Citizens Financial (CFG) 10-Q 7 Nov 18 2018 Q3 Quarterly report Financial data

Document and Entity Information

Document and Entity Information - shares	9 Months Ended
	Sep. 30, 2018	Nov. 01, 2018
Document and Entity Information [Abstract]
Document Type	10-Q
Entity Central Index Key	759,944
Amendment Flag	false
Document Period End Date	Sep. 30, 2018
Document Fiscal Year Focus	2,018
Document Fiscal Period Focus	Q3
Trading Symbol	CFG
Entity Registrant Name	CITIZENS FINANCIAL GROUP INC/RI
Current Fiscal Year End Date	--12-31
Entity Filer Category	Large Accelerated Filer
Entity Emerging Growth Company	false
Entity Small Business	false
Entity Common Stock, Shares Outstanding		467,912,054

CONSOLIDATED BALANCE SHEETS (UN

CONSOLIDATED BALANCE SHEETS (UNAUDITED) - USD ($) $ in Millions		Sep. 30, 2018	Dec. 31, 2017
ASSETS:
Cash and due from banks		$ 976	$ 987
Interest-bearing cash and due from banks		3,015	2,045
Interest-bearing deposits in banks		142	192
Debt securities available for sale, at fair value (including $372 and $91 pledged to creditors, respectively)	[1]	20,152	20,157
Debt securities held to maturity (fair value of $4,102 and $4,668, respectively)		4,284	4,685
Equity securities, at fair value		175	169
Equity securities, at cost		874	722
Loans held for sale, at fair value		1,303	497
Other loans held for sale		27	221
Loans and leases	[2],[3]	114,720	110,617
Less: Allowance for loan and lease losses		(1,242)	(1,236)
Net loans and leases		113,478	109,381
Derivative assets		173	617
Premises and equipment, net		753	685
Bank-owned life insurance		1,687	1,656
Goodwill		6,946	6,887
Due from broker		0	6
Other assets		4,613	3,429
TOTAL ASSETS		158,598	152,336
Deposits:
Noninterest-bearing		29,785	29,279
Interest-bearing		87,290	85,810
Total deposits		117,075	115,089
Federal funds purchased and securities sold under agreements to repurchase		374	815
Other short-term borrowed funds		2,006	1,856
Derivative liabilities		449	310
Deferred taxes, net		430	571
Long-term borrowed funds		15,639	11,765
Due to broker		381	0
Other liabilities		1,968	1,660
TOTAL LIABILITIES		138,322	132,066
Contingencies (refer to Note 12)
Preferred stock, $25.00 par value, authorized 100,000,000 shares:
Preferred stock, $25.00 par value, 100,000,000 shares authorized		543	247
Common stock:
$0.01 par value, 1,000,000,000 shares authorized; 566,686,274 shares issued and 474,120,616 shares outstanding at September 30, 2018 and 565,850,984 shares issued and 490,812,912 shares outstanding at December 31, 2017		6	6
Additional paid-in capital		18,816	18,781
Retained earnings		5,062	4,164
Treasury stock, at cost, 92,565,658 and 75,038,072 shares at September 30, 2018 and December 31, 2017, respectively		(2,833)	(2,108)
Accumulated other comprehensive loss		(1,318)	(820)
TOTAL STOCKHOLDERS’ EQUITY		20,276	20,270
TOTAL LIABILITIES AND STOCKHOLDERS’ EQUITY		$ 158,598	$ 152,336
[1]	Includes only collateral pledged by the Company where counterparties have the right to sell or pledge the collateral.
[2]	Excluded from the table above are loans held for sale totaling $1.3 billion and $718 million as of September 30, 2018 and December 31, 2017, respectively.
[3]	Mortgage loans serviced for others by the Company’s subsidiaries are not included above, and amounted to $67.5 billion and $20.3 billion at September 30, 2018 and December 31, 2017, respectively.

CONSOLIDATED BALANCE SHEETS (_2

CONSOLIDATED BALANCE SHEETS (UNAUDITED) (Parenthetical) - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
ASSETS:
Securities held-to-maturity, fair value	$ 4,102	$ 4,668
STOCKHOLDERS’ EQUITY:
Preferred stock, par value (in dollars per share)	$ 25	$ 25
Preferred stock, authorized (in shares)	100,000,000	100,000,000
Common stock, par value (in dollars per share)	$ 0.01	$ 0.01
Common stock, authorized (in shares)	1,000,000,000	1,000,000,000
Common stock, issued (in shares)	566,686,274	565,850,984
Common stock, outstanding (in shares)	474,120,616	490,812,912
Treasury stock (in shares)	92,565,658	75,038,072
Available-for-sale Securities
ASSETS:
Securities, pledged to creditors	$ 372	$ 91
Held-to-maturity Securities
ASSETS:
Securities held-to-maturity, fair value	$ 4,102	$ 4,668

CONSOLIDATED STATEMENTS OF OPER

CONSOLIDATED STATEMENTS OF OPERATIONS (UNAUDITED) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
INTEREST INCOME:
Interest and fees on loans and leases	$ 1,287	$ 1,096	$ 3,663	$ 3,128
Interest and fees on loans held for sale, at fair value	14	5	23	13
Interest and fees on other loans held for sale	2	3	9	6
Investment securities	167	155	500	469
Interest-bearing deposits in banks	7	5	21	13
Total interest income	1,477	1,264	4,216	3,629
INTEREST EXPENSE:
Deposits	214	123	540	311
Federal funds purchased and securities sold under agreements to repurchase	2	1	4	2
Other short-term borrowed funds	19	7	42	22
Long-term borrowed funds	94	71	270	201
Total interest expense	329	202	856	536
Net interest income	1,148	1,062	3,360	3,093
Provision for credit losses	78	72	241	238
Net interest income after provision for credit losses	1,070	990	3,119	2,855
NONINTEREST INCOME:
Service charges and fees	131	131	382	385
Card fees	61	58	182	177
Capital markets fees	47	53	134	152
Trust and investment services fees	45	38	128	116
Letter of credit and loan fees	32	30	94	90
Foreign exchange and interest rate products	31	24	92	77
Mortgage banking fees	49	27	101	80
Securities gains, net	3	2	13	9
Net impairment losses recognized in earnings on debt securities	(1)	(1)	(3)	(6)
Other income	18	19	52	50
Total noninterest income	416	381	1,175	1,130
NONINTEREST EXPENSE:
Salaries and employee benefits	474	438	1,397	1,316
Outside services	107	99	312	286
Occupancy	81	78	241	239
Equipment expense	70	65	201	196
Amortization of software	47	45	139	134
Other operating expense	131	133	378	405
Total noninterest expense	910	858	2,668	2,576
Income before income tax expense	576	513	1,626	1,409
Income tax expense	133	165	370	423
NET INCOME	443	348	1,256	986
Net income available to common stockholders	$ 436	$ 341	$ 1,242	$ 972
Weighted-average common shares outstanding:
Basic (in Shares)	475,957,526	500,861,076	482,691,884	505,529,991
Diluted (in Shares)	477,599,917	502,157,384	484,250,843	507,062,805
Per common share information:
Basic earnings (in Dollars per Share)	$ 0.92	$ 0.68	$ 2.57	$ 1.92
Diluted earnings (in Dollars per Share)	0.91	0.68	2.57	1.92
Dividends declared and paid (in Dollars per Share)	$ 0.27	$ 0.18	$ 0.71	$ 0.46

CONSOLIDATED STATEMENTS OF COMP

CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME (UNAUDITED) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Statement of Comprehensive Income [Abstract]
Net income	$ 443	$ 348	$ 1,256	$ 986
Other comprehensive (loss) income:
Net unrealized derivative instrument (losses) gains arising during the periods, net of income taxes of ($9), ($1), ($31) and $13, respectively	(26)	(1)	(91)	22
Reclassification adjustment for net derivative losses (gains) included in net income, net of income taxes of $3, ($2), $6 and ($8), respectively	11	(2)	19	(13)
Net unrealized debt securities (losses) gains arising during the periods, net of income taxes of ($34), $8, ($139) and $44, respectively	(95)	13	(427)	74
Other-than-temporary impairment not recognized in earnings on debt securities, net of income taxes of ($1), $0, ($1) and ($1), respectively	0	0	(1)	(2)
Reclassification of net debt securities gains to net income, net of income taxes of $0, $0, ($2) and ($1), respectively	(2)	(1)	(8)	(2)
Amortization of actuarial loss, net of income taxes of $1, $2, $3 and $6, respectively	4	3	10	8
Total other comprehensive (loss) income, net of income taxes	(108)	12	(498)	87
Total comprehensive income	$ 335	$ 360	$ 758	$ 1,073

CONSOLIDATED STATEMENTS OF CO_2

CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME (UNAUDITED) (Parenthetical) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Statement of Comprehensive Income [Abstract]
Net unrealized derivative instrument (losses) gains arising during the periods, tax	$ (9)	$ (1)	$ (31)	$ 13
Reclassification adjustment for net derivative losses (gains) included in net income, tax	3	(2)	6	(8)
Net unrealized debt securities (losses) gains arising during the periods, tax	(34)	8	(139)	44
Other-than-temporary impairment not recognized in earnings on debt securities, tax	(1)	0	(1)	(1)
Reclassification of net debt securities (gains) losses to net income, tax	0	0	(2)	(1)
Amortization of actuarial loss, tax	$ 1	$ 2	$ 3	$ 6

CONSOLIDATED STATEMENTS OF CHAN

CONSOLIDATED STATEMENTS OF CHANGES IN STOCKHOLDERS' EQUITY (UNAUDITED) - USD ($) $ in Millions	Total	Preferred Stock	Common Stock	Additional Paid-in Capital	Retained Earnings	Treasury Stock, at Cost	Accumulated Other Comprehensive Loss
Beginning balance (in shares) at Dec. 31, 2016		0	512,000,000
Beginning balance at Dec. 31, 2016	$ 19,747	$ 247	$ 6	$ 18,722	$ 2,703	$ (1,263)	$ (668)
Increase (Decrease) in Stockholders' Equity [Roll Forward]
Dividends to common stockholders	(233)				(233)
Dividends to preferred stockholders	(14)				(14)
Treasury stock purchased (in shares)			(13,000,000)
Treasury stock purchased	(485)			25		(510)
Share-based compensation plans (in shares)			1,000,000
Share-based compensation plans	12			12		0
Employee stock purchase plan shares purchased	9			9
Total comprehensive income:
Net income	986				986
Other comprehensive loss	87						87
Total comprehensive income	1,073				986		87
Ending balance (in shares) at Sep. 30, 2017		0	500,000,000
Ending balance at Sep. 30, 2017	20,109	$ 247	$ 6	18,768	3,442	(1,773)	(581)
Beginning balance at Jun. 30, 2017							(593)
Increase (Decrease) in Stockholders' Equity [Roll Forward]
Dividends to preferred stockholders	(7)
Treasury stock purchased	(225)
Total comprehensive income:
Net income	348
Other comprehensive loss	12
Total comprehensive income	360
Ending balance (in shares) at Sep. 30, 2017		0	500,000,000
Ending balance at Sep. 30, 2017	20,109	$ 247	$ 6	18,768	3,442	(1,773)	(581)
Beginning balance (in shares) at Dec. 31, 2017		0	491,000,000
Beginning balance at Dec. 31, 2017	20,270	$ 247	$ 6	18,781	4,164	(2,108)	(820)
Increase (Decrease) in Stockholders' Equity [Roll Forward]
Dividends to common stockholders	(344)				(344)
Dividends to preferred stockholders	(14)				(14)
Preferred stock issued (in shares)		1,000,000
Preferred stock issued	$ 296	$ 296
Treasury stock purchased (in shares)	(17,527,586)		(18,000,000)
Treasury stock purchased	$ (725)			0		(725)
Share-based compensation plans (in shares)			1,000,000
Share-based compensation plans	24			24
Employee stock purchase plan shares purchased	11			11
Total comprehensive income:
Net income	1,256				1,256
Other comprehensive loss	(498)						(498)
Total comprehensive income	758				1,256		(498)
Ending balance (in shares) at Sep. 30, 2018		1,000,000	474,000,000
Ending balance at Sep. 30, 2018	20,276	$ 543	$ 6	18,816	5,062	(2,833)	(1,318)
Beginning balance at Jun. 30, 2018							(1,210)
Increase (Decrease) in Stockholders' Equity [Roll Forward]
Dividends to preferred stockholders	(7)
Treasury stock purchased	(400)
Total comprehensive income:
Net income	443
Other comprehensive loss	(108)
Total comprehensive income	335
Ending balance (in shares) at Sep. 30, 2018		1,000,000	474,000,000
Ending balance at Sep. 30, 2018	$ 20,276	$ 543	$ 6	$ 18,816	$ 5,062	$ (2,833)	$ (1,318)

CONSOLIDATED STATEMENTS OF CASH

CONSOLIDATED STATEMENTS OF CASH FLOWS (UNAUDITED) - USD ($) $ in Millions		3 Months Ended		9 Months Ended		12 Months Ended
		Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017	Dec. 31, 2017
OPERATING ACTIVITIES
Net income				$ 1,256	$ 986
Adjustments to reconcile net income to net cash provided by operating activities:
Provision for credit losses				241	238
Originations of mortgage loans held for sale				(4,384)	(2,159)
Proceeds from sales of mortgage loans held for sale				4,259	2,372
Purchases of commercial loans held for sale				(1,450)	(1,513)
Proceeds from sales of commercial loans held for sale				1,457	1,441
Depreciation, amortization and accretion				357	371
Mortgage servicing rights valuation recovery				(3)	(1)
Debt securities impairment		$ 1	$ 1	3	6
Deferred income taxes				23	(23)
Share-based compensation				40	35
Net gain on sales of:
Debt securities		(3)	(2)	(13)	(9)
Equity securities				0	(1)
Increase in other assets				(918)	(155)
Increase (decrease) in other liabilities				339	(138)
Net cash provided by operating activities				1,207	1,450
Investment securities:
Purchases of debt securities available for sale				(3,084)	(4,088)
Proceeds from maturities and paydowns of debt securities available for sale				2,512	2,564
Proceeds from sales of debt securities available for sale				405	914
Purchases of debt securities held to maturity				0	(171)
Proceeds from maturities and paydowns of debt securities held to maturity				402	422
Purchases of equity securities, at fair value				(122)	(286)
Proceeds from sales of equity securities, at fair value				116	217
Purchases of equity securities, at cost				(568)	(307)
Proceeds from sales of equity securities, at cost				416	495
Net decrease in interest-bearing deposits in banks				50	152
Purchases of mortgage servicing rights				(16)	0
Acquisition, net of cash acquired				(533)	0
Net increase in loans and leases				(4,278)	(3,549)
Net increase in bank-owned life insurance				(31)	(34)
Premises and equipment:
Purchases				(157)	(115)
Capitalization of software				(175)	(138)
Net cash used in investing activities				(5,063)	(3,924)
FINANCING ACTIVITIES
Net increase in deposits				1,986	3,431
Net decrease in federal funds purchased and securities sold under agreements to repurchase				(441)	(695)
Net decrease in other short-term borrowed funds				(3,107)	(1,708)
Proceeds from issuance of long-term borrowed funds				17,503	12,108
Repayments of long-term borrowed funds				(10,333)	(11,501)
Treasury stock purchased				(725)	(485)
Net proceeds from issuance of preferred stock				296	0
Dividends declared and paid to common stockholders				(344)	(233)
Dividends declared and paid to preferred stockholders				(7)	(7)
Payments of employee tax withholding for share-based compensation				(13)	(20)
Net cash provided by financing activities				4,815	890
Increase in cash and cash equivalents	[1]			959	(1,584)
Cash and cash equivalents at beginning of period	[1]			3,032	3,704	$ 3,704
Cash and cash equivalents at end of period	[1]	$ 3,991	$ 2,120	$ 3,991	$ 2,120	$ 3,032
[1]	Cash and cash equivalents includes cash and due from banks and interest-bearing cash and due from banks as reflected on the Consolidated Balance Sheets.

