated with derivatives is reflected in the fair values recorded for those positions. The liability for off-balance sheet credit exposure related to loan commitments and other credit guarantees is included in other liabilities. Because business processes and credit risks associated with unfunded credit commitments are essentially the same as for loans, the Company utilizes similar processes to estimate its liability for unfunded credit commitments. Activity in the allowance for credit losses by portfolio class was as follows: Three Months Ended June 30, (Dollars in Millions) Commercial Commercial Residential Credit Other Total Loans, Covered Total 2015 Balance at beginnng of period $ 1,200 $ 721 $ 764 $ 871 $ 738 $ 4,294 $ 57 $ 4,351 Add Provision for credit losses 22 15 6 171 65 279 2 281 Deduct Loans charged off 65 9 41 190 75 380 – 380 Less recoveries of loans charged off (23 ) (8 ) (8 ) (21 ) (24 ) (84 ) – (84 ) Net loans charged off 42 1 33 169 51 296 – 296 Other changes (a) – – – – – – (10 ) (10 ) Balance at end of period $ 1,180 $ 735 $ 737 $ 873 $ 752 $ 4,277 $ 49 $ 4,326 2014 Balance at beginnng of period $ 1,091 $ 742 $ 862 $ 884 $ 785 $ 4,364 $ 133 $ 4,497 Add Provision for credit losses 75 (21 ) 43 163 63 323 1 324 Deduct Loans charged off 76 9 62 188 95 430 2 432 Less recoveries of loans charged off (21 ) (13 ) (5 ) (18 ) (26 ) (83 ) – (83 ) Net loans charged off 55 (4 ) 57 170 69 347 2 349 Other changes (a) – – – (3 ) – (3 ) (20 ) (23 ) Balance at end of period $ 1,111 $ 725 $ 848 $ 874 $ 779 $ 4,337 $ 112 $ 4,449 (a) Includes net changes in credit losses to be reimbursed by the FDIC and reductions in the allowance for covered loans where the reversal of a previously recorded allowance was offset by an associated decrease in the indemnification asset, and the impact of any loan sales. Six Months Ended June 30, (Dollars in Millions) Commercial Commercial Residential Credit Other Total Loans, Covered Total 2015 Balance at beginnng of period $ 1,146 $ 726 $ 787 $ 880 $ 771 $ 4,310 $ 65 $ 4,375 Add Provision for credit losses 120 (8 ) 18 325 88 543 2 545 Deduct Loans charged off 139 14 82 372 156 763 – 763 Less recoveries of loans charged off (54 ) (31 ) (14 ) (40 ) (49 ) (188 ) – (188 ) Net loans charged off 85 (17 ) 68 332 107 575 – 575 Other changes (a) (1 ) – – – – (1 ) (18 ) (19 ) Balance at end of period $ 1,180 $ 735 $ 737 $ 873 $ 752 $ 4,277 $ 49 $ 4,326 2014 Balance at beginnng of period $ 1,075 $ 776 $ 875 $ 884 $ 781 $ 4,391 $ 146 $ 4,537 Add Provision for credit losses 127 (58 ) 87 333 143 632 (2 ) 630 Deduct Loans charged off 139 17 123 372 195 846 8 854 Less recoveries of loans charged off (48 ) (24 ) (9 ) (32 ) (50 ) (163 ) (1 ) (164 ) Net loans charged off 91 (7 ) 114 340 145 683 7 690 Other changes (a) – – – (3 ) – (3 ) (25 ) (28 ) Balance at end of period $ 1,111 $ 725 $ 848 $ 874 $ 779 $ 4,337 $ 112 $ 4,449 (a) Includes net changes in credit losses to be reimbursed by the FDIC and reductions in the allowance for covered loans where the reversal of a previously recorded allowance was offset by an associated decrease in the indemnification asset, and the impact of any loan sales. Additional detail of the allowance for credit losses by portfolio class was as follows: (Dollars in Millions) Commercial Commercial Residential Credit Other Total Loans, Covered Total Allowance Balance at June 30, 2015 Related to Loans individually evaluated for impairment (a) $ 7 $ 2 $ – $ – $ – $ 9 $ – $ 9 TDRs collectively evaluated for impairment 8 8 294 55 37 402 2 404 Other loans collectively evaluated for impairment 1,165 709 443 818 715 3,850 2 3,852 Loans acquired with deteriorated credit quality – 16 – – – 16 45 61 Total allowance for credit losses $ 1,180 $ 735 $ 737 $ 873 $ 752 $ 4,277 $ 49 $ 4,326 Allowance Balance at December 31, 2014 Related to Loans individually evaluated for impairment (a) $ 5 $ 4 $ – $ – $ – $ 9 $ – $ 9 TDRs collectively evaluated for impairment 12 12 319 61 41 445 4 449 Other loans collectively evaluated for impairment 1,129 