Loans and Allowance for Credit Losses | Note 5: Loans and Allowance for Credit Losses Table 5.1 presents total loans outstanding by portfolio segment and class of financing receivable. Outstanding balances include a total net reduction of $4.5 billion and $3.8 billion at September 30, 2016 , and December 31, 2015 , respectively, for unearned income, net deferred loan fees, and unamortized discounts and premiums. Outstanding balances at September 30, 2016 also reflect the acquisition of various loans and capital leases from GE Capital as described in Note 2 (Business Combinations). Table 5.1: Loans Outstanding (in millions) Sep 30, Dec 31, Commercial: Commercial and industrial $ 324,020 299,892 Real estate mortgage 130,223 122,160 Real estate construction 23,340 22,164 Lease financing 18,871 12,367 Total commercial 496,454 456,583 Consumer: Real estate 1-4 family first mortgage 278,689 273,869 Real estate 1-4 family junior lien mortgage 48,105 53,004 Credit card 34,992 34,039 Automobile 62,873 59,966 Other revolving credit and installment 40,213 39,098 Total consumer 464,872 459,976 Total loans $ 961,326 916,559 Our foreign loans are reported by respective class of financing receivable in the table above. Substantially all of our foreign loan portfolio is commercial loans. Loans are classified as foreign primarily based on whether the borrower’s primary address is outside of the United States. Table 5.2 presents total commercial foreign loans outstanding by class of financing receivable. Table 5.2: Commercial Foreign Loans Outstanding (in millions) Sep 30, Dec 31, Commercial foreign loans: Commercial and industrial $ 51,515 49,049 Real estate mortgage 8,466 8,350 Real estate construction 310 444 Lease financing 958 274 Total commercial foreign loans $ 61,249 58,117 Loan Purchases, Sales, and Transfers Table 5.3 summarizes the proceeds paid or received for purchases and sales of loans and transfers from loans held for investment to mortgages/loans held for sale at lower of cost or fair value. This loan activity also includes participating interests, whereby we receive or transfer a portion of a loan. The table excludes PCI loans and loans for which we have elected the fair value option, including loans originated for sale because their loan activity normally does not impact the allowance for credit losses. Table 5.3: Loan Purchases, Sales, and Transfers 2016 2015 (in millions) Commercial (1) Consumer (2) Total Commercial Consumer (2) Total Quarter ended September 30, Purchases $ 1,902 — 1,902 1,818 29 1,847 Sales (324 ) (306 ) (630 ) (286 ) (130 ) (416 ) Transfers to MHFS/LHFS (44 ) (1 ) (45 ) (39 ) (7 ) (46 ) Nine months ended September 30, Purchases $ 29,155 — 29,155 12,648 340 12,988 Sales (932 ) (985 ) (1,917 ) (649 ) (160 ) (809 ) Transfers to MHFS/LHFS (145 ) (5 ) (150 ) (91 ) (14 ) (105 ) (1) Purchases include loans and capital leases from the GE Capital business acquisitions as described in Note 2 (Business Combinations). (2) Excludes activity in government insured/guaranteed real estate 1-4 family first mortgage loans. As servicer, we are able to buy delinquent insured/guaranteed loans out of the Government National Mortgage Association (GNMA) pools, and manage and/or resell them in accordance with applicable requirements. These loans are predominantly insured by the Federal Housing Administration (FHA) or guaranteed by the Department of Veterans Affairs (VA). Accordingly, these loans have limited impact on the allowance for loan losses. Commitments to Lend A commitment to lend is a legally binding agreement to lend funds to a customer, usually at a stated interest rate, if funded, and for specific purposes and time periods. We generally require a fee to extend such commitments. Certain commitments are subject to loan agreements with covenants regarding the financial performance of the customer or borrowing base formulas on an ongoing basis that must be met before we are required to fund the commitment. We may reduce or cancel consumer commitments, including home equity lines and credit card lines, in