BASIS OF PRESENTATION

BASIS OF PRESENTATION	9 Months Ended
	Sep. 30, 2018
Organization, Consolidation and Presentation of Financial Statements [Abstract]
BASIS OF PRESENTATION	BASIS OF PRESENTATION Basis of Presentation The unaudited interim Consolidated Financial Statements, including the Notes thereto of Citizens Financial Group, Inc., have been prepared in accordance with GAAP interim reporting requirements, and therefore do not include all information and Notes included in the audited Consolidated Financial Statements in conformity with GAAP. These unaudited interim Consolidated Financial Statements and Notes thereto should be read in conjunction with the Company’s audited Consolidated Financial Statements and accompanying Notes included in the Company’s Annual Report on Form 10-K for the year ended December 31, 2017. The Company’s principal business activity is banking, conducted through its subsidiaries, Citizens Bank, National Association and Citizens Bank of Pennsylvania. The unaudited interim Consolidated Financial Statements include the accounts of the Company and subsidiaries in which the Company has a controlling financial interest. All intercompany transactions and balances have been eliminated. The Company has evaluated its unconsolidated entities and does not believe that any entity in which it has an interest, but does not currently consolidate, meets the requirements to be consolidated as a variable interest entity. The unaudited interim Consolidated Financial Statements include all adjustments, consisting of normal recurring adjustments, necessary for a fair presentation of the results for the interim periods. The results for interim periods are not necessarily indicative of results for a full year. The preparation of financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. Material estimates that are particularly susceptible to significant change in the near-term relate to the determination of the ACL, evaluation of unrealized losses on securities for other-than-temporary impairment, accounting for income taxes, the valuation of AFS and HTM securities, and derivatives. Significant Accounting Policies For further information regarding the Company’s significant accounting policies, see Note 1 “Basis of Presentation” to the Company’s audited Consolidated Financial Statements in the Annual Report on Form 10-K for the year ended December 31, 2017 . Acquisition On August 1, 2018 , the Company acquired certain assets and assumed certain liabilities of Franklin American Mortgage Company (“FAMC”), a Franklin, Tennessee-based national mortgage servicing and origination firm, for total consideration of $582 million . As part of this transaction, the Company expanded its mortgage servicing position with the addition of an MSR portfolio which had an acquisition date fair value of $590 million . Refer to Note 5 “Mortgage Banking” for more information. The Company also recognized goodwill of $59 million and other intangibles of $32 million related to the transaction. Refer to Note 6 “Goodwill and Intangible Assets” for more information. The Company expects that some adjustments of the fair values assigned to the assets acquired and liabilities assumed at August 1, 2018 may subsequently be recorded, although any adjustments are not expected to be material. Accounting Pronouncements Adopted in 2018 Pronouncement Summary of Guidance Effects on Financial Statements Revenue Recognition: Revenue from Contracts with Customers Issued May 2014 • Requires that revenue from contracts with customers be recognized upon transfer of control of a good or service in the amount of consideration expected to be received. • Changes the accounting for certain contract costs including whether they may be offset against revenues in the Consolidated Statements of Operations. • Requires new qualitative and quantitative disclosures, including information about disaggregation of revenue and performance obligations. • May be adopted using a full retrospective approach or a modified cumulative effect approach wherein the guidance is applied only to existing contracts as of the date of initial adoption and to new contracts transacted after that date. • The Company adopted the new standard on January 1, 2018 under the modified retrospective method. Net interest income on financial assets and liabilities is explicitly excluded from the scope of the pronouncement. • Adoption of the new standard did not result in a change in the timing or amount of revenue recognized from contracts with customers. The Company did not recognize a cumulative adjustment to Retained Earnings upon adoption. • Effective January 1, 2018, underwriting fees are presented on a gross basis in capital market fees, while underwriting costs are presented in other operating expense. Prior to adoption, such costs were presented net of the related underwriting fees. Stock Compensation Issued May 2017 • Requires modification accounting unless the fair value, vesting conditions, and classification of the modified award are the same as the original award immediately before the modification. • Applied prospectively to all modifications of share-based awards after the adoption date. • The Company adopted the new standard as of January 1, 2018. • Adoption did not have an impact on the Company’s Consolidated Financial Statements. Presentation of Net Periodic Pension Cost and Net Periodic Postretirement Benefit Cost • Requires the service cost component of net periodic pension and postretirement benefit cost to be reported separately in the Consolidated Statements of Operations from the other components (e.g., expected return on assets, interest costs, amortization of gains/losses and prior service costs). • Requires presentation in the Consolidated Statements of Operations of the service cost component in the same line item as other employee compensation costs and presentation of the other components in a different line item from the service cost component. • Retrospective application is required for all periods presented. • The Company retrospectively adopted the new standard as of January 1, 2018. • Adoption did not have an impact on the Company’s net income. • The Company reclassified prior period amounts in the Consolidated Statement of Operations, which resulted in an immaterial increase in salaries and employee benefits and a corresponding decrease in other operating expense. Recognition and Measurement of Financial Assets and Financial Liabilities Issued January 2016 • Requires equity securities with readily determinable fair values to be measured at fair value on the balance sheet, with changes in the fair value recognized through earnings. • Requires separate presentation of financial assets and financial liabilities by measurement category and form of financial assets on the balance sheet or in the notes to the financial statements. • Makes several other targeted amendments to the existing accounting and disclosure requirements for financial instruments, including revised guidance related to valuation allowance assessments when recognizing deferred tax assets on unrealized losses on debt securities available for sale. • The Company adopted the new standard as of January 1, 2018. • Adoption had an immaterial impact on the Company’s Consolidated Financial Statements. Classification of Certain Cash Receipts and Cash Payments Issued August 2016 • Amends guidance on specific cashflows to determine the appropriate classification as operating, investing or financing activities which has required significant judgment. • The application of judgment has resulted in diversity in how certain cash receipts and cash payments are classified. • The Company adopted the new standard as of January 1, 2018. • Adoption did not have an impact on the Company’s Consolidated Financial Statements. Accounting Pronouncements Pending Adoption Pronouncement Summary of Guidance Effects on Financial Statements Derivatives and Hedging Issued August 2017 • Reduces the complexity and operational burdens of the current hedge accounting model and portrays more clearly the effects of hedge accounting in the financial statements. • Modifies current requirements to facilitate the application of hedge accounting to partial-term hedges, hedges of prepayable financial instruments, and other strategies. Adoption of these optional changes would occur on a prospective basis. • Requires the effects of fair value hedges to be classified in the same income statement line as the earnings effect of the hedged item. Adoption of this change will occur on a prospective basis. • Requires all effects of cash flow hedges to be deferred in other comprehensive income until the hedged cash flows affect earnings. Periodic hedge ineffectiveness will no longer be recognized in earnings. Adoption of this change will occur on a modified retrospective basis through a cumulative-effect adjustment directly to retained earnings as of the beginning of the period of adoption. • Required effective date: January 1, 2019. Early adoption is permitted. The Company does not intend to adopt the guidance prior to the required effective date. • The transition entries required upon adoption are not expected to have a material impact on the Company’s Consolidated Financial Statements. Leases Issued February 2016 • Requires lessees to recognize a right-of-use asset and corresponding lease liability for all leases with a lease term of greater than one year. • Requires lessees and lessors to classify most leases using principles similar to existing lease accounting, but eliminates the “bright line” classification tests. • Requires that for finance leases, a lessee recognize interest expense on the lease liability separately from the amortization of the right-of-use asset in the Consolidated Statements of Operations, while for operating leases, such amounts should be recognized as a combined expense. • Requires expanded disclosures about the nature and terms of lease agreements. • Provides the option to adopt using either a modified cumulative-effect approach wherein the guidance is applied to all periods presented, or through a cumulative-effect adjustment beginning in the period of adoption. • Requires companies with land easements to assess whether the easement meets the definition of a lease before applying other accounting guidance. • Required effective date: January 1, 2019. Early adoption is permitted. The Company does not intend to adopt the guidance prior to the effective date. • The Company intends to adopt the guidance through a cumulative-effect adjustment to retained earnings on January 1, 2019. Periods prior to January 1, 2019 will not be adjusted. • The Company occupies certain banking offices and equipment under non-cancelable operating lease agreements, which currently are not reflected on its Consolidated Balance Sheets. • Upon adoption, the Company expects to recognize a right-of-use asset and corresponding lease liability in the approximate range of $600 million to $750 million in its Consolidated Balance Sheets for non-cancelable operating lease agreements. • The evaluation of the impact of the leasing pronouncement will be adjusted based on execution of new leases, termination of existing leases prior to the effective date, and any changes to key lease assumptions such as renewals, extensions and discount rates. • The Company does not expect a material change to the timing of expense recognition on the Consolidated Statements of Operations. Financial Instruments - Credit Losses Issued June 2016 • Replaces existing incurred loss impairment guidance and establishes a single allowance framework for financial assets carried at amortized cost (including securities HTM), which will reflect management’s estimate of credit losses over the full remaining expected life of the financial assets. • Amends existing impairment guidance for securities AFS to incorporate an allowance, which will allow for reversals of impairment losses in the event that the credit of an issuer improves. • Requires a cumulative-effect adjustment to retained earnings as of the beginning of the reporting period of adoption. • Required effective date: January 1, 2020. Early adoption permitted on January 1, 2019. The Company does not intend to adopt the guidance prior to the required effective date. • A company-wide, cross-discipline governance structure to implement the new standard has been in place for more than 18 months. The Company is currently identifying and researching key interpretive issues and completing the development of most loss forecasting models to meet the requirements of the new guidance. The implementation team is also in the process of assessing forecast accuracy and potential macroeconomic factors that will be used to determine the reasonable and supportable forecast period. • The Company expects the standard will result in earlier recognition of credit losses and an increase in the ACL, as it will cover estimated credit losses over the full remaining expected life of loans and commitments and will consider future reasonable and supportable changes in macroeconomic conditions. Since the magnitude of the increase in the Company’s ACL will be impacted by economic conditions, forecasted economic conditions, credit quality and trends in the Company’s portfolio at the time of adoption, the quantitative impact cannot yet be reasonably estimated. Implementation Costs Incurred in a Cloud Computing Arrangement Issued August 2018 • Requires implementation costs incurred in a cloud computing arrangement that is a service contract be deferred and recognized over the term of the arrangement if those costs would be capitalized in a software licensing arrangement. • Requires amortization expense be presented in the same income statement line item as the related hosting service arrangement expense. • Permits adoption prospectively for all implementation costs incurred after adoption or retrospectively through a cumulative-effect adjustment as of the beginning of the first period presented. • Required effective date: January 1, 2020. Early adoption is permitted. The Company is evaluating whether it will adopt this guidance prior to the required effective date. • Adoption is not expected to have a material impact on the Company’s Consolidated Financial Statements. Disclosure Requirements - Fair Value Measurements Issued August 2018 • Amends disclosure requirements on fair value measurements. • The guidance eliminates requirements for certain disclosures that are no longer considered relevant or cost beneficial, requires new disclosures and modifies existing disclosures that are expected to enhance the usefulness of the financial statements. • Prospective application is required for new disclosure requirements. • Retrospective application is required for all other amendments for all periods presented. • Required effective date: January 1, 2020. Early adoption is permitted. The Company is evaluating whether it will adopt this guidance prior to the required effective date. • Adoption is not expected to have a material impact on the Company’s Consolidated Financial Statements. Disclosure Requirements - Defined Benefit Plan Issued August 2018 • Amends disclosure requirements for employers that sponsor defined benefit pension and/or other postretirement defined benefit plans. • The guidance eliminates requirements for certain disclosures that are no longer considered relevant or cost beneficial and requires new disclosures that are expected to enhance the usefulness of the financial statements. • Retrospective application is required for all periods presented. • Required effective date: January 1, 2021. Early adoption is permitted. The Company is evaluating whether it will adopt this guidance prior to the required effective date. • Adoption is not expected to have a material impact on the Company’s Consolidated Financial Statements.

