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 • Residential real estate • Commercial real estate • Home equity • 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, but not limited to, trends in delinquency rates, nonperforming status, analyses of PD and LGD ratings, updated credit scores and originated and updated LTV ratios. We manage credit risk based on the risk profile of the borrower, repayment sources, underlying collateral and other support given current events, economic conditions and expectations. We refine our practices to address operating environment changes such as inflation levels, industry specific risks, interest rate levels, the level of consumer savings and deposit balances, and structural and secular changes such as those arising from the pandemic. We offer loan modifications and collection programs to assist our customers, enhance support and mitigate losses. Table 48 presents the composition and delinquency status of our loan portfolio at December 31, 2024 and December 31, 2023. Loan delinquencies include government insured or guaranteed loans and loans accounted for under the fair value option. Table 48: 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 December 31, 2024 Commercial Commercial and industrial $ 174,988 $ 159 $ 43 $ 72 $ 274 $ 528 $ 175,790 Commercial real estate 32,657 25 18 43 919 33,619 Equipment lease financing 6,687 41 12 53 15 6,755 Total commercial 214,332 225 73 72 370 1,462 216,164 Consumer Residential real estate 45,134 234 106 188 528 (c) 278 $ 475 46,415 Home equity 25,351 71 26 97 482 61 25,991 Automobile 15,155 83 22 9 114 86 15,355 Credit card 6,696 49 38 81 168 15 6,879 Education 1,557 25 15 39 79 (c) 1,636 Other consumer 3,998 10 8 8 26 3 4,027 Total consumer 97,891 472 215 325 1,012 864 536 100,303 Total $ 312,223 $ 697 $ 288 $ 397 $ 1,382 $ 2,326 $ 536 $ 316,467 Percentage of total loans 98.66 % 0.22 % 0.09 % 0.13 % 0.44 % 0.73 % 0.17 % 100.00 % December 31, 2023 Commercial Commercial and industrial $ 176,796 $ 104 $ 45 $ 76 $ 225 $ 559 $ 177,580 Commercial real estate 34,685 7 9 16 735 35,436 Equipment lease financing 6,480 41 8 49 13 6,542 Total commercial 217,961 152 53 85 290 1,307 219,558 Consumer Residential real estate 46,159 282 101 192 575 (c) 294 $ 516 47,544 Home equity 25,533 63 27 90 458 69 26,150 Automobile 14,638 91 20 7 118 104 14,860 Credit card 6,991 54 39 86 179 10 7,180 Education 1,850 27 19 49 95 (c) 1,945 Other consumer 4,227 16 11 10 37 7 4,271 Total consumer 99,398 533 217 344 1,094 873 585 101,950 Total $ 317,359 $ 685 $ 270 $ 429 $ 1,384 $ 2,180 $ 585 $ 321,508 Percentage of total loans 98.71 % 0.21 % 0.08 % 0.13 % 0.43 % 0.68 % 0.18 % 100.00 % (a) Amounts in table represent loans held for investment and do not include any associated ALLL. (b) The accrued interest associated with our loan portfolio totaled $1.3 billion and $1.5 billion at December 31, 2024 and 2023, respectively. These amounts are included in Other assets (c) Past due loan amounts include government insured or guaranteed residential real estate loans and education loans totaling $0.3 billion and $0.1 billion at both December 31, 2024 and 2023, respectively. (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 policy criteria. Given that these loans are not accounted for at amortized cost, they have been excluded from the nonperforming loan population. (e) Includes unearned income, unamortized deferred fees and costs on originated loans and premiums or discounts on purchased loans totaling $1.0 billion at both December 31, 2024 