Loans and Related Allowance for Credit Losses | Note 6: Loans and Related Allowance for Credit Losses Table 6.1 presents total loans outstanding by portfolio segment and class of financing receivable. Outstanding balances include unearned income, net deferred loan fees or costs, and unamortized discounts and premiums. These amounts were less than 1% of our total loans outstanding at March 31, 2020 , and December 31, 2019 . Outstanding balances exclude accrued interest receivable on loans which are included in other assets. During the quarter ended March 31, 2020 , we reversed accrued interest receivable by reversing interest income of $9 million for our commercial portfolio segment and $63 million for our consumer portfolio segment. See Note 9 (Other Assets) for additional information on accrued interest receivable. Table 6.1: Loans Outstanding (in millions) Mar 31, Dec 31, Commercial: Commercial and industrial $ 405,020 354,125 Real estate mortgage 122,767 121,824 Real estate construction 20,812 19,939 Lease financing 19,136 19,831 Total commercial 567,735 515,719 Consumer: Real estate 1-4 family first mortgage 292,920 293,847 Real estate 1-4 family junior lien mortgage 28,527 29,509 Credit card 38,582 41,013 Automobile 48,568 47,873 Other revolving credit and installment 33,511 34,304 Total consumer 442,108 446,546 Total loans $ 1,009,843 962,265 Our non-U.S. loans are reported by respective class of financing receivable in the table above. Substantially all of our non-U.S. loan portfolio is commercial loans. Table 6.2 presents total non-U.S. commercial loans outstanding by class of financing receivable. Table 6.2: Non-U.S. Commercial Loans Outstanding (in millions) Mar 31, Dec 31, Non-U.S. Commercial Loans Commercial and industrial $ 78,753 70,494 Real estate mortgage 6,309 7,004 Real estate construction 1,478 1,434 Lease financing 1,120 1,220 Total non-U.S. commercial loans $ 87,660 80,152 Loan Purchases, Sales, and Transfers Table 6.3 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. The table excludes loans for which we have elected the fair value option and government insured/guaranteed real estate 1-4 family first mortgage loans because their loan activity normally does not impact the ACL. In first quarter 2020, we sold $709 million of 1-4 family first mortgage loans for a gain of $463 million , which is included in other noninterest income on our consolidated income statement. These whole loans were reclassified to MLHFS in 2019. Table 6.3: Loan Purchases, Sales, and Transfers 2020 2019 (in millions) Commercial Consumer Total Commercial Consumer Total Quarter ended March 31, Purchases $ 341 1 342 329 3 332 Sales (813 ) (26 ) (839 ) (421 ) (179 ) (600 ) Transfers (to) from MLHFS/LHFS 77 2 79 (3 ) — (3 ) 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. The unfunded amount of these temporary advance arrangements totaled approximately $72.7 billion at March 31, 2020 . We issue commercial letters of credit to assist customers in purchasing goods or services, typically for international trade. At March 31, 2020 , and December 31, 2019 , we had $981.3 million and $862 million , respectively, 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 13 (Guarantees, Pledged Assets and Collateral, and Other Commitments) 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 are not funded. 