Loans and Related Allowance for Credit Losses | Loans and Related Allowance for Credit Losses Loan Portfolio Our loan portfolio consists of two portfolio segments – Commercial and Consumer. Each of these segments comprises multiple loan classes. Classes are characterized by similarities in risk attributes and the manner in which we monitor and assess credit risk. Commercial Consumer • Commercial and industrial • Home equity • Commercial real estate • Residential real estate • Equipment lease financing • Automobile • Credit card • Education • Other consumer See Note 1 Accounting Policies for additional information on our loan related policies. Credit Quality We closely monitor economic conditions and loan performance trends to manage and evaluate our exposure to credit risk within the loan portfolio based on our defined loan classes. In doing so, we use several credit quality indicators, including trends in delinquency rates, nonperforming status, analysis of PD and LGD ratings, updated credit scores, and originated and updated LTV ratios. The measurement of delinquency status is based on the contractual terms of each loan. Loans that are 30 days or more past due in terms of payment are considered delinquent. With the adoption of the CECL standard, accruing loans past due as of September 30, 2020 include PCD loans, while amounts as of December 31, 2019 excluded purchased impaired loans. See Note 1 Accounting Policies for additional information related to the adoption of this standard, including the discontinuation of purchased impaired loan accounting. The following table presents the composition and delinquency status of our loan portfolio at September 30, 2020 and December 31, 2019 . Pursuant to the interagency guidance issued in April 2020 and in connection with the credit reporting rules from the CARES Act, the September 30, 2020 delinquency status of loans modified due to COVID-19 related hardships aligns with the rules set forth for banks to report delinquency status to the credit agencies. These rules require that COVID-19 related loan modifications be reported as follows: • if current at the time of modification, the loan remains current throughout the modification period, • if delinquent at the time of modification and the borrower was not made current as part of the modification, the loan maintains its reported delinquent status during the modification period, or • if delinquent at the time of modification and the borrower was made current as part of the modification or became current during the modification period, the loan is reported as current. As a result, certain loans modified due to COVID-19 related hardships are not being reported as past due as of September 30, 2020 based on the contractual terms of the loan, even where borrowers may not be making payments on their loans during the modification period. Loan modifications due to COVID-19 related hardships that permanently reduce either the contractual interest rate or the principal balance of a loan do not qualify for TDR relief under the CARES Act or the interagency guidance. Table 44 : Analysis of Loan Portfolio Accruing Dollars in millions Current or Less Than 30 Days Past Due 30-59 Days Past Due 60-89 Days Past Due 90 Days Or More Past Due Total Past Due (c) Nonperforming Loans Fair Value Option Nonaccrual Loans (d) Total Loans (e)(f) September 30, 2020 (a) (b) Commercial Commercial and industrial $ 136,381 $ 56 $ 37 $ 36 $ 129 $ 677 $ 137,187 Commercial real estate 28,799 6 6 12 217 29,028 Equipment lease financing 6,447 7 4 11 21 6,479 Total commercial 171,627 69 47 36 152 915 172,694 Consumer Home equity 23,774 48 22 70 639 $ 56 24,539 Residential real estate 21,503 188 80 269 537 (c) 339 507 22,886 Automobile 14,646 116 32 12 160 171 14,977 Credit card 6,153 44 33 60 137 13 6,303 Education 2,905 57 26 63 146 (c) 3,051 Other consumer 4,785 17 11 8 36 8 4,829 Total consumer 73,766 470 204 412 1,086 1,170 563 76,585 Total $ 245,393 $ 539 $ 251 $ 448 $ 1,238 $ 2,085 $ 563 $ 249,279 Percentage of total loans 98.43 % .22 % .10 % .18 % .50 % .84 % .23 % 100.00 % (a) Amounts in table represent loans held for investment and do not include any associated valuation allowance. (b) The accrued interest associated with our loan portfolio at September 30, 2020 totaled $.7 billion and is included in Other assets on the Consolidated Balance Sheet. (c) Past due loan amounts include government insured or guaranteed Residential real estate loans and Education loans