Loans and Related Allowance for Credit Losses | L OANS A ND R ELATED A LLOWANCE F OR C REDIT L OSSES 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 included in Item 8 of our 2020 Form 10-K 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. Loan delinquencies include government insured or guaranteed loans, loans accounted for under the fair value option and PCD loans. The following table presents the composition and delinquency status of our loan portfolio at March 31, 2021 and December 31, 2020. Pursuant to the interagency guidance issued in April 2020 and in connection with the credit reporting rules from the CARES Act, the 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 March 31, 2021 and December 31, 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 40: Analysis of Loan Portfolio (a) (b) Accruing Dollars in millions Current or Less 30-59 60-89 90 Days Total Nonperforming Fair Value Total Loans March 31, 2021 Commercial Commercial and industrial $ 129,130 $ 80 $ 13 $ 63 $ 156 $ 512 $ 129,798 Commercial real estate 28,085 12 1 13 221 28,319 Equipment lease financing 6,351 21 1 22 16 6,389 Total commercial 163,566 113 15 63 191 749 164,506 Consumer Home equity 22,706 43 20 63 656 $ 68 23,493 Residential real estate 20,862 162 73 275 510 (c) 541 505 22,418 Automobile 13,305 76 19 6 101 178 13,584 Credit card 5,561 31 24 52 107 7 5,675 Education 2,692 49 25 76 150 (c) 2,842 Other consumer 4,464 11 6 7 24 7 4,495 Total consumer 69,590 372 167 416 955 1,389 573 72,507 Total $ 233,156 $ 485 $ 182 $ 479 $ 1,146 $ 2,138 $ 573 $ 237,013 Percentage of total loans 98.38 % 0.20 % 0.08 % 0.20 % 0.48 % 0.90 % 0.24 % 100.00 % December 31, 2020 Commercial Commercial and industrial $ 131,245 $ 106 $ 26 $ 30 $ 162 $ 666 $ 132,073 Commercial real estate 28,485 6 1 7 224 28,716 Equipment lease financing 6,345 31 5 36 33 6,414 Total commercial 166,075 143 32 30 205 923 167,203 Consumer Home equity 23,318 50 21 71 645 $ 54 24,088 Residential real estate 20,945 181 78 319 578 (c) 528 509 22,560 Automobile 13,863 134 34 12 180 175 14,218 Credit card 6,074 43 30 60 133 8 6,215 Education 2,785 55 29 77 161 (c) 2,946 Other consumer 4,656 14 10 11 35 7 4,698 Total consumer 71,641 477 202 479 1,158 1,363 563 74,725 Total $ 237,716 $ 620 $ 234 $ 509 $ 1,363 $ 2,286 $ 563 $ 241,928 Percentage of total loans 98.27 % 0.26 % 0.10 % 0.21 % 0.56 % 0.94 % 0.23 % 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 totaled $0.7 billion at both March 31, 2021 and December 31, 2020 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 $0.4 billion and $0.1 billion at March 31, 2021. Comparable amounts at December 31, 2020 were $0.4 billion and $0.2 billion. (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 and $1.3 billion at March 31, 2021 and December 31, 2020, respectively. (f) Collateral dependent loans totaled $1.4 billion and $1.5 billion at March 31, 2021 and December 31, 2020, respectively. The majority of these loans are within the Home equity and Residential real estate loan classes and are secured by consumer real estate. At March 31, 2021, we pledged $28.6 billion of commercial loans to the Federal Reserve Bank and $66.9 billion of residential real estate and other loans to the FHLB as collateral for the ability to borrow, if necessary. The comparable amounts at December 31, 2020 were $30.1 billion and $69.0 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 The following table presents our nonperforming assets as of March 31, 2021 and December 31, 2020 , respectively: Table 41: Nonperforming Assets Dollars in millions March 31 December 31 Nonperforming loans Commercial $ 749 $ 923 Consumer (a) 1,389 1,363 Total nonperforming loans (b) 2,138 2,286 OREO and foreclosed assets 41 51 Total nonperforming assets $ 2,179 $ 2,337 Nonperforming loans to total loans 0.90 % 0.94 % Nonperforming assets to total loans, OREO and foreclosed assets 0.92 % 0.97 % Nonperforming assets to total assets 0.46 % 0.50 % (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 $0.7 billion at March 31, 2021, and is primarily comprised of loans with a fair value of collateral that exceeds the amortized cost basis. The comparable amount at December 31, 2020 was $0.8 billion. 