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 6.4 . The table excludes the issued standby and commercial letters of credit and temporary advance arrangements described above. Table 6.4: Unfunded Credit Commitments (in millions) Mar 31, Dec 31, Commercial: Commercial and industrial $ 314,135 346,991 Real estate mortgage 9,360 8,206 Real estate construction 17,236 17,729 Total commercial 340,731 372,926 Consumer: Real estate 1-4 family first mortgage 42,691 34,391 Real estate 1-4 family junior lien mortgage 36,301 36,916 Credit card 118,339 114,933 Other revolving credit and installment 25,187 25,898 Total consumer 222,518 212,138 Total unfunded credit commitments $ 563,249 585,064 Allowance for Credit Losses for Loans Table 6.5 presents the allowance for credit losses for loans, which consists of the allowance for loan losses and the allowance for unfunded credit commitments. On January 1, 2020, we adopted CECL. Additional information on our adoption of CECL is included in Note 1 (Summary of Significant Accounting Policies). In first quarter 2020, after the adoption of CECL, we added a net $2.9 billion to our ACL for loans predominantly driven by the expected impacts from the COVID-19 pandemic. These expected impacts were most significantly affected by anticipated changes to economic variables, as well as higher expected losses from certain industries in our commercial portfolio segment that we expect to be directly and most adversely affected by the COVID-19 pandemic. In addition, the increase included expected impacts on oil and gas loans due to lower oil prices and deteriorating credit trends. Table 6.5: Allowance for Credit Losses for Loans Quarter ended March 31, (in millions) 2020 2019 Balance, beginning of period 10,456 10,707 Cumulative effect from change in accounting policies (1) (1,337 ) — Allowance for purchased credit-deteriorated (PCD) loans (2) 8 — Balance, beginning of period, adjusted 9,127 10,707 Provision for credit losses 3,833 845 Interest income on certain loans (3) (38 ) (39 ) Loan charge-offs: Commercial: Commercial and industrial (377 ) (176 ) Real estate mortgage (3 ) (12 ) Real estate construction — (1 ) Lease financing (13 ) (11 ) Total commercial (393 ) (200 ) Consumer: Real estate 1-4 family first mortgage (23 ) (43 ) Real estate 1-4 family junior lien mortgage (30 ) (34 ) Credit card (471 ) (437 ) Automobile (156 ) (187 ) Other revolving credit and installment (165 ) (162 ) Total consumer (845 ) (863 ) Total loan charge-offs (1,238 ) (1,063 ) Loan recoveries: Commercial: Commercial and industrial 44 43 Real estate mortgage 5 6 Real estate construction 16 3 Lease financing 4 3 Total commercial 69 55 Consumer: Real estate 1-4 family first mortgage 26 55 Real estate 1-4 family junior lien mortgage 35 43 Credit card 94 85 Automobile 74 96 Other revolving credit and installment 31 34 Total consumer 260 313 Total loan recoveries 329 368 Net loan charge-offs (909 ) (695 ) Other 9 3 Balance, end of period 12,022 10,821 Components: Allowance for loan losses 11,263 9,900 Allowance for unfunded credit commitments 759 921 Allowance for credit losses for loans 12,022 10,821 Net loan charge-offs (annualized) as a percentage of average total loans 0.38 0.30 Allowance for loan losses as a percentage of total loans 1.12 1.04 Allowance for credit losses for loans as a percentage of total loans 1.19 1.14 (1) Represents the overall decrease in our allowance for credit losses for loans as a result of our adoption of CECL on January 1, 2020. (2) Represents the allowance estimated for PCI loans that automatically became PCD loans with the adoption of CECL. For more information, see Note 1 (Summary of Significant Accounting Policies). (3) Loans with an allowance measured 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 6.6 summarizes the activity in the allowance for credit losses for loans by our commercial and consumer portfolio segments. Table 6.6: Allowance for Credit Losses for Loans Activity by Portfolio Segment 2020 2019 (in millions) Commercial Consumer Total Commercial Consumer Total Quarter ended March 31, Balance, beginning of period $ 6,245 4,211 10,456 6,417 4,290 10,707 Cumulative effect from change in accounting policies (1) (2,861 ) 