totaling $.4 billion and $.1 billion , respectively, at September 30, 2020 . (d) Consumer loans accounted for under the fair value option for which we do not expect to collect substantially all principal and interest are subject to nonaccrual accounting and classification upon meeting any of our nonaccrual policies. Given that these loans are not accounted for at amortized cost, these loans have been excluded from the nonperforming loan population. (e) Net of unearned income, unamortized deferred fees and costs on originated loans, and premiums or discounts on purchased loans totaling $1.4 billion at September 30, 2020 . (f) Collateral dependent loans totaled $1.2 billion at September 30, 2020 . The majority of these loans are within the Home equity and Residential real estate loan classes and are secured by consumer real estate. Accruing Dollars in millions Current or Less Than 30 Days Past Due 30-59 Days Past Due 60-89 Days Past Due 90 Days Or More Past Due Total Past Due (h) Nonperforming Loans Fair Value Option Nonaccrual Loans (i) Purchased Impaired Loans Total Loans (j) December 31, 2019 (g) Commercial Commercial and industrial $ 124,695 $ 102 $ 30 $ 85 $ 217 $ 425 $ 125,337 Commercial real estate 28,061 4 1 5 44 28,110 Equipment lease financing 7,069 49 5 54 32 7,155 Total commercial 159,825 155 36 85 276 501 160,602 Consumer Home equity 23,791 58 24 82 669 $ 543 25,085 Residential real estate 19,640 140 69 315 524 (h) 315 $ 166 1,176 21,821 Automobile 16,376 178 47 18 243 135 16,754 Credit card 7,133 60 37 67 164 11 7,308 Education 3,156 55 34 91 180 (h) 3,336 Other consumer 4,898 15 11 9 35 4 4,937 Total consumer 74,994 506 222 500 1,228 1,134 166 1,719 79,241 Total $ 234,819 $ 661 $ 258 $ 585 $ 1,504 $ 1,635 $ 166 $ 1,719 $ 239,843 Percentage of total loans 97.90 % .28 % .11 % .24 % .63 % .68 % .07 % .72 % 100.00 % (g) Amounts in table represent recorded investment and exclude loans held for sale. Recorded investment does not include any associated valuation allowance. (h) Past due loan amounts exclude purchased impaired loans, even if contractually past due (or if we do not expect to receive payment in full based on the original contractual terms), as we accreted interest income over the expected life of the loans. Past due loan amounts include government insured or guaranteed Residential real estate loans totaling $.4 billion and Education loans totaling $.2 billion at December 31, 2019. (i) Consumer loans accounted for under the fair value option for which we do not expect to collect substantially all principal and interest are subject to nonaccrual accounting and classification upon meeting any of our nonaccrual policies. Given that these loans are not accounted for at amortized cost, these loans have been excluded from the nonperforming loan population. (j) Net of unearned income, unamortized deferred fees and costs on originated loans, and premiums or discounts on purchased loans totaling $1.1 billion at December 31, 2019. At September 30, 2020 , we pledged $ 30.5 billion of commercial loans to the Federal Reserve Bank and $ 68.9 billion of residential real estate and other loans to the Federal Home Loan Bank as collateral for the ability to borrow, if necessary. The comparable amounts at December 31, 2019 were $16.9 billion and $68.0 billion , respectively. Amounts pledged reflect the unpaid principal balances. Nonperforming Assets Nonperforming assets include nonperforming loans and leases, OREO and foreclosed assets. Nonperforming loans are those loans accounted for at amortized cost whose credit quality has deteriorated to the extent that full collection of contractual principal and interest is not probable. Interest income is not recognized on these loans. Loans accounted for under the fair value option are reported as performing loans, however, when nonaccrual criteria is met interest income is not recognized on these loans. Additionally, certain government insured or guaranteed loans for which we expect to collect substantially all principal and interest are not reported as nonperforming loans and continue to accrue interest. With the adoption of the CECL standard, nonperforming loans as of September 30, 2020 include PCD loans. Amounts as of December 31, 2019 excluded purchased impaired loans as we were accreting interest income over the expected life of the loans. See Note 1 Accounting Policies for additional information related to the adoption of this standard and our nonperforming loan and lease