SECURITIES

SECURITIES	9 Months Ended
	Sep. 30, 2018
Investments, Debt and Equity Securities [Abstract]
SECURITIES	SECURITIES The following table presents the major components of securities at amortized cost and fair value: September 30, 2018 December 31, 2017 (in millions) Amortized Cost Gross Unrealized Gains Gross Unrealized Losses Fair Value Amortized Cost Gross Unrealized Gains Gross Unrealized Losses Fair Value Debt Securities Available for Sale, at Fair Value U.S. Treasury and other $12 $— $— $12 $12 $— $— $12 State and political subdivisions 5 — — 5 6 — — 6 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities 20,703 8 (825 ) 19,886 20,065 40 (277 ) 19,828 Other/non-agency 251 4 (6 ) 249 311 7 (7 ) 311 Total mortgage-backed securities 20,954 12 (831 ) 20,135 20,376 47 (284 ) 20,139 Total debt securities available for sale, at fair value $20,971 $12 ($831 ) $20,152 $20,394 $47 ($284 ) $20,157 Debt Securities Held to Maturity Mortgage-backed securities: Federal agencies and U.S. government sponsored entities $3,525 $— ($177 ) $3,348 $3,853 $7 ($46 ) $3,814 Other/non-agency 759 1 (6 ) 754 832 22 — 854 Total mortgage-backed securities 4,284 1 (183 ) 4,102 4,685 29 (46 ) 4,668 Total debt securities held to maturity $4,284 $1 ($183 ) $4,102 $4,685 $29 ($46 ) $4,668 Equity Securities, at Fair Value Money market mutual fund investments $175 $— $— $175 $165 $— $— $165 Other investments — — — — 4 — — 4 Total equity securities, at fair value $175 $— $— $175 $169 $— $— $169 Equity Securities, at Cost Federal Reserve Bank stock $463 $— $— $463 $463 $— $— $463 Federal Home Loan Bank stock 404 — — 404 252 — — 252 Other equity securities 7 — — 7 7 — — 7 Total equity securities, at cost $874 $— $— $874 $722 $— $— $722 The amortized cost and fair value of debt securities by contractual maturity as of September 30, 2018 are presented below. Expected maturities may differ from contractual maturities because issuers may have the right to call or prepay obligations with or without incurring penalties. September 30, 2018 Distribution of Maturities (in millions) 1 Year or Less 1-5 Years 5-10 Years After 10 Years Total Amortized Cost: Debt securities available for sale U.S. Treasury and other $12 $— $— $— $12 State and political subdivisions — — — 5 5 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — 312 1,595 18,796 20,703 Other/non-agency 2 11 — 238 251 Total debt securities available for sale 14 323 1,595 19,039 20,971 Debt securities held to maturity Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — — — 3,525 3,525 Other/non-agency — — — 759 759 Total debt securities held to maturity — — — 4,284 4,284 Total amortized cost of debt securities $14 $323 $1,595 $23,323 $25,255 Fair Value: Debt securities available for sale U.S. Treasury and other $12 $— $— $— $12 State and political subdivisions — — — 5 5 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — 306 1,555 18,025 19,886 Other/non-agency 2 11 — 236 249 Total debt securities available for sale 14 317 1,555 18,266 20,152 Debt securities held to maturity Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — — — 3,348 3,348 Other/non-agency — — — 754 754 Total debt securities held to maturity — — — 4,102 4,102 Total fair value of debt securities $14 $317 $1,555 $22,368 $24,254 Taxable interest income from investment securities as presented on the Consolidated Statements of Operations was $167 million and $155 million for the three months ended September 30, 2018 and 2017 , respectively, and was $500 million and $469 million for the nine months ended September 30, 2018 and 2017 , respectively. Realized gains and losses on securities are presented below: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Gains on sale of debt securities $3 $2 $13 $9 Losses on sale of debt securities — — — — Debt securities gains, net $3 $2 $13 $9 Equity securities gains $— $— $— $1 The amortized cost and fair value of debt securities pledged are presented below: September 30, 2018 December 31, 2017 (in millions) Amortized Cost Fair Value Amortized Cost Fair Value Pledged against repurchase agreements $391 $376 $358 $357 Pledged against FHLB borrowed funds 764 760 839 861 Pledged against derivatives, to qualify for fiduciary powers, and to secure public and other deposits as required by law 3,699 3,519 3,113 3,082 The Company regularly enters into security repurchase agreements with unrelated counterparties. Repurchase agreements are financial transactions that involve the transfer of a security from one party to another and a subsequent transfer of substantially the same security back to the original party. The Company’s repurchase agreements are typically short-term transactions and accounted for as secured borrowed funds on the Company’s Consolidated Balance Sheets. When permitted by GAAP, the Company offsets short-term receivables associated with its reverse repurchase agreements against short-term payables associated with its repurchase agreements. The Company recognized no offsetting of short-term receivables or payables as of September 30, 2018 or December 31, 2017 . The Company offsets certain derivative assets and derivative liabilities on the Consolidated Balance Sheets. For further information see Note 9 “Derivatives.” Securitizations of mortgage loans retained in the investment portfolio for the three months ended September 30, 2018 and 2017 were $32 million and $38 million , respectively, and $87 million and $82 million for the nine months ended September 30, 2018 and 2017 , respectively. These securitizations include a substantive guarantee by a third party. In 2018 and 2017, the guarantors were FNMA, FHLMC, and GNMA. The debt securities received from the guarantors are classified as AFS. The following tables present mortgage-backed debt securities whose fair values are below carrying values, segregated by those that have been in a continuous unrealized loss position for less than twelve months and those that have been in a continuous unrealized loss position for twelve months or longer: September 30, 2018 Less than 12 Months 12 Months or Longer Total (dollars in millions) Number of Issues Fair Value Gross Unrealized Losses Number of Issues Fair Value Gross Unrealized Losses Number of Issues Fair Value Gross Unrealized Losses Federal agencies and U.S. government sponsored entities 493 $15,177 ($514 ) 159 $7,215 ($488 ) 652 $22,392 ($1,002 ) Other/non-agency 14 542 (6 ) 11 76 (6 ) 25 618 (12 ) Total 507 $15,719 ($520 ) 170 $7,291 ($494 ) 677 $23,010 ($1,014 ) December 31, 2017 Less than 12 Months 12 Months or Longer Total (dollars in millions) Number of Issues Fair Value Gross Unrealized Losses Number of Issues Fair Value Gross Unrealized Losses Number of Issues Fair Value Gross Unrealized Losses Federal agencies and U.S. government sponsored entities 294 $10,163 ($97 ) 152 $8,061 ($226 ) 446 $18,224 ($323 ) Other/non-agency 6 55 (1 ) 10 84 (6 ) 16 139 (7 ) Total 300 $10,218 ($98 ) 162 $8,145 ($232 ) 462 $18,363 ($330 ) The following table presents the cumulative credit-related losses recognized in earnings on debt securities held by the Company: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Cumulative balance at beginning of period $81 $79 $80 $75 Credit impairments recognized in earnings on debt securities that have been previously impaired 1 1 3 6 Reductions due to increases in cash flow expectations on impaired debt securities (1) (1 ) — (2 ) (1 ) Cumulative balance at end of period $81 $80 $81 $80 (1) Reported in interest income from investment securities on the Consolidated Statements of Operations. Cumulative credit losses recognized in earnings for impaired AFS debt securities held as of September 30, 2018 and 2017 were $81 million and $80 million , respectively. There were no credit losses recognized in earnings for the Company’s HTM portfolio for the three and nine months ended September 30, 2018 and 2017 . For the three months ended September 30, 2018 and 2017 , the Company incurred non-agency MBS credit-related other-than-temporary impairment losses in earnings of $1 million . For the nine months ended September 30, 2018 and 2017 , the Company incurred non-agency MBS credit-related other-than-temporary impairment losses in earnings of $3 million and $6 million , respectively. There were no credit-impaired debt securities sold during the three and nine months ended September 30, 2018 and 2017 . The Company does not currently have the intent to sell these impaired debt securities, and it is not more likely than not that the Company will be required to sell these debt securities prior to the recovery of their amortized cost bases. The Company has determined that credit losses are not expected to be incurred on the remaining agency and non-agency MBS identified with unrealized losses as of September 30, 2018 . The unrealized losses on these debt securities reflect non-credit-related factors such as changing interest rates and market liquidity. Therefore, the Company has determined that these debt securities are not other-than-temporarily impaired because the Company does not currently have the intent to sell these debt securities, and it is not more likely than not that the Company will be required to sell these debt securities prior to the recovery of their amortized cost bases. Any subsequent increases in the valuation of impaired debt securities do not impact their recorded cost bases.

LOANS AND LEASES

LOANS AND LEASES	9 Months Ended
	Sep. 30, 2018
Receivables [Abstract]
LOANS AND LEASES	LOANS AND LEASES The Company’s loans and leases are disclosed in portfolio segments and classes. The Company’s loan and lease portfolio segments are commercial and retail. The classes of loans and leases are: commercial, commercial real estate, leases, residential mortgages, home equity loans, home equity lines of credit, home equity loans serviced by others, home equity lines of credit serviced by others, automobile, education, credit cards and other retail. The Company’s SBO portfolio consists of purchased home equity loans and lines that were originally serviced by others, which the Company services a portion of internally. A summary of the loans and leases portfolio is presented below: (in millions) September 30, 2018 December 31, 2017 Commercial $39,770 $37,562 Commercial real estate 12,630 11,308 Leases 3,005 3,161 Total commercial loans and leases 55,405 52,031 Residential mortgages 18,493 17,045 Home equity loans 1,131 1,392 Home equity lines of credit 12,863 13,483 Home equity loans serviced by others 429 542 Home equity lines of credit serviced by others 114 149 Automobile 12,255 13,204 Education 8,712 8,134 Credit cards 1,911 1,848 Other retail 3,407 2,789 Total retail loans 59,315 58,586 Total loans and leases (1) (2) $114,720 $110,617 (1) Excluded from the table above are loans held for sale totaling $1.3 billion and $718 million as of September 30, 2018 and December 31, 2017 , respectively. (2) Mortgage loans serviced for others by the Company’s subsidiaries are not included above, and amounted to $67.5 billion and $20.3 billion at September 30, 2018 and December 31, 2017 , respectively. Loans held for sale at fair value as of September 30, 2018 totaled $1.3 billion and consisted of residential mortgages originated for sale of $1.1 billion and loans in the commercial trading portfolio of $163 million . Loans held for sale at fair value as of December 31, 2017 totaled $497 million and consisted of residential mortgages originated for sale of $326 million and loans in the commercial trading portfolio of $171 million . Other loans held for sale totaled $27 million and $221 million as of September 30, 2018 and December 31, 2017 , respectively, and consisted of commercial loans associated with the Company’s syndication business. Loans pledged as collateral for FHLB borrowed funds, primarily residential mortgages and home equity loans, totaled $25.3 billion and $24.9 billion at September 30, 2018 and December 31, 2017 , respectively. Loans pledged as collateral to support the contingent ability to borrow at the FRB discount window, if necessary, was primarily comprised of auto and commercial loans, and totaled $18.7 billion and $18.1 billion at September 30, 2018 and December 31, 2017 , respectively. During the three months ended September 30, 2018 and 2017 , the Company purchased $98 million and $63 million of education loans, respectively. During the nine months ended September 30, 2018 , the Company purchased $321 million of education loans. During the nine months ended September 30, 2017 , the Company purchased $795 million of education loans and $153 million of automobile loans. The Company had no loan portfolio sales during the three months ended September 30, 2018 and 2017 . During the nine months ended September 30, 2018 , the Company sold $553 million of commercial loans. During the nine months ended September 30, 2017 , the Company sold $596 million of commercial loans and $206 million of residential mortgage loans.

