Loans and Allowance for Credit Losses | Note 4 Loans and Allowance for Credit Losses The composition of the loan portfolio, disaggregated by class and underl y September 30, 2019 December 31, 2018 (Dollars in Millions) Amount Percent Amount Percent Commercial Commercial $ 99,067 33.6 % $ 96,849 33.8 % Lease financing 5,587 1.9 5,595 1.9 Total commercial 104,654 35.5 102,444 35.7 Commercial Real Estate Commercial mortgages 28,664 9.7 28,596 10.0 Construction and development 10,604 3.6 10,943 3.8 Total commercial real estate 39,268 13.3 39,539 13.8 Residential Mortgages Residential mortgages 58,465 19.9 53,034 18.5 Home equity loans, first liens 10,913 3.7 12,000 4.2 Total residential mortgages 69,378 23.6 65,034 22.7 Credit Card 23,890 8.1 23,363 8.1 Other Retail Retail leasing 8,463 2.9 8,546 3.0 Home equity and second mortgages 15,453 5.2 16,122 5.6 Revolving credit 2,889 1.0 3,088 1.1 Installment 10,827 3.7 9,676 3.4 Automobile 19,583 6.6 18,719 6.5 Student 233 .1 279 .1 Total other retail 57,448 19.5 56,430 19.7 Total loans $ 294,638 100.0 % $ 286,810 100.0 % The Company had loans of $94.5 billion at September 30, 2019, and $88.7 billion at December 31, 2018, pledged at the Federal Home Loan Bank, and loans of $74.6 billion at September 30, 2019, and $70.1 billion at December 31, 2018, pledged at the Federal Reserve Bank. Originated loans are reported at the principal amount outstanding, net of unearned interest and deferred fees and costs, and any partial charge-offs recorded. Net unearned interest and deferred fees and costs amounted to $785 million at September 30, 2019 and $872 million at December 31, 2018. All purchased loans 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.” The Company offers a broad array of lending products and categorizes its loan portfolio into two segments, which is the level at which it develops and documents a systematic methodology to determine the allowance for credit losses. The Company’s two loan portfolio segments are commercial lending and consumer lending. Previously, the Company categorized loans covered under loss sharing or similar credit protection agreements with the Federal Deposit Insurance Corporation (“FDIC”), along with the related indemnification asset, in a separate covered loans segment. During 2018 the majority of these loans were sold and the loss share coverage expired. Any remaining balances were reclassified to be included in their respective portfolio category. 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. The allowance for credit losses is increased through provisions charged to earnings and reduced by net charge-offs. Management evaluates the appropriateness of the allowance for incurred losses on a quarterly basis. 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. 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 the selected loss experience is appropriate 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, delinquency status, 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 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 and other relevant business practices; results of internal review; 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 off-balance 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 Covered Total 2019 Balance at beginning of period $ 1,464 $ 794 $ 438 $ 1,132 $ 638 $ – $ 4,466 Add Provision for credit losses 101 3 (10 ) 212 61 – 367 Deduct Loans charged-off 91 7 8 248 97 – 451 Less recoveries of loans charged-off (16 ) (1 ) (11 ) (37 ) (34 ) – (99 ) Net loans charged-off 75 6 (3 ) 211 63 – 352 Balance at end of period $ 1,490 $ 791 $ 431 $ 1,133 $ 636 $ – $ 4,481 2018 Balance at beginning of period $ 1,391 $ 812 $ 436 $ 1,082 $ 667 $ 23 $ 4,411 Add Provision for credit losses 88 (12 ) 8 221 41 (3 ) 343 Deduct Loans charged-off 88 1 12 231 96 – 428 Less recoveries of loans charged-off (22 ) (10 ) (8 ) (25 ) (35 ) – (100 ) Net loans charged-off 66 (9 ) 4 