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: September 30, 2015 December 31, 2014 (Dollars in Millions) Amount Percent Amount Percent Commercial Commercial $ 80,313 31.5 % $ 74,996 30.2 % Lease financing 5,226 2.1 5,381 2.2 Total commercial 85,539 33.6 80,377 32.4 Commercial Real Estate Commercial mortgages 32,089 12.6 33,360 13.5 Construction and development 10,389 4.1 9,435 3.8 Total commercial real estate 42,478 16.7 42,795 17.3 Residential Mortgages Residential mortgages 39,341 15.4 38,598 15.6 Home equity loans, first liens 13,008 5.1 13,021 5.2 Total residential mortgages 52,349 20.5 51,619 20.8 Credit Card 18,583 7.3 18,515 7.5 Other Retail Retail leasing 5,387 2.1 5,871 2.4 Home equity and second mortgages 16,188 6.3 15,916 6.4 Revolving credit 3,334 1.3 3,309 1.3 Installment 6,949 2.7 6,242 2.5 Automobile 16,484 6.5 14,822 6.0 Student 2,709 1.1 3,104 1.3 Total other retail 51,051 20.0 49,264 19.9 Total loans, excluding covered loans 250,000 98.1 242,570 97.9 Covered Loans 4,791 1.9 5,281 2.1 Total loans $ 254,791 100.0 % $ 247,851 100.0 % The Company had loans of $78.5 billion at September 30, 2015, and $79.8 billion at December 31, 2014, pledged at the Federal Home Loan Bank, and loans of $62.8 billion at September 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 $559 million at September 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 Nine Months Ended (Dollars in Millions) 2015 2014 2015 2014 Balance at beginning of period $ 1,076 $ 1,487 $ 1,309 $ 1,655 Accretion (91 ) (105 ) (289 ) (336 ) Disposals (32 ) (34 ) (102 ) (103 ) Reclassifications from nonaccretable difference (a) 120 38 157 172 Other 1 – (1 ) (2 ) Balance at end of period $ 1,074 $ 1,386 $ 1,074 $ 1,386 (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 September 30, (Dollars in Millions) Commercial Commercial Residential Credit Other Total Loans, Covered Total 2015 Balance at beginning of period $ 1,180 $ 735 $ 737 $ 873 $ 752 $ 4,277 $ 49 $ 4,326 Add Provision for credit losses 114 (10 ) (24 ) 156 46 282 – 282 Deduct Loans charged off 91 2 31 171 77 372 – 372 Less recoveries of loans charged off (20 ) (13 ) (6 ) (18 ) (23 ) (80 ) – (80 ) Net loans charged off 71 (11 ) 25 153 54 292 – 292 Other changes (a) – – – – – – (10 ) (10 ) Balance at end of period $ 1,223 $ 736 $ 688 $ 876 $ 744 $ 4,267 $ 39 $ 4,306 2014 Balance at beginning of period $ 1,111 $ 725 $ 848 $ 874 $ 779 $ 4,337 $ 112 $ 4,449 Add Provision for credit losses 83 (6 ) (13 ) 162 84 310 1 311 Deduct Loans charged off 80 10 48 174 96 408 2 410 Less recoveries of loans charged off (22 ) (6 ) (6 ) (16 ) (23 ) (73 ) (1 ) (74 ) Net loans charged off 58 4 42 158 73 335 1 336 Other changes (a) – – – – – – (10 ) (10 ) Balance at end of period $ 1,136 $ 715 $ 793 $ 878 $ 790 $ 4,312 $ 102 $ 4,414 (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. Nine Months Ended September 30, (Dollars in Millions) Commercial Commercial Residential Credit Other Total Loans, Covered Total 2015 Balance at beginning of period $ 1,146 $ 726 $ 787 $ 880 $ 771 $ 4,310 $ 65 $ 4,375 Add Provision for credit losses 234 (18 ) (6 ) 481 134 825 2 827 Deduct Loans charged off 230 16 113 543 233 1,135 – 1,135 Less recoveries of loans charged off (74 ) (44 ) (20 ) (58 ) (72 ) (268 ) – (268 ) Net loans charged off 156 (28 ) 93 485 161 867 – 867 Other changes (a) (1 ) – – – – (1 ) (28 ) (29 ) Balance at end of period $ 1,223 $ 736 $ 688 $ 876 $ 744 $ 4,267 $ 39 $ 4,306 2014 Balance at beginning of period $ 1,075 $ 776 $ 875 $ 884 $ 781 $ 4,391 $ 146 $ 4,537 Add Provision for credit losses 210 (64 ) 74 495 227 942 (1 ) 941 Deduct Loans charged off 219 27 171 546 291 1,254 10 1,264 Less recoveries of loans charged off (70 ) (30 ) (15 ) (48 ) (73 ) (236 ) (2 ) (238 ) Net loans charged off 149 (3 ) 156 498 218 1,018 8 1,026 Other changes (a) – – – (3 ) – (3 ) (35 ) (38 ) Balance at end of period $ 1,136 $ 715 $ 793 $ 878 $ 790 $ 4,312 $ 102 $ 4,414 (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 September 30, 2015 Related to Loans individually evaluated for impairment (a) $ 8 $ 1 $ – $ – $ – $ 9 $ – $ 9 TDRs collectively evaluated for impairment 8 11 280 56 36 391 2 393 Other loans collectively evaluated for impairment 1,207 710 408 820 708 3,853 1 3,854 Loans acquired with deteriorated credit quality – 14 – – – 14 36 50 Total allowance for credit losses $ 1,223 $ 736 $ 688 $ 876 $ 744 $ 4,267 $ 39 $ 4,306 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 September 30, 2015 Loans individually evaluated for impairment (a) $ 267 $ 42 $ 13 $ – $ – $ 322 $ – $ 322 TDRs collectively evaluated for impairment 136 250 4,387 214 219 5,206 35 5,241 Other loans collectively evaluated for impairment 85,135 41,873 47,948 18,369 50,832 244,157 2,176 