ALLOWANCE FOR CREDIT LOSSES, NO

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK	9 Months Ended
	Sep. 30, 2018
Receivables [Abstract]
ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK	ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK The ACL consists of the ALLL and the reserve for unfunded commitments. It is increased through a provision for credit losses that is charged to earnings, based on the Company’s quarterly evaluation of the loan and lease portfolio and related commitments, and is reduced by net charge-offs and the ALLL associated with sold loans. See Note 5 “Allowance for Credit Losses, Nonperforming Assets, and Concentrations of Credit Risk” to the Company’s audited Consolidated Financial Statements in the Annual Report on Form 10-K for the year ended December 31, 2017 , for a detailed discussion of the ALLL reserve methodology and estimation techniques. On a quarterly basis, the Company reviews and refines its estimate of the ACL, taking into consideration changes in portfolio size and composition, historical loss experience, internal risk ratings, current economic conditions, industry performance trends and other pertinent information. As of September 30, 2018 , there were no material changes in assumptions or estimation techniques compared with prior periods that impacted the determination of the current period’s ALLL and the reserve for unfunded lending commitments. As of December 31, 2017, the Company enhanced the method for assessing various qualitative risks, factors and events that may not be measured in the modeled results. The new methodology includes a statistical analysis of prior charge-off rates on a historical basis combined with a qualitative assessment based on quantitative measures affecting the determination of incurred losses in the loan and lease portfolio, and provides better alignment of the qualitative ALLL to the commercial and retail loan portfolios. The impact of the change was an increase of approximately $50 million to the commercial ALLL with a corresponding decrease to the retail ALLL; there was not a significant impact on the total qualitative ALLL as of December 31, 2017. A summary of changes in the ACL is presented below: Three Months Ended September 30, 2018 Nine Months Ended September 30, 2018 (in millions) Commercial Retail Total Commercial Retail Total Allowance for loan and lease losses, beginning of period $715 $538 $1,253 $685 $551 $1,236 Charge-offs (18 ) (109 ) (127 ) (35 ) (328 ) (363 ) Recoveries 2 39 41 10 121 131 Net charge-offs (16 ) (70 ) (86 ) (25 ) (207 ) (232 ) Provision charged to income 8 67 75 47 191 238 Allowance for loan and lease losses, end of period 707 535 1,242 707 535 1,242 Reserve for unfunded lending commitments, beginning of period 88 — 88 88 — 88 Provision for unfunded lending commitments 3 — 3 3 — 3 Reserve for unfunded lending commitments, end of period 91 — 91 91 — 91 Total allowance for credit losses, end of period $798 $535 $1,333 $798 $535 $1,333 Three Months Ended September 30, 2017 Nine Months Ended September 30, 2017 (in millions) Commercial Retail Total Commercial Retail Total Allowance for loan and lease losses, beginning of period $614 $605 $1,219 $663 $573 $1,236 Charge-offs (12 ) (108 ) (120 ) (60 ) (321 ) (381 ) Recoveries 12 43 55 27 127 154 Net charge-offs — (65 ) (65 ) (33 ) (194 ) (227 ) Provision charged to income 24 46 70 8 207 215 Allowance for loan and lease losses, end of period 638 586 1,224 638 586 1,224 Reserve for unfunded lending commitments, beginning of period 93 — 93 72 — 72 Provision for unfunded lending commitments 2 — 2 23 — 23 Reserve for unfunded lending commitments, end of period 95 — 95 95 — 95 Total allowance for credit losses, end of period $733 $586 $1,319 $733 $586 $1,319 The recorded investment in loans and leases based on the Company’s evaluation methodology is presented below: September 30, 2018 December 31, 2017 (in millions) Commercial Retail Total Commercial Retail Total Individually evaluated $430 $735 $1,165 $370 $761 $1,131 Formula-based evaluation 54,975 58,580 113,555 51,661 57,825 109,486 Total loans and leases $55,405 $59,315 $114,720 $52,031 $58,586 $110,617 A summary of the ACL by evaluation method is presented below: September 30, 2018 December 31, 2017 (in millions) Commercial Retail Total Commercial Retail Total Individually evaluated $59 $27 $86 $47 $34 $81 Formula-based evaluation 739 508 1,247 726 517 1,243 Allowance for credit losses $798 $535 $1,333 $773 $551 $1,324 For commercial loans and leases, the Company utilizes regulatory classification ratings to monitor credit quality. Loans with a “pass” rating are those that the Company believes will be fully repaid in accordance with the contractual loan terms. Commercial loans and leases that are “criticized” are those that have some weakness or potential weakness that indicate an increased probability of future loss. “Criticized” loans are grouped into three categories, “special mention,” “substandard” and “doubtful.” Special mention loans have potential weaknesses that, if left uncorrected, may result in deterioration of the Company’s credit position at some future date. Substandard loans are inadequately protected loans; these loans have well-defined weaknesses that could hinder normal repayment or collection of the debt. Doubtful loans have the same weaknesses as substandard, with the added characteristics that the possibility of loss is high and collection of the full amount of the loan is improbable. For retail loans, the Company primarily uses the loan’s payment and delinquency status to monitor credit quality. The further a loan is past due, the greater the likelihood of future credit loss. These credit quality indicators for both commercial and retail loans are continually updated and monitored. The recorded investment in commercial loans and leases based on regulatory classification ratings is presented below: September 30, 2018 Criticized (in millions) Pass Special Mention Substandard Doubtful Total Commercial $37,242 $1,441 $854 $233 $39,770 Commercial real estate 12,193 282 127 28 12,630 Leases 2,909 49 47 — 3,005 Total commercial loans and leases $52,344 $1,772 $1,028 $261 $55,405 December 31, 2017 Criticized (in millions) Pass Special Mention Substandard Doubtful Total Commercial $35,430 $1,143 $785 $204 $37,562 Commercial real estate 10,706 500 74 28 11,308 Leases 3,069 73 19 — 3,161 Total commercial loans and leases $49,205 $1,716 $878 $232 $52,031 The recorded investment in classes of retail loans, categorized by delinquency status is presented below: September 30, 2018 Days Past Due (in millions) Current 1-29 30-59 60-89 90 or More Total Residential mortgages $18,173 $136 $37 $13 $134 $18,493 Home equity loans 999 79 11 3 39 1,131 Home equity lines of credit 12,214 383 55 25 186 12,863 Home equity loans serviced by others 382 24 6 2 15 429 Home equity lines of credit serviced by others 87 17 2 1 7 114 Automobile 10,849 1,109 189 51 57 12,255 Education 8,514 151 24 13 10 8,712 Credit cards 1,814 57 14 9 17 1,911 Other retail 3,291 69 20 15 12 3,407 Total retail loans $56,323 $2,025 $358 $132 $477 $59,315 December 31, 2017 Days Past Due (in millions) Current 1-29 30-59 60-89 90 or More Total Residential mortgages $16,714 $147 $46 $18 $120 $17,045 Home equity loans 1,212 102 20 4 54 1,392 Home equity lines of credit 12,756 438 78 23 188 13,483 Home equity loans serviced by others 477 29 10 4 22 542 Home equity lines of credit serviced by others 116 21 4 1 7 149 Automobile 11,596 1,273 220 55 60 13,204 Education 7,898 160 23 12 41 8,134 Credit cards 1,747 63 12 9 17 1,848 Other retail 2,679 68 20 12 10 2,789 Total retail loans $55,195 $2,301 $433 $138 $519 $58,586 Nonperforming Assets The following table presents nonperforming loans and leases and loans accruing and 90 days or more past due: Nonperforming Accruing and 90 days or more past due (in millions) September 30, 2018 December 31, 2017 September 30, 2018 December 31, 2017 Commercial $228 $238 $— $5 Commercial real estate 30 27 — 3 Leases — — — — Total commercial loans and leases 258 265 — 8 Residential mortgages (1) 136 128 16 16 Home equity loans 53 72 — — Home equity lines of credit 221 233 — — Home equity loans serviced by others 19 25 — — Home equity lines of credit serviced by others 16 18 — — Automobile 67 70 — — Education 38 38 3 3 Credit card 17 17 — — Other retail 7 5 6 5 Total retail loans 574 606 25 24 Total $832 $871 $25 $32 (1) Nonperforming balances exclude first lien residential mortgage loans that are 100% guaranteed by the Federal Housing Administration. These loans, which are accruing and 90 days or more past due, totaled $13 million and $15 million as of September 30, 2018 and December 31, 2017 , respectively. Nonperforming balances also exclude guaranteed residential mortgage loans sold to GNMA for which the Company has the right, but not the obligation, to repurchase. These loans totaled $116 million and $30 million as of September 30, 2018 and December 31, 2017 , respectively. These loans are included in the Company’s Consolidated Balance Sheets. Other nonperforming assets consisted primarily of other real estate owned and was presented in other assets on the Consolidated Balance Sheets. Other real estate owned, net of valuation allowance, was $31 million and $36 million as of September 30, 2018 and December 31, 2017, respectively. A summary of nonperforming loan and lease key performance indicators is presented below: September 30, 2018 December 31, 2017 Nonperforming commercial loans and leases as a percentage of total loans and leases 0.23 % 0.24 % Nonperforming retail loans as a percentage of total loans and leases 0.50 0.55 Total nonperforming loans and leases as a percentage of total loans and leases 0.73 % 0.79 % Nonperforming commercial assets as a percentage of total assets 0.16 % 0.17 % Nonperforming retail assets as a percentage of total assets 0.38 % 0.43 % Total nonperforming assets as a percentage of total assets 0.54 % 0.60 % The recorded investment in mortgage loans collateralized by residential real estate property for which formal foreclosure proceedings are in process was $174 million and $181 million as of September 30, 2018 and December 31, 2017 , respectively. An analysis of the age of both accruing and nonaccruing loan and lease past due amounts is presented below: September 30, 2018 December 31, 2017 Days Past Due Days Past Due (in millions) 30-59 60-89 90 or More Total 30-59 60-89 90 or More Total Commercial $46 $3 $94 $143 $26 $4 $243 $273 Commercial real estate 46 7 27 80 38 20 30 88 Leases — — — — 4 1 — 5 Total commercial loans and leases 92 10 121 223 68 25 273 366 Residential mortgages 37 13 134 184 46 18 120 184 Home equity loans 11 3 39 53 20 4 54 78 Home equity lines of credit 55 25 186 266 78 23 188 289 Home equity loans serviced by others 6 2 15 23 10 4 22 36 Home equity lines of credit serviced by others 2 1 7 10 4 1 7 12 Automobile 189 51 57 297 220 55 60 335 Education 24 13 10 47 23 12 41 76 Credit cards 14 9 17 40 12 9 17 38 Other retail 20 15 12 47 20 12 10 42 Total retail loans 358 132 477 967 433 138 519 1,090 Total $450 $142 $598 $1,190 $501 $163 $792 $1,456 Impaired Loans Impaired loans include nonaccruing larger balance (greater than $3 million carrying value), non-homogeneous commercial and commercial real estate loans, and restructured loans that are deemed TDRs. A summary of impaired loans by class is presented below: September 30, 2018 (in millions) Impaired Loans With a Related Allowance Allowance on Impaired Loans Impaired Loans Without a Related Allowance Unpaid Contractual Balance Total Recorded Investment in Impaired Loans Commercial $237 $52 $133 $439 $370 Commercial real estate 31 7 29 78 60 Leases — — — — — Total commercial loans and leases 268 59 162 517 430 Residential mortgages 28 2 128 201 156 Home equity loans 34 3 72 145 106 Home equity lines of credit 18 1 190 253 208 Home equity loans serviced by others 23 2 20 57 43 Home equity lines of credit serviced by others 2 — 7 12 9 Automobile 2 — 23 31 25 Education 134 11 23 158 157 Credit cards 24 7 — 25 24 Other retail 4 1 3 8 7 Total retail loans 269 27 466 890 735 Total $537 $86 $628 $1,407 $1,165 December 31, 2017 (in millions) Impaired Loans With a Related Allowance Allowance on Impaired Loans Impaired Loans Without a Related Allowance Unpaid Contractual Balance Total Recorded Investment in Impaired Loans Commercial $183 $42 $159 $403 $342 Commercial real estate 25 5 3 40 28 Leases — — — — — Total commercial loans and leases 208 47 162 443 370 Residential mortgages 25 2 126 197 151 Home equity loans 41 4 80 162 121 Home equity lines of credit 16 1 181 241 197 Home equity loans serviced by others 29 2 22 67 51 Home equity lines of credit serviced by others 2 — 7 14 9 Automobile 2 — 21 30 23 Education 154 17 21 175 175 Credit cards 24 7 1 25 25 Other retail 5 1 4 10 9 Total retail loans 298 34 463 921 761 Total $506 $81 $625 $1,364 $1,131 Additional information on impaired loans is presented below: Three Months Ended September 30, 2018 2017 (in millions) Interest Income Recognized Average Recorded Investment Interest Income Recognized Average Recorded Investment Commercial $3 $334 $1 $391 Commercial real estate — 34 — 33 Leases — — — — Total commercial loans and leases 3 368 1 424 Residential mortgages 1 154 — 137 Home equity loans 1 107 1 125 Home equity lines of credit 2 202 2 192 Home equity loans serviced by others 1 43 — 51 Home equity lines of credit serviced by others — 9 — 9 Automobile — 23 — 21 Education 3 160 3 178 Credit cards — 24 — 25 Other retail — 7 — 10 Total retail loans 8 729 6 748 Total $11 $1,097 $7 $1,172 Nine Months Ended September 30, 2018 2017 (in millions) Interest Income Recognized Average Recorded Investment Interest Income Recognized Average Recorded Investment Commercial $7 $318 $3 $402 Commercial real estate — 33 — 39 Leases — — — — Total commercial loans and leases 7 351 3 441 Residential mortgages 4 148 3 128 Home equity loans 4 107 4 124 Home equity lines of credit 6 189 5 178 Home equity loans serviced by others 2 44 2 51 Home equity lines of credit serviced by others — 9 — 9 Automobile — 21 — 18 Education 7 159 7 178 Credit cards 1 22 1 23 Other retail — 7 — 10 Total retail loans 24 706 22 719 Total $31 $1,057 $25 $1,160 Troubled Debt Restructurings In situations where, for economic or legal reasons related to the borrower’s financial difficulties, the Company grants a concession to the borrower that it would not otherwise consider, the related loan is classified as a TDR. TDRs typically result from the Company’s loss mitigation efforts and are undertaken in order to improve the likelihood of recovery and continuity of the relationship. The Company’s loan modifications are handled on a case-by-case basis and are negotiated to achieve mutually agreeable terms that maximize loan collectability and meet the borrower’s financial needs. Concessions granted in TDRs for all classes of loans may include lowering the interest rate, forgiving a portion of principal, extending the loan term, lowering scheduled payments for a specified period of time, waiving or delaying a scheduled payment of principal or interest for other than an insignificant time period, or capitalizing past due amounts. A rate increase can be a concession if the increased rate is lower than a market rate for debt with risk similar to that of the restructured loan. TDRs for commercial loans and leases may also involve creating a multiple note structure, accepting non-cash assets, accepting an equity interest, or receiving a performance-based fee. In some cases, a TDR may involve multiple concessions. The financial effects of TDRs for all loan classes may include lower income (either due to a lower interest rate or a delay in the timing of cash flows), larger loan loss provisions, and accelerated charge-offs if the modification renders the loan collateral-dependent. In some cases, interest income throughout the term of the loan may increase if, for example, the loan is extended or the interest rate is increased as a result of the restructuring. Because TDRs are impaired loans, the Company measures impairment by comparing the present value of expected future cash flows, or when appropriate, the fair value of collateral less costs to sell, to the loan’s recorded investment. Any excess of recorded investment over the present value of expected future cash flows or collateral value is included in the ALLL. Any portion of the loan’s recorded investment the Company does not expect to collect as a result of the modification is charged off at the time of modification. For Retail TDR accounts where the expected value of cash flows is utilized, any recorded investment in excess of the present value of expected cash flows is recognized by creating or increasing the ALLL. For Retail TDR accounts assessed based on the fair value of collateral, any portion of the loan’s recorded investment in excess of the collateral value less costs to sell is charged off at the time of modification or at the time of subsequent and regularly recurring valuations. The table below summarizes TDRs by class and total unfunded commitments: (in millions) September 30, 2018 December 31, 2017 Commercial $253 $129 Retail 735 761 Unfunded commitments tied to TDRs 28 39 The table below summarizes how loans were modified during the three months ended September 30, 2018 , the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during the three months ended September 30, 2018 and were paid off in full, charged off, or sold prior to September 30, 2018 . Primary Modification Types Interest Rate Reduction (1) Maturity Extension (2) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Commercial 1 $— $— 13 $1 $1 Commercial real estate — — — — — — Total commercial loans 1 — — 13 1 1 Residential mortgages 9 1 1 17 2 2 Home equity loans 10 — 1 — — — Home equity lines of credit 27 3 3 58 10 10 Home equity loans serviced by others 2 — — — — — Home equity lines of credit serviced by others 1 — — — — — Automobile 45 1 — 9 — — Education — — — — — — Credit cards 623 4 4 — — — Other retail — — — — — — Total retail loans 717 9 9 84 12 12 Total 718 $9 $9 97 $13 $13 Primary Modification Types Other (3) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Net Change to ALLL Resulting from Modification Charge-offs Resulting from Modification Commercial 1 $— $— $— $— Commercial real estate — — — — — Total commercial loans 1 — — — — Residential mortgages 31 4 3 (1 ) — Home equity loans 40 2 2 — — Home equity lines of credit 104 7 7 — — Home equity loans serviced by others 5 1 1 — — Home equity lines of credit serviced by others 8 — — — — Automobile 315 5 4 — 2 Education 45 1 1 1 — Credit cards — — — 1 — Other retail — — — — — Total retail loans 548 20 18 1 2 Total 549 $20 $18 $1 $2 (1) Includes modifications that consist of multiple concessions, one of which is an interest rate reduction. (2) Includes modifications that consist of multiple concessions, one of which is a maturity extension (unless one of the other concessions was an interest rate reduction). (3) Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forgiveness, and capitalizing arrearages. Also included are the following: deferrals, trial modifications, certain bankruptcies, loans in forbearance and prepayment plans. Modifications can include the deferral of accrued interest resulting in post modification balances being higher than pre-modification. The table below summarizes how loans were modified during the three months ended September 30, 2017 , the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during the three months ended September 30, 2017 and were paid off in full, charged off, or sold prior to September 30, 2017 . Primary Modification Types Interest Rate Reduction (1) Maturity Extension (2) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Commercial 3 $1 $1 17 $8 $7 Commercial real estate — — — 1 — — Total commercial loans 3 1 1 18 8 7 Residential mortgages 13 1 2 15 1 2 Home equity loans 25 2 1 — — — Home equity lines of credit 11 1 1 86 11 11 Home equity loans serviced by others 3 — — — — — Home equity lines of credit serviced by others — — — — — — Automobile 28 1 1 8 — — Education — — — — — — Credit cards 661 3 3 — — — Other retail — — — — — — Total retail loans 741 8 8 109 12 13 Total 744 $9 $9 127 $20 $20 Primary Modification Types Other (3) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Net Change to ALLL Resulting from Modification Charge-offs Resulting from Modification Commercial 7 $28 $30 $— $— Commercial real estate 1 — — — — Total commercial loans 8 28 30 — — Residential mortgages 38 3 3 (1 ) — Home equity loans 49 3 3 — — Home equity lines of credit 110 6 7 — 1 Home equity loans serviced by others 11 1 — — — Home equity lines of credit serviced by others 8 1 — — — Automobile 392 7 6 — 1 Education 67 2 2 — — Credit cards — — — 1 — Other retail 2 — — — — Total retail loans 677 23 21 — 2 Total 685 $51 $51 $— $2 (1) Includes modifications that consist of multiple concessions, one of which is an interest rate reduction. (2) Includes modifications that consist of multiple concessions, one of which is a maturity extension (unless one of the other concessions was an interest rate reduction). (3) Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forgiveness, and capitalizing arrearages. Also included are the following: deferrals, trial modifications, certain bankruptcies, loans in forbearance and prepayment plans. Modifications can include the deferral of accrued interest resulting in post modification balances being higher than pre-modification. The table below summarizes how loans were modified during the nine months ended September 30, 2018 , the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during the nine months ended September 30, 2018 and were paid off in full, charged off, or sold prior to September 30, 2018 . Primary Modification Types Interest Rate Reduction (1) Maturity Extension (2) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Commercial 6 $1 $1 23 $2 $2 Commercial real estate — — — 1 — — Total commercial loans 6 1 1 24 2 2 Residential mortgages 32 3 4 47 6 6 Home equity loans 32 2 3 1 — — Home equity lines of credit 55 5 5 147 21 21 Home equity loans serviced by others 3 — — — — — Home equity lines of credit serviced by others 5 — — 1 — — Automobile 122 3 2 42 1 1 Education — — — — — — Credit cards 1,776 10 10 — — — Other retail 1 — — — — — Total retail loans 2,026 23 24 238 28 28 Total 2,032 $24 $25 262 $30 $30 Primary Modification Types Other (3) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Net Change to ALLL Resulting from Modification Charge-offs Resulting from Modification Commercial 40 $155 $156 $— $— Commercial real estate 2 31 31 — — Total commercial loans 42 186 187 — — Residential mortgages 117 14 14 (1 ) — Home equity loans 106 5 5 — — Home equity lines of credit 310 22 21 — — Home equity loans serviced by others 20 1 1 — — Home equity lines of credit serviced by others 13 — — — — Automobile 893 15 13 — 3 Education 296 5 5 1 — Credit cards — — — 3 — Other retail 4 — — — — Total retail loans 1,759 62 59 3 3 Total 1,801 $248 $246 $3 $3 (1) Includes modifications that consist of multiple concessions, one of which is an interest rate reduction. (2) Includes modifications that consist of multiple concessions, one of which is a maturity extension (unless one of the other concessions was an interest rate reduction). (3) Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forgiveness, and capitalizing arrearages. Also included are the following: deferrals, trial modifications, certain bankruptcies, loans in forbearance and prepayment plans. Modifications can include the deferral of accrued interest resulting in post modification balances being higher than pre-modification. The table below summarizes how loans were modified during the nine months ended September 30, 2017 , the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during the nine months ended September 30, 2017 and were paid off in full, charged off, or sold prior to September 30, 2017 . Primary Modification Types Interest Rate Reduction (1) Maturity Extension (2) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Commercial 7 $2 $2 35 $22 $21 Commercial real estate — — — 1 — — Total commercial loans 7 2 2 36 22 21 Residential mortgages 56 6 7 50 9 10 Home equity loans 68 4 4 1 — — Home equity lines of credit 41 2 2 204 26 26 Home equity loans serviced by others 14 1 1 — — — Home equity lines of credit serviced by others 3 — — 2 — — Automobile 93 2 2 23 — — Education — — — — — — Credit cards 1,850 10 10 — — — Other retail 1 — — — — — Total retail loans 2,126 25 26 280 35 36 Total 2,133 $27 $28 316 $57 $57 Primary Modification Types Other (3) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Net Change to ALLL Resulting from Modification Charge-offs Resulting from Modification Commercial 12 $64 $65 $1 $— Commercial real estate 1 — — — — Total commercial loans 13 64 65 1 — Residential mortgages 122 13 13 (1 ) — Home equity loans 192 11 11 — — Home equity lines of credit 295 20 20 — 1 Home equity loans serviced by others 41 2 1 — — Home equity lines of credit serviced by others 21 2 1 — — Automobile 1,017 18 16 — 3 Education 235 4 4 1 — Credit cards — — — 3 — Other retail 5 — — (1 ) — Total retail loans 1,928 70 66 2 4 Total 1,941 $134 $131 $3 $4 (1) Includes modifications that consist of multiple concessions, one of which is an interest rate reduction. (2) Includes modifications that consist of multiple concessions, one of which is a maturity extension (unless one of the other concessions was an interest rate reduction). (3) Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forgiveness, and capitalizing arrearages. Also included are the following: deferrals, trial modifications, certain bankruptcies, loans in forbearance and prepayment plans. Modifications can include the deferral of accrued interest resulting in post modification balances being higher than pre-modification. The table below summarizes TDRs that defaulted within 12 months of their modification date during the nine months ended September 30, 2018 and 2017 , respectively. For purposes of this table, a payment default refers to a loan that becomes 90 days or more past due under the modified terms. Amounts represent the loan’s recorded investment at the time of payment default. If a TDR of any loan type becomes 90 days past due after being modified, the loan is written down to the fair value of collateral less cost to sell. The amount written off is charged to the ALLL. Three Months Ended September 30, Nine Months Ended September 30, 2018 2017 2018 2017 (dollars in millions) Number of Contracts Balance Defaulted Number of Contracts Balance Defaulted Number of Contracts Balance Defaulted Number of Contracts Balance Defaulted Commercial 9 $32 2 $4 15 $52 7 $5 Commercial real estate — — — — 1 — 1 4 Total commercial loans 9 32 2 4 16 52 8 9 Residential mortgages 33 4 35 5 103 12 121 15 Home equity loans 6 — 12 — 24 1 35 1 Home equity lines of credit 59 5 55 4 165 13 152 11 Home equity loans serviced by others 3 — 6 — 13 — 16 — Home equity lines of credit serviced by others 2 — 4 — 3 — 8 — Automobile 40 — 42 — 116 1 103 1 Education 1 — 5 1 13 1 41 1 Credit cards 106 1 116 — 327 2 344 2 Other retail 1 — 2 — 1 — 4 — Total retail loans 251 10 277 10 765 30 824 31 Total 260 $42 279 $14 781 $82 832 $40 Concentrations of Credit Risk Most of the Company’s lending activity is with customers located in the New England, Mid-Atlantic and Midwest regions. Generally, loans are collateralized by assets including real estate, inventory, accounts receivable, other personal property and investment securities. As of September 30, 2018 and December 31, 2017 , the Company had a significant amount of loans collateralized by residential and commercial real estate. There were no significant concentration risks within the commercial loan or retail loan portfolios. Exposure to credit losses arising from lending transactions may fluctuate with fair values of collateral supporting loans, which may not perform according to contractual agreements. The Company’s policy is to collateralize loans to the extent necessary; however, unsecured loans are also granted on the basis of the financial strength of the applicant and the facts surrounding the transaction. Certain loan products, including residential mortgages, home equity loans and lines of credit, and credit cards, have contractual features that may increase credit exposure to the Company in the event of an increase in interest rates or a decline in housing values. These products include loans that exceed 90% of the value of the underlying collateral (high LTV loans), interest-only and negative amortization residential mortgages, and loans with low introductory rates. Certain loans have more than one of these characteristics. The following tables present balances of loans with these characteristics: September 30, 2018 (in millions) Residential Mortgages Home Equity Loans and Lines of Credit Home Equity Products Serviced by Others Credit Cards Total High loan-to-value $339 $107 $174 $— $620 Interest-only/negative amortization 1,786 — — — 1,786 Low introductory rate — — — 211 211 Multiple characteristics and other 1 — — — 1 Total $2,126 $107 $174 $211 $2,618 December 31, 2017 (in millions) Residential Mortgages Home Equity Loans and Lines of Credit Home Equity Products Serviced by Others Credit Cards Education Total High loan-to-value $366 $166 $264 $— $— $796 Interest-only/negative amortization 1,763 — — — 1 1,764 Low introductory rate — — — 197 — 197 Multiple characteristics and other 1 — — — — 1 Total $2,130 $166 $264 $197 $1 $2,758