678 468 819 730 3,824 1 3,825 Loans acquired with deteriorated credit quality – 32 – – – 32 60 92 Total allowance for credit losses $ 1,146 $ 726 $ 787 $ 880 $ 771 $ 4,310 $ 65 $ 4,375 (a) Represents the allowance for credit losses related to loans greater than $5 million classified as nonperforming or TDRs. Additional detail of loan balances by portfolio class was as follows: (Dollars in Millions) Commercial Commercial Residential Credit Other Total Loans, Covered Total June 30, 2015 Loans individually evaluated for impairment (a) $ 209 $ 83 $ 12 $ – $ – $ 304 $ – $ 304 TDRs collectively evaluated for impairment 129 255 4,508 218 219 5,329 35 5,364 Other loans collectively evaluated for impairment 84,281 41,603 46,816 17,570 47,433 237,703 2,288 239,991 Loans acquired with deteriorated credit quality 1 317 1 – – 319 2,661 2,980 Total loans $ 84,620 $ 42,258 $ 51,337 $ 17,788 $ 47,652 $ 243,655 $ 4,984 $ 248,639 December 31, 2014 Loans individually evaluated for impairment (a) $ 159 $ 128 $ 12 $ – $ – $ 299 $ – $ 299 TDRs collectively evaluated for impairment 124 393 4,653 240 237 5,647 34 5,681 Other loans collectively evaluated for impairment 80,093 41,744 46,953 18,275 49,027 236,092 2,463 238,555 Loans acquired with deteriorated credit quality 1 530 1 – – 532 2,784 3,316 Total loans $ 80,377 $ 42,795 $ 51,619 $ 18,515 $ 49,264 $ 242,570 $ 5,281 $ 247,851 (a) Represents loans greater than $5 million classified as nonperforming or TDRs. (b) Includes expected reimbursements from the FDIC under loss sharing agreements. Credit Quality The quality of the Company’s loan portfolios is assessed as a function of net credit losses, levels of nonperforming assets and delinquencies, and credit quality ratings as defined by the Company. For all loan classes, loans are considered past due based on the number of days delinquent except for monthly amortizing loans which are classified delinquent based upon the number of contractually required payments not made (for example, two missed payments is considered 30 days delinquent). When a loan is placed on nonaccrual status, unpaid accrued interest is reversed. Commercial lending segment loans are generally placed on nonaccrual status when the collection of principal and interest has become 90 days past due or is otherwise considered doubtful. Commercial lending segment loans are generally fully or partially charged down to the fair value of the collateral securing the loan, less costs to sell, when the loan is considered uncollectible. Consumer lending segment loans are generally charged-off at a specific number of days or payments past due. Residential mortgages and other retail loans secured by 1-4 family properties are generally charged down to the fair value of the collateral securing the loan, less costs to sell, at 180 days past due, and placed on nonaccrual status in instances where a partial charge-off occurs unless the loan is well secured and in the process of collection. Loans and lines in a junior lien position secured by 1-4 family properties are placed on nonaccrual status at 120 days past due or when behind a first lien that has become 180 days or greater past due or placed on nonaccrual status. Any secured consumer lending segment loan whose borrower has had debt discharged through bankruptcy, for which the loan amount exceeds the fair value of the collateral, is charged down to the fair value of the related collateral and the remaining balance is placed on nonaccrual status. Credit card loans continue to accrue interest until the account is charged off. Credit cards are charged off at 180 days past due. Other retail loans not secured by 1-4 family properties are charged-off at 120 days past due; and revolving consumer lines are charged off at 180 days past due. Similar to credit cards, other retail loans are generally not placed on nonaccrual status because of the relative short period of time to charge-off. Certain retail customers having financial difficulties may have the terms of their credit card and other loan agreements modified to require only principal payments and, as such, are reported as nonaccrual. For all loan classes, interest payments received on nonaccrual loans are generally recorded as a reduction to a loan’s carrying amount while a loan is on nonaccrual and are recognized as interest income upon payoff of the loan. However, interest income may be recognized for interest payments if the remaining carrying amount of the loan is believed to be collectible. In certain circumstances, loans in any class may be restored to accrual status, such as when a loan has demonstrated sustained repayment performance or no amounts are past due and prospects for future payment are no longer in doubt; or when the loan becomes well secured and is in the process of collection. Loans where there has been a partial charge-off may be returned to accrual status if all principal and interest (including amounts previously charged-off) is expected to be collected and the loan is current. Covered loans not considered to be purchased impaired are evaluated for delinquency, nonaccrual status and charge-off consistent with the class of loan they would be included in had the loss share coverage not been in place. Generally, purchased impaired loans are considered accruing loans. However, the timing and amount of future cash flows for some loans is not reasonably estimable, and those loans are classified as nonaccrual loans with interest income not recognized until the timing and amount of the future cash flows can be reasonably estimated. The following table provides a summary of loans by portfolio class, including the delinquency status of those that continue to accrue interest, and those that are nonperforming: Accruing (Dollars in Millions) Current 30-89 Days 90 Days or Nonperforming Total June 30, 2015 Commercial $ 84,292 $ 195 $ 43 $ 90 $ 84,620 Commercial real estate 42,011 52 20 175 42,258 Residential mortgages (a) 50,217 195 156 769 51,337 Credit card 17,383 206 183 16 17,788 Other retail 47,214 193 67 178 47,652 Total loans, excluding covered loans 241,117 841 469 1,228 243,655 Covered loans 4,568 73 332 11 4,984 Total loans $ 245,685 $ 914 $ 801 $ 1,239 $ 248,639 December 31, 2014 Commercial $ 79,977 $ 247 $ 41 $ 112 $ 80,377 Commercial real estate 42,406 110 20 259 42,795 Residential mortgages (a) 50,330 221 204 864 51,619 Credit card 18,046 229 210 30 18,515 Other retail 48,764 238 75 187 49,264 Total loans, excluding covered loans 239,523 1,045 550 1,452 242,570 Covered loans 4,804 68 395 14 5,281 Total loans $ 244,327 $ 1,113 $ 945 $ 1,466 $ 247,851 (a) At June 30, 2015, $375 million of loans 30–89 days past due and $2.9 billion of loans 90 days or more past due purchased from Government National Mortgage Association (“GNMA”) mortgage pools whose repayments are insured by the Federal Housing Administration or guaranteed by the Department of Veterans Affairs, were classified as current, compared with $431 million and $3.1 billion at December 31, 2014, respectively. At June 30, 2015, the amount of foreclosed residential real estate held by the Company, and included in other real estate owned, was $274 million ($239 million excluding covered assets), compared with $270 million ($233 million excluding covered assets) at December 31, 2014. This excludes $753 million and $641 million at June 30, 2015 and December 31, 2014, respectively, of foreclosed residential real estate related to mortgage loans whose payments are primarily insured by the Federal Housing Administration or guaranteed by the Department of Veterans Affairs. In addition, the amount of residential mortgage loans secured by residential real estate in the process of foreclosure at June 30, 2015 and December 31, 2014, was $2.8 billion and $2.9 billion, respectively, of which $2.1 billion related to loans purchased from Government National Mortgage Association (“GNMA”) mortgage pools whose repayments are insured by the Federal Housing Administration or guaranteed by the Department of Veterans Affairs. The Company classifies its loan portfolios using internal credit quality ratings on a quarterly basis. These ratings include: pass, special mention and classified, and are an important part of the Company’s overall credit risk management process and evaluation of the allowance for credit losses. Loans with a pass rating represent those not classified on the Company’s rating scale for problem credits, as minimal credit risk has been identified. Special mention loans are those that have a potential weakness deserving management’s close attention. Classified loans are those where a well-defined weakness has been identified that may put full collection of contractual cash flows at risk. It is possible that others, given the same information, may reach different reasonable conclusions regarding the credit quality rating classification of specific loans. The following table provides a summary of loans by portfolio class and the Company’s internal credit quality rating: Criticized (Dollars in Millions) Pass Special Classified (a) Total Total June 30, 2015 Commercial (b) $ 81,686 $ 1,808 $ 1,126 $ 2,934 $ 84,620 Commercial real estate 41,075 357 826 1,183 42,258 Residential mortgages (c) 50,343 8 986 994 51,337 Credit card 17,589 – 199 199 17,788 Other retail 47,347 6 299 305 47,652 Total loans, excluding covered loans 238,040 2,179 3,436 5,615 243,655 Covered loans 4,882 – 102 102 4,984 Total loans $ 242,922 $ 2,179 $ 3,538 $ 5,717 $ 248,639 Total outstanding commitments $ 508,702 $ 3,773 $ 4,197 $ 7,970 $ 516,672 December 31, 2014 Commercial (b) $ 78,409 $ 1,204 $ 764 $ 1,968 $ 80,377 Commercial real estate 41,322 451 1,022 1,473 42,795 Residential mortgages (c) 50,479 5 1,135 1,140 51,619 Credit card 18,275 – 240 240 18,515 Other retail 48,932 20 312 332 49,264 Total loans, excluding covered loans 237,417 1,680 3,473 5,153 242,570 Covered loans 5,164 – 117 117 5,281 Total loans $ 242,581 $ 1,680 $ 3,590 $ 5,270 $ 247,851 Total outstanding commitments $ 501,535 $ 2,964 $ 4,179 $ 7,143 $ 508,678 (a) Classified rating on consumer loans primarily based on delinquency status. (b) At June 30, 2015, $907 million of loans to customers in energy-related businesses had a special mention or classified rating, compared with $122 million at December 31, 2014. (c) At June 30, 2015, $2.9 billion of GNMA loans 90 days or more past due and $2.1 billion of restructured GNMA loans whose repayments are insured by the Federal Housing Administration or guaranteed by the Department of Veterans Affairs were classified with a pass rating, compared with $3.1 billion and $2.2 billion at December 31, 2014, respectively. For all loan classes, a loan is considered to be impaired when, based on current events or information, it is probable the Company will be unable to collect all amounts due per the contractual terms of the loan agreement. Impaired loans include all nonaccrual and TDR loans. For all loan classes, interest income on TDR loans is recognized under the modified terms and conditions if the borrower has demonstrated repayment performance at a level commensurate with the modified terms over several payment cycles. Interest income is generally not recognized on other impaired loans until the loan is paid off. However, interest income may be recognized for interest payments if the remaining carrying amount of the loan is believed to be collectible. Factors used by the Company in determining whether all principal and interest payments due on commercial and commercial real estate loans will be collected and therefore whether those loans are impaired include, but are not limited to, the financial condition of the borrower, collateral and/or guarantees on the loan, and the borrower’s estimated future ability to pay based on industry, geographic location and certain financial ratios. The evaluation of impairment on residential mortgages, credit card loans and other retail loans is primarily driven by delinquency status of individual loans or whether a loan has been modified, and considers any government guarantee where applicable. Individual covered loans, whose future losses are covered by loss sharing agreements with the FDIC that substantially reduce the risk of credit losses to the Company, are evaluated for impairment and accounted for in a manner consistent with the class of loan they would have been included in had the loss sharing coverage not been in place. A summary of impaired loans, which include all nonaccrual and TDR loans, by portfolio class was as follows: (Dollars in Millions) Period-end Unpaid Valuation Commitments June 30, 2015 Commercial $ 376 $ 901 $ 17 $ 57 Commercial real estate 415 1,026 14 11 Residential mortgages 2,700 3,426 250 – Credit card 218 218 55 – Other retail 334 537 40 3 Total impaired loans, excluding GNMA and covered loans 4,043 6,108 376 71 Loans purchased from GNMA mortgage pools 2,080 2,080 48 – Covered loans 42 49 2 1 Total $ 6,165 $ 8,237 $ 426 $ 72 December 31, 2014 Commercial $ 329 $ 769 $ 21 $ 51 Commercial real estate 624 1,250 23 18 Residential mortgages 2,730 3,495 273 – Credit card 240 240 61 – Other retail 361 570 44 4 Total impaired loans, excluding GNMA and covered loans 4,284 6,324 422 73 Loans purchased from GNMA mortgage pools 2,244 2,244 50 – Covered loans 43 55 4 1 Total $ 6,571 $ 8,623 $ 476 $ 74 (a) Substantially all loans classified as impaired at June 30, 2015 and December 31, 2014, had an associated allowance for credit losses. Additional information on impaired loans follows: 2015 2014 (Dollars in Millions) Average Interest Average Interest Three Months Ended June 30 Commercial $ 335 $ 4 $ 447 $ 2 Commercial real estate 445 7 592 4 Residential mortgages 2,688 33 2,739 37 Credit card 222 1 281 3 Other retail 342 3 381 4 Total impaired loans, excluding GNMA and covered loans 4,032 48 4,440 50 Loans purchased from GNMA mortgage pools 2,119 25 2,766 33 Covered loans 42 – 397 5 Total $ 6,193 $ 73 $ 7,603 $ 88 Six Months Ended June 30 Commercial $ 323 $ 6 $ 432 $ 4 Commercial real estate 497 10 626 13 Residential mortgages 2,696 66 2,746 72 Credit card 228 3 290 6 Other retail 348 7 385 8 Total impaired loans, excluding GNMA and covered loans 4,092 92 4,479 103 Loans purchased from GNMA mortgage pools 2,160 50 2,714 66 Covered loans 42 – 416 10 Total $ 6,294 $ 142 $ 7,609 $ 179 Troubled Debt Restructurings In certain circumstances, the Company may modify the terms of a loan to maximize the collection of amounts due when a borrower is experiencing financial difficulties or is expected to experience difficulties in the near-term. Concessionary modifications are classified as TDRs unless the modification results in only an insignificant delay in payments to be received. The Company recognizes interest on TDRs if the borrower complies with the revised terms and conditions as agreed upon with the Company and has demonstrated repayment performance at a level commensurate with the modified terms over several payment cycles, which is generally six months or greater. To the extent a previous restructuring was insignificant, the Company considers the cumulative effect of past restructurings related to the receivable when determining whether a current restructuring is a TDR. Loans classified as TDRs are considered impaired loans for reporting and measurement purposes. The following table provides a summary of loans modified as TDRs during the periods presented by portfolio class: 2015 2014 (Dollars in Millions) Number Pre-Modification Balance Post-Modification Balance Number Pre-Modification Balance Post-Modification Balance Three Months Ended June 30 Commercial 430 $ 93 $ 98 566 $ 74 $ 66 Commercial real estate 29 27 26 12 8 7 Residential mortgages 1,065 135 134 679 91 91 Credit card 6,352 32 32 6,516 36 36 Other retail 662 12 12 649 13 14 Total loans, excluding GNMA and covered loans 8,538 299 302 8,422 222 214 Loans purchased from GNMA mortgage pools 1,950 242 241 2,362 281 279 Covered loans 8 3 3 7 2 2 Total loans 10,496 $ 544 $ 546 10,791 $ 505 $ 495 Six Months Ended June 30 Commercial 789 $ 116 $ 121 1,185 $ 