206 61 – 328 Balance at end of period $ 1,413 $ 809 $ 440 $ 1,097 $ 647 $ 20 $ 4,426 Nine Months Ended September 30 (Dollars in Millions) Commercial Commercial Residential Credit Other Covered Total 2019 Balance at beginning of period $ 1,454 $ 800 $ 455 $ 1,102 $ 630 $ – $ 4,441 Add Provision for credit losses 243 (2 ) (20 ) 694 194 – 1,109 Deduct Loans charged-off 300 11 27 767 283 – 1,388 Less recoveries of loans charged-off (93 ) (4 ) (23 ) (104 ) (95 ) – (319 ) Net loans charged-off 207 7 4 663 188 – 1,069 Balance at end of period $ 1,490 $ 791 $ 431 $ 1,133 $ 636 $ – $ 4,481 2018 Balance at beginning of period $ 1,372 $ 831 $ 449 $ 1,056 $ 678 $ 31 $ 4,417 Add Provision for credit losses 225 (34 ) 6 668 156 (10 ) 1,011 Deduct Loans charged-off 265 6 37 727 283 – 1,318 Less recoveries of loans charged-off (81 ) (18 ) (22 ) (100 ) (96 ) – (317 ) Net loans charged-off 184 (12 ) 15 627 187 – 1,001 Other changes (a) – – – – – (1 ) (1 ) Balance at end of period $ 1,413 $ 809 $ 440 $ 1,097 $ 647 $ 20 $ 4,426 (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 Allowance Balance at September 30, 2019 Related to Loans individually evaluated for impairment (a) $ 19 $ 3 $ – $ – $ – $ 22 TDRs collectively evaluated for impairment 20 4 107 80 12 223 Other loans collectively evaluated for impairment 1,451 784 309 1,053 624 4,221 Loans acquired with deteriorated credit quality – – 15 – – 15 Total allowance for credit losses $ 1,490 $ 791 $ 431 $ 1,133 $ 636 $ 4,481 Allowance Balance at December 31, 2018 Related to Loans individually evaluated for impairment (a) $ 16 $ 8 $ – $ – $ – $ 24 TDRs collectively evaluated for impairment 15 3 126 69 12 225 Other loans collectively evaluated for impairment 1,423 788 314 1,033 618 4,176 Loans acquired with deteriorated credit quality – 1 15 – – 16 Total allowance for credit losses $ 1,454 $ 800 $ 455 $ 1,102 $ 630 $ 4,441 (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 September 30, 2019 Loans individually evaluated for impairment (a) $ 340 $ 40 $ – $ – $ – $ 380 TDRs collectively evaluated for impairment 178 142 3,168 262 190 3,940 Other loans collectively evaluated for impairment 104,136 39,052 65,950 23,628 57,258 290,024 Loans acquired with deteriorated credit quality – 34 260 – – 294 Total loans $ 104,654 $ 39,268 $ 69,378 $ 23,890 $ 57,448 $ 294,638 December 31, 2018 Loans individually evaluated for impairment (a) $ 262 $ 86 $ – $ – $ – $ 348 TDRs collectively evaluated for impairment 151 129 3,252 245 183 3,960 Other loans collectively evaluated for impairment 102,031 39,297 61,465 23,118 56,247 282,158 Loans acquired with deteriorated credit quality – 27 317 – – 344 Total loans $ 102,444 $ 39,539 $ 65,034 $ 23,363 $ 56,430 $ 286,810 (a) Represents loans greater than $5 million classified as nonperforming or TDRs. 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 1-4 charge-off 1-4 family charged-off. charged-off 1-4 charged-off charged-off charge-off. 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 charged-off) 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, 2019 Commercial $ 103,782 $ 450 $ 103 $ 319 $ 104,654 Commercial real estate 39,126 51 2 89 39,268 Residential mortgages (a) 68,845 167 115 251 69,378 Credit card 23,296 316 278 — 23,890 Other retail 56,785 391 102 170 57,448 Total loans $ 291,834 $ 1,375 $ 600 $ 829 $ 294,638 December 31, 2018 Commercial $ 101,844 $ 322 $ 69 $ 209 $ 102,444 Commercial real estate 39,354 70 — 115 39,539 Residential mortgages (a) 64,443 181 114 296 65,034 Credit card 22,746 324 293 — 23,363 Other retail 55,722 403 108 197 56,430 Total loans $ 284,109 $ 1,300 $ 584 $ 817 $ 286,810 (a) At September 30, 2019, $391 million of loans 30–89 days past due and $1.7 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 United States Department of Veterans Affairs, were classified as current, compared with $430 million and $1.7 billion at December 31, 2018, respectively. At September 30, 