MORTGAGE BANKING

MORTGAGE BANKING	9 Months Ended
	Sep. 30, 2018
Mortgage Banking [Abstract]
MORTGAGE BANKING	MORTGAGE BANKING In its mortgage banking business, the Company sells residential mortgages to government-sponsored entities and other parties, who may issue securities backed by pools of such loans. The Company retains no beneficial interests in these sales, but may retain the servicing rights for the loans sold. The Company is obligated to subsequently repurchase a loan if the purchaser discovers a representation or warranty violation such as noncompliance with eligibility or servicing requirements, or customer fraud that should have been identified in a loan file review. The following table summarizes activity related to residential mortgage loans sold with servicing rights retained for the three and nine months ended September 30, 2018 and 2017. Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Residential mortgage loans sold with servicing retained $1,848 $828 $3,173 $2,372 Gain on sales (1) 29 25 59 54 Contractually specified servicing, late and other ancillary fees (1) 38 13 69 40 (1) Reported in mortgage banking fees in the Consolidated Statements of Operations. The Company recognizes the right to service residential mortgage loans for others, or MSRs, as separate assets, which are presented in other assets on the Consolidated Balance Sheets, when purchased, or when servicing is contractually separated from the underlying mortgage loans by sale with servicing rights retained. MSRs are initially recorded at fair value. Subsequent to the initial recognition, MSRs are measured using either the fair value method or the amortization method. MSRs accounted for under the amortization method are subsequently accounted for at lower of cost or fair value, net of accumulated amortization, which is recorded in proportion to, and over the period of, net servicing income. As of August 1, 2018, the Company maintains two separate classes of MSRs which at the time of initial capitalization, are differentiated by how the risk associated with valuation changes of the MSRs is managed. The acquired FAMC portfolio is accounted for under the fair value method while the Company’s MSR portfolio held before the FAMC acquisition is accounted for under the amortization method. The Company implemented an active hedging strategy to manage the risk associated with changes in the value of the MSR portfolio accounted for under the fair value method, which includes the purchase of freestanding derivatives. Any change in fair value during the period for MSRs carried under the fair value method, as well as amortization and impairment of MSRs under the amortization method, is recorded in mortgage banking fees in the Consolidated Statements of Operations. The following tables summarize changes in MSRs recorded using the amortization method and the fair value method for the three and nine months ended September 30, 2018 and 2017. Amortization Method As of and for the Three Months Ended September 30, As of and for the Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 MSRs: Balance as of beginning of period $217 $170 $201 $167 Amount capitalized 11 9 26 28 Purchases — — 16 — Amortization (9 ) (8 ) (24 ) (24 ) Carrying amount before valuation allowance 219 171 219 171 Valuation allowance for servicing assets: Balance as of beginning of period — 4 3 5 Valuation recoveries — — (3 ) (1 ) Balance at end of period — 4 — 4 Net carrying value of MSRs $219 $167 $219 $167 For the purposes of impairment evaluation and measurement of MSRs under the amortization method, MSRs are stratified based on predominant risk characteristics (such as interest rate, loan size, origination date, term, or geographic location) of the underlying loans. An allowance is established in the event the recorded value of an individual stratum exceeds fair value. Fair Value Method As of and for the Three Months Ended September 30, 2018 As of and for the Nine Months Ended September 30, 2018 (in millions) MSRs: Fair value as of beginning of the period $— $— Acquired MSRs 590 590 Amounts capitalized 29 29 Changes in unpaid principal balance during the period (1) (12 ) (12 ) Changes in fair value during the period (2) 5 5 Fair value at end of the period $612 $612 (1) Represents changes in value due to i) passage of time including the impact from both regularly scheduled loan principal payments and partial paydowns, and ii) loans that paid off during the period. (2) Represents changes in value primarily due to market driven changes in interest rates and prepayment speeds. The fair value of MSRs is estimated using the present value of estimated future net servicing cash flows, taking into consideration actual and expected mortgage loan prepayment rates, discount rates, contractual servicing fee income, servicing costs, default rates, ancillary income, and other economic factors, which are determined based on current market interest rates. The valuation does not attempt to forecast or predict the future direction of interest rates. The sensitivity analysis below presents the impact to current fair value of an immediate 50 basis point and 100 basis point adverse change in the key economic assumptions and presents the decline in fair value that would occur if the adverse change were realized. These sensitivities are hypothetical, with the effect of a variation in a particular assumption on the fair value of the mortgage servicing rights calculated independently without changing any other assumption. In reality, changes in one factor may result in changes in another (e.g., changes in interest rates, which drive changes in prepayment rates, could result in changes in the discount rates), which may amplify or counteract the sensitivities. The primary risk inherent in the Company’s MSRs is an increase in prepayments of the underlying mortgage loans serviced, which is dependent upon movements in market interest rates. For MSRs under the amortization method, the key economic assumptions used to estimate the fair value are presented below: September 30, 2018 December 31, 2017 Actual Decline in fair value due to Actual Decline in fair value due to (dollars in millions) Fair value $261 50 bps adverse change 100 bps adverse change $218 50 bps adverse change 100 bps adverse change Weighted average life (in years) 6.9 5.9 Weighted average constant prepayment rate 7.7% $18 $43 10.0% $22 $46 Weighted average discount rate 9.3% 5 10 9.9% 4 8 For MSRs under the fair value method, the key economic assumptions used to estimate the fair value are presented below: September 30, 2018 Actual Decline in fair value due to (dollars in millions) Fair value $612 50 bps adverse change 100 bps adverse change Weighted average life (in years) 8.7 Weighted average constant prepayment rate 7.3% $54 $123 Weighted average option adjusted spread 625 bps 14 27 The Company economically hedges the value of certain MSRs using derivative instruments. Refer to Note 9 “Derivatives” for additional information.