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 included in Item 8 of our 2020 Form 10-K and the Troubled Debt Restructurings section of this Note 4 for additional information on TDRs. Total nonperforming loans in Table 41 include TDRs of $0.9 billion at both March 31, 2021 and December 31, 2020. TDRs that are performing, including consumer credit card TDR loans, totaled $0.7 billion at both March 31, 2021 and December 31, 2020 and are excluded from nonperforming loans. Additional Credit Quality Indicators by Loan Class Commercial Loan Classes See Note 4 Loans and Related Allowance for Credit Losses included in Item 8 of our 2020 Form 10-K for additional information related to these loan classes, including discussion around the credit quality indicators that we use to monitor and manage the credit risk associated with each loan class. The following table presents credit quality indicators for the Commercial loan classes: Table 42: Commercial Credit Quality Indicators (a) Term Loans by Origination Year March 31, 2021 - In millions 2021 2020 2019 2018 2017 Prior Revolving Loans Revolving Loans Converted to Term Total Commercial and industrial Pass Rated $ 13,796 $ 19,870 $ 12,404 $ 7,540 $ 5,559 $ 10,715 $ 53,161 $ 51 $ 123,096 Criticized 158 429 725 603 317 594 3,856 20 6,702 Total commercial and industrial 13,954 20,299 13,129 8,143 5,876 11,309 57,017 71 129,798 Commercial real estate Pass Rated 1,041 3,261 6,034 3,195 2,675 8,673 239 25,118 Criticized 132 137 663 166 487 1,597 19 3,201 Total commercial real estate 1,173 3,398 6,697 3,361 3,162 10,270 258 28,319 Equipment lease financing Pass Rated 339 1,360 1,142 868 678 1,711 6,098 Criticized 11 71 73 79 34 23 291 Total equipment lease financing 350 1,431 1,215 947 712 1,734 6,389 Total commercial $ 15,477 $ 25,128 $ 21,041 $ 12,451 $ 9,750 $ 23,313 $ 57,275 $ 71 $ 164,506 Term Loans by Origination Year December 31, 2020 - In millions 2020 2019 2018 2017 2016 Prior Revolving Loans Revolving Loans Converted to Term Total Commercial and industrial Pass Rated $ 31,680 $ 13,340 $ 8,209 $ 5,956 $ 4,242 $ 7,141 $ 54,775 $ 53 $ 125,396 Criticized 339 702 578 334 224 351 4,130 19 6,677 Total commercial and industrial 32,019 14,042 8,787 6,290 4,466 7,492 58,905 72 132,073 Commercial real estate Pass Rated 3,709 6,268 3,426 2,841 2,341 6,792 218 25,595 Criticized 319 548 148 423 400 1,159 124 3,121 Total commercial real estate 4,028 6,816 3,574 3,264 2,741 7,951 342 28,716 Equipment lease financing Pass Rated 1,429 1,202 942 738 405 1,350 6,066 Criticized 78 92 86 39 22 31 348 Total equipment lease financing 1,507 1,294 1,028 777 427 1,381 6,414 Total commercial $ 37,554 $ 22,152 $ 13,389 $ 10,331 $ 7,634 $ 16,824 $ 59,247 $ 72 $ 167,203 (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 March 31, 2021 and December 31, 2020. Consumer Loan Classes See Note 4 Loans and Related Allowance for Credit Losses included in Item 8 of our 2020 Form 10-K for additional information related to these loan classes, including discussion around the credit quality indicators that we use to monitor and manage the credit risk associated with each loan class. Home Equity and Residential Real Estate The following table presents credit quality indicators for the home equity and residential real estate loan classes: Table 43: Home Equity and Residential Real Estate Credit Quality Indicators Term Loans by Origination Year March 31, 2021 - In millions 2021 2020 2019 2018 2017 Prior Revolving Loans Revolving