accordance with the contracts and applicable law. We may, as a representative for other lenders, advance funds or provide for the issuance of letters of credit under syndicated loan or letter of credit agreements. Any advances are generally repaid in less than a week and would normally require default of both the customer and another lender to expose us to loss. These temporary advance arrangements totaled approximately $75 billion at both September 30, 2016 and December 31, 2015 . We issue commercial letters of credit to assist customers in purchasing goods or services, typically for international trade. At both September 30, 2016 , and December 31, 2015 , we had $1.1 billion of outstanding issued commercial letters of credit. We also originate multipurpose lending commitments under which borrowers have the option to draw on the facility for different purposes in one of several forms, including a standby letter of credit. See Note 10 (Guarantees, Pledged Assets and Collateral) for additional information on standby letters of credit. When we make commitments, we are exposed to credit risk. The maximum credit risk for these commitments will generally be lower than the contractual amount because a significant portion of these commitments is expected to expire without being used by the customer. In addition, we manage the potential risk in commitments to lend by limiting the total amount of commitments, both by individual customer and in total, by monitoring the size and maturity structure of these commitments and by applying the same credit standards for these commitments as for all of our credit activities. For loans and commitments to lend, we generally require collateral or a guarantee. We may require various types of collateral, including commercial and consumer real estate, automobiles, other short-term liquid assets such as accounts receivable or inventory and long-lived assets, such as equipment and other business assets. Collateral requirements for each loan or commitment may vary based on the loan product and our assessment of a customer’s credit risk according to the specific credit underwriting, including credit terms and structure. The contractual amount of our unfunded credit commitments, including unissued standby and commercial letters of credit, is summarized by portfolio segment and class of financing receivable in Table 5.4 . The table excludes the standby and commercial letters of credit and temporary advance arrangements described above. Table 5.4: Unfunded Credit Commitments (in millions) Sep 30, Dec 31, Commercial: Commercial and industrial $ 309,075 296,710 Real estate mortgage 7,807 7,378 Real estate construction 18,735 18,047 Lease financing 17 — Total commercial 335,634 322,135 Consumer: Real estate 1-4 family first mortgage 39,066 34,621 Real estate 1-4 family junior lien mortgage 41,974 43,309 Credit card 102,252 98,904 Other revolving credit and installment 28,584 27,899 Total consumer 211,876 204,733 Total unfunded credit commitments $ 547,510 526,868 Allowance for Credit Losses Table 5.5 presents the allowance for credit losses, which consists of the allowance for loan losses and the allowance for unfunded credit commitments. Table 5.5: Allowance for Credit Losses Quarter ended September 30, Nine months ended September 30, (in millions) 2016 2015 2016 2015 Balance, beginning of period $ 12,749 12,614 12,512 13,169 Provision for credit losses 805 703 2,965 1,611 Interest income on certain impaired loans (1) (54 ) (48 ) (153 ) (150 ) Loan charge-offs: Commercial: Commercial and industrial (324 ) (172 ) (1,110 ) (459 ) Real estate mortgage (7 ) (9 ) (13 ) (48 ) Real estate construction — — (1 ) (2 ) Lease financing (4 ) (5 ) (25 ) (11 ) Total commercial (335 ) (186 ) (1,149 ) (520 ) Consumer: Real estate 1-4 family first mortgage (106 ) (145 ) (366 ) (394 ) Real estate 1-4 family junior lien mortgage (119 ) (159 ) (385 ) (501 ) Credit card (296 ) (259 ) (930 ) (821 ) Automobile (215 ) (186 ) (602 ) (531 ) Other revolving credit and installment (170 ) (160 ) (508 ) (465 ) Total