GOODWILL AND INTANGIBLE ASSETS

GOODWILL AND INTANGIBLE ASSETS	9 Months Ended
	Sep. 30, 2018
Goodwill and Intangible Assets Disclosure [Abstract]
GOODWILL AND INTANGIBLE ASSETS	GOODWILL AND INTANGIBLE ASSETS Goodwill is the purchase premium excess of the fair value allocated to net assets associated with the acquisition of a business and is assigned to reporting units at the acquisition date. A reporting unit is a business operating segment or a component of a business operating segment. Once goodwill has been assigned to reporting units, it no longer retains its association with a particular acquisition, and all of the activities within a reporting unit, whether acquired or organically grown, are available to support the value of the goodwill. The Company has identified and allocated goodwill to two reporting units - Consumer Banking and Commercial Banking - based upon reviews of the structure of the Company’s executive team and supporting functions, resource allocations and financial reporting processes. For further detail regarding the Company’s Goodwill see Note 9 “Goodwill” to the Company’s audited Financial Statements in the Annual Report on Form 10-K for the year ended December 31, 2017. In August 2018, the Company acquired certain assets and assumed certain liabilities of FAMC, which resulted in an increase to goodwill of $59 million . Refer to Note 1 “Basis of Presentation” for more information. The change in the carrying value of goodwill for the nine months ended September 30, 2018 is presented below: (in millions) Consumer Banking Commercial Banking Total Balance at December 31, 2017 $2,136 $4,751 $6,887 Business acquisition 59 — 59 Balance at September 30, 2018 $2,195 $4,751 $6,946 Accumulated impairment losses related to the Consumer Banking reporting unit totaled $5.9 billion at September 30, 2018 and December 31, 2017 . The accumulated losses related to the Commercial Banking reporting unit totaled $50 million at September 30, 2018 and December 31, 2017 . There was no impairment recorded for the three and nine months ended September 30, 2018 and 2017 . Other Intangibles Other intangible assets are recognized separately from goodwill if the asset arises as a result of contractual rights or if the asset is capable of being separated and sold, transferred or exchanged. Intangible assets are recorded in other assets on the Consolidated Balance Sheets and are amortized on a straight-line basis. Intangible assets are subject to an annual impairment evaluation. Amortization expense is recorded in other expenses in our Consolidated Statements of Operations. A summary of the carrying value of intangible assets is presented below. Included in the carrying value at September 30, 2018 are $32 million in other intangibles related to the FAMC acquisition. September 30, 2018 December 31, 2017 (in millions) Amortizable Lives (years) Gross Accumulated Amortization Net Gross Accumulated Amortization Net Acquired technology 7 $20 $— $20 $— $— $— Acquired relationships 5 - 15 11 1 10 2 — 2 Other 2 - 3 3 — 3 — — — Total $34 $1 $33 $2 $— $2 As of September 30, 2018 , all of the Company’s intangible assets were being amortized. Amortization expense recognized on intangible assets was $1 million for the three and nine month s ended September 30, 2018 . There was no amortization expense for the three and nine month s ended September 30, 2017 . The Company’s projection of amortization expense is based on balances as of September 30, 2018 , and future amortization expense may vary from these projections. Estimated intangible asset amortization expense for the remainder of 2018 through 2022 is as follows: (in millions) Total Remainder of 2018 $1 2019 5 2020 5 2021 4 2022 4

VARIABLE INTEREST ENTITIES

VARIABLE INTEREST ENTITIES	9 Months Ended
	Sep. 30, 2018
Equity Method Investments and Joint Ventures [Abstract]
VARIABLE INTEREST ENTITIES	VARIABLE INTEREST ENTITIES The Company is involved in various entities that are considered VIEs, including investments in limited partnerships that sponsor affordable housing projects, limited liability companies that sponsor renewable energy projects and lending to special purpose entities. The Company’s maximum exposure to loss as a result of its involvement with these entities is limited to the balance sheet carrying amount of its equity investment and outstanding loans to special purpose entities. A summary of these investments is presented below: (in millions) September 30, 2018 December 31, 2017 LIHTC investment included in other assets $1,211 $951 LIHTC unfunded commitments included in other liabilities 677 491 Renewable energy investments included in other assets 323 335 Lending to special purpose entities included in loans and leases 449 — Low Income Housing Tax Credit Partnerships The purpose of the Company’s equity investments is to assist in achieving the goals of the Community Reinvestment Act and to earn an adequate return of capital. LIHTC partnerships are managed by unrelated general partners that have the power to direct the activities which most significantly affect the performance of the partnerships. The Company is therefore not the primary beneficiary of any LIHTC partnerships. Accordingly, the Company does not consolidate these VIEs and accounts for these investments in other assets on the Consolidated Balance Sheets. The Company applies the proportional amortization method to account for its LIHTC investments. Under the proportional amortization method, the Company applies a practical expedient and amortizes the initial cost of the investment in proportion to the tax credits received in the current period as compared to the total tax credits expected to be received over the life of the investment. The amortization and tax benefits are included as a component of income tax expense. The tax credits received are reported as a reduction of income tax expense (or an increase to income tax benefit) related to these transactions. The following table presents other information related to the Company’s affordable housing tax credit investments: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Tax credits included in income tax expense $28 $20 $79 $63 Amortization expense included in income tax expense 31 22 86 67 Other tax benefits included in income tax expense 7 7 19 22 No LIHTC investment impairment losses were recognized during the three and nine months ended September 30, 2018 and 2017 , respectively. Renewable Energy Entities The Company’s investments in renewable energy entities provide benefits from a return generated by government incentives plus other tax attributes that are associated with tax ownership (e.g., tax depreciation). As a tax equity investor, the Company does not have the power to direct the activities which most significantly affect the performance of these entities and therefore is not the primary beneficiary of any renewable energy entities. Accordingly, the Company does not consolidate these VIEs and accounts for these investments in other assets on the Consolidated Balance Sheets. Lending to Special Purpose Entities The Company provides lending facilities to third-party sponsored special purpose entities. Because the sponsor for each respective entity has the power to direct how proceeds from the Company are utilized, as well as maintains responsibility for any associated servicing commitments, the Company is not the primary beneficiary of these entities. Accordingly, the Company does not consolidate these VIEs on the Consolidated Balance Sheets. As of September 30, 2018 , the lending facilities had aggregate unpaid principal balances of $449 million and undrawn commitments to extend credit of $534 million . The Company did not provide these lending facilities as of December 31, 2017.

BORROWED FUNDS

BORROWED FUNDS	9 Months Ended
	Sep. 30, 2018
Debt Disclosure [Abstract]
BORROWED FUNDS	BORROWED FUNDS A summary of the Company’s short-term borrowed funds is presented below: (in millions) September 30, 2018 December 31, 2017 Federal funds purchased $— $460 Securities sold under agreements to repurchase 374 355 Other short-term borrowed funds (1) 2,006 1,856 Total short-term borrowed funds $2,380 $2,671 (1) September 30, 2018 includes $1.5 billion of debt issued under CBNA’s Global Bank Note Program maturing within one year, with unamortized deferred issuance costs and/or discounts of ($1) million and other basis adjustments of ($5) million . December 31, 2017 includes $750 million of debt issued under CBNA’s Global Bank Note Program maturing within one year, with unamortized deferred issuance costs and/or discounts of ($1) million and other basis adjustments of ($4) million . Key data related to short-term borrowed funds is presented in the following table: As of and for the Three Months Ended September 30, As of and for the Nine Months Ended September 30, As of and for the Year Ended December 31, (dollars in millions) 2018 2017 2018 2017 2017 Weighted-average interest rate at period-end: (1) Federal funds purchased and securities sold under agreements to repurchase — % — % — % — % 0.74 % Other short-term borrowed funds 2.41 1.47 2.41 1.47 1.72 Maximum amount outstanding at any month-end during the period: Federal funds purchased and securities sold under agreements to repurchase (2) $382 $724 $1,045 $1,174 $1,174 Other short-term borrowed funds 2,502 1,755 2,502 3,508 3,508 Average amount outstanding during the period: Federal funds purchased and securities sold under agreements to repurchase (2) $643 $733 $598 $807 $776 Other short-term borrowed funds 2,239 1,624 1,802 2,283 2,321 Weighted-average interest rate during the period: (1) Federal funds purchased and securities sold under agreements to repurchase 0.91 % 0.47 % 0.76 % 0.34 % 0.36 % Other short-term borrowed funds 2.45 1.48 2.38 1.22 1.32 (1) Rates exclude certain hedging costs. (2) Balances are net of certain short-term receivables associated with reverse repurchase agreements, as applicable. A summary of the Company’s long-term borrowed funds is presented below: (in millions) September 30, 2018 December 31, 2017 Parent Company: 2.375% fixed-rate senior unsecured debt, due 2021 $349 $349 4.150% fixed-rate subordinated debt, due 2022 348 348 5.158% fixed-to-floating rate callable subordinated debt, due 2023 (1) — 333 3.750% fixed-rate subordinated debt, due 2024 250 250 4.023% fixed-rate subordinated debt, due 2024 42 42 4.350% fixed-rate subordinated debt, due 2025 249 249 4.300% fixed-rate subordinated debt, due 2025 749 749 Banking Subsidiaries: 2.450% senior unsecured notes, due 2019 (2) 742 743 2.500% senior unsecured notes, due 2019 (2) (3) — 741 2.250% senior unsecured notes, due 2020 (2) 687 692 Floating-rate senior unsecured notes, due 2020 (2) 300 299 Floating-rate senior unsecured notes, due 2020 (2) 250 249 2.200% senior unsecured notes, due 2020 (2) 499 498 2.250% senior unsecured notes, due 2020 (2) 731 742 2.550% senior unsecured notes, due 2021 (2) 951 964 Floating-rate senior unsecured notes, due 2022 (2) 249 249 2.650% senior unsecured notes, due 2022 (2) 478 491 3.700% senior unsecured notes, due 2023 (2) 492 — Floating-rate senior unsecured notes, due 2023 (2) 249 — Federal Home Loan Bank advances due through 2038 8,012 3,761 Other 12 16 Total long-term borrowed funds $15,639 $11,765 (1) Redeemed on June 29, 2018. (2) Issued under CBNA’s Global Bank Note Program. (3) Reclassified to short-term borrowed funds. The Parent Company’s long-term borrowed funds as of September 30, 2018 and December 31, 2017 included principal balances of $2.0 billion and $ 2.3 billion , respectively, with unamortized deferred issuance costs and/or discounts of ($5) million for each period. The banking subsidiaries’ long-term borrowed funds as of September 30, 2018 and December 31, 2017 included principal balances of $13.8 billion and $9.5 billion , respectively, with unamortized deferred issuance costs and/or discounts of ($17) million and ($19) million , respectively, and hedging basis adjustments of ($105) million and ($63) million , respectively. See Note 9 “Derivatives” for further information about the Company’s hedging of certain long-term borrowed funds. Advances, lines of credit, and letters of credit from the FHLB are collateralized by pledged mortgages and pledged securities at least sufficient to satisfy the collateral maintenance level established by the FHLB. The utilized borrowing capacity for FHLB advances and letters of credit was $13.8 billion and $9.4 billion at September 30, 2018 and December 31, 2017 , respectively. The Company’s available FHLB borrowing capacity was $3.7 billion and $8.0 billion at September 30, 2018 and December 31, 2017 , respectively. The Company can also borrow from the FRB discount window to meet short-term liquidity requirements. Collateral, including certain loans, is pledged to support this borrowing capacity. At September 30, 2018 , the Company’s unused secured borrowing capacity was approximately $36.3 billion , which includes unencumbered securities, FHLB borrowing capacity, and FRB discount window capacity. A summary of maturities for the Company’s long-term borrowed funds at September 30, 2018 is presented below: (in millions) Parent Company Banking Subsidiaries Consolidated Year 2019 $— $3,244 $3,244 2020 — 7,972 7,972 2021 349 954 1,303 2022 348 732 1,080 2023 — 741 741 2024 and thereafter 1,290 9 1,299 Total $1,987 $13,652 $15,639

DERIVATIVES

DERIVATIVES	9 Months Ended
	Sep. 30, 2018
Derivative Instruments and Hedging Activities Disclosure [Abstract]
DERIVATIVES	DERIVATIVES In the normal course of business, the Company enters into a variety of derivative transactions in order to meet the financing needs of its customers and to reduce its own exposure to fluctuations in interest rates and foreign currency exchange rates. These transactions include interest rate swap contracts, interest rate options, foreign exchange contracts, residential loan commitment rate locks, interest rate future contracts, swaptions, forward commitments to sell to-be-announced mortgage securities (“TBAs”), forward sale contracts and purchase options. The Company monitors the results of each transaction to ensure that management’s intent is satisfied. The Company does not use derivatives for speculative purposes. The Company’s derivative instruments are recognized on the Consolidated Balance Sheets at fair value. Information regarding the valuation methodology and inputs used to estimate the fair value of the Company’s derivative instruments is described in Note 13 “Fair Value Measurements.” The following table presents derivative instruments included on the Consolidated Balance Sheets in derivative assets and derivative liabilities: September 30, 2018 December 31, 2017 (in millions) Notional Amount (1) Derivative Assets Derivative Liabilities Notional Amount (1) Derivative Assets Derivative Liabilities Derivatives designated as hedging instruments: Interest rate contracts $10,050 $5 $— $13,300 $— $— Derivatives not designated as hedging instruments: Interest rate contracts 111,837 160 469 80,180 538 379 Foreign exchange contracts 10,346 116 105 9,882 148 149 Other contracts 5,201 19 1 1,039 7 5 Total derivatives not designated as hedging instruments 295 575 693 533 Gross derivative fair values 300 575 693 533 Less: Gross amounts offset in the Consolidated Balance Sheets (2) (85 ) (85 ) (72 ) (72 ) Less: Cash collateral applied (2) (42 ) (41 ) (4 ) (151 ) Total net derivative fair values presented in the Consolidated Balance Sheets $173 $449 $617 $310 (1) The notional or contractual amount of interest rate derivatives and foreign exchange contracts is the amount upon which interest and other payments under the contract are based. For interest rate contracts, the notional amount is typically not exchanged. Therefore, notional amounts should not be taken as the measure of credit or market risk, as they do not measure the true economic risk of these contracts. (2) Amounts represent the impact of enforceable master netting agreements that allow the Company to net settle positive and negative positions. The Company’s derivative transactions are internally divided into three sub-groups: institutional, customer and residential loan. The Company has certain derivative transactions which are designated as fair value or cash flow hedges, described as follows: Derivatives designated as hedging instruments The Company’s institutional derivatives portfolio qualifies for hedge accounting treatment. This includes interest rate swaps that are designated as highly effective fair value and cash flow hedging relationships. The Company formally documents at inception all hedging relationships, as well as risk management objectives and strategies for undertaking various accounting hedges. Additionally, the Company uses dollar offset or regression analysis at the hedge’s inception, and monthly thereafter, to assess whether the derivatives are expected to be, or have been, highly effective in offsetting changes in the hedged item’s expected cash flows. The Company discontinues hedge accounting treatment when it is determined that a derivative is not expected to be, or has ceased to be, effective as a hedge and then reflects changes in fair value in earnings after termination of the hedge relationship. Fair value hedges The Company has outstanding interest rate swap agreements to manage the interest rate exposure on its medium-term borrowings. The change in value of fair value hedges, to the extent that the hedging relationship is effective, is recorded through other income and offset against the change in the fair value of the hedged item. The following table presents the effect on other income of fair value hedges described above: Amounts Recognized in Other Income for the Three Months Ended September 30, 2018 Three Months Ended September 30, 2017 (in millions) Derivative Hedged Item Hedge Ineffectiveness Derivative Hedged Item Hedge Ineffectiveness Hedges of interest rate risk on borrowings using interest rate swaps ($6 ) $7 $1 ($5 ) $4 ($1 ) Amounts Recognized in Other Income for the Nine Months Ended September 30, 2018 Nine Months Ended September 30, 2017 (in millions) Derivative Hedged Item Hedge Ineffectiveness Derivative Hedged Item Hedge Ineffectiveness Hedges of interest rate risk on borrowings using interest rate swaps ($32 ) $31 ($1 ) $5 ($5 ) $— Cash flow hedges The Company has outstanding interest rate swap agreements designed to hedge a portion of the Company’s floating rate assets and financing liabilities (including its borrowed funds). All of these swaps have been deemed as highly effective cash flow hedges. The effective portion of the hedging gains and losses associated with these hedges are recorded in OCI; the ineffective portion of the hedging gains and losses is recorded in earnings (other income). Hedging gains and losses on derivative contracts reclassified from OCI to current period earnings are included in the line item in the accompanying Consolidated Statements of Operations in which the hedged item is recorded and in the same period that the hedged item affects earnings. During the next 12 months, there are $17 million in pre-tax net losses on derivative instruments included in OCI expected to be reclassified to net interest income in the Consolidated Statements of Operations. Hedging gains and losses associated with the Company’s cash flow hedges are immediately reclassified from OCI to current period earnings (other income) if it becomes probable that the hedged forecasted transactions will not occur during the originally specified time period. The following table presents the effect of cash flow hedges on net income and stockholders' equity: Amounts Recognized for the Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Effective portion of (loss) gain recognized in OCI (1) ($35 ) ($2 ) ($122 ) $35 Amount of net (loss) gain reclassified from OCI to interest income (2) (17 ) 3 (36 ) 23 Amount of net gain (loss) reclassified from OCI to interest expense (2) 3 1 11 (2 ) (1) The cumulative effective gains and losses on the Company’s cash flow hedging activities are included on the accumulated other comprehensive loss line item on the Consolidated Balance Sheets. (2) This amount includes both (i) the amortization of effective gains and losses associated with the Company’s terminated cash flow hedges and (ii) the current reporting period’s interest settlements realized on the Company’s active cash flow hedges. Both (i) and (ii) were previously included on the accumulated other comprehensive loss line item on the Consolidated Balance Sheets and were subsequently recorded as adjustments to the interest income or expense of the underlying hedged item. Derivatives not designated as hedging instruments Economic hedges The Company’s customer derivatives are recorded on the Consolidated Balance Sheets at fair value. These include interest rate and foreign exchange derivative contracts that are designed to meet the hedging and financing needs of the Company’s customers. The mark-to-market gains and losses associated with the customer derivatives are mitigated by mark-to-market gains and losses on interest rate and foreign exchange derivative contracts transacted. The Company also purchases interest rate floors primarily to hedge the exposure related to customer deposit products that have embedded minimum interest rate guarantees. The Company utilizes interest rate floors in non-qualifying hedging relationships. The Company’s residential loan derivatives (including residential loan commitments and forward sales contracts) are recorded on the Consolidated Balance Sheets at fair value. The Company also uses derivatives to hedge the risk of changes in the fair value of its residential MSR portfolio measured at fair value. Certain residential MSRs are accounted for at fair value with changes in the fair value influenced primarily by changes in interest rates. Derivatives used to hedge the fair value of residential MSRs include TBAs, interest rate swaptions, interest rate futures and interest rate swaps. The following table presents the effect of economic hedges on noninterest income: Amounts Recognized in Noninterest Income for the Affected Line Item in the Consolidated Statements of Operations Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Economic Hedge Type Customer interest rate contracts Foreign exchange and interest rate products ($84 ) $12 ($363 ) $92 Customer foreign exchange contracts Foreign exchange and interest rate products 30 61 (27 ) 157 Derivatives transactions to hedge interest rate risk Foreign exchange and interest rate products 97 (2 ) 403 (58 ) Derivatives transactions to hedge foreign exchange risk Foreign exchange and interest rate products 24 (55 ) 99 (140 ) Residential loan commitments Mortgage banking fees 6 — 6 3 Forward sale contracts Mortgage banking fees (13 ) (1 ) (15 ) (7 ) Interest rate derivative contracts used to hedge residential MSRs Mortgage banking fees (3 ) — (3 ) — Total $57 $15 $100 $47