Loans Converted to Term Total Loans Home equity Current estimated LTV ratios . Greater than 100% $ 8 $ 41 $ 13 $ 10 $ 73 $ 471 $ 254 $ 870 Greater than or equal to 80% to 100% $ 35 253 200 39 27 139 1,384 615 2,692 Less than 80% 196 3,019 1,560 482 712 4,081 6,418 3,463 19,931 Total home equity $ 231 $ 3,280 $ 1,801 $ 534 $ 749 $ 4,293 $ 8,273 $ 4,332 $ 23,493 Updated FICO scores Greater than or equal to 780 $ 127 $ 1,925 $ 960 $ 273 $ 467 $ 2,640 $ 5,148 $ 1,844 $ 13,384 720 to 779 84 947 505 138 164 865 1,950 1,084 5,737 660 to 719 19 346 264 83 80 428 905 678 2,803 Less than 660 1 61 71 39 37 350 255 628 1,442 No FICO score available 1 1 1 1 10 15 98 127 Total home equity $ 231 $ 3,280 $ 1,801 $ 534 $ 749 $ 4,293 $ 8,273 $ 4,332 $ 23,493 Residential real estate Current estimated LTV ratios Greater than 100% $ 4 $ 56 $ 23 $ 28 $ 150 $ 261 Greater than or equal to 80% to 100% $ 346 142 274 70 113 328 1,273 Less than 80% 2,175 7,157 2,995 856 1,485 5,286 19,954 Government insured or guaranteed loans 8 29 25 39 829 930 Total residential real estate $ 2,521 $ 7,311 $ 3,354 $ 974 $ 1,665 $ 6,593 $ 22,418 Updated FICO scores Greater than or equal to 780 $ 1,409 $ 5,220 $ 2,411 $ 661 $ 1,206 $ 3,564 $ 14,471 720 to 779 1,061 1,767 708 182 308 1,056 5,082 660 to 719 51 267 166 81 85 518 1,168 Less than 660 43 38 23 24 501 629 No FICO score available 6 2 2 3 125 138 Government insured or guaranteed loans 8 29 25 39 829 930 Total residential real estate $ 2,521 $ 7,311 $ 3,354 $ 974 $ 1,665 $ 6,593 $ 22,418 Term Loans by Origination Year December 31, 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 100% $ 8 $ 44 $ 18 $ 15 $ 9 $ 88 $ 580 $ 279 $ 1,041 Greater than or equal to 80% to 100% 517 320 59 42 25 158 1,781 591 3,493 Less than 80% 2,909 1,636 513 773 660 3,754 6,433 2,876 19,554 Total home equity $ 3,434 $ 2,000 $ 590 $ 830 $ 694 $ 4,000 $ 8,794 $ 3,746 $ 24,088 Updated FICO scores Greater than or equal to 780 $ 2,019 $ 1,094 $ 311 $ 525 $ 449 $ 2,467 $ 5,382 $ 1,480 $ 13,727 720 to 779 1,028 558 153 181 145 777 2,137 941 5,920 660 to 719 334 273 86 84 66 402 985 625 2,855 Less than 660 52 74 39 39 33 345 277 620 1,479 No FICO score available 1 1 1 1 1 9 13 80 107 Total home equity $ 3,434 $ 2,000 $ 590 $ 830 $ 694 $ 4,000 $ 8,794 $ 3,746 $ 24,088 Residential real estate Current estimated LTV ratios Greater than 100% $ 3 $ 52 $ 26 $ 42 $ 41 $ 160 $ 324 Greater than or equal to 80% to 100% 495 422 127 156 124 307 1,631 Less than 80% 7,491 3,656 992 1,706 1,847 3,991 19,683 Government insured or guaranteed loans 7 28 27 38 57 765 922 Total residential real estate $ 7,996 $ 4,158 $ 1,172 $ 1,942 $ 2,069 $ 5,223 $ 22,560 Updated FICO scores Greater than or equal to 780 $ 5,425 $ 3,099 $ 814 $ 1,432 $ 1,538 $ 2,551 $ 14,859 720 to 779 2,268 820 220 340 335 818 4,801 660 to 719 252 161 76 98 92 475 1,154 Less than 660 40 48 33 31 41 485 678 No FICO score available 4 2 2 3 6 129 146 Government insured or guaranteed loans 7 28 27 38 57 765 922 Total residential real estate $ 7,996 $ 4,158 $ 1,172 $ 1,942 $ 2,069 $ 5,223 $ 22,560 Automobile, Credit Card, Education and Other Consumer The following table presents credit quality indicators for the automobile, credit card, education and other consumer loan classes: Table 44: Credit Quality Indicators for Automobile, Credit Card, Education and Other Consumer Loan Classes Term Loans by Origination Year March 31, 2021 - In millions 2021 2020 2019 2018 2017 Prior Revolving Loans Revolving Loans Converted to Term Total Loans Updated FICO Scores Automobile FICO score greater than or equal to 780 $ 775 $ 1,545 $ 1,701 $ 688 $ 362 $ 216 $ 5,287 720 to 779 242 1,067 1,380 678 320 157 3,844 660 to 719 63 591 1,076 590 240 106 2,666 Less than 660 4 228 723 535 208 89 1,787 Total automobile $ 1,084 $ 3,431 $ 4,880 $ 2,491 $ 1,130 $ 568 $ 13,584 Credit card FICO score