consumer (906 ) (909 ) (2,791 ) (2,712 ) Total loan charge-offs (1,241 ) (1,095 ) (3,940 ) (3,232 ) Loan recoveries: Commercial: Commercial and industrial 65 50 210 192 Real estate mortgage 35 32 90 97 Real estate construction 18 8 30 25 Lease financing 2 2 10 6 Total commercial 120 92 340 320 Consumer: Real estate 1-4 family first mortgage 86 83 284 182 Real estate 1-4 family junior lien mortgage 70 70 200 195 Credit card 51 43 153 123 Automobile 78 73 248 249 Other revolving credit and installment 31 31 100 102 Total consumer 316 300 985 851 Total loan recoveries 436 392 1,325 1,171 Net loan charge-offs (805 ) (703 ) (2,615 ) (2,061 ) Other (1 ) (4 ) (15 ) (7 ) Balance, end of period $ 12,694 12,562 12,694 12,562 Components: Allowance for loan losses $ 11,583 11,659 11,583 11,659 Allowance for unfunded credit commitments 1,111 903 1,111 903 Allowance for credit losses $ 12,694 12,562 12,694 12,562 Net loan charge-offs (annualized) as a percentage of average total loans 0.33 % 0.31 0.37 0.31 Allowance for loan losses as a percentage of total loans 1.20 1.29 1.20 1.29 Allowance for credit losses as a percentage of total loans 1.32 1.39 1.32 1.39 (1) Certain impaired loans with an allowance calculated by discounting expected cash flows using the loan’s effective interest rate over the remaining life of the loan recognize changes in allowance attributable to the passage of time as interest income. Table 5.6 summarizes the activity in the allowance for credit losses by our commercial and consumer portfolio segments. Table 5.6: Allowance Activity by Portfolio Segment 2016 2015 (in millions) Commercial Consumer Total Commercial Consumer Total Quarter ended September 30, Balance, beginning of period $ 7,441 5,308 12,749 6,279 6,335 12,614 Provision for credit losses 158 647 805 348 355 703 Interest income on certain impaired loans (14 ) (40 ) (54 ) (3 ) (45 ) (48 ) Loan charge-offs (335 ) (906 ) (1,241 ) (186 ) (909 ) (1,095 ) Loan recoveries 120 316 436 92 300 392 Net loan charge-offs (215 ) (590 ) (805 ) (94 ) (609 ) (703 ) Other (1 ) — (1 ) (4 ) — (4 ) Balance, end of period $ 7,369 5,325 12,694 6,526 6,036 12,562 Nine months ended September 30, Balance, beginning of period $ 6,872 5,640 12,512 6,377 6,792 13,169 Provision for credit losses 1,350 1,615 2,965 368 1,243 1,611 Interest income on certain impaired loans (29 ) (124 ) (153 ) (12 ) (138 ) (150 ) Loan charge-offs (1,149 ) (2,791 ) (3,940 ) (520 ) (2,712 ) (3,232 ) Loan recoveries 340 985 1,325 320 851 1,171 Net loan charge-offs (809 ) (1,806 ) (2,615 ) (200 ) (1,861 ) (2,061 ) Other (15 ) — (15 ) (7 ) — (7 ) Balance, end of period $ 7,369 5,325 12,694 6,526 6,036 12,562 Table 5.7 disaggregates our allowance for credit losses and recorded investment in loans by impairment methodology. Table 5.7: Allowance by Impairment Methodology Allowance for credit losses Recorded investment in loans (in millions) Commercial Consumer Total Commercial Consumer Total September 30, 2016 Collectively evaluated (1) $ 6,254 3,531 9,785 489,945 430,259 920,204 Individually evaluated (2) 1,113 1,794 2,907 5,672 17,741 23,413 PCI (3) 2 — 2 837 16,872 17,709 Total $ 7,369 5,325 12,694 496,454 464,872 961,326 December 31, 2015 Collectively evaluated (1) $ 5,999 3,436 9,435 452,063 420,705 872,768 Individually evaluated (2) 872 2,204 3,076 3,808 20,012 23,820 PCI (3) 1 — 1 712 19,259 19,971 Total $ 6,872 5,640 12,512 456,583 459,976 916,559 (1) Represents loans collectively evaluated for impairment in accordance with Accounting Standards Codification (ASC) 450-20, Loss Contingencies (formerly FAS 5), and pursuant to amendments by ASU 2010-20 regarding allowance for non-impaired loans. (2) Represents loans individually evaluated for impairment in accordance with ASC 310-10, Receivables (formerly FAS 114), and pursuant to amendments by ASU 2010-20 regarding allowance for impaired loans. (3) Represents the allowance and related loan carrying value determined in accordance with ASC 310-30 , Receivables – Loans and Debt Securities Acquired with Deteriorated Credit Quality (formerly