policies. The following table presents our nonperforming assets as of September 30, 2020 and December 31, 2019, respectively. Table 45 : Nonperforming Assets Dollars in millions September 30 December 31 Nonperforming loans Commercial $ 915 $ 501 Consumer (a) 1,170 1,134 Total nonperforming loans (b) 2,085 1,635 OREO and foreclosed assets 67 117 Total nonperforming assets $ 2,152 $ 1,752 Nonperforming loans to total loans .84 % .68 % Nonperforming assets to total loans, OREO and foreclosed assets .86 % .73 % Nonperforming assets to total assets .47 % .43 % (a) Excludes most unsecured consumer loans and lines of credit, which are charged off after 120 to 180 days past due and are not placed on nonperforming status. (b) Nonperforming loans for which there is no related ALLL totaled $.6 billion at September 30, 2020 , and is primarily comprised of loans with a valuation that exceeds the amortized cost basis. Nonperforming loans also include certain loans whose terms have been restructured in a manner that grants a concession to a borrower experiencing financial difficulties. In accordance with applicable accounting guidance, these loans are considered TDRs. See Note 1 Accounting Policies and the TDR section of this Note 4 for additional information on TDRs. Total nonperforming loans in Table 45 include TDRs of $.8 billion and $.9 billion at September 30, 2020 and December 31, 2019 , respectively. TDRs that are performing, including consumer credit card TDR loans, totaled $.8 billion at both September 30, 2020 and December 31, 2019 and are excluded from nonperforming loans. Additional Credit Quality Indicators by Loan Class Commercial and Industrial For commercial and industrial loans, we monitor the performance of the borrower in a disciplined and regular manner based upon the level of credit risk inherent in the loan. To evaluate the level of credit risk, we assign an internal risk rating reflecting the borrower’s PD and LGD. This two-dimensional credit risk rating methodology provides granularity in the risk monitoring process. These ratings are reviewed and updated, generally at least once per year. For small balance homogeneous pools of commercial and industrial loans and leases, we apply scoring techniques to assist in determining the PD. The combination of the PD and LGD ratings assigned to commercial and industrial loans, capturing both the combination of expectations of default and loss severity in the event of default, reflects credit quality characteristics as of the reporting date and are used as inputs into our loss forecasting process. Based upon the amount of the lending arrangement and our risk rating assessment, we follow a formal schedule of written periodic reviews. Quarterly, we conduct formal reviews of a market’s or business unit’s loan portfolio, focusing on those loans which we perceive to be of higher risk, based upon PDs and LGDs, or loans for which credit quality is weakening. If circumstances warrant, it is our practice to review any customer obligation and its level of credit risk more frequently. We attempt to proactively manage our loans by using various procedures that are customized to the risk of a given loan, including ongoing outreach, contact, and assessment of obligor financial conditions, collateral inspection and appraisal. Commercial Real Estate We manage credit risk associated with our commercial real estate projects and commercial mortgages similar to commercial and industrial loans by evaluating PD and LGD. Risks associated with commercial real estate projects and commercial mortgage activities tend to be correlated to the loan structure and collateral location, project progress and business environment. As a result, these attributes are also monitored and utilized in assessing credit risk. As with the commercial and industrial loan class, a formal schedule of periodic reviews is also performed to assess market/geographic risk and business unit/industry risk. Often as a result of these overviews, more in-depth reviews and increased scrutiny are placed on areas of higher risk, such as adverse changes in risk ratings, deteriorating operating trends, and/or areas that concern management. These reviews are designed to assess risk and facilitate actions to mitigate such risks. Equipment Lease Financing We manage credit risk associated with our equipment lease financing loan class similar to commercial and industrial loans by analyzing PD and LGD. Based upon the dollar amount of the lease and the