greater than or equal to 780 $ 1,513 $ 3 $ 1,516 720 to 779 1,541 11 1,552 660 to 719 1,621 25 1,646 Less than 660 817 46 863 No FICO score available or required (a) 94 4 98 Total credit card $ 5,586 $ 89 $ 5,675 Education FICO score greater than or equal to 780 $ 1 $ 64 $ 86 $ 70 $ 55 $ 450 $ 726 720 to 779 4 34 44 37 27 202 348 660 to 719 4 10 14 14 8 90 140 Less than 660 1 1 3 2 2 35 44 No FICO score available or required (a) 3 12 9 5 3 1 33 Education loans using FICO credit metric 13 121 156 128 95 778 1,291 Other internal credit metrics 1,551 1,551 Total education $ 13 $ 121 $ 156 $ 128 $ 95 $ 2,329 $ 2,842 Other consumer FICO score greater than or equal to 780 $ 31 $ 135 $ 150 $ 49 $ 15 $ 40 $ 73 $ 1 $ 494 720 to 779 33 169 206 65 16 23 109 621 660 to 719 27 111 185 68 13 14 107 525 Less than 660 1 34 81 34 7 7 47 1 212 Other consumer loans using FICO credit metric 92 449 622 216 51 84 336 2 1,852 Other internal credit metrics 32 29 28 29 26 126 2,365 8 2,643 Total other consumer $ 124 $ 478 $ 650 $ 245 $ 77 $ 210 $ 2,701 $ 10 $ 4,495 Term Loans by Origination Year December 31, 2020 - In millions 2020 2019 2018 2017 2016 Prior Revolving Loans Revolving Loans Converted to Term Total Loans Updated FICO Scores Automobile FICO score greater than or equal to 780 $ 1,807 $ 1,915 $ 807 $ 452 $ 246 $ 58 $ 5,285 720 to 779 1,098 1,581 789 381 167 44 4,060 660 to 719 617 1,222 684 288 109 31 2,951 Less than 660 192 776 598 240 87 29 1,922 Total automobile $ 3,714 $ 5,494 $ 2,878 $ 1,361 $ 609 $ 162 $ 14,218 Credit card FICO score greater than or equal to 780 $ 1,635 $ 3 $ 1,638 720 to 779 1,724 11 1,735 660 to 719 1,765 26 1,791 Less than 660 902 51 953 No FICO score available or required (a) 94 4 98 Total credit card $ 6,120 $ 95 $ 6,215 Education FICO score greater than or equal to 780 $ 34 $ 90 $ 74 $ 59 $ 50 $ 428 $ 735 720 to 779 24 46 38 28 20 190 346 660 to 719 15 15 14 9 6 90 149 Less than 660 3 2 3 2 2 37 49 No FICO score available or required (a) 16 10 6 3 1 36 Education loans using FICO credit metric 92 163 135 101 78 746 1,315 Other internal credit metrics 1,631 1,631 Total education $ 92 $ 163 $ 135 $ 101 $ 78 $ 2,377 $ 2,946 Other consumer FICO score greater than or equal to 780 $ 162 $ 187 $ 63 $ 21 $ 5 $ 42 $ 86 $ 1 $ 567 720 to 779 197 247 82 22 5 22 123 698 660 to 719 127 210 81 17 3 14 117 1 570 Less than 660 28 86 41 9 2 8 53 1 228 Other consumer loans using FICO credit metric 514 730 267 69 15 86 379 3 2,063 Other internal credit metrics 67 33 37 26 60 75 2,334 3 2,635 Total other consumer $ 581 $ 763 $ 304 $ 95 $ 75 $ 161 $ 2,713 $ 6 $ 4,698 (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. Troubled Debt Restructurings Table 45 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 months ended March 31, 2021 and March 31, 2020. Additionally, the table provides information about the types of TDR concessions. See Note 1 Accounting Policies and Note 4 Loans and Related Allowance for Credit Losses included in Item 8 of our 2020 Form 10-K for additional discussion of TDRs. Table 45: Financial Impact and TDRs by Concession Type (a) Pre-TDR Post-TDR Amortized Cost Basis (c) During the three months ended March 31, 2021 Number Principal Rate Other Total Commercial 19 $ 93 $ 94 $ 94 Consumer 2,096 32 $ 16 12 28 Total TDRs 2,115 $ 125 $ 16 $ 106 $ 122 During the three months ended March 31, 2020 Commercial 13 $ 62 $ 6 $ 37 $ 43 Consumer 3,567 36 $ 22 10 32 Total TDRs 3,580 $ 98 $ 6 $ 22 $ 47 $ 75 (a) Impact of partial charge-offs at TDR date is 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. 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. Loans that were both (i) classified as TDRs within the last twelve months from the balance sheet date, and (ii) subsequently defaulted during the the three months ended March 31, 2021 and March 31, 2020 totaled $15 million and $29 million, respectively. 