SOP 03-3) and pursuant to amendments by ASU 2010-20 regarding allowance for PCI loans. Credit Quality We monitor credit quality by evaluating various attributes and utilize such information in our evaluation of the appropriateness of the allowance for credit losses. The following sections provide the credit quality indicators we most closely monitor. The credit quality indicators are generally based on information as of our financial statement date, with the exception of updated Fair Isaac Corporation (FICO) scores and updated loan-to-value (LTV)/combined LTV (CLTV).We obtain FICO scores at loan origination and the scores are generally updated at least quarterly, except in limited circumstances, including compliance with the Fair Credit Reporting Act (FCRA). Generally, the LTV and CLTV indicators are updated in the second month of each quarter, with updates no older than June 30, 2016 . See the “Purchased Credit-Impaired Loans” section in this Note for credit quality information on our PCI portfolio. COMMERCIAL CREDIT QUALITY INDICATORS In addition to monitoring commercial loan concentration risk, we manage a consistent process for assessing commercial loan credit quality. Generally, commercial loans are subject to individual risk assessment using our internal borrower and collateral quality ratings. Our ratings are aligned to Pass and Criticized categories. The Criticized category includes Special Mention, Substandard, and Doubtful categories which are defined by bank regulatory agencies. Table 5.8 provides a breakdown of outstanding commercial loans by risk category. Of the $22.3 billion in criticized commercial and industrial loans and $6.0 billion in criticized commercial real estate (CRE) loans at September 30, 2016 , $3.3 billion and $839 million , respectively, have been placed on nonaccrual status and written down to net realizable collateral value. Table 5.8: Commercial Loans by Risk Category (in millions) Commercial and industrial Real estate mortgage Real estate construction Lease financing Total September 30, 2016 By risk category: Pass $ 301,402 124,350 22,729 17,616 466,097 Criticized 22,251 5,463 551 1,255 29,520 Total commercial loans (excluding PCI) 323,653 129,813 23,280 18,871 495,617 Total commercial PCI loans (carrying value) 367 410 60 — 837 Total commercial loans $ 324,020 130,223 23,340 18,871 496,454 December 31, 2015 By risk category: Pass $ 281,356 115,025 21,546 11,772 429,699 Criticized 18,458 6,593 526 595 26,172 Total commercial loans (excluding PCI) 299,814 121,618 22,072 12,367 455,871 Total commercial PCI loans (carrying value) 78 542 92 — 712 Total commercial loans $ 299,892 122,160 22,164 12,367 456,583 Table 5.9 provides past due information for commercial loans, which we monitor as part of our credit risk management practices. Table 5.9: Commercial Loans by Delinquency Status (in millions) Commercial and industrial Real estate mortgage Real estate construction Lease financing Total September 30, 2016 By delinquency status: Current-29 days past due (DPD) and still accruing $ 319,764 128,888 23,197 18,645 490,494 30-89 DPD and still accruing 511 141 24 134 810 90+ DPD and still accruing 47 4 — — 51 Nonaccrual loans 3,331 780 59 92 4,262 Total commercial loans (excluding PCI) 323,653 129,813 23,280 18,871 495,617 Total commercial PCI loans (carrying value) 367 410 60 — 837 Total commercial loans $ 324,020 130,223 23,340 18,871 496,454 December 31, 2015 By delinquency status: Current-29 DPD and still accruing $ 297,847 120,415 21,920 12,313 452,495 30-89 DPD and still accruing 507 221 82 28 838 90+ DPD and still accruing 97 13 4 — 114 Nonaccrual loans 1,363 969 66 26 2,424 Total commercial loans (excluding PCI) 299,814 121,618 22,072 12,367 455,871 Total commercial PCI loans (carrying value) 78 542 92 — 712 Total commercial loans $ 299,892 122,160 22,164 12,367 456,583 CONSUMER CREDIT QUALITY INDICATORS We have various classes of consumer loans that present unique risks. Loan delinquency, FICO credit scores and LTV for loan types are common credit quality indicators that we monitor and utilize in our evaluation of the appropriateness of the allowance for credit losses for the consumer portfolio segment. Many of our loss estimation techniques used for the allowance for credit losses rely on delinquency-based models; therefore, delinquency is an important indicator of credit quality and the establishment of our allowance for credit losses. Table 5.10 provides the outstanding balances of our consumer portfolio by delinquency status. Table 5.10: Consumer Loans by Delinquency Status (in millions) Real estate 1-4 family first mortgage Real estate 1-4 family junior lien mortgage Credit card Automobile Other revolving credit and installment Total September 30, 2016 By delinquency status: Current-29 DPD $ 237,074 47,094 34,158 61,498 39,821 419,645 30-59 DPD 1,810 288 262 1,032 150 3,542 60-89 DPD 714 147 180 253 113 1,407 90-119 DPD 312 102 151 85 85 735 120-179 DPD 338 112 239 5 24 718 180+ DPD 1,894 320 2 — 20 2,236 Government insured/guaranteed loans (1) 19,717 — — — — 19,717 Total consumer loans (excluding PCI) 261,859 48,063 34,992 62,873 40,213 448,000 Total consumer PCI loans (carrying value) 16,830 42 — — — 16,872 Total consumer loans $ 278,689 48,105 34,992 62,873 40,213 464,872 December 31, 2015 By delinquency status: Current-29 DPD $ 225,195 51,778 33,208 58,503 38,690 407,374 30-59 DPD 2,072 325 257 1,121 175 3,950 60-89 DPD 821 184 177 253 107 1,542 90-119 DPD 402 110 150 84 86 832 120-179 DPD 460 145 246 4 21 876 180+ DPD 3,376 393 1 1 19 3,790 Government insured/guaranteed loans (1) 22,353 — — — — 22,353 Total consumer loans (excluding PCI) 254,679 52,935 34,039 59,966 39,098 440,717 Total consumer PCI loans (carrying value) 19,190 69 — — — 19,259 Total consumer loans $ 273,869 53,004 34,039 59,966 39,098 459,976 (1) Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA. Loans insured/guaranteed by the FHA/VA and 90+ DPD totaled $9.8 billion at September 30, 2016 , compared with $12.4 billion at December 31, 2015 . Of the $3.7 billion of consumer loans not government insured/guaranteed that are 90 days or more past due at September 30, 2016 , $802 million was accruing, compared with $5.5 billion past due and $867 million accruing at December 31, 2015 . Real estate 1-4 family first mortgage loans 180 days or more past due totaled $1.9 billion , or 0.7% of total first mortgages (excluding PCI), at September 30, 2016 , compared with $3.4 billion , or 1.3% , at December 31, 2015 . Table 5.11 provides a breakdown of our consumer portfolio by FICO. Most of the scored consumer portfolio has an updated FICO of 680 and above, reflecting a strong current borrower credit profile. FICO is not available for certain loan types and may not be obtained if we deem it unnecessary due to strong collateral and other borrower attributes, substantially all of which are security-based loans originated through retail brokerage of $7.6 billion at September 30, 2016 , and $7.0 billion at December 31, 2015 . Table 5.11: Consumer Loans by FICO (in millions) Real estate 1-4 family first mortgage Real estate 1-4 family junior lien mortgage Credit card Automobile Other revolving credit and installment Total September 30, 2016 By FICO: < 600 $ 7,177 2,720 3,245 9,919 943 24,004 600-639 5,661 2,017 2,984 6,982 1,052 18,696 640-679 11,334 3,910 5,492 10,447 2,396 33,579 680-719 23,451 6,783 7,124 11,341 4,395 53,094 720-759 38,387 9,864 7,357 8,718 5,997 70,323 760-799 100,971 15,365 5,938 8,159 8,548 138,981 800+ 49,460 6,638 2,776 6,881 6,600 72,355 No FICO available 5,701 766 76 426 2,651 9,620 FICO not required — — — — 7,631 7,631 Government insured/guaranteed loans (1) 19,717 — — — — 19,717 Total consumer loans (excluding PCI) 261,859 48,063 34,992 62,873 40,213 448,000 Total consumer PCI loans (carrying value) 16,830 42 — — — 16,872 Total consumer loans $ 278,689 48,105 34,992 62,873 40,213 464,872 December 31, 2015 By FICO: < 600 $ 8,716 3,025 2,927 9,260 965 24,893 600-639 6,961 2,367 2,875 6,619 1,086 19,908 640-679 13,006 4,613 5,354 10,014 2,416 35,403 680-719 24,460 7,863 6,857 10,947 