level of credit risk, we follow a formal schedule of periodic reviews. Generally, this occurs quarterly, although we have established practices to review such credit risk more frequently if circumstances warrant. Our review process entails analysis of the following factors: equipment value/residual value, exposure levels, jurisdiction risk, industry risk, guarantor requirements, and regulatory compliance as applicable. Table 46 : Commercial Credit Quality Indicators (a) Term Loans by Origination Year September 30, 2020 - In millions 2020 2019 2018 2017 2016 Prior Revolving Loans Revolving Loans Converted to Term Total Loans Commercial and industrial Pass Rated $ 30,385 $ 14,778 $ 9,241 $ 6,474 $ 4,531 $ 7,916 $ 56,000 $ 55 $ 129,380 Criticized 331 721 725 382 217 531 4,881 19 7,807 Total commercial and industrial 30,716 15,499 9,966 6,856 4,748 8,447 60,881 74 137,187 Commercial real estate Pass Rated 3,226 6,552 3,625 3,384 2,622 7,574 164 27,147 Criticized 194 139 53 305 340 753 97 1,881 Total commercial real estate 3,420 6,691 3,678 3,689 2,962 8,327 261 29,028 Equipment lease financing Pass Rated 1,048 1,258 1,043 826 494 1,454 6,123 Criticized 61 95 95 46 26 33 356 Total equipment lease financing 1,109 1,353 1,138 872 520 1,487 6,479 Total commercial $ 35,245 $ 23,543 $ 14,782 $ 11,417 $ 8,230 $ 18,261 $ 61,142 $ 74 $ 172,694 December 31, 2019 - In millions Pass Rated Criticized Total Loans Commercial and industrial $ 119,761 $ 5,576 $ 125,337 Commercial real estate 27,424 686 28,110 Equipment lease financing 6,891 264 7,155 Total commercial $ 154,076 $ 6,526 $ 160,602 (a) Loans in our commercial portfolio are classified as Pass Rated or Criticized based on the regulatory definitions, which are driven by the PD and LGD ratings that we assign. The Criticized classification includes loans that were rated special mention, substandard or doubtful as of September 30, 2020 and December 31, 2019. Home Equity and Residential Real Estate We use several credit quality indicators, including delinquency information, nonperforming loan information, updated credit scores, originated and updated LTV ratios, to monitor and manage credit risk within the home equity and residential real estate loan classes. A summary of credit quality indicators follows: Delinquency/Delinquency Rates : We monitor trending of delinquency/delinquency rates for home equity and residential real estate loans. See Table 44 for additional information. Nonperforming Loans : We monitor trending of nonperforming loans for home equity and residential real estate loans. See Table 44 for additional information. Credit Scores: We use a national third-party provider to update FICO credit scores for home equity and residential real estate loans at least quarterly. The updated scores are incorporated into a series of credit management reports, which are utilized to monitor the risk in the loan classes. LTV (inclusive of combined loan-to-value (CLTV) for first and subordinate lien positions): At least annually, we update the property values of real estate collateral and calculate an updated LTV ratio. For open-end credit lines secured by real estate in regions experiencing significant declines in property values, more frequent valuations may occur. We examine LTV migration and stratify LTV into categories to monitor the risk in the loan classes. We use a combination of original LTV and updated LTV for internal risk management and reporting purposes ( e.g. , line management, loss mitigation strategies). In addition to the fact that estimated property values by their nature are estimates, given certain data limitations, it is important to note that updated LTVs may be based upon management’s assumptions ( i.e. , if an updated LTV is not provided by the third-party service provider, HPI changes will be incorporated in arriving at management’s estimate of updated LTV). Updated LTV is estimated using modeled property values. The related estimates and inputs are based upon an approach that uses a combination of third-party automated valuation models, broker price opinions, HPI indices, property location, internal and external balance information, origination data and management assumptions. We generally utilize origination lien balances provided by a third-party, where applicable, which do not include an amortization assumption when calculating updated LTV. Accordingly, the results of the calculations do not represent actual appraised loan level collateral or updated LTV based