1,524 (1,337 ) — — — Allowance for purchased credit-deteriorated (PCD) loans (2) — 8 8 — — — Balance, beginning of period, adjusted 3,384 5,743 9,127 6,417 4,290 10,707 Provision for credit losses 2,240 1,593 3,833 164 681 845 Interest income on certain loans (3) (14 ) (24 ) (38 ) (11 ) (28 ) (39 ) Loan charge-offs (393 ) (845 ) (1,238 ) (200 ) (863 ) (1,063 ) Loan recoveries 69 260 329 55 313 368 Net loan charge-offs (324 ) (585 ) (909 ) (145 ) (550 ) (695 ) Other (7 ) 16 9 3 — 3 Balance, end of period $ 5,279 $ 6,743 $ 12,022 $ 6,428 $ 4,393 $ 10,821 (1) Represents the overall decrease in our allowance for credit losses for loans as a result of our adoption of CECL on January 1, 2020. (2) Represents the allowance estimated for PCI loans that automatically became PCD loans with the adoption of CECL. For more information, see Note 1 (Summary of Significant Accounting Policies). (3) Loans with an allowance measured 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 6.7 disaggregates our allowance for credit losses for loans and recorded investment in loans by impairment methodology. This is no longer relevant after December 31, 2019, given our adoption of CECL on January 1, 2020, which has a single impairment methodology. Table 6.7: Allowance for Credit Losses for Loans by Impairment Methodology Allowance for credit losses for loans Recorded investment in loans (in millions) Commercial Consumer Total Commercial Consumer Total December 31, 2019 Collectively evaluated (1) $ 5,778 3,364 9,142 512,586 436,081 948,667 Individually evaluated (2) 467 847 1,314 3,133 9,897 13,030 PCI (3) — — — — 568 568 Total $ 6,245 4,211 10,456 515,719 446,546 962,265 (1) Represents non-impaired loans evaluated collectively for impairment. (2) Represents impaired loans evaluated individually for impairment. (3) Represents the allowance for loan losses and related loan carrying value 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 December 31, 2019 . Amounts disclosed in the credit quality tables that follow are not comparative between reported periods due to our adoption of CECL on January 1, 2020. For more information, see Note 1 (Summary of Significant Accounting Policies). COMMERCIAL CREDIT QUALITY INDICATORS 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, which is our primary credit quality indicator. Our ratings are aligned to federal banking regulators’ definitions of pass and criticized categories with the criticized category including special mention, substandard, doubtful, and loss categories. Table 6.8 provides a breakdown of outstanding commercial loans by risk category. In connection with our adoption of CECL, credit quality information is provided with the year of origination for term loans. Revolving loans may convert to term loans as a result of a contractual provision in the original loan agreement or if modified in a TDR. Table 6.8: Commercial Loans Categories by Risk Categories and Vintage (1) Term loans by origination year Revolving loans Revolving loans converted to term loans Total (in millions) 2020 2019 2018 2017 2016 Prior March 31, 2020 Commercial and industrial Pass $ 32,531 53,904 23,788 11,603 7,815 5,061 250,893 209 385,804 Criticized 885 1,053 948 721 433 458 14,718 — 19,216 Total commercial and industrial 33,416 54,957 24,736 12,324 8,248 5,519 265,611 209 405,020 Real estate mortgage Pass 7,336 31,320 23,268 14,577 15,376 21,087 5,563 128 118,655 Criticized 60 452 515 741 546 1,525 273 — 4,112 Total real estate mortgage 7,396 31,772 23,783 15,318 15,922 22,612 5,836 128 122,767 Real estate construction Pass 1,293 7,226 5,528 3,024 1,290 472 1,750 7 20,590 Criticized 2 98 93 6 8 14 1 — 222 Total real estate construction 1,295 7,324 5,621 3,030 1,298 486 1,751 7 20,812 Lease financing Pass 1,439 5,566 3,769 