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 included in Item 8 of our 2020 Form 10-K for a discussion of the methodologies used to determine this allowance. A rollforward of the ACL related to loans follows: Table 46: Rollforward of Allowance for Credit Losses (a) Three months ended March 31, 2021 Three Months Ended March 31, 2020 In millions Commercial Consumer Total Commercial Consumer Total Allowance for loan and lease losses Beginning balance $ 3,337 $ 2,024 $ 5,361 $ 1,812 $ 930 $ 2,742 Adoption of ASU 2016-13 (b) (304) 767 463 Beginning balance, adjusted 3,337 2,024 5,361 1,508 1,697 3,205 Charge-offs (69) (174) (243) (83) (221) (304) Recoveries 18 79 97 24 68 92 Net (charge-offs) (51) (95) (146) (59) (153) (212) Provision for (recapture of) credit losses (204) (298) (502) 531 421 952 Other 1 1 (1) (1) Ending balance $ 3,083 $ 1,631 $ 4,714 $ 1,979 $ 1,965 $ 3,944 Allowance for unfunded lending related commitments (c) Beginning balance $ 485 $ 99 $ 584 $ 316 $ 2 $ 318 Adoption of ASU 2016-13 (b) 53 126 179 Beginning balance, adjusted 485 99 584 369 128 497 Provision for (recapture of) credit losses (82) 5 (77) (25) (22) (47) Ending balance $ 403 $ 104 $ 507 $ 344 $ 106 $ 450 Allowance for credit losses at March 31 $ 3,486 $ 1,735 $ 5,221 $ 2,323 $ 2,071 $ 4,394 Allowance for credit losses at December 31 $ 3,822 $ 2,123 $ 5,945 $ 2,128 $ 932 $ 3,060 (a) Excludes allowances for investment securities and other financial assets, which together totaled $136 million and $21 million at March 31, 2021 and March 31, 2020, respectively. (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 8 Commitments for additional information about the underlying commitments related to this allowance. The ACL at March 31, 2021 totaled $5.2 billion, a $0.7 billion decrease compared to December 31, 2020. This decrease in reserves was primarily attributable to the improved economic outlook and portfolio changes, partially offset by increases in qualitative factor reserves due to portfolio sensitivity from specific customers and segments still impacted by the pandemic. The following summarizes the changes in these factors that influenced the current ACL: • The economic scenarios used for the period ended March 31, 2021 were designed to reflect an improved near-term economic outlook in comparison to the scenarios used for the period ended December 31, 2020. This improvement was the result of declining COVID-19 cases, more rapid vaccine distribution, the passage of the American Rescue Plan stimulus package and economic momentum fueled by increased consumer spending. • Portfolio changes primarily reflecting decreases in both commercial and consumer loan balances drove reserve declines at March 31, 2021. Declines were attributable to lower utilization of loan commitments and softer loan production in the commercial portfolio and paydowns outpacing new originations in the consumer portfolio. • Increases in qualitative factor reserves at March 31, 2021 were attributable to the considerable uncertainty that remains regarding overall lifetime loss content for both our commercial and consumer portfolios, specifically as it relates to our customers that are less likely to benefit from the economic recovery currently underway. For commercial borrowers, there are concerns around industries that are dependent on in-person gatherings, hospitality and tourism. For consumer borrowers, payment behavior once the government stimulus wanes is also difficult to predict. The ACL at March 31, 2020 totaled $4.4 billion, a $1.3 billion increase in reserves compared to December 31, 2019. This increase reflected the day-one CECL transition adjustment along with the significantly adverse economic impacts of the pandemic and its resulting effects on credit quality and loan growth in the first quarter of 2020. |