and 2023, respectively. (f) Collateral dependent loans totaled $1.6 billion and $1.4 billion at December 31, 2024 and 2023, respectively. In the normal course of business, we originate or purchase loan products with contractual characteristics that, when concentrated, may increase our exposure as a holder of those loan products. Possible product features that may create a concentration of credit risk would include a high original or updated LTV ratio, term lengths that may expose the borrower to payment terms above market interest rates and interest-only loans, among others. We originate interest-only loans to commercial borrowers. Such credit arrangements are usually designed to match borrower cash flow expectations ( e.g. , working capital lines, revolvers). These products are standard in the financial services industry and product features are considered during the underwriting process to mitigate the increased risk that borrowers may not be able to make interest and principal payments when due as a result of the interest-only feature. We do not believe that these product features create a concentration of credit risk. At December 31, 2024, we pledged unpaid principal balances in the amounts of $43.4 billion of commercial and other loans to the Federal Reserve Bank and $89.0 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, 2023 were $51.3 billion and $89.5 billion, respectively. 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 generally 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. See Note 1 Accounting Policies for additional information on our nonperforming loan and lease policies. The following table presents our nonperforming assets as of December 31, 2024 and 2023: Table 49: Nonperforming Assets Dollars in millions December 31, 2024 December 31, 2023 Nonperforming loans Commercial $ 1,462 $ 1,307 Consumer (a) 864 873 Total nonperforming loans (b) 2,326 2,180 OREO and foreclosed assets 31 36 Total nonperforming assets $ 2,357 $ 2,216 Nonperforming loans to total loans 0.73 % 0.68 % Nonperforming assets to total loans, OREO and foreclosed assets 0.74 % 0.69 % Nonperforming assets to total assets 0.42 % 0.39 % (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 $0.6 billion and $0.5 billion at December 31, 2024 and 2023, respectively. This primarily includes loans with a fair value of collateral that exceeds the amortized cost basis. 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 generally reviewed and updated 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 PD and LGD, 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 reviews, 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. The following table presents credit quality indicators for our commercial loan classes: Table 50: Commercial Credit Quality Indicators (a) Term Loans by Origination Year December 31, 2024 In millions 2024 2023 2022 2021 2020 Prior Revolving Loans Revolving Loans Converted to Term Total Commercial and industrial Pass Rated $ 22,145 $ 13,815 $ 17,043 $ 5,275 $ 4,594 $ 11,270 $ 91,389 $ 522 $ 166,053 Criticized 761 878 1,856 601 144 580 4,868 49 9,737 Total commercial and industrial loans 22,906 14,693 18,899 5,876 4,738 11,850 96,257 571 175,790 Gross charge-offs (b) 22 (c) 32 51 25 5 7 133 53 328 Commercial real estate Pass Rated 2,331 5,575 6,875 2,232 1,220 9,685 423 28,341 Criticized 141 335 1,974 485 465 1,853 25 5,278 Total commercial real estate loans 2,472 5,910 8,849 2,717 1,685 11,538 448 33,619 Gross charge-offs (b) 28 5 2 1 322 358 Equipment lease financing Pass Rated 1,814 1,264 1,112 478 478 1,305 6,451 Criticized 51 79 88 35 21 30 304 Total equipment lease financing loans 1,865 1,343 1,200 513 499 1,335 6,755 Gross charge-offs (b) 1 6 12 5 4 6 34 Total commercial loans $ 27,243 $ 21,946 $ 28,948 $ 9,106 $ 6,922 $ 24,723 $ 96,705 $ 571 $ 216,164 Total commercial gross charge-offs $ 51 $ 43 $ 63 $ 32 $ 10 $ 335 $ 133 $ 53 $ 720 Term Loans by Origination Year December 31, 2023 In millions 2023 2022 2021 2020 2019 Prior Revolving Loans Revolving Loans Converted to Term Total Commercial and industrial Pass Rated $ 23,019 $ 26,657 $ 7,562 $ 5,783 $ 4,110 $ 11,982 $ 88,467 $ 573 $ 168,153 Criticized 838 1,781 739 331 281 698 4,708 51 9,427 Total commercial and industrial loans 23,857 28,438 8,301 6,114 4,391 12,680 93,175 624 177,580 Gross charge-offs (b) 25 (c) 32 33 8 3 26 105 12 244 Commercial real estate Pass Rated 4,182 8,571 2,986 2,190 4,887 7,411 383 30,610 Criticized 155 1,300 455 490 622 1,753 51 4,826 Total commercial real estate loans 4,337 9,871 3,441 2,680 5,509 9,164 434 35,436 Gross charge-offs (b) 12 31 137 180 Equipment lease financing Pass Rated 1,522 1,424 689 690 452 1,378 6,155 Criticized 90 81 81 51 35 49 387 Total equipment lease financing loans 1,612 1,505 770 741 487 1,427 6,542 Gross charge-offs (b) 4 4 4 4 1 1 18 Total commercial loans $ 29,806 $ 39,814 $ 12,512 $ 9,535 $ 10,387 $ 23,271 $ 93,609 $ 624 $ 219,558 Total commercial gross charge-offs $ 29 $ 36 $ 37 $ 24 $ 35 $ 164 $ 105 $ 12 $ 442 (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 December 31, 2024 and 2023. (b) Gross charge-offs are presented on a year-to-date basis, as of the period end date. (c) Includes charge-offs of deposit overdrafts. Residential Real Estate and Home Equity We use several credit quality indicators, including delinquency information, nonperforming loan information, updated credit scores and originated and updated LTV ratios, to monitor and manage credit risk within the residential real estate and home equity loan classes. A summary of credit quality indicators follows: Delinquency/Delinquency Rates : We monitor delinquency/delinquency rate trends for residential real estate and home equity loans. See Table 48 for additional information. Nonperforming Loans : We monitor nonperforming loan trends for residential real estate and home equity loans. See Table 48 for additional information. Credit Scores: We use a national third-party provider to update FICO credit scores for residential real estate and home equity 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 CLTV for first and subordinate lien positions): At least quarterly, 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. The following table presents credit quality indicators for our residential real estate and home equity loan classes: Table 51: Credit Quality Indicators for Residential Real Estate and Home Equity Loan Classes Term Loans by Origination Year December 31, 2024 In millions 2024 2023 2022 2021 2020 Prior Revolving Loans Revolving Loans Converted to Term Total Residential real estate Current estimated LTV ratios Greater than 100% $ 10 $ 55 $ 85 $ 52 $ 23 $ 32 $ 257 Greater than or equal to 80% to 100% 591 485 954 601 171 111 2,913 Less than 80% 2,043 4,039 8,450 13,958 6,084 8,039 42,613 No LTV available 9 3 12 Government insured or guaranteed loans 1 16 23 17 66 497 620 Total residential real estate loans $ 2,645 $ 4,595 $ 9,512 $ 14,637 $ 6,344 $ 8,682 $ 46,415 Updated FICO scores Greater than or equal to 780 $ 1,730 $ 3,264 $ 7,584 $ 11,723 $ 4,683 $ 4,858 $ 33,842 720 to 779 789 805 1,406 2,035 1,004 1,567 7,606 660 to 719 115 270 401 620 324 784 2,514 Less than 660 9 108 90 156 116 696 1,175 No FICO score available 1 132 8 86 151 280 658 Government insured or guaranteed loans 1 16 23 17 66 497 620 Total residential real estate loans $ 2,645 $ 4,595 $ 9,512 $ 14,637 $ 6,344 $ 8,682 $ 46,415 Gross charge-offs (a) $ 1 $ 2 $ 3 Home equity (b) Current estimated LTV ratios Greater than 100% $ 1 $ 12 $ 17 $ 368 $ 372 $ 770 Greater than or equal to 80% to 100% 5 31 30 1,098 1,619 2,783 Less than 80% 141 1,670 2,807 6,907 10,913 22,438 Total home equity loans $ 147 $ 1,713 $ 2,854 $ 8,373 $ 12,904 $ 25,991 Updated FICO scores Greater than or equal to 780 $ 94 $ 1,145 $ 1,753 $ 4,720 $ 6,211 $ 13,923 720 to 779 34 352 572 2,251 3,274 6,483 660 to 719 14 151 289 1,193 2,085 3,732 Less than 660 5 63 234 202 1,290 1,794 No FICO score available 2 6 7 44 59 Total home equity loans $ 147 $ 1,713 $ 2,854 $ 8,373 $ 12,904 $ 25,991 Gross charge-offs (a) $ 1 $ 16 $ 19 $ 36 (Continued from previous page) Term Loans by Origination Year December 31, 2023 In millions 2023 2022 2021 2020 2019 Prior Revolving Loans Revolving Loans Converted to Term Total Residential real estate Current estimated LTV ratios Greater than 100% $ 15 $ 139 $ 79 $ 31 $ 10 $ 28 $ 302 Greater than or equal to 80% to 100% 1,665 1,928 955 221 69 92 4,930 Less than 80% 3,585 7,977 14,421 6,514 2,154 6,935 41,586 No LTV available 56 13 4 73 Government insured or guaranteed loans 14 20 16 66 37 500 653 Total residential real estate loans $ 5,335 $ 10,064 $ 15,484 $ 6,832 $ 2,270 $ 7,559 $ 47,544 Updated FICO scores Greater than or equal to 780 $ 3,206 $ 7,797 $ 12,197 $ 5,035 $ 1,492 $ 4,004 $ 33,731 720 to 779 1,482 1,659 2,389 1,107 432 1,388 8,457 660 to 719 400 508 657 334 171 721 2,791 Less than 660 93 71 133 122 82 680 1,181 No FICO score available 140 9 92 168 56 266 731 Government insured or guaranteed loans 14 20 16 66 37 500 653 Total residential real estate loans $ 5,335 $ 10,064 $ 15,484 $ 6,832 $ 2,270 $ 7,559 $ 47,544 Gross charge-offs (a) $ 2 $ 1 $ 1 $ 4 $ 8 Home equity (b) Current estimated LTV ratios Greater than 100% $ 1 $ 12 $ 6 $ 14 $ 306 $ 309 $ 648 Greater than or equal to 80% to 100% 4 40 17 22 1,116 1,743 2,942 Less than 80% 157 1,866 845 2,556 6,843 10,293 22,560 Total home equity loans $ 162 $ 1,918 $ 868 $ 2,592 $ 8,265 $ 12,345 $ 26,150 Updated FICO scores Greater than or equal to 780 $ 102 $ 1,254 $ 489 $ 1,605 $ 4,604 $ 6,083 $ 14,137 720 to 779 38 423 216 488 2,222 3,225 6,612 660 to 719 17 174 110 271 1,207 1,894 3,673 Less than 660 5 65 52 220 223 1,089 1,654 No FICO score available 2 1 8 9 54 74 Total home equity loans $ 162 $ 1,918 $ 868 $ 2,592 $ 8,265 $ 12,345 $ 26,150 Gross charge-offs (a) $ 4 $ 7 $ 10 $ 21 (a) Gross charge-offs are presented on a year-to-date basis, as of the period end date. (b) Beginning January 1, 2022, new originations consist of only revolving Home Equity Lines of Credit. 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 our automobile, credit card, education and other consumer loan classes: Table 52: Credit Quality Indicators for Automobile, Credit Card, Education and Other Consumer Loan Classes Term Loans by Origination Year December 31, 2024 In millions 2024 2023 2022 2021 2020 Prior Revolving Loans Revolving Loans Converted to Term Total Automobile Updated FICO scores Greater than or equal to 780 $ 3,288 $ 1,717 $ 1,094 $ 865 $ 241 $ 125 $ 7,330 720 to 779 2,047 1,123 636 415 129 90 4,440 660 to 719 963 671 367 227 82 74 