2,447 1,844 2,739 — — 17,804 Criticized 83 422 365 196 139 127 — — 1,332 Total lease financing 1,522 5,988 4,134 2,643 1,983 2,866 — — 19,136 Total commercial loans $ 43,629 100,041 58,274 33,315 27,451 31,483 273,198 344 567,735 Commercial Real Real Lease Total December 31, 2019 By risk category: Pass $ 338,740 118,054 19,752 18,655 495,201 Criticized 15,385 3,770 187 1,176 20,518 Total commercial loans $ 354,125 121,824 19,939 19,831 515,719 (1) Disclosure is not comparative due to our adoption of CECL on January 1, 2020. For more information, see Note 1 (Summary of Significant Accounting Policies). Table 6.9 provides past due information for commercial loans, which we monitor as part of our credit risk management practices; however, delinquency is not a primary credit quality indicator for commercial loans. Table 6.9: Commercial Loan Categories by Delinquency Status (in millions) Commercial and industrial Real estate mortgage Real estate construction Lease financing Total March 31, 2020 By delinquency status: Current-29 days past due (DPD) and still accruing $ 402,706 121,621 20,696 18,793 563,816 30-89 DPD and still accruing 511 174 94 212 991 90+ DPD and still accruing 24 28 1 — 53 Nonaccrual loans 1,779 944 21 131 2,875 Total commercial loans $ 405,020 122,767 20,812 19,136 567,735 December 31, 2019 By delinquency status: Current-29 DPD and still accruing $ 352,110 120,967 19,845 19,484 512,406 30-89 DPD and still accruing 423 253 53 252 981 90+ DPD and still accruing 47 31 — — 78 Nonaccrual loans 1,545 573 41 95 2,254 Total commercial loans $ 354,125 121,824 19,939 19,831 515,719 CONSUMER CREDIT QUALITY INDICATORS We have various classes of consumer loans that present unique credit risks. Loan delinquency, FICO credit scores and LTV for 1-4 family mortgage loans are the primary 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 6.10 provides the outstanding balances of our consumer portfolio by delinquency status. In connection with our adoption of CECL, credit quality information is provided with the year of origination for term loans. Revolving loans may convert to term loans as a result of a contractual provision in the original loan agreement or if modified in a TDR. The revolving loans converted to term loans in the credit card loan category represent credit card loans with modified terms that require payment over a specific term. Table 6.10: Consumer Loan Categories by Delinquency Status and Vintage (1) Term loans by origination year Revolving loans Revolving loans converted to term loans (in millions) 2020 2019 2018 2017 2016 Prior Total March 31, 2020 Real estate 1-4 family first mortgage By delinquency status: Current-29 DPD $ 14,238 59,044 25,047 36,185 41,121 93,490 7,981 2,020 279,126 30-59 DPD 14 65 30 39 64 1,184 38 57 1,491 60-89 DPD 2 3 6 5 8 370 20 27 441 90-119 DPD — — 3 — 6 190 8 17 224 120-179 DPD — — 1 4 7 142 11 22 187 180+ DPD — — 4 7 5 466 5 125 612 Government insured/guaranteed loans (2) 2 32 150 271 498 9,726 — — 10,679 Loans held at fair value — — — — — 160 — — 160 Total real estate 1-4 family first mortgage 14,256 59,144 25,241 36,511 41,709 105,728 8,063 2,268 292,920 Real estate 1-4 family junior mortgage By delinquency status: Current-29 DPD 8 44 51 48 39 1,491 19,178 7,058 27,917 30-59 DPD — — — — — 34 76 119 229 60-89 DPD — — — 1 1 15 28 58 103 90-119 DPD — — — — — 8 19 32 59 120-179 DPD — — — — — 6 17 44 67 180+ DPD — — — — 1 16 10 125 152 Total real estate 1-4 family junior mortgage 8 44 51 49 41 1,570 19,328 7,436 28,527 Credit cards By delinquency status: Current-29 DPD — — — — — — 37,320 259 37,579 30-59 DPD — — — — — — 260 18 278 60-89 DPD — — — — — — 184 13 197 90-119 DPD — — — — — — 167 14 181 120-179 DPD — — — — — — 335 10 345 180+ DPD — — — — — — 2 — 2 Total credit cards — — — — — — 