2019, the amount of foreclosed residential real estate held by the Company, and included in other real estate owned (“OREO”), was $80 million, compared with $106 million at December 31, 2018. These amounts exclude $ $1.2 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 United States 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 loans not classified on the Company’s rating scale for problem credits, as minimal credit risk has been identified. Special mention loans are those loans that have a potential weakness deserving management’s close attention. Classified loans are those loans 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, 2019 Commercial $ 102,543 $ 1,022 $ 1,089 $ 2,111 $ 104,654 Commercial real estate 38,287 625 356 981 39,268 Residential mortgages (b) 68,960 3 415 418 69,378 Credit card 23,612 – 278 278 23,890 Other retail 57,142 12 294 306 57,448 Total loans $ 290,544 $ 1,662 $ 2,432 $ 4,094 $ 294,638 Total outstanding commitments $ 614,479 $ 2,297 $ 3,076 $ 5,373 $ 619,852 December 31, 2018 Commercial $ 100,014 $ 1,149 $ 1,281 $ 2,430 $ 102,444 Commercial real estate 38,473 584 482 1,066 39,539 Residential mortgages (b) 64,570 1 463 464 65,034 Credit card 23,070 – 293 293 23,363 Other retail 56,101 6 323 329 56,430 Total loans $ 282,228 $ 1,740 $ 2,842 $ 4,582 $ 286,810 Total outstanding commitments $ 600,407 $ 2,801 $ 3,448 $ 6,249 $ 606,656 (a) Classified rating on consumer loans primarily based on delinquency status. (b) At September 30, 2019, $1.7 billion of GNMA loans 90 days or more past due and $1.7 billion of restructured GNMA loans whose repayments are insured by the Federal Housing Administration or guaranteed by the United States Department of Veterans Affairs were classified with a pass rating, compared with $1.7 billion and $1.6 billion at December 31, 2018, 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. 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, 2019 Commercial $ 583 $ 1,183 $ 41 $ 197 Commercial real estate 234 587 8 – Residential mortgages 1,573 1,891 74 – Credit card 262 262 80 – Other retail 322 412 14 2 Total loans, excluding loans purchased from GNMA mortgage pools 2,974 4,335 217 199 Loans purchased from GNMA mortgage pools 1,690 1,690 34 – Total $ 4,664 $ 6,025 $ 251 $ 199 December 31, 2018 Commercial $ 467 $ 1,006 $ 32 $ 106 Commercial real estate 279 511 12 2 Residential mortgages 1,709 1,879 86 – Credit card 245 245 69 – Other retail 335 418 14 5 Total loans, excluding loans purchased from GNMA mortgage pools 3,035 4,059 213 113 Loans purchased from GNMA mortgage pools 1,639 1,639 41 – Total $ 4,674 $ 5,698 $ 254 $ 113 (a) Substantially all loans classified as impaired at September 30, 2019 and December 31, 2018, had an associated allowance for credit losses. Additional information on impaired loans 2019 2018 (Dollars in Millions) Average Interest Average Interest Three Months Ended September 30 Commercial $ 552 $ 4 $ 470 $ 3 Commercial real estate 232 3 279 4 Residential mortgages 1,597 23 1,779 18 Credit card 260 – 236 1 Other retail 319 3 309 4 Covered Loans – – 23 – Total loans, excluding loans purchased from GNMA mortgage pools 2,960 33 3,096 30 Loans purchased from GNMA mortgage pools 1,644 18 1,666 12 Total $ 4,604 $ 51 $ 4,762 $ 42 Nine Months Ended September 30 Commercial $ 516 $ 7 $ 510 $ 5 Commercial real estate 251 8 263 8 Residential mortgages 1,649 70 1,846 57 Credit card 255 – 234 3 Other retail 323 9 304 12 Covered Loans – – 33 1 Total loans, excluding loans purchased from GNMA mortgage pools 2,994 94 3,190 86 Loans purchased from GNMA mortgage pools 1,613 52 1,635 36 Total $ 4,607 $ 146 $ 4,825 $ 122 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: 2019 2018 (Dollars in Millions) Number Pre-Modification Post-Modification Number Pre-Modification Post-Modification Three Months Ended September 30 Commercial 886 $ 116 $ 100 700 $ 42 $ 33 Commercial real estate 32 23 23 38 123 125 