upon lien balances held by others, and as such, are necessarily imprecise and subject to change as we refine our methodology. The following table presents credit quality indicators for the home equity and residential real estate loan classes. Table 47 : Home Equity and Residential Real Estate Credit Quality Indicators Term Loans by Origination Year September 30, 2020 - In millions 2020 2019 2018 2017 2016 Prior Revolving Loans Revolving Loans Converted to Term Total Loans Home equity Current estimated LTV ratios . Greater than or equal to 100% $ 5 $ 41 $ 18 $ 17 $ 10 $ 100 $ 605 $ 309 $ 1,105 Greater than or equal to 90% to less than 100% 29 95 21 15 8 69 687 226 1,150 Less than 90% 2,609 2,121 621 889 750 4,225 7,941 3,128 22,284 Total home equity $ 2,643 $ 2,257 $ 660 $ 921 $ 768 $ 4,394 $ 9,233 $ 3,663 $ 24,539 Updated FICO scores Greater than 660 $ 2,580 $ 2,156 $ 605 $ 867 $ 725 $ 3,955 $ 8,818 $ 2,846 $ 22,552 Less than or equal to 660 62 101 54 53 42 429 402 732 1,875 No FICO score available 1 1 1 1 10 13 85 112 Total home equity $ 2,643 $ 2,257 $ 660 $ 921 $ 768 $ 4,394 $ 9,233 $ 3,663 $ 24,539 Residential real estate Current estimated LTV ratios Greater than or equal to 100% $ 34 $ 33 $ 49 $ 49 $ 189 $ 354 Greater than or equal to 90% to less than 100% $ 15 69 32 54 37 114 321 Less than 90% 6,174 4,757 1,329 2,153 2,254 4,693 21,360 Government insured or guaranteed loans 5 23 23 34 49 717 851 Total residential real estate $ 6,194 $ 4,883 $ 1,417 $ 2,290 $ 2,389 $ 5,713 $ 22,886 Updated FICO scores Greater than 660 $ 6,151 $ 4,813 $ 1,362 $ 2,215 $ 2,272 $ 4,295 $ 21,108 Less than or equal to 660 36 45 30 37 62 567 777 No FICO score available 2 2 2 4 6 134 150 Government insured or guaranteed loans 5 23 23 34 49 717 851 Total residential real estate $ 6,194 $ 4,883 $ 1,417 $ 2,290 $ 2,389 $ 5,713 $ 22,886 Home equity Residential real estate December 31, 2019 - In millions Current estimated LTV ratios Greater than or equal to 100% $ 1,243 $ 333 Greater than or equal to 90% to less than 100% 1,047 340 Less than 90% 22,068 19,305 No LTV ratio available 184 83 Government insured or guaranteed loans 584 Purchased impaired loans 543 1,176 Total loans $ 25,085 $ 21,821 Updated FICO Scores Greater than 660 $ 22,245 $ 19,341 Less than or equal to 660 2,019 569 No FICO score available 278 151 Government insured or guaranteed loans 584 Purchased impaired loans 543 1,176 Total loans $ 25,085 $ 21,821 Automobile, Credit Card, Education and Other Consumer We monitor a variety of credit quality information in the management of these consumer loan classes. For all loan types, we generally use a combination of internal loan parameters as well as an updated FICO score. We use FICO scores as a primary credit quality indicator for automobile and credit card loans, as well as non-government guaranteed or non-insured education loans and other secured and unsecured lines and loans. Internal credit metrics, such as delinquency status, are heavily relied upon as credit quality indicators for government guaranteed or insured education loans and consumer loans to high net worth individuals, as internal credit metrics are more relevant than FICO scores for these types of loans. Along with the monitoring of delinquency trends and losses for each class, FICO credit score updates are obtained at least quarterly along with a variety of credit bureau attributes. Loans with high FICO scores tend to have a lower likelihood of loss. Conversely, loans with low FICO scores tend to have a higher likelihood of loss. The following table presents credit quality indicators for the automobile, credit card, education and other consumer loan classes. Table 48 : Credit Quality Indicators for Automobile, Credit Card, Education and Other Consumer Loan Classes Term Loans by Origination Year September 30, 2020 - In millions 2020 2019 2018 2017 2016 Prior Revolving Loans Revolving Loans Converted to Term Total Loans Automobile FICO score greater than 719 $ 2,184 $ 3,573 $ 1,663 $ 916 $ 496 $ 141 $ 8,973 650 to 719 630 1,642 929 403 162 53 3,819 620 to 649 90 365 213 83 31 12 794 Less than 620 75 532 474 202 78 30 1,391 Total automobile $ 2,979 $ 6,112 $ 3,279 $ 1,604 $ 767 $ 236 $ 14,977 Credit card FICO score greater than 719 $ 3,309 $ 13 $ 3,322 650 to 719 2,033 31 2,064 620 to 649 348 13 361 Less than 620 419 40 459 No FICO score available or required (a) 94 3 97 Total credit card $ 6,203 $ 100 $ 6,303 Education FICO score greater than 719 $ 17 $ 88 $ 117 $ 89 $ 