38,268 314 38,582 Automobile By delinquency status: Current-29 DPD 6,334 19,682 9,085 5,509 4,857 2,145 — — 47,612 30-59 DPD 8 158 134 111 168 104 — — 683 60-89 DPD — 49 40 32 53 34 — — 208 90-119 DPD — 18 13 9 15 10 — — 65 120-179 DPD — — — — — — — — — 180+ DPD — — — — — — — — — Total automobile 6,342 19,907 9,272 5,661 5,093 2,293 — — 48,568 Other revolving credit and installment By delinquency status: Current-29 DPD 948 3,580 2,207 1,468 1,298 5,751 17,766 202 33,220 30-59 DPD 1 9 10 12 9 66 19 7 133 60-89 DPD — 5 6 5 5 32 9 4 66 90-119 DPD — 4 6 6 6 31 9 3 65 120-179 DPD — — — — — — 15 2 17 180+ DPD — — — — — 1 2 7 10 Total other revolving credit and installment 949 3,598 2,229 1,491 1,318 5,881 17,820 225 33,511 Total consumer loans $ 21,555 82,693 36,793 43,712 48,161 115,472 83,479 10,243 442,108 (continued on following page) (continued from previous page) Real estate 1-4 family first mortgage Real estate 1-4 family junior lien mortgage Credit card Automobile Other revolving credit and installment Total December 31, 2019 By delinquency status: Current-29 DPD $ 279,722 28,870 39,935 46,650 33,981 429,158 30-59 DPD 1,136 216 311 882 140 2,685 60-89 DPD 404 115 221 263 81 1,084 90-119 DPD 197 69 202 77 74 619 120-179 DPD 160 71 343 1 18 593 180+ DPD 503 155 1 — 10 669 Government insured/guaranteed loans (2) 10,999 — — — — 10,999 Loans held at fair value 171 — — — — 171 Total consumer loans (excluding PCI) 293,292 29,496 41,013 47,873 34,304 445,978 Total consumer PCI loans (carrying value) (3) 555 13 — — — 568 Total consumer loans $ 293,847 29,509 41,013 47,873 34,304 446,546 (1) Disclosure is not comparative due to our adoption of CECL on January 1, 2020. For more information, see Note 1 (Summary of Significant Accounting Policies). (2) Represents loans whose repayments are predominantly insured by the Federal Housing Administration (FHA) or guaranteed by the Department of Veterans Affairs (VA). Loans insured/guaranteed by the FHA/VA and 90+ DPD totaled $6.1 billion at March 31, 2020 , compared with $6.4 billion at December 31, 2019 . (3) 26% of the adjusted unpaid principal balance for consumer PCI loans was 30+ DPD at December 31, 2019 . Of the $2.0 billion of consumer loans not government insured/guaranteed that are 90 days or more past due at March 31, 2020 , $828 million was accruing, compared with $1.9 billion past due and $855 million accruing at December 31, 2019 . Table 6.11 provides a breakdown of our consumer portfolio by FICO. Substantially all 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, or may not be required if we deem it unnecessary due to strong collateral and other borrower attributes. Loans not requiring a FICO score totaled $8.9 billion and $9.1 billion at March 31, 2020 and December 31, 2019 , respectively. Substantially all loans not requiring a FICO score are securities-based loans originated through retail brokerage. Table 6.11: Consumer Loan Categories by FICO and Vintage (1) Term loans by origination year Revolving loans Revolving loans converted to term loans (in millions) 2020 2019 2018 2017 2016 Prior Total March 31, 2020 By FICO: Real estate 1-4 family first mortgage < 600 $ 2 27 43 60 92 2,643 209 229 3,305 600-639 10 105 67 68 128 1,663 148 115 2,304 640-679 80 481 297 311 368 3,075 298 171 5,081 680-719 458 1,870 905 1,181 1,301 5,847 665 264 12,491 720-759 1,896 6,104 2,198 2,901 3,147 9,491 1,024 291 27,052 760-799 6,242 16,885 5,542 7,135 7,458 15,595 1,609 298 60,764 800+ 5,522 33,344 15,917 24,461 28,544 55,278 3,824 512 167,402 No FICO available 45 296 122 123 173 2,249 286 388 3,682 Government insured/guaranteed loans (2) 1 32 150 271 498 9,887 — — 10,839 Total real estate 1-4 family first mortgage 14,256 59,144 25,241 36,511 41,709 105,728 8,063 2,268 292,920 Real estate 1-4 