RECLASSIFICATIONS OUT OF ACCUMU

RECLASSIFICATIONS OUT OF ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS)	9 Months Ended
	Sep. 30, 2018
Equity [Abstract]
RECLASSIFICATIONS OUT OF ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS)	RECLASSIFICATIONS OUT OF ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS) The following tables present the changes in the balances, net of income taxes, of each component of AOCI: As of and for the Three Months Ended September 30, (in millions) Net Unrealized (Losses) Gains on Derivatives Net Unrealized (Losses) Gains on Debt Securities Employee Benefit Plans Total AOCI Balance at July 1, 2017 ($76 ) ($128 ) ($389 ) ($593 ) Other comprehensive income before reclassifications (1 ) 13 — 12 Other-than-temporary impairment not recognized in earnings on debt securities — — — — Amounts reclassified to the Consolidated Statements of Operations (2 ) (1 ) 3 — Net other comprehensive income (3 ) 12 3 12 Balance at September 30, 2017 ($79 ) ($116 ) ($386 ) ($581 ) Balance at July 1, 2018 ($200 ) ($575 ) ($435 ) ($1,210 ) Other comprehensive loss before reclassifications (26 ) (95 ) — (121 ) Other-than-temporary impairment not recognized in earnings on debt securities — — — — Amounts reclassified to the Consolidated Statements of Operations 11 (2 ) 4 13 Net other comprehensive loss (15 ) (97 ) 4 (108 ) Balance at September 30, 2018 ($215 ) ($672 ) ($431 ) ($1,318 ) As of and for the Nine Months Ended September 30, (in millions) Net Unrealized (Losses) Gains on Derivatives Net Unrealized (Losses) Gains on Debt Securities Employee Benefit Plans Total AOCI Balance at January 1, 2017 ($88 ) ($186 ) ($394 ) ($668 ) Other comprehensive income before reclassifications 22 74 — 96 Other-than-temporary impairment not recognized in earnings on debt securities — (2 ) — (2 ) Amounts reclassified to the Consolidated Statements of Operations (13 ) (2 ) 8 (7 ) Net other comprehensive income 9 70 8 87 Balance at September 30, 2017 ($79 ) ($116 ) ($386 ) ($581 ) Balance at January 1, 2018 ($143 ) ($236 ) ($441 ) ($820 ) Other comprehensive loss before reclassifications (91 ) (427 ) — (518 ) Other-than-temporary impairment not recognized in earnings on debt securities — (1 ) — (1 ) Amounts reclassified to the Consolidated Statements of Operations 19 (8 ) 10 21 Net other comprehensive loss (72 ) (436 ) 10 (498 ) Balance at September 30, 2018 ($215 ) ($672 ) ($431 ) ($1,318 ) The following table presents the amounts reclassified out of each component of AOCI and into the Consolidated Statements of Operations: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Details about AOCI Components Affected Line Item in the Consolidated Statements of Operations Reclassification adjustment for net derivative (losses) gains included in net income: ($17 ) $3 ($36 ) $23 Interest income 3 1 11 (2 ) Interest expense (14 ) 4 (25 ) 21 Income before income tax expense (3 ) 2 (6 ) 8 Income tax expense ($11 ) $2 ($19 ) $13 Net income Reclassification of net debt securities gains (losses) to net income: $3 $2 $13 $9 Securities gains, net (1 ) (1 ) (3 ) (6 ) Net debt securities impairment losses recognized in earnings 2 1 10 3 Income before income tax expense — — 2 1 Income tax expense $2 $1 $8 $2 Net income Reclassification of changes related to the employee benefit plan: ($5 ) ($5 ) ($13 ) ($14 ) Other operating expense (5 ) (5 ) (13 ) (14 ) Income before income tax expense (1 ) (2 ) (3 ) (6 ) Income tax expense ($4 ) ($3 ) ($10 ) ($8 ) Net income Total reclassification (losses) gains ($13 ) $— ($21 ) $7 Net income The following table presents the effects on net income of the amounts reclassified out of AOCI: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Net interest income (includes ($14), $4, ($25) and $21 of AOCI reclassifications, respectively) $1,148 $1,062 $3,360 $3,093 Provision for credit losses 78 72 241 238 Noninterest income (includes $2, $1, $10 and $3 of AOCI reclassifications, respectively) 416 381 1,175 1,130 Noninterest expense includes $5, $5, $13 and $14 of AOCI reclassifications, respectively) 910 858 2,668 2,576 Income before income tax expense 576 513 1,626 1,409 Income tax expense (includes ($4), $0, ($7) and $3 income tax net expense from reclassification items, respectively) 133 165 370 423 Net income $443 $348 $1,256 $986

STOCKHOLDERS' EQUITY

STOCKHOLDERS' EQUITY	9 Months Ended
	Sep. 30, 2018
Equity [Abstract]
STOCKHOLDERS' EQUITY	STOCKHOLDERS’ EQUITY Preferred Stock The Company had 100,000,000 shares authorized of $25.00 par value undesignated preferred stock as of September 30, 2018 and December 31, 2017 . At September 30, 2018 and December 31, 2017 , the Company had 550,000 and 250,000 shares of preferred stock issued and outstanding, respectively, with carrying amounts of $543 million and $247 million , respectively. On October 25, 2018, the Company issued $300 million , or 300,000 shares, of 6.375% fixed-to-floating rate non-cumulative perpetual Series C Preferred Stock, par value of $25.00 per share with a liquidation preference of $1,000 per share (the “Series C Preferred Stock”). As a result of this issuance, the Company received net proceeds of $296 million after the underwriting discount and other expenses. The Series C Preferred Stock has no stated maturity and will not be subject to any sinking fund or other obligation of the Company. Dividends, if declared, will accrue and be payable quarterly, in arrears, at a rate equal to 6.375% per annum from the date of issuance to, but excluding, April 6, 2024, and thereafter at a floating rate per annum equal to three-month LIBOR plus 3.157% , payable quarterly, in arrears, beginning July 6, 2024. The Series C Preferred Stock is redeemable at the Company’s option, in whole or in part, on any dividend payment date, on or after April 6, 2024, or in whole but not in part, at any time within the 90 days following a regulatory capital treatment event, in each case at a redemption price equal to $1,000 per share, plus any declared and unpaid dividends. The Company may not redeem shares of the Series C Preferred Stock without obtaining the prior approval of the FRB if then required under applicable capital guidelines. Except in certain limited circumstances, the Series C Preferred Stock does not have any voting rights. On May 24, 2018, the Company issued $300 million , or 300,000 shares, of 6.000% fixed-to-floating rate non-cumulative perpetual Series B Preferred Stock, par value of $25.00 per share with a liquidation preference of $1,000 per share (the “Series B Preferred Stock”). As a result of this issuance, the Company received net proceeds of $296 million after the underwriting discount and other expenses. The Series B Preferred Stock has no stated maturity and will not be subject to any sinking fund or other obligation of the Company. Dividends, if declared, will accrue and be payable semi-annually, in arrears, at a rate equal to 6.000% per annum from the date of issuance to, but excluding, July 6, 2023, and thereafter at a floating rate per annum equal to three-month LIBOR plus 3.003% , payable quarterly, in arrears, beginning October 6, 2023. The Series B Preferred Stock is redeemable at the Company’s option, in whole or in part, on any dividend payment date, on or after July 6, 2023, or in whole but not in part, at any time within the 90 days following a regulatory capital treatment event, in each case at a redemption price equal to $1,000 per share, plus any declared and unpaid dividends. The Company may not redeem shares of the Series B Preferred Stock without obtaining the prior approval of the FRB if then required under applicable capital guidelines. Except in certain limited circumstances, the Series B Preferred Stock does not have any voting rights. At September 30, 2018 and December 31, 2017, the Company had 250,000 shares of 5.500% fixed-to-floating rate non-cumulative perpetual Series A Preferred Stock issued and outstanding with liquidation preference of $1,000 per share and a carrying amount of $247 million . For further detail regarding the terms and conditions of the Company’s Series A Preferred Stock see Note 16 “Stockholders’ Equity” to the Company’s audited Financial Statements in the Annual Report on Form 10-K for the year ended December 31, 2017. Treasury Stock During the nine months ended September 30, 2018 , the Company repurchased $725 million , or 17,527,586 shares, of its outstanding common stock. The repurchased shares are held in treasury stock.

COMMITMENTS AND CONTINGENCIES

COMMITMENTS AND CONTINGENCIES	9 Months Ended
	Sep. 30, 2018
Commitments and Contingencies Disclosure [Abstract]
COMMITMENTS AND CONTINGENCIES	COMMITMENTS AND CONTINGENCIES A summary of outstanding off-balance sheet arrangements is presented below: (in millions) September 30, 2018 December 31, 2017 Undrawn commitments to extend credit $66,729 $62,959 Financial standby letters of credit 1,934 2,036 Performance letters of credit 131 47 Commercial letters of credit 74 53 Marketing rights 37 41 Risk participation agreements 14 16 Residential mortgage loans sold with recourse 6 7 Total $68,925 $65,159 Commitments to Extend Credit Commitments to extend credit are agreements to lend to customers in accordance with conditions contractually agreed upon in advance. Generally, the commitments have fixed expiration dates or termination clauses and may require payment of a fee. Since many of these commitments are expected to expire without being drawn upon, the contract amounts are not necessarily indicative of future cash requirements. Letters of Credit Standby letters of credit, both financial and performance, are issued by the Company for its customers. They are used as conditional guarantees of payment to a third party in the event the customer either fails to make specific payments (financial) or fails to complete a specific project (performance). Commercial letters of credit are used to facilitate the import of goods. The commercial letter of credit is used as the method of payment to the Company’s customers’ suppliers. The Company’s exposure to credit loss in the event of counterparty nonperformance in connection with the above instruments is represented by the contractual amount of those instruments, net of the value of collateral held. Standby letters of credit and commercial letters of credit are issued for terms of up to ten years and one year , respectively. Generally, letters of credit are collateralized by cash, accounts receivable, inventory or investment securities. Credit risk associated with letters of credit is considered in determining the appropriate amounts of reserves for unfunded commitments. The Company recognizes a liability on the Consolidated Balance Sheets representing its obligation to stand ready to perform over the term of the standby letters of credit in the event that the specified triggering events occur. The liability for these guarantees was $2 million and $3 million at September 30, 2018 and December 31, 2017 , respectively. Marketing Rights During 2003, the Company entered into a 25 -year agreement to acquire the naming and marketing rights of a baseball stadium in Pennsylvania. The Company paid $4 million for the nine months ended September 30, 2018 and paid $3 million for the year ended December 31, 2017 . As of September 30, 2018 , the Company is obligated to pay $37 million over the remainder of the contract. Risk Participation Agreements RPAs are guarantees issued by the Company to other parties for a fee, whereby the Company agrees to participate in the credit risk of a derivative customer of the other party. Under the terms of these agreements, the “participating bank” receives a fee from the “lead bank” in exchange for the guarantee of reimbursement if the customer defaults on an interest rate swap. The interest rate swap is transacted such that any and all exchanges of interest payments (favorable and unfavorable) are made between the lead bank and the customer. In the event that an early termination of the swap occurs and the customer is unable to make a required close out payment, the participating bank assumes that obligation and is required to make this payment. RPAs where the Company acts as the lead bank are referred to as “participations-out,” in reference to the credit risk associated with the customer derivatives being transferred out of the Company. Participations-out generally occur concurrently with the sale of new customer derivatives. RPAs where the Company acts as the participating bank are referred to as “participations-in,” in reference to the credit risk associated with the counterparty’s derivatives being assumed by the Company. The Company’s maximum credit exposure is based on its proportionate share of the settlement amount of the referenced interest rate swap. Settlement amounts are generally calculated based on the fair value of the swap plus outstanding accrued interest receivable from the customer. The Company’s estimate of the credit exposure associated with its risk participations-in as of September 30, 2018 and December 31, 2017 is $14 million and $16 million , respectively. The current amount of credit exposure is spread out over 87 counterparties. RPAs generally have terms ranging from one to five years; however, certain outstanding agreements have terms as long as ten years . Residential Loans Sold with Recourse The Company is an originator and servicer of residential mortgages and routinely sells such mortgage loans in the secondary market and to government-sponsored entities. In the context of such sales, the Company makes certain representations and warranties regarding the characteristics of the underlying loans and, as a result, may be contractually required to repurchase such loans or indemnify certain parties against losses for certain breaches of those representations and warranties. Other Commitments In second quarter 2018, the Company entered into an agreement to purchase education loans on a quarterly basis beginning with second quarter 2018 and ending with fourth quarter 2018. The total minimum and maximum amount of the aggregate purchase principal balance of loans under the terms of the agreement are $425 million and $700 million , respectively, and the remaining maximum purchase commitment is $188 million as of September 30, 2018 . The agreement may be extended by written agreement of the parties for an additional four quarters. The agreement will terminate immediately if at any time during its term the aggregate purchase principal balance of loans equals the maximum amount. The Company may also terminate the agreement at will with payment of a termination fee equal to the product of $1 million times the number of quarters remaining under the agreement. The Company’s commercial loan trading desk provides ongoing secondary market support and liquidity to its clients. Unsettled loan trades (i.e., loan purchase contracts) represent firm commitments to purchase loans from a third party at an agreed-upon price. Principal amounts associated with unsettled commercial loan trades are off-balance sheet commitments until delivery of the loans has taken place. Fair value adjustments associated with each unsettled loan trade are recognized on the Consolidated Balance Sheets and classified within other assets or other liabilities, depending on whether the fair value of the unsettled trade represents an unrealized gain or unrealized loss. The principal balances of unsettled commercial loan trade purchases and sales were $87 million and $121 million , respectively, at September 30, 2018 and $ 65 million and $132 million , respectively, at December 31, 2017 . Settled loans purchased by the trading desk are classified as loans held for sale, at fair value on the Consolidated Balance Sheets. Refer to Note 13 “Fair Value Measurements” for further information. Contingencies The Company operates in a legal and regulatory environment that exposes it to potentially significant risks. A certain amount of litigation ordinarily results from the nature of the Company’s banking and other businesses. The Company is a party to legal proceedings, including class actions. The Company is also the subject of investigations, reviews, subpoenas, and regulatory matters arising out of its normal business operations, which, in some instances, relate to concerns about fair lending, unfair and/or deceptive practices, mortgage-related issues, and mis-selling of certain products. In addition, the Company engages in discussions with relevant governmental and regulatory authorities on a regular and ongoing basis regarding various issues, and any issues discussed or identified may result in investigatory or other action being taken. Litigation and regulatory matters may result in settlements, damages, fines, penalties, public or private censure, increased costs, required remediation, restrictions on business activities, or other impacts on the Company. In these disputes and proceedings, the Company contests liability and the amount of damages as appropriate. Given their complex nature, and based on the Company's experience, it may be years before some of these matters are finally resolved. Moreover, before liability can be reasonably estimated for a claim, numerous legal and factual issues may need to be examined, including through potentially lengthy discovery and determination of important factual matters, and by addressing novel or unsettled legal issues relevant to the proceedings in question. The Company cannot predict with certainty if, how, or when such claims will be resolved or what the eventual settlement, fine, penalty or other relief, if any, may be, particularly for claims that are at an early stage in their development or where claimants seek substantial or indeterminate damages. The Company recognizes a provision for a claim when, in the opinion of management after seeking legal advice, it is probable that a liability exists and the amount of loss can be reasonably estimated. In many proceedings, however, it is not possible to determine whether any loss is probable or to estimate the amount of any loss. Based on information currently available, the advice of legal counsel and other advisers, and established reserves, management believes that the aggregate liabilities, if any, potentially arising from these proceedings will not have a materially adverse effect on the Company’s unaudited interim Consolidated Financial Statements.