4,388 54,515 720-759 38,309 10,966 7,017 8,279 6,010 70,581 760-799 92,975 16,369 5,693 7,761 8,351 131,149 800+ 44,452 6,895 3,090 6,654 6,510 67,601 No FICO available 3,447 837 226 432 2,395 7,337 FICO not required — — — — 6,977 6,977 Government insured/guaranteed loans (1) 22,353 — — — — 22,353 Total consumer loans (excluding PCI) 254,679 52,935 34,039 59,966 39,098 440,717 Total consumer PCI loans (carrying value) 19,190 69 — — — 19,259 Total consumer loans $ 273,869 53,004 34,039 59,966 39,098 459,976 (1) Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA. LTV refers to the ratio comparing the loan’s unpaid principal balance to the property’s collateral value. CLTV refers to the combination of first mortgage and junior lien mortgage (including unused line amounts for credit line products) ratios. LTVs and CLTVs are updated quarterly using a cascade approach which first uses values provided by automated valuation models (AVMs) for the property. If an AVM is not available, then the value is estimated using the original appraised value adjusted by the change in Home Price Index (HPI) for the property location. If an HPI is not available, the original appraised value is used. The HPI value is normally the only method considered for high value properties, generally with an original value of $1 million or more, as the AVM values have proven less accurate for these properties. Table 5.12 shows the most updated LTV and CLTV distribution of the real estate 1-4 family first and junior lien mortgage loan portfolios. We consider the trends in residential real estate markets as we monitor credit risk and establish our allowance for credit losses. In the event of a default, any loss should be limited to the portion of the loan amount in excess of the net realizable value of the underlying real estate collateral value. Certain loans do not have an LTV or CLTV due to industry data availability and portfolios acquired from or serviced by other institutions. Table 5.12: Consumer Loans by LTV/CLTV September 30, 2016 December 31, 2015 (in millions) Real estate 1-4 family first mortgage by LTV Real estate 1-4 family junior lien mortgage by CLTV Total Real estate 1-4 family first mortgage by LTV Real estate 1-4 family junior lien mortgage by CLTV Total By LTV/CLTV: 0-60% $ 119,444 16,499 135,943 109,558 15,805 125,363 60.01-80% 100,450 15,571 116,021 92,005 16,579 108,584 80.01-100% 16,509 9,381 25,890 22,765 11,385 34,150 100.01-120% (1) 3,015 4,055 7,070 4,480 5,545 10,025 > 120% (1) 1,385 2,041 3,426 2,065 3,051 5,116 No LTV/CLTV available 1,339 516 1,855 1,453 570 2,023 Government insured/guaranteed loans (2) 19,717 — 19,717 22,353 — 22,353 Total consumer loans (excluding PCI) 261,859 48,063 309,922 254,679 52,935 307,614 Total consumer PCI loans (carrying value) 16,830 42 16,872 19,190 69 19,259 Total consumer loans $ 278,689 48,105 326,794 273,869 53,004 326,873 (1) Reflects total loan balances with LTV/CLTV amounts in excess of 100%. In the event of default, the loss content would generally be limited to only the amount in excess of 100% LTV/CLTV. (2) Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA. NONACCRUAL LOANS Table 5.13 provides loans on nonaccrual status. PCI loans are excluded from this table because they continue to earn interest from accretable yield, independent of performance in accordance with their contractual terms. Table 5.13: Nonaccrual Loans (in millions) Sep 30, Dec 31, Commercial: Commercial and industrial $ 3,331 1,363 Real estate mortgage 780 969 Real estate construction 59 66 Lease financing 92 26 Total commercial 4,262 2,424 Consumer: Real estate 1-4 family first mortgage (1) 5,310 7,293 Real estate 1-4 family junior lien mortgage 1,259 1,495 Automobile 108 121 Other revolving credit and installment 47 49 Total consumer 6,724 8,958 Total nonaccrual loans (excluding PCI) $ 10,986 11,382 (1) Includes MHFS of $150 million and $177 million at September 30, 2016 , and December 31, 2015 , respectively. LOANS IN PROCESS OF FORECLOSURE Our recorded investment in consumer mortgage loans collateralized by residential real estate property that are in process of foreclosure was $8.5 billion and $11.0 billion at September 30, 2016 and December 31, 2015 , respectively, which included $5.0 billion and $6.2 billion , respectively, of loans that are government insured/guaranteed. We commence the foreclosure process on consumer real estate loans when a borrower becomes 120 days delinquent in accordance with Consumer Finance Protection Bureau Guidelines. Foreclosure procedures and timelines vary depending on whether the property address resides in a judicial or non-judicial state. Judicial states require the foreclosure to be processed through the state’s courts while non-judicial states are processed without court intervention. Foreclosure timelines vary according to state law. LOANS 90 DAYS OR MORE PAST DUE AND STILL ACCRUING Certain loans 90 days or more past due as to interest or principal are still accruing, because they are (1) well-secured and in the process of collection or (2) real estate 1-4 family mortgage loans or consumer loans exempt under regulatory rules from being classified as nonaccrual until later delinquency, usually 120 days past due. PCI loans of $2.2 billion at September 30, 2016 , and $2.9 billion at December 31, 2015 , are not included in these past due and still accruing loans even though they are 90 days or more contractually past due. These PCI loans are considered to be accruing because they continue to earn interest from accretable yield, independent of performance in accordance with their contractual terms. Table 5.14 shows non-PCI loans 90 days or more past due and still accruing by class for loans not government insured/guaranteed. Table 5.14: Loans 90 Days or More Past Due and Still Accruing (in millions) Sep 30, 2016 Dec 31, 2015 Total (excluding PCI): $ 12,068 14,380 Less: FHA insured/guaranteed by the VA (1)(2) 11,198 13,373 Less: Student loans guaranteed under the FFELP (3) 17 26 Total, not government insured/guaranteed $ 853 981 By segment and class, not government insured/guaranteed: Commercial: Commercial and industrial $ 47 97 Real estate mortgage 4 13 Real estate construction — 4 Total commercial 51 114 Consumer: Real estate 1-4 family first mortgage (2) 171 224 Real estate 1-4 family junior lien mortgage (2) 54 65 Credit card 392 397 Automobile 81 79 Other revolving credit and installment 104 102 Total consumer 802 867 Total, not government insured/guaranteed $ 853 981 (1) Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA. (2) Includes mortgages held for sale 90 days or more past due and still accruing. (3) Represents loans whose repayments are predominantly guaranteed by agencies on behalf of the U.S. Department of Education under the FFELP. IMPAIRED LOANS Table 5.15 summarizes key information for impaired loans. Our impaired loans predominantly include loans on nonaccrual status in the commercial portfolio segment and loans modified in a TDR, whether on accrual or nonaccrual status. These impaired loans generally have estimated losses which are included in the allowance for credit losses. We have impaired loans with no allowance for credit losses when loss content has been previously recognized through charge-offs and we do not anticipate additional charge-offs or losses, or certain loans are currently performing in accordance with their terms and for which no loss has been estimated. Impaired loans exclude PCI loans. Table 5.15 includes trial modifications that totaled $348 million at September 30, 2016 , and $402 million at December 31, 2015 . For additional information on our impaired loans and allowance for credit losses, see Note 1 (Summary of Significant Accounting Policies) in our 2015 Form 10-K. Table 5.15: Impaired Loans Summary Recorded investment (in millions) Unpaid principal balance (1) Impaired loans Impaired loans with related allowance for credit losses Related allowance for credit losses September 30, 2016 Commercial: Commercial and industrial $ 5,054 3,885 3,444 780 Real estate mortgage 1,996 1,588 1,566 292 Real estate construction 