246,333 Loans acquired with deteriorated credit quality 1 313 1 – – 315 2,580 2,895 Total loans $ 85,539 $ 42,478 $ 52,349 $ 18,583 $ 51,051 $ 250,000 $ 4,791 $ 254,791 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 September 30, 2015 Commercial $ 85,119 $ 207 $ 44 $ 169 $ 85,539 Commercial real estate 42,252 62 20 144 42,478 Residential mortgages (a) 51,262 181 171 735 52,349 Credit card 18,132 235 204 12 18,583 Other retail 50,607 202 71 171 51,051 Total loans, excluding covered loans 247,372 887 510 1,231 250,000 Covered loans 4,404 61 315 11 4,791 Total loans $ 251,776 $ 948 $ 825 $ 1,242 $ 254,791 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 September 30, 2015, $337 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 September 30, 2015, the amount of foreclosed residential real estate held by the Company, and included in other real estate owned, was $271 million ($240 million excluding covered assets), compared with $270 million ($233 million excluding covered assets) at December 31, 2014. This excludes $648 million and $641 million at September 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 September 30, 2015 and December 31, 2014, was $2.8 billion and $2.9 billion, respectively, of which $2.0 billion and $2.1 billion, respectively, 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 September 30, 2015 Commercial (b) $ 82,468 $ 1,803 $ 1,268 $ 3,071 $ 85,539 Commercial real estate 41,411 324 743 1,067 42,478 Residential mortgages (c) 51,375 7 967 974 52,349 Credit card 18,367 – 216 216 18,583 Other retail 50,749 5 297 302 51,051 Total loans, excluding covered loans 244,370 2,139 3,491 5,630 250,000 Covered loans 4,696 – 95 95 4,791 Total loans $ 249,066 $ 2,139 $ 3,586 $ 5,725 $ 254,791 Total outstanding commitments $ 523,370 $ 3,820 $ 4,229 $ 8,049 $ 531,419 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 September 30, 2015, $917 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 September 30, 2015, $2.9 billion of GNMA loans 90 days or more past due and $2.0 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 September 30, 2015 Commercial $ 439 $ 1,002 $ 19 $ 100 Commercial real estate 362 921 16 2 Residential mortgages 2,638 3,345 239 – Credit card 214 214 56 – Other retail 324 523 39 4 Total impaired loans, excluding GNMA and covered loans 3,977 6,005 369 106 Loans purchased from GNMA mortgage pools 2,000 2,000 44 – Covered loans 42 46 2 1 Total $ 6,019 $ 8,051 $ 415 $ 107 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 September 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 September 30 Commercial $ 408 $ 3 $ 425 $ 4 Commercial real estate 388 3 541 4 Residential mortgages 2,669 31 2,740 33 Credit card 216 1 264 1 Other retail 329 3 373 5 Total impaired loans, excluding GNMA and covered loans 4,010 41 4,343 47 Loans purchased from GNMA mortgage pools 2,040 24 2,647 29 Covered loans 42 – 335 5 Total $ 6,092 $ 65 $ 7,325 $ 81 Nine Months Ended September 30 Commercial $ 351 $ 9 $ 430 $ 8 Commercial real estate 461 13 598 17 Residential mortgages 2,687 97 2,744 105 Credit card 224 4 281 7 Other retail 342 10 381 13 Total impaired loans, excluding GNMA and covered loans 4,065 133 4,434 150 Loans purchased from GNMA mortgage pools 2,120 74 2,691 95 Covered loans 42 – 389 15 Total $ 6,227 $ 207 $ 7,514 $ 260 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 September 30 Commercial 381 $ 111 $ 102 448 $ 28 $ 26 Commercial real estate 35 24 23 27 14 13 Residential mortgages 381 48 47 525 71 70 Credit card 7,289 35 36 6,708 35 36 Other retail 690 19 19 810 18 18 Total loans, excluding GNMA and covered loans 8,776 237 227 8,518 166 163 Loans purchased from GNMA mortgage pools 1,986 244 245 2,273 278 278 Covered loans 4 1 1 18 3 3 Total loans 10,766 $ 482 $ 473 10,809 $ 447 $ 444 Nine Months Ended September 30 Commercial 1,170 $ 227 $ 223 1,633 $ 181 $ 169 Commercial real estate 89 64 62 54 33 28 Residential mortgages 1,820 234 232 1,732 232 231 Credit card 19,978 100 101 20,040 111 112 Other retail 1,974 42 42 2,246 52 52 Total loans, excluding GNMA and covered loans 25,031 667 660 25,705 609 592 Loans purchased from GNMA mortgage pools 5,960 732 731 7,198 816 803 Covered loans 13 4 4 38 14 13 Total loans 31,004 $ 1,403 $ 1,395 32,941 $ 1,439 $ 1,408 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 third quarter of 2015, at September 30, 2015, 205 residential mortgages, 102 home equity and second mortgage loans and 1,726 loans purchased from GNMA mortgage pools with outstanding balances of $25 million, $9 million and $226 million, respectively, were in a trial period and have estimated post-modification balances of $31 million, $10 million and $230 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 res |