family junior lien mortgage < 600 — — — — — 133 370 611 1,114 600-639 — — — — — 82 310 361 753 640-679 — — — — — 134 686 610 1,430 680-719 — — — — — 250 1,697 1,102 3,049 720-759 — — — — — 274 2,751 1,243 4,268 760-799 — — — — — 228 3,785 1,198 5,211 800+ — — — — — 359 9,220 2,009 11,588 No FICO available 8 44 51 49 41 110 509 302 1,114 Total real estate 1-4 family junior lien mortgage 8 44 51 49 41 1,570 19,328 7,436 28,527 Credit Card < 600 — — — — — — 3,117 119 3,236 600-639 — — — — — — 2,657 49 2,706 640-679 — — — — — — 6,291 61 6,352 680-719 — — — — — — 9,324 53 9,377 720-759 — — — — — — 7,866 24 7,890 760-799 — — — — — — 5,176 6 5,182 800+ — — — — — — 3,678 1 3,679 No FICO available — — — — — — 159 1 160 Total credit card — — — — — — 38,268 314 38,582 Automobile < 600 419 2,045 1,163 825 1,082 541 — — 6,075 600-639 687 1,849 715 425 453 216 — — 4,345 640-679 1,031 2,830 1,168 644 596 262 — — 6,531 680-719 1,104 3,383 1,549 885 749 318 — — 7,988 720-759 1,045 3,334 1,554 911 723 312 — — 7,879 760-799 991 3,335 1,533 890 652 270 — — 7,671 800+ 1,065 3,112 1,580 1,064 808 349 — — 7,978 No FICO available — 19 10 17 30 25 — — 101 Total automobile 6,342 19,907 9,272 5,661 5,093 2,293 — — 48,568 Other revolving credit and installment < 600 3 49 65 50 47 204 219 27 664 600-639 12 66 59 40 41 198 188 15 619 640-679 51 226 169 105 96 410 525 23 1,605 680-719 124 472 310 195 172 719 1,005 29 3,026 720-759 191 683 399 248 226 969 1,169 28 3,913 760-799 249 857 445 288 265 1,179 1,524 18 4,825 800+ 274 1,024 621 452 453 2,118 2,690 44 7,676 No FICO available 45 221 161 113 18 84 1,564 41 2,247 FICO not required — — — — — — 8,936 — 8,936 Total other revolving credit and installment 949 3,598 2,229 1,491 1,318 5,881 17,820 225 33,511 Total consumer loans $ 21,555 82,693 36,793 43,712 48,161 115,472 83,479 10,243 442,108 (continued on next page) (continued from prior page) Real estate Real estate Credit Automobile Other Total December 31, 2019 By FICO: < 600 $ 3,264 1,164 3,373 6,041 704 14,546 600-639 2,392 782 2,853 4,230 670 10,927 640-679 5,068 1,499 6,626 6,324 1,730 21,247 680-719 12,844 3,192 9,732 7,871 3,212 36,851 720-759 27,879 4,407 8,376 7,839 4,097 52,598 760-799 61,559 5,483 5,648 7,624 4,915 85,229 800+ 165,460 11,851 4,037 7,900 7,585 196,833 No FICO available 3,656 1,118 368 44 2,316 7,502 FICO not required — — — — 9,075 9,075 Government insured/guaranteed loans (2) 11,170 — — — — 11,170 Total consumer loans (excluding PCI) 293,292 29,496 41,013 47,873 34,304 445,978 Total consumer PCI loans (carrying value) (3) 555 13 — — — 568 Total consumer loans $ 293,847 29,509 41,013 47,873 34,304 446,546 (1) Disclosure is not comparative due to our adoption of CECL on January 1, 2020. For more information, see Note 1 (Summary of Significant Accounting Policies). (2) Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA. (3) 41% of the adjusted unpaid principal balance for consumer PCI loans had FICO scores less than 680 and 19% where no FICO was available to us at December 31, 2019 . 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 6.12 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 6.12: Consumer Loan Categories by LTV/CLTV and Vintage (1) Term loans by origination year Revolving loans Revolving loans converted to term loans (in millions) 2020 2019 2018 2017 2016 Prior Total March 31, 2020 Real estate 1-4 family first mortgage By LTV/CLTV: 0-60% $ 4,143 16,842 8,032 14,961 22,878 76,122 5,503 1,644 150,125 60.01-80% 9,526 34,239 14,133 19,674 17,326 17,228 1,672 401 114,199 80.01-100% 544 7,791 2,714 1,412 814 1,757 585 155 15,772 100.01-120% (2) — 80 96 86 72 310 169 39 852 > 120% (2) — 47 29 27 29 124 71 14 341 No LTV/CLTV available 42 113 87 80 92 300 63 15 792 Government insured/guaranteed loans (3) 1 32 150 271 498 