153 $ 143 Commercial real estate 54 40 39 27 19 15 Residential mortgages 1,439 186 185 1,207 161 161 Credit card 12,689 65 65 13,332 76 76 Other retail 1,284 23 23 1,436 34 34 Total loans, excluding GNMA and covered loans 16,255 430 433 17,187 443 429 Loans purchased from GNMA mortgage pools 3,974 488 486 4,925 538 525 Covered loans 9 3 3 20 11 10 Total loans 20,238 $ 921 $ 922 22,132 $ 992 $ 964 Residential mortgages, home equity and second mortgages, and loans purchased from GNMA mortgage pools in the table above include trial period arrangements offered to customers during the periods presented. The post-modification balances for these loans reflect the current outstanding balance until a permanent modification is made. In addition, the post-modification balances typically include capitalization of unpaid accrued interest and/or fees under the various modification programs. For those loans modified as TDRs during the second quarter of 2015, at June 30, 2015, 237 residential mortgages, 57 home equity and second mortgage loans and 2,154 loans purchased from GNMA mortgage pools with outstanding balances of $33 million, $4 million and $279 million, respectively, were in a trial period and have estimated post-modification balances of $33 million, $3 million and $284 million, respectively, assuming permanent modification occurs at the end of the trial period. The Company has implemented certain restructuring programs that may result in TDRs. However, many of the Company’s TDRs are also determined on a case-by-case basis in connection with ongoing loan collection processes. For the commercial lending segment, modifications generally result in the Company working with borrowers on a case-by-case basis. Commercial and commercial real estate modifications generally include extensions of the maturity date and may be accompanied by an increase or decrease to the interest rate, which may not be deemed a market rate of interest. In addition, the Company may work with the borrower in identifying other changes that mitigate loss to the Company, which may include additional collateral or guarantees to support the loan. To a lesser extent, the Company may waive contractual principal. The Company classifies all of the above concessions as TDRs to the extent the Company determines that the borrower is experiencing financial difficulty. Modifications for the consumer lending segment are generally part of programs the Company has initiated. The Company participates in the U.S. Department of Treasury Home Affordable Modification Program (“HAMP”). HAMP gives qualifying homeowners an opportunity to permanently modify residential mortgage loans and achieve more affordable monthly payments, with the U.S. Department of Treasury compensating the Company for a portion of the reduction in monthly amounts due from borrowers participating in this program. The Company also modifies residential mortgage loans under Federal Housing Administration, Department of Veterans Affairs, or its own internal programs. Under these programs, the Company provides concessions to qualifying borrowers experiencing financial difficulties. The concessions may include adjustments to interest rates, conversion of adjustable rates to fixed rates, extension of maturity dates or deferrals of payments, capitalization of accrued interest and/or outstanding advances, or in limited situations, partial forgiveness of loan principal. In most instances, participation in residential mortgage loan restructuring programs requires the customer to complete a short-term trial period. A permanent loan modification is contingent on the customer successfully completing the trial period arrangement and the loan documents are not modified until that time. The Company reports loans in a trial period arrangement as TDRs and continues to report them as TDRs after the trial period. Credit card and other retail loan TDRs are generally part of distinct restructuring programs providing customers experiencing financial difficulty with modif |