186 103 103 23 Lease financing 119 96 96 18 Total commercial 7,355 5,672 5,209 1,113 Consumer: Real estate 1-4 family first mortgage 17,189 15,028 9,898 1,328 Real estate 1-4 family junior lien mortgage 2,486 2,236 1,645 344 Credit card 294 294 294 100 Automobile 156 89 32 5 Other revolving credit and installment 101 94 84 17 Total consumer (2) 20,226 17,741 11,953 1,794 Total impaired loans (excluding PCI) $ 27,581 23,413 17,162 2,907 December 31, 2015 Commercial: Commercial and industrial $ 2,746 1,835 1,648 435 Real estate mortgage 2,369 1,815 1,773 405 Real estate construction 262 131 112 23 Lease financing 38 27 27 9 Total commercial 5,415 3,808 3,560 872 Consumer: Real estate 1-4 family first mortgage 19,626 17,121 11,057 1,643 Real estate 1-4 family junior lien mortgage 2,704 2,408 1,859 447 Credit card 299 299 299 94 Automobile 173 105 41 5 Other revolving credit and installment 86 79 71 15 Total consumer (2) 22,888 20,012 13,327 2,204 Total impaired loans (excluding PCI) $ 28,303 23,820 16,887 3,076 (1) Excludes the unpaid principal balance for loans that have been fully charged off or otherwise have zero recorded investment. (2) Includes the recorded investment of $1.6 billion and 1.8 billion at September 30, 2016 , and December 31, 2015 , respectively, of government insured/guaranteed loans that are predominantly insured by the FHA or guaranteed by the VA and generally do not have an allowance. Impaired loans may also have limited, if any, allowance when the recorded investment of the loan approximates estimated net realizable value as a result of charge-offs prior to a TDR modification. Commitments to lend additional funds on loans whose terms have been modified in a TDR amounted to $440 million and $363 million at September 30, 2016 and December 31, 2015 , respectively. Table 5.16 provides the average recorded investment in impaired loans and the amount of interest income recognized on impaired loans by portfolio segment and class. Table 5.16: Average Recorded Investment in Impaired Loans Quarter ended September 30, Nine months ended September 30, 2016 2015 2016 2015 (in millions) Average recorded investment Recognized interest income Average recorded investment Recognized interest income Average recorded investment Recognized interest income Average recorded investment Recognized interest income Commercial: Commercial and industrial $ 3,961 25 1,407 21 3,350 65 1,108 64 Real estate mortgage 1,644 33 2,109 34 1,699 99 2,241 108 Real estate construction 108 3 232 7 117 8 260 22 Lease financing 99 — 27 — 89 — 24 — Total commercial 5,812 61 3,775 62 5,255 172 3,633 194 Consumer: Real estate 1-4 family first mortgage 15,471 203 17,761 231 16,224 635 18,125 697 Real estate 1-4 family junior lien mortgage 2,268 32 2,467 34 2,327 99 2,499 103 Credit card 292 9 310 10 294 26 321 30 Automobile 90 3 111 3 95 9 118 11 Other revolving credit and installment 91 2 61 1 84 5 57 3 Total consumer 18,212 249 20,710 279 19,024 774 21,120 844 Total impaired loans (excluding PCI) $ 24,024 310 24,485 341 24,279 946 24,753 1,038 Interest income: Cash basis of accounting $ 87 104 274 323 Other (1) 223 237 672 715 Total interest income $ 310 341 946 1,038 (1) Includes interest recognized on accruing TDRs, interest recognized related to certain impaired loans which have an allowance calculated using discounting, and amortization of purchase accounting adjustments related to certain impaired loans. TROUBLED DEBT RESTRUCTURINGS (TDRs) When, for economic or legal reasons related to a borrower’s financial difficulties, we grant a concession for other than an insignificant period of time to a borrower that we would not otherwise consider, the related loan is classified as a TDR, the balance of which totaled $21.5 billion and $22.7 billion at September 30, 2016 and December 31, 2015 , respectively. We do not consider any loans modified through a loan resolution such as foreclosure or short sale to be a TDR. We may require some consumer borrowers experiencing financial difficulty to make trial payments generally for a period |