FAIR VALUE MEASUREMENTS

FAIR VALUE MEASUREMENTS	9 Months Ended
	Sep. 30, 2018
Fair Value Disclosures [Abstract]
FAIR VALUE MEASUREMENTS	FAIR VALUE MEASUREMENTS As discussed in Note 19 “Fair Value Measurements,” to the Company’s audited Financial Statements in the Annual Report on Form 10-K for the year ended December 31, 2017, the Company measures or monitors many of its assets and liabilities on a fair value basis. Fair value is used on a recurring basis for assets and liabilities for which fair value is the required or elected measurement basis of accounting. Additionally, fair value is used on a nonrecurring basis to evaluate assets for impairment or for disclosure purposes. Nonrecurring fair value adjustments typically involve the application of lower of cost or market accounting or write-downs of individual assets. The Company also applies the fair value measurement guidance to determine amounts reported for certain disclosures in this Note for assets and liabilities that are not required to be reported at fair value in the financial statements. The Company elected to account for residential mortgage loans held for sale and certain commercial and commercial real estate loans held for sale at fair value. Applying fair value accounting to the residential mortgage loans held for sale better aligns the reported results of the economic changes in the value of these loans and their related economic hedge instruments. Certain commercial and commercial real estate held for sale loans are managed by a commercial secondary loan desk that provides liquidity to banks, finance companies and institutional investors. Applying fair value accounting to this portfolio is appropriate because the Company holds these loans with the intent to sell within the near-term periods. Fair Value Option Residential Mortgage Loans Held for Sale The fair value of residential mortgage loans held for sale is derived from observable mortgage security prices and includes adjustments for loan servicing value, agency guarantee fees, and other loan level attributes which are mostly observable in the marketplace. Credit risk does not significantly impact the valuation since these loans are sold shortly after origination. Therefore, the Company classifies the residential mortgage loans held for sale in Level 2 of the fair value hierarchy. The election of the fair value option for financial assets and financial liabilities is optional and irrevocable. The residential mortgage loans accounted for under the fair value option are initially measured at fair value (i.e., acquisition cost) when the financial asset is acquired. Subsequent changes in fair value are recognized in mortgage banking fees on the Consolidated Statements of Operations. The Company recognized changes in fair value in mortgage banking income of ($8) million and ($1) million for the three months ended September 30, 2018 and 2017, respectively. The Company recognized changes in fair value in mortgage banking income of ($7) million and $9 million for the nine months ended September 30, 2018 and 2017 , respectively. Interest income on residential mortgage loans held for sale is calculated based on the contractual interest rate of the loan and is recorded in interest income. Commercial and Commercial Real Estate Loans Held for Sale The fair value of commercial and commercial real estate loans held for sale is estimated using observable prices of similar loans that transact in the marketplace. In addition, the Company uses external pricing services that provide estimates of fair values based on quotes from various dealers transacting in the market, sector curves or benchmarking techniques. Therefore, the Company classifies the commercial and commercial real estate loans managed by the commercial secondary loan desk in Level 2 of the fair value hierarchy given the observable market inputs. There were no loans in this portfolio that were 90 days or more past due or nonaccruing as of September 30, 2018 and December 31, 2017 . The loans accounted for under the fair value option are initially measured at fair value when the financial asset is recognized. Subsequent changes in fair value are recognized in other noninterest income on the Consolidated Statements of Operations. Since all loans in the Company’s commercial trading portfolio consist of floating rate obligations, all changes in fair value are due to changes in credit risk. Such credit-related fair value changes may include observed changes in overall credit spreads and/or changes to the creditworthiness of an individual borrower. Unsettled trades within the commercial trading portfolio are not recognized on the Consolidated Balance Sheets and represent off-balance sheet commitments. Refer to Note 12 “Commitments and Contingencies” for further information. Interest income on commercial and commercial real estate loans held for sale is calculated based on the contractual interest rate of the loan and is recorded in interest income. The Company recognized $1 million in other noninterest income related to its commercial trading portfolio for the three months ended September 30, 2018 and 2017.The Company recognized $1 million and $4 million in other noninterest income related to its commercial trading portfolio for the nine months ended September 30, 2018 and 2017. The following table presents the difference between the aggregate fair value and the aggregate unpaid principal balance of loans held for sale measured at fair value: September 30, 2018 December 31, 2017 (in millions) Aggregate Fair Value Aggregate Unpaid Principal Aggregate Fair Value Less Aggregate Unpaid Principal Aggregate Fair Value Aggregate Unpaid Principal Aggregate Fair Value Less Aggregate Unpaid Principal Residential mortgage loans held for sale, at fair value $1,140 $1,140 $— $326 $326 $— Commercial and commercial real estate loans held for sale, at fair value 163 163 — 171 171 — Recurring Fair Value Measurements The Company utilizes a variety of valuation techniques to measure its assets and liabilities at fair value. The valuation methodologies used for significant assets and liabilities carried on the balance sheet at fair value on a recurring basis are presented below: Debt securities available for sale The fair value of debt securities classified as AFS is based upon quoted prices, if available. Where observable quoted prices are available in an active market, the security is classified as Level 1 in the fair value hierarchy. Classes of instruments that are valued using this market approach include debt securities issued by the U.S. Treasury. If quoted market prices are not available, the fair value for the security is estimated under the market or income approach using pricing models. These instruments are classified as Level 2 because they currently trade in active markets and the inputs to the valuations are observable. The pricing models used to value securities generally begin with market prices (or rates) for similar instruments and make adjustments based on the characteristics of the instrument being valued. These adjustments reflect assumptions made regarding the sensitivity of each security’s value to changes in interest rates and prepayment speeds. Classes of instruments that are valued using this market approach include specified pool mortgage “pass-through” securities and other debt securities issued by U.S. government-sponsored entities and state and political subdivisions. The pricing models used to value securities under the income approach generally begin with the contractual cash flows of each security and make adjustments based on forecasted prepayment speeds, default rates, and other market-observable information. The adjusted cash flows are then discounted at a rate derived from observed rates of return for comparable assets or liabilities that are traded in the market. Classes of instruments that are valued using this market approach include residential and commercial CMOs. A significant majority of the Company’s Level 1 and 2 debt securities are priced using an external pricing service. The Company verifies the accuracy of the pricing provided by its primary outside pricing service on a quarterly basis. This process involves using a secondary external vendor to provide valuations for the Company’s securities portfolio for comparison purposes. Any valuation discrepancies beyond a certain threshold are researched and, if necessary, corroborated by an independent outside broker. In certain cases where there is limited activity or less transparency around inputs to the valuation model, securities are classified as Level 3. Residential loans held for sale See the “Fair Value Option, Residential Mortgage Loans Held for Sale” discussion above. Commercial loans held for sale See the “Fair Value Option, Commercial and Commercial Real Estate Loans Held for Sale” discussion above. Mortgage Servicing Rights - Fair Value Method MSRs do not trade in an active market with readily observable prices. MSRs are classified as Level 3 since the valuation methodology utilizes significant unobservable inputs. The fair value was calculated using a discounted cash flow model which used assumptions, including weighted-average life, prepayment assumptions and weighted-average option adjusted spread. The underlying assumptions and estimated values are corroborated by values received from independent third parties based on their review of the servicing portfolio, and comparisons to market transactions. In addition, the MSR Policy is approved by the Asset Liability Committee. Refer to Note 5 “Mortgage Banking” for more information. Derivatives The vast majority of the Company’s derivatives portfolio is composed of “plain vanilla” interest rate swaps, which are traded in over-the-counter markets where quoted market prices are not readily available. For these interest rate derivatives, fair value is determined utilizing models that primarily use market observable inputs, such as swap rates and yield curves. The pricing models used to value interest rate swaps calculate the sum of each instrument’s fixed and variable cash flows, which are then discounted using an appropriate yield curve (i.e., LIBOR or Overnight Index Swap curve) to arrive at the fair value of each swap. The pricing models do not contain a high level of subjectivity as the methodologies used do not require significant judgment. The Company also considers certain adjustments to the modeled price that market participants would make when pricing each instrument, including a credit valuation adjustment that reflects the credit quality of the swap counterparty. The Company incorporates the effect of exposure to a particular counterparty’s credit by netting its derivative contracts with the available collateral and calculating a credit valuation adjustment on the basis of the net position with the counterparty where permitted. The determination of this adjustment requires judgment on behalf of Company management; however, the total amount of this portfolio-level adjustment is not material to the total fair value of the interest rate swaps in their entirety . Therefore, interest rate swaps are classified as Level 2 in the valuation hierarchy. The Company’s other derivatives include foreign exchange contracts. The fair value of foreign exchange derivatives uses the mid-point of daily quoted currency spot prices. A valuation model estimates fair value based on the quoted spot rates together with interest rate yield curves and forward currency rates. Since all of these inputs are observable in the market, foreign exchange derivatives are classified as Level 2 in the fair value hierarchy. Money Market Mutual Fund Investments Fair value is determined based upon unadjusted quoted market prices and is considered a Level 1 fair value measurement. Other equity securities The fair values of the Company’s other equity securities are based on security prices in markets that are not active; therefore, these investments are classified as Level 2 in the fair value hierarchy. The following table presents assets and liabilities measured at fair value, including gross derivative assets and liabilities on a recurring basis at September 30, 2018 : (in millions) Total Level 1 Level 2 Level 3 Debt securities available for sale: Mortgage-backed securities $20,135 $— $20,135 $— State and political subdivisions 5 — 5 — U.S. Treasury and other 12 12 — — Total debt securities available for sale 20,152 12 20,140 — Loans held for sale, at fair value: Residential loans held for sale 1,140 — 1,140 — Commercial loans held for sale 163 — 163 — Total loans held for sale, at fair value 1,303 — 1,303 — Mortgage servicing rights 612 — — 612 Derivative assets: Interest rate contracts 165 — 165 — Foreign exchange contracts 116 — 116 — Other contracts 19 — 19 — Total derivative assets 300 — 300 — Equity securities, at fair value: Money market mutual fund investments 175 175 — — Other investments — — — — Total equity securities, at fair value 175 175 — — Total assets $22,542 $187 $21,743 $612 Derivative liabilities: Interest rate contracts $469 $— $469 $— Foreign exchange contracts 105 — 105 — Other contracts 1 — 1 — Total derivative liabilities 575 — 575 — Total liabilities $575 $— $575 $— The following table presents assets and liabilities measured at fair value, including gross derivative assets and liabilities on a recurring basis at December 31, 2017 : (in millions) Total Level 1 Level 2 Level 3 Debt securities available for sale: Mortgage-backed securities $20,139 $— $20,139 $— State and political subdivisions 6 — 6 — U.S. Treasury and other 12 12 — — Total debt securities available for sale 20,157 12 20,145 — Loans held for sale, at fair value: Residential loans held for sale 326 — 326 — Commercial loans held for sale 171 — 171 — Total loans held for sale, at fair value 497 — 497 — Derivative assets: Interest rate contracts 538 — 538 — Foreign exchange contracts 148 — 148 — Other contracts 7 — 7 — Total derivative assets 693 — 693 — Equity securities, at fair value: Money market mutual fund investments 165 165 — — Other investments 4 — 4 — Total equity securities, at fair value 169 165 4 — Total assets $21,516 $177 $21,339 $— Derivative liabilities: Interest rate contracts $379 $— $379 $— Foreign exchange contracts 149 — 149 — Other contracts 5 — 5 — Total derivative liabilities 533 — 533 — Total liabilities $533 $— $533 $— The following tables present a rollforward of the balance sheet amounts for assets measured at fair value on a recurring basis and classified as Level 3 for the three and nine months ended September 30, 2018. There were no assets measