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, 2016 December 31, 2015 (Dollars in Millions) Amount Percent Amount Percent Commercial Commercial $ 87,851 32.4 % $ 83,116 31.9 % Lease financing 5,350 2.0 5,286 2.0 Total commercial 93,201 34.4 88,402 33.9 Commercial Real Estate Commercial mortgages 31,916 11.8 31,773 12.2 Construction and development 11,552 4.2 10,364 3.9 Total commercial real estate 43,468 16.0 42,137 16.1 Residential Mortgages Residential mortgages 42,846 15.8 40,425 15.5 Home equity loans, first liens 13,383 4.9 13,071 5.0 Total residential mortgages 56,229 20.7 53,496 20.5 Credit Card 20,706 7.6 21,012 8.1 Other Retail Retail leasing 6,076 2.2 5,232 2.0 Home equity and second mortgages 16,467 6.1 16,384 6.3 Revolving credit 3,247 1.2 3,354 1.3 Installment 7,983 2.9 7,030 2.7 Automobile 17,559 6.5 16,587 6.3 Student 2,332 .9 2,619 1.0 Total other retail 53,664 19.8 51,206 19.6 Total loans, excluding covered loans 267,268 98.5 256,253 98.2 Covered Loans 4,021 1.5 4,596 1.8 Total loans $ 271,289 100.0 % $ 260,849 100.0 % The Company had loans of $83.9 billion at September 30, 2016, and $78.1 billion at December 31, 2015, pledged at the Federal Home Loan Bank, and loans of $65.2 billion at September 30, 2016, and $63.4 billion at December 31, 2015, 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 $626 million at September 30, 2016, and $550 million at December 31, 2015. 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) 2016 2015 2016 2015 Balance at beginning of period $ 891 $ 1,076 $ 957 $ 1,309 Accretion (102 ) (91 ) (297 ) (289 ) Disposals (23 ) (32 ) (77 ) (102 ) Reclassifications from nonaccretable difference (a) 31 120 214 157 Other – 1 – (1 ) Balance at end of period $ 797 $ 1,074 $ 797 $ 1,074 (a) Primarily relates to changes in expected credit performance. Allowance for Credit Losses The allowance for credit losses is established 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 15-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, less selling costs, 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 each loan segment 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 2016 Balance at beginning of period $ 1,473 $ 748 $ 544 $ 884 $ 643 $ 4,292 $ 37 $ 4,329 Add Provision for credit losses 90 34 (12 ) 178 37 327 (2 ) 325 Deduct Loans charged off 104 9 19 182 84 398 – 398 Less recoveries of loans charged off (17 ) (8 ) (7 ) (21 ) (30 ) (83 ) – (83 ) Net loans charged off 87 1 12 161 54 315 – 315 Other changes (a) – – – – – – (1 ) (1 ) Balance at end of period $ 1,476 $ 781 $ 520 $ 901 $ 626 $ 4,304 $ 34 $ 4,338 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 (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 2016 Balance at beginning of period $ 1,287 $ 724 $ 631 $ 883 $ 743 $ 4,268 $ 38 $ 4,306 Add Provision for credit losses 438 53 (63 ) 514 42 984 (2 ) 982 Deduct Loans charged off 322 19 67 559 243 1,210 – 1,210 Less recoveries of loans charged off (73 ) (23 ) (19 ) (64 ) (84 ) (263 ) – (263 ) Net loans charged off 249 (4 ) 48 495 159 947 – 947 Other changes (a) – – – (1 ) – (1 ) (2 ) (3 ) Balance at end of period $ 1,476 $ 781 $ 520 $ 901 $ 626 $ 4,304 $ 34 $ 4,338 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 (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, 2016 Related to Loans individually evaluated for impairment (a) $ 56 $ 2 $ – $ – $ – $ 58 $ – $ 58 TDRs collectively evaluated for impairment 10 4 195 62 28 299 1 300 Other loans collectively evaluated for impairment 1,410 765 325 839 598 3,937 – 3,937 Loans acquired with deteriorated credit quality – 10 – – – 10 33 43 Total allowance for credit losses $ 1,476 $ 781 $ 520 $ 901 $ 626 $ 4,304 $ 34 $ 4,338 Allowance Balance at December 31, 2015 Related to Loans individually evaluated for impairment (a) $ 11 $ 2 $ – $ – $ – $ 13 $ – $ 13 TDRs collectively evaluated for impairment 10 7 236 57 33 343 2 345 Other loans collectively evaluated for impairment 1,266 703 395 826 710 3,900 – 3,900 Loans acquired with deteriorated credit quality – 12 – – – 12 36 48 Total allowance for credit losses $ 1,287 $ 724 $ 631 $ 883 $ 743 $ 4,268 $ 38 $ 4,306 (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, 2016 Loans individually evaluated for impairment (a) $ 600 $ 37 $ – $ – $ – $ 637 $ – $ 637 TDRs collectively evaluated for impairment 145 165 3,519 217 178 4,224 37 4,261 Other loans collectively evaluated for impairment 92,449 43,016 52,710 20,489 53,486 262,150 1,662 263,812 Loans acquired with deteriorated credit quality 7 250 – – – 257 2,322 2,579 Total loans $ 93,201 $ 43,468 $ 56,229 $ 20,706 $ 53,664 $ 267,268 $ 4,021 $ 271,289 December 31, 2015 Loans individually evaluated for impairment (a) $ 336 $ 41 $ 13 $ – $ – $ 390 $ – $ 390 TDRs collectively evaluated for impairment 138 235 4,241 210 211 5,035 35 5,070 Other loans collectively evaluated for impairment 87,927 41,566 49,241 20,802 50,995 250,531 2,059 252,590 Loans acquired with deteriorated credit quality 1 295 1 – – 297 2,502 2,799 Total loans $ 88,402 $ 42,137 $ 53,496 $ 21,012 $ 51,206 $ 256,253 $ 4,596 $ 260,849 (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 credit 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, reducing interest income in the current period. 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 placed on nonaccrual. 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 they are 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, 2016 Commercial $ 92,414 $ 221 $ 49 $ 517 $ 93,201 Commercial real estate 43,320 36 7 105 43,468 Residential mortgages (a) 55,310 146 159 614 56,229 Credit card 20,209 264 229 4 20,706 Other retail 53,183 254 74 153 53,664 Total loans, excluding covered loans 264,436 921 518 1,393 267,268 Covered loans 3,729 55 230 7 4,021 Total loans $ 268,165 $ 976 $ 748 $ 1,400 $ 271,289 December 31, 2015 Commercial $ 87,863 $ 317 $ 48 $ 174 $ 88,402 Commercial real estate 41,907 89 14 127 42,137 Residential mortgages (a) 52,438 170 176 712 53,496 Credit card 20,532 243 228 9 21,012 Other retail 50,745 224 75 162 51,206 Total loans, excluding covered loans 253,485 1,043 541 1,184 256,253 Covered loans 4,236 62 290 8 4,596 Total loans $ 257,721 $ 1,105 $ 831 $ 1,192 $ 260,849 (a) At September 30, 2016, $307 million of loans 30–89 days past due and $2.4 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 $320 million and $2.9 billion at December 31, 2015, respectively. At September 30, 2016, the amount of foreclosed residential real estate held by the Company, and included in other real estate owned (“OREO”), was $229 million ($201 million excluding covered assets), compared with $282 million ($250 million excluding covered assets) at December 31, 2015. This excludes $397 million and $535 million at September 30, 2016 and December 31, 2015, 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, 2016 and December 31, 2015, was $2.2 billion and $2.6 billion, respectively, of which $1.6 billion and $1.9 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, 2016 Commercial (b) $ 89,289 $ 1,702 $ 2,210 $ 3,912 $ 93,201 Commercial real estate 42,204 512 752 1,264 43,468 Residential mortgages (c) 55,394 6 829 835 56,229 Credit card 20,474 – 232 232 20,706 Other retail 53,387 5 272 277 53,664 Total loans, excluding covered loans 260,748 2,225 4,295 6,520 267,268 Covered loans 3,946 – 75 75 4,021 Total loans $ 264,694 $ 2,225 $ 4,370 $ 6,595 $ 271,289 Total outstanding commitments $ 557,554 $ 4,805 $ 5,927 $ 10,732 $ 568,286 December 31, 2015 Commercial (b) $ 85,206 $ 1,629 $ 1,567 $ 3,196 $ 88,402 Commercial real estate 41,079 365 693 1,058 42,137 Residential mortgages (c) 52,548 2 946 948 53,496 Credit card 20,775 – 237 237 21,012 Other retail 50,899 6 301 307 51,206 Total loans, excluding covered loans 250,507 2,002 3,744 5,746 256,253 Covered loans 4,507 – 89 89 4,596 Total loans $ 255,014 $ 2,002 $ 3,833 $ 5,835 $ 260,849 Total outstanding commitments $ 539,614 $ 3,945 $ 4,845 $ 8,790 $ 548,404 (a) Classified rating on consumer loans primarily based on delinquency status. (b) At September 30, 2016, $1.4 billion of energy loans ($3.2 billion of total outstanding commitments) had a special mention or classified rating, compared with $1.1 billion of energy loans ($1.9 billion of total outstanding commitments) at December 31, 2015. (c) At September 30, 2016, $2.4 billion of GNMA loans 90 days or more past due and $1.3 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 $2.9 billion and $1.9 billion at December 31, 2015, 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, 2016 Commercial $ 825 $ 1,354 $ 68 $ 378 Commercial real estate 379 790 8 1 Residential mortgages 2,363 2,952 165 – Credit card 217 217 62 – Other retail 281 457 30 3 Total loans, excluding GNMA and covered loans 4,065 5,770 333 382 Loans purchased from GNMA mortgage pools 1,344 1,344 31 – Covered loans 38 43 1 1 Total $ 5,447 $ 7,157 $ 365 $ 383 December 31, 2015 Commercial $ 520 $ 1,110 $ 25 $ 154 Commercial real estate 336 847 11 1 Residential mortgages 2,575 3,248 199 – Credit card 210 210 57 – Other retail 309 503 35 4 Total loans, excluding GNMA and covered loans 3,950 5,918 327 159 Loans purchased from GNMA mortgage pools 1,913 1,913 40 – Covered loans 39 48 2 1 Total $ 5,902 $ 7,879 $ 369 $ 160 (a) Substantially all loans classified as impaired at September 30, 2016 and December 31, 2015, had an associated allowance for credit losses. Additional information on impaired loans follows: 2016 2015 (Dollars in Millions) Average Interest Average Interest Three Months Ended September 30 Commercial $ 845 $ 2 $ 408 $ 3 Commercial real estate 334 6 388 3 Residential mortgages 2,381 30 2,669 31 Credit card 214 1 216 1 Other retail 287 3 329 3 Total loans, excluding GNMA and covered loans 4,061 42 4,010 41 Loans purchased from GNMA mortgage pools 1,458 23 2,040 24 Covered loans 38 – 42 – Total $ 5,557 $ 65 $ 6,092 $ 65 Nine Months Ended September 30 Commercial $ 786 $ 6 $ 351 $ 9 Commercial real estate 321 12 461 13 Residential mortgages 2,457 93 2,687 97 Credit card 212 3 224 4 Other retail 296 9 342 10 Total loans, excluding GNMA and covered loans 4,072 123 4,065 133 Loans purchased from GNMA mortgage pools 1,674 71 2,120 74 Covered loans 38 1 42 – Total $ 5,784 $ 195 $ 6,227 $ 207 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: 2016 2015 (Dollars in Millions) Number Pre-Modification Post-Modification Number Pre-Modification Post-Modification Three Months Ended September 30 Commercial 638 $ 200 $ 169 381 $ 111 $ 102 Commercial real estate 26 225 223 35 24 23 Residential mortgages 700 81 87 381 48 47 Credit card 8,051 38 40 7,289 35 36 Other retail 593 9 9 690 19 19 Total loans, excluding GNMA and covered loans 10,008 553 528 8,776 237 227 Loans purchased from GNMA mortgage pools 2,609 317 308 1,986 244 245 Covered loans 15 3 3 4 1 1 Total loans 12,632 $ 873 $ 839 10,766 $ 482 $ 473 Nine Months Ended September 30 Commercial 1,734 $ 692 $ 567 1,170 $ 227 $ 223 Commercial real estate 70 242 240 89 64 62 Residential mortgages 1,192 129 136 1,820 234 232 Credit card 22,693 109 111 19,978 100 101 Other retail 1,669 27 28 1,974 42 42 Total loans, excluding GNMA and covered loans 27,358 1,199 1,082 25,031 667 660 Loans purchased from GNMA mortgage pools 6,978 770 761 5,960 732 731 Covered loans 35 6 6 13 4 4 Total loans 34,371 $ 1,975 $ 1,849 31,004 $ 1,403 $ 1,395 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 2016, at September 30, 2016, 526 residential mortgages, 7 home equity and second mortgage loans and 510 loans purchased from GNMA mortgage pools with outstanding balances of $50 million, less than $1 million and $68 million, respectively, were in a trial period and have estimated post-modification balances of $64 million, less than $1 million and $67 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 peri |