2,384 Less than 660 246 351 231 174 87 112 1,201 Total automobile loans $ 6,544 $ 3,862 $ 2,328 $ 1,681 $ 539 $ 401 $ 15,355 Gross charge-offs (a) $ 9 $ 44 $ 27 $ 17 $ 12 $ 22 $ 131 Credit card Updated FICO scores Greater than or equal to 780 $ 2,090 $ 2 $ 2,092 720 to 779 1,859 5 1,864 660 to 719 1,815 16 1,831 Less than 660 936 57 993 No FICO score available or required (b) 97 2 99 Total credit card loans $ 6,797 $ 82 $ 6,879 Gross charge-offs (a) $ 316 $ 39 $ 355 Education Updated FICO scores Greater than or equal to 780 $ 22 $ 58 $ 79 $ 39 $ 33 $ 318 $ 549 720 to 779 20 36 38 20 14 116 244 660 to 719 13 14 15 6 5 46 99 Less than 660 3 3 3 1 1 19 30 No FICO score available or required (b) 12 5 4 1 1 23 Total loans using FICO credit metric 70 116 139 67 53 500 945 Other internal credit metrics 691 691 Total education loans $ 70 $ 116 $ 139 $ 67 $ 53 $ 1,191 $ 1,636 Gross charge-offs (a) $ 1 $ 1 $ 1 $ 16 $ 19 Other consumer Updated FICO scores Greater than or equal to 780 $ 245 $ 129 $ 64 $ 20 $ 5 $ 6 $ 37 $ 1 $ 507 720 to 779 292 141 70 21 6 6 72 1 609 660 to 719 203 97 72 22 8 6 79 1 488 Less than 660 20 33 34 15 6 5 40 1 154 Total loans using FICO credit metric 760 400 240 78 25 23 228 4 1,758 Other internal credit metrics 6 9 77 12 11 90 2,056 8 2,269 Total other consumer loans $ 766 $ 409 $ 317 $ 90 $ 36 $ 113 $ 2,284 $ 12 $ 4,027 Gross charge-offs (a) $ 76 (c) $ 27 $ 26 $ 13 $ 8 $ 9 $ 11 $ 1 $ 171 (Continued from previous page) Term Loans by Origination Year December 31, 2023 In millions 2023 2022 2021 2020 2019 Prior Revolving Loans Revolving Loans Converted to Term Total Automobile Updated FICO scores Greater than or equal to 780 $ 2,722 $ 1,650 $ 1,483 $ 535 $ 368 $ 88 $ 6,846 720 to 779 1,797 1,104 778 301 250 80 4,310 660 to 719 1,014 604 408 186 186 70 2,468 Less than 660 264 272 243 152 200 105 1,236 Total automobile loans $ 5,797 $ 3,630 $ 2,912 $ 1,174 $ 1,004 $ 343 $ 14,860 Gross charge-offs (a) $ 8 $ 24 $ 22 $ 17 $ 30 $ 20 $ 121 Credit card Updated FICO scores Greater than or equal to 780 $ 2,017 $ 1 $ 2,018 720 to 779 1,976 4 1,980 660 to 719 1,979 13 1,992 Less than 660 1,036 48 1,084 No FICO score available or required (b) 103 3 106 Total credit card loans $ 7,111 $ 69 $ 7,180 Gross charge-offs (a) $ 290 $ 29 $ 319 Education Updated FICO scores Greater than or equal to 780 $ 35 $ 88 $ 45 $ 40 $ 51 $ 331 $ 590 720 to 779 32 47 24 19 24 131 277 660 to 719 20 17 8 6 8 54 113 Less than 660 4 3 2 1 2 21 33 No FICO score available or required (b) 15 5 4 2 1 27 Total loans using FICO credit metric 106 160 83 68 85 538 1,040 Other internal credit metrics 905 905 Total education loans $ 106 $ 160 $ 83 $ 68 $ 85 $ 1,443 $ 1,945 Gross charge-offs (a) $ 1 $ 1 $ 2 $ 13 $ 17 Other consumer Updated FICO scores Greater than or equal to 780 $ 241 $ 127 $ 47 $ 21 $ 14 $ 11 $ 39 $ 1 $ 501 720 to 779 286 157 54 26 17 11 80 1 632 660 to 719 147 140 57 27 21 11 87 2 492 Less than 660 19 52 31 17 14 8 43 1 185 Total loans using FICO credit metric 693 476 189 91 66 41 249 5 1,810 Other internal credit metrics 19 97 33 48 71 34 2,149 10 2,461 Total other consumer loans $ 712 $ 573 $ 222 $ 139 $ 137 $ 75 $ 2,398 $ 15 $ 4,271 Gross charge-offs (a) $ 75 (c) $ 23 $ 18 $ 14 $ 14 $ 8 $ 11 $ 1 $ 164 (a) Gross charge-offs are presented on a year-to-date basis, as of the period end date. (b) Loans where FICO scores are not 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. (c) Includes charge-offs of deposit overdrafts. Loan Modifications to Borrowers Experiencing Financial Difficulty Loan modifications to borrowers experiencing financial difficulty (FDMs) result from our loss mitigation activities and include principal forgiveness, interest rate reductions, term extensions, payment delays, repayment plans or combinations thereof. See Note 1 Accounting Policies for additional information on FDMs. The following table presents the amortized cost basis, as of the period end date, of FDMs granted during the twelve months ended December 31, 2024: Table 53: Loan Modifications Granted to Borrowers Experiencing Financial Difficulty (a) (b) Year ended December 31, 2024 Dollars in millions Interest Rate Reduction Term Extension Payment Delay Repayment Plan Interest Rate Reduction and Payment Delay Interest Rate Reduction and Term Extension Payment Delay and Term Extension Other (c) Total % of Loan Class Commercial Commercial and industrial $ 14 $ 995 $ 34 $ 15 $ 111 $ 154 $ 106 $ 1,429 0.81 % Commercial real estate 964 94 232 1,290 3.84 % Equipment lease financing 2 2 0.03 % Total commercial 14 1,961 128 15 111 386 106 2,721 1.26 % Consumer Residential real estate 1 84 6 7 98 0.21 % Home equity 13 $ 7 18 38 0.15 % Credit card 62 62 0.90 % Education 5 5 0.31 % Other consumer 1 1 0.02 % Total consumer 6 97 70 6 25 204 0.20 % Total $ 14 $ 1,967 $ 225 $ 70 $ 15 $ 117 $ 386 $ 131 $ 2,925 0.92 % Year ended December 31, 2023 Dollars in millions Interest Rate Reduction Term Extension Payment Delay Repayment Plan Interest Rate Reduction and Payment Delay Interest Rate Reduction and Term Extension Payment Delay and Term Extension Other (c) Total % of Loan Class Commercial Commercial and industrial $ 13 $ 683 $ 65 $ 14 $ 18 $ 156 $ 150 $ 1,099 0.62 % Commercial real estate 47 816 17 87 967 2.73 % Total commercial 60 1,499 65 14 18 173 237 2,066 0.94 % Consumer Residential real estate 2 1 95 5 6 109 0.23 % Home equity 1 10 $ 8 12 31 0.12 % Credit card 58 58 0.81 % Education 5 5 0.26 % Other consumer 1 1 0.02 % Total consumer 2 7 105 67 5 18 204 0.20 % Total $ 62 $ 1,506 $ 170 $ 67 $ 14 $ 23 $ 173 $ 255 $ 2,270 0.71 % (a) The unfunded lending related commitments on FDMs granted were $0.9 billion and $0.4 billion during the year ended December 31, 2024 and 2023, respectively. (b) Excludes the amortized cost basis of modified loans that were paid off, charged-off or otherwise liquidated as of the period end date. (c) Represents all other modifications, and includes trial modifications and loans where we have received notification that a borrower has filed for Chapter 7 bankruptcy relief, but specific instructions as to the terms of the relief have not been formally ruled upon by the court. Table 54 presents the weighted average financial effect of FDMs granted during the twelve months ended December 31, 2024 and 2023: Table 54: Financial Effect of FDMs (a) Year ended December 31, 2024 Dollars in millions Amortized cost basis (b) Weighted Average Financial Effect Term Extension Commercial and industrial $1,260 Extended contractual term by 16 months. Commercial real estate $1,196 Extended contractual term by 17 months. Equipment lease financing $2 Extended contractual term by 43 months. Residential real estate $7 Extended contractual term by 94 months. Education $5 Extended contractual term by 13 months. Interest Rate Reduction Commercial and industrial $140 Reduced contractual interest rate by 1.42%. Residential real estate $6 Reduced contractual interest rate by 2.00%. Payment Delay Commercial and industrial $203 Provided 8 months of payment deferral. Commercial real estate $326 Provided 8 months of payment deferral. Residential real estate $84 Provided 9 months of payment deferral. Home equity $13 Provided 4 months of payment deferral. Year ended December 31, 2023 Dollars in millions Amortized cost basis (b) Weighted Average Financial Effect Term Extension Commercial and industrial $857 Extended contractual term by 12 months. Commercial real estate $833 Extended contractual term by 14 months. Residential real estate $6 Extended contractual term by 80 months. Home equity $1 Extended contractual term by 232 months. Education $5 Extended contractual term by 20 months. Interest Rate Reduction Commercial and industrial $45 Reduced contractual interest rate by 2.70%. Commercial real estate $47 Reduced contractual interest rate by 4.54%. Residential real estate $7 Reduced contractual interest rate by 1.34%. Payment Delay Commercial and industrial $235 Provided 3 months of payment deferral. Commercial real estate $17 Provided 5 months of payment deferral. Residential real estate $95 Provided 9 months of payment deferral. Home equity $10 Provided 4 months of payment deferral. (a) Excludes the financial effects of modifications for loans that were paid off, charged-off or otherwise liquidated as of the period end date. (b) The amortized cost basis presented in Table 54 includes combination modification categories in addition to the standalone modification categories presented in Table 53. Primarily due to this reason, the amortized cost basis presented in Table 54 may not agree to the amortized cost basis presented alongside the standalone modification categories in Table 53. Amortized cost basis is as of the period end date. Repayment plans are excluded from Table 54. The terms of these programs, which are offered for certain consumer products, are as follows: • Credit card and unsecured lines of credit • Short-term programs are granted for periods of 6 and 12 months. These programs are structurally similar such that the interest rate is reduced to a standard rate of 4.99% and the minimum payment percentage is adjusted to 1.90% of the outstanding balance. At the end of the 6 or 12 months, the borrower is returned to the original contractual interest rate and minimum payment amount specified in the original lending agreement. • Fully-amortized repayment plans are also granted, the most common of which being a 60 month program. In this program, we convert the borrower’s drawn and unpaid balances into a fully-amortized repayment plan consisting of an interest rate of 4.99% and an adjusted minimum payment percentage of 1.90% of the outstanding balance. This fully-amortized program is designed in a manner that allows the drawn and unpaid amounts to be recaptured at the end of the 60 months. • Home equity loans and lines of credit • Fixed payment plan programs establish a modified monthly payment that is informed by the borrower’s financial situation and the current market environment at the time of modification, among other factors. As such, we may change the borrower’s interest rate, modify the term of the loan, and/or defer payment to arrive at the modified monthly payment. Each of the aforementioned terms may increase or decrease, and may vary from loan to loan, based on the individual loan and borrower characteristics. After we modify a loan, we continue to track its performance under its most recent modified terms. The following table presents the performance, as of period end date, of FDMs granted during the year ended December 31, 2024 and 2023: Table 55: Delinquency Status of FDMs (a) (b) Year e |