9,887 — — 10,839 Total real estate 1-4 family first mortgage 14,256 59,144 25,241 36,511 41,709 105,728 8,063 2,268 292,920 Real estate 1-4 family junior lien mortgage By LTV/CLTV: 0-60% — — — — — 634 9,526 4,023 14,183 60.01-80% — — — — — 450 6,827 2,055 9,332 80.01-100% — — — — — 290 2,165 971 3,426 100.01-120% (2) — — — — — 102 566 262 930 > 120% (2) — — — — — 33 216 80 329 No LTV/CLTV available 8 44 51 49 41 61 28 45 327 Total real estate 1-4 family junior lien mortgage 8 44 51 49 41 1,570 19,328 7,436 28,527 Total $ 14,264 59,188 25,292 36,560 41,750 107,298 27,391 9,704 321,447 December 31, 2019 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% $ 151,478 14,603 166,081 60.01-80% 114,795 9,663 124,458 80.01-100% 13,867 3,574 17,441 100.01-120% (2) 860 978 1,838 > 120% (2) 338 336 674 No LTV/CLTV available 784 342 1,126 Government insured/guaranteed loans (3) 11,170 — 11,170 Total consumer loans (excluding PCI) 293,292 29,496 322,788 Total consumer PCI loans (carrying value) (4) 555 13 568 Total consumer loans $ 293,847 29,509 323,356 (1) Disclosure is not comparative due to our adoption of CECL on January 1, 2020. For more information, see Note 1 (Summary of Significant Accounting Policies). (2) 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. (3) Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA. (4) 9% of the adjusted unpaid principal balance for consumer PCI loans have LTV/CLTV amounts greater than 80% at December 31, 2019 . NONACCRUAL LOANS Table 6.13 provides loans on nonaccrual status. In connection with our adoption of CECL, nonaccrual loans may have an allowance for credit losses or a negative allowance for credit losses from expected recoveries of amounts previously written off. Table 6.13: Nonaccrual Loans (1) Amortized cost (in millions) Nonaccrual loans Nonaccrual loans without related allowance for credit losses (2) Recognized interest income March 31, 2020 Commercial: Commercial and industrial $ 1,779 243 16 Real estate mortgage 944 194 8 Real estate construction 21 5 4 Lease financing 131 10 — Total commercial 2,875 452 28 Consumer: Real estate 1-4 family first mortgage 2,372 1,382 44 Real estate 1-4 family junior lien mortgage 769 431 16 Automobile 99 — 3 Other revolving credit and installment 41 — 1 Total consumer 3,281 1,813 64 Total nonaccrual loans $ 6,156 2,265 92 December 31, 2019 Commercial: Commercial and industrial $ 1,545 Real estate mortgage 573 Real estate construction 41 Lease financing 95 Total commercial 2,254 Consumer: Real estate 1-4 family first mortgage 2,150 Real estate 1-4 family junior lien mortgage 796 Automobile 106 Other revolving credit and installment 40 Total consumer 3,092 Total nonaccrual loans (excluding PCI) $ 5,346 (1) Disclosure is not comparative due to our adoption of CECL on January 1, 2020. For more information, see Note 1 (Summary of Significant Accounting Policies). (2) Nonaccrual loans may not have an allowance for credit losses if the loss expectations are zero given solid collateral value. 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 $3.4 billion and $3.5 billion at March 31, 2020 , and December 31, 2019 , respectively, which included $2.7 billion and $2.8 billion , respectively, of loans that are government insured/guaranteed. Under the Consumer Financial Protection Bureau guidelines, we do not commence the foreclosure process on real estate 1-4 family mortgage loans until after the loan is 120 days delinquent. 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. In connection with our actions to support customers during the COVID-19 pandemic, we have suspended certain mortgage foreclosure activities. LOANS 90 DAYS OR MORE PAST DUE AND STILL ACCRUING Certain loans 90 days or more past due 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 |