73 $ 651 $ 1,035 650 to 719 6 10 14 9 7 102 148 620 to 649 1 2 1 1 15 20 Less than 620 1 1 1 16 19 No FICO score available or required (a) 11 10 7 5 1 1 35 Total loans using FICO credit metric 34 109 141 105 83 785 1,257 Other internal credit metrics 30 58 1,706 1,794 Total education $ 64 $ 167 $ 141 $ 105 $ 83 $ 2,491 $ 3,051 Other consumer FICO score greater than 719 $ 338 $ 487 $ 164 $ 50 $ 14 $ 69 $ 209 $ 1 $ 1,332 650 to 719 129 273 112 25 6 19 138 1 703 620 to 649 12 42 18 4 1 4 22 103 Less than 620 9 38 25 7 2 7 32 1 121 Total loans using FICO credit metric 488 840 319 86 23 99 401 3 2,259 Other internal credit metrics 63 41 40 28 61 77 2,246 14 2,570 Total other consumer $ 551 $ 881 $ 359 $ 114 $ 84 $ 176 $ 2,647 $ 17 $ 4,829 December 31, 2019 - In millions Automobile Credit Card Education Other Consumer FICO score greater than 719 $ 9,232 $ 3,867 $ 1,139 $ 1,421 650 to 719 4,577 2,326 197 843 620 to 649 1,001 419 25 132 Less than 620 1,603 544 27 143 No FICO score available or required (a) 341 152 15 27 Total loans using FICO credit metric 16,754 7,308 1,403 2,566 Consumer loans using other internal credit metrics 1,933 2,371 Total loans $ 16,754 $ 7,308 $ 3,336 $ 4,937 Weighted-average updated FICO score (b) 726 724 773 727 (a) Loans with no FICO score available or required generally refers to new accounts issued to borrowers with limited credit history, accounts for which we cannot obtain an updated FICO score (e.g., recent profile changes), cards issued with a business name and/or cards secured by collateral. Management proactively assesses the risk and size of this loan category and, when necessary, takes actions to mitigate the credit risk. (b) Weighted-average updated FICO score excludes accounts with no FICO score available or required. Troubled Debt Restructurings (TDRs) A TDR is a loan whose terms have been restructured in a manner that grants a concession to a borrower experiencing financial difficulty. Loans that have been restructured for COVID-19 related hardships and meet certain criteria under the CARES Act are not categorized as TDRs. See Note 1 Accounting Policies for additional information related to TDRs. Table 49 quantifies the number of loans that were classified as TDRs as well as the change in the loans’ balance as a result of becoming a TDR during the three and nine months ended September 30, 2020 and September 30, 2019 . Additionally, the table provides information about the types of TDR concessions. See Note 3 Asset Quality in our 2019 Form 10-K for additional details on these TDR concessions. Table 49 : Financial Impact and TDRs by Concession Type Pre-TDR Amortized Cost Basis (b) Post-TDR Amortized Cost Basis (c) During the three months ended September 30, 2020 (a) Number Principal Forgiveness Rate Reduction Other Total Commercial 16 $ 95 $ 10 $ 69 $ 79 Consumer 2,769 46 26 14 40 Total TDRs 2,785 $ 141 $ 36 $ 83 $ 119 During the nine months ended September 30, 2020 (a) Commercial 58 $ 304 $ 39 $ 10 $ 231 $ 280 Consumer 9,925 139 67 59 126 Total TDRs 9,983 $ 443 $ 39 $ 77 $ 290 $ 406 (a) Impact of partial charge-offs at TDR date are included in this table. (b) Represents the amortized cost basis of the loans as of the quarter end prior to TDR designation. (c) Represents the amortized cost basis of the TDRs as of the end of the quarter in which the TDR occurs. Pre-TDR Recorded Investment (e) Post-TDR Recorded Investment (f) During the three months ended September 30, 2019 (d) Number Principal Forgiveness Rate Reduction Other Total Commercial 21 $ 97 $ 72 $ 72 Consumer 3,656 45 $ 24 19 43 Total TDRs 3,677 $ 142 $ 24 $ 91 $ 115 During the nine months ended September 30, 2019 (d) Commercial 58 $ 233 $ 1 $ 208 $ 209 Consumer 11,009 131 72 51 123 Total TDRs 11,067 $ 364 $ 73 $ 259 $ 332 (d) Impact of partial charge-offs at TDR date are included in this table. (e) Represents the recorded investment of the loans as of the quarter end prior to TDR designation, and excludes immaterial amounts of accrued interest receivable. (f) Represents the recorded investment of the TDRs as of the end of the quarter in which the TDR occurs, and excludes immaterial amounts of accrued interest receivable. After a loan is determined to be a TDR, we continue to track its performance under its most recent restructured terms. We consider a TDR to have subsequently defaulted when it becomes 60 days past due after the most recent date the loan was restructured. The following table provides a summary of TDRs that subsequently defaulted during the periods presented and were classified as TDRs during the applicable 12-month period preceding September 30, 2020 and September 30, 2019 . Table 50 : Subsequently Defaulted TDRs In millions 2020 2019 Three months ended September 30 $ 26 $ 42 Nine months ended September 30 $ 46 $ 68 Allowance for Credit Losses We maintain the ACL related to loans at levels that we believe to be appropriate to absorb expected credit losses in the portfolios as of the balance sheet date. See Note 1 Accounting Policies for a discussion of the methodologies used to determine this allowance. A rollforward of the ACL related to loans follows. Table 51 : Rollforward of Allowance for Credit Losses (a) Three months ended September 30, 2020 Nine months ended September 30, 2020 In millions Commercial Consumer Total Commercial Consumer Total Allowance for loan and lease losses Beginning balance $ 3,380 $ 2,548 $ 5,928 $ 1,812 $ 930 $ 2,742 Adoption of ASU 2016-13 (b) (304 ) 767 463 Beginning balance, adjusted 3,380 2,548 5,928 1,508 1,697 3,205 Charge-offs (64 ) (183 ) (247 ) (269 ) (596 ) (865 ) Recoveries 26 66 92 65 197 262 Net (charge-offs) (38 ) (117 ) (155 ) (204 ) (399 ) (603 ) Provision for (recapture of) credit losses 185 (208 ) (23 ) 2,224 925 3,149 Other 1 1 Ending balance $ 3,528 $ 2,223 $ 5,751 $ 3,528 $ 2,223 $ 5,751 Allowance for unfunded lending related commitments (c) Beginning balance $ 548 $ 114 $ 662 $ 316 $ 2 $ 318 Adoption of ASU 2016-13 (b) 53 126 179 Beginning balance, adjusted 548 114 662 369 128 497 Provision for (recapture of) credit losses 34 (7 ) 27 213 (21 ) 192 Ending balance $ 582 $ 107 $ 689 $ 582 $ 107 $ 689 Allowance for credit losses at September 30 $ 4,110 $ 2,330 $ 6,440 $ 4,110 $ 2,330 $ 6,440 (a) Excludes allowances for investment securities and other financial assets, which together totaled $98 million at September 30, 2020 . (b) Represents the impact of adopting ASU 2016-13, Financial Instruments - Credit Losses on January 1, 2020 and our transition from an incurred loss methodology for our reserves to an expected credit loss methodology. (c) See Note 9 Commitments The following presents an analysis of changes impacting the ACL related to loans for the nine months ended September 30, 2020 . Table 52 : Analysis of Changes in the Allowance for Credit Losses (a) In millions (a) Excludes allowances for investment securities and other financial assets, which together totaled $98 million at September 30, 2020 . (b) Portfolio changes primarily represents the impact of increases/decreases in loan balances, age and mix due to new originations/purchases, as well as credit quality and net charge-off activity. (c) Economic and qualitative factors primarily represent our evaluation and determination of an economic forecast applied to our loan portfolio, as well as updates to qualitative factor adjustments. The $2.7 billion increase in the ACL since January 1, 2020 was driven by the following factors in the commercial and consumer portfolios: • Commercial reserves increased $2.2 billion attributable to the significantly adverse economic impact of the pandemic and its resulting effects on credit quality and loan growth. • Consumer reserves increased $.5 billion primarily reflecting the significantly adverse economic impact of the pandemic. Allowance for Loan and Lease Losses A rollforward of the ALLL and associated loan data follows: Table 53 : Rollforward of Allowance for Loan and Lease Losses and Associated Loan Data At or for the nine months ended September 30, 2019 Commercial Consumer Total Allowance for loan and lease losses January 1, 2019 $ 1,663 $ 966 $ 2,629 Charge-offs (138 ) (545 ) (683 ) Recoveries 59 191 250 Net (charge-offs) (79 ) (354 ) (433 ) Provision for credit losses 247 305 552 Net decrease in allowance for unfunded loan commitments and letters of credit (20 ) 1 (19 ) Other 9 9 September 30, 2019 $ 1,811 $ 927 $ 2,738 TDRs individually evaluated for impairment $ 34 $ 95 $ 129 Other loans individually evaluated for impairment 47 47 Loans collectively evaluated for impairment 1,730 554 2,284 Purchased impaired loans 278 278 September 30, 2019 $ 1,811 $ 927 $ 2,738 Loan portfolio TDRs individually evaluated for impairment $ 420 $ 1,343 $ 1,763 Other loans individually evaluated for impairment 265 265 Loans collectively evaluated for impairment 159,503 73,298 232,801 Fair value option loans (a) 754 754 Purchased impaired loans 1,794 1,794 September 30, 2019 $ 160,188 $ 77,189 $ 237,377 |