Residential mortgages 117 17 15 144 19 17 Credit card 8,429 46 46 8,450 42 43 Other retail 814 20 19 763 17 16 Covered Loans – – – 3 1 1 Total loans, excluding loans purchased from GNMA mortgage pools 10,278 222 203 10,098 244 235 Loans purchased from GNMA mortgage pools 1,524 211 203 1,649 216 211 Total loans 11,802 $ 433 $ 406 11,747 $ 460 $ 446 Nine Months Ended September 30 Commercial 2,622 $ 242 $ 215 2,047 $ 255 $ 234 Commercial real estate 76 95 93 97 154 155 Residential mortgages 318 43 41 397 56 53 Credit card 26,018 140 141 24,457 122 124 Other retail 2,029 44 42 1,857 45 43 Covered Loans – – – 3 1 1 Total loans, excluding loans purchased from GNMA mortgage pools 31,063 564 532 28,858 633 610 Loans purchased from GNMA mortgage pools 4,617 629 606 4,785 631 619 Total loans 35,680 $ 1,193 $ 1,138 33,643 $ 1,264 $ 1,229 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 2019, at September 30, 2019, 68 residential mortgages, 34 home equity and second mortgage loans and 1,046 loans purchased from GNMA mortgage pools with outstanding balances of $11 million, $3 million and $144 million, respectively, were in a trial period and have estimated post-modification balances of $10 million, $3 million and $141 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 For the commercial lending segment, modifications generally result in the Company working with borrowers on a case-by-case Modifications for the consumer lending segment are generally part of programs the Company has initiated. The Company modifies residential mortgage loans under Federal Housing Administration, United States Department of Veterans Affairs, or its own internal programs. Under these programs, the Company offers qualifying homeowners the opportunity to permanently modify their loan and achieve more affordable monthly payments by providing loan concessions. These 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 modifications whereby balances may be amortized up to 60 months, and generally include waiver of fees and reduced interest rates. In addition, the Company considers secured loans to consumer borrowers that have debt discharged through bankruptcy where the borrower has not reaffirmed the debt to be TDRs. Acquired loans restructured after acquisition are not considered TDRs for accounting and disclosure purposes if the loans evidenced credit deterioration as of the acquisition date and are accounted for in pools. The following table provides a summary of TDR loans that defaulted (fully or partially charged-off 2019 2018 (Dollars in Millions) Number Amount Number Amount Three Months Ended September 30 Commercial 263 $ 9 207 $ 51 Commercial real estate 8 7 10 2 Residential mortgages 13 1 34 4 Credit card 2,025 10 1,924 9 Other retail 72 1 93 1 Total loans, excluding loans purchased from GNMA mortgage pools 2,381 28 2,268 67 Loans purchased from GNMA mortgage pools 263 33 380 50 Total loans 2,644 $ 61 2,648 $ 117 Nine Months Ended September 30 Commercial 749 $ 18 623 $ 63 Commercial real estate 23 17 26 8 Residential mortgages 124 14 148 15 Credit card 6,001 29 5,893 26 Other retail 299 9 240 3 Covered loans – – 1 – Total loans, excluding loans purchased from GNMA mortgage pools 7,196 87 6,931 115 Loans purchased from GNMA mortgage pools 697 93 1,129 148 Total loans 7,893 $ 180 8,060 $ 263 In addition to the defaults in the table above, the Company had a total of 185 and 600 residential mortgage loans, home equity and second mortgage loans and loans purchased from GNMA mortgage pools for the three months and nine months ended September 30, 2019, respectively, where borrowers did not successfully complete the trial period arrangement and, therefore, are no longer eligible for a permanent modification under the applicable modification program. These loans had aggregate outstanding balances of $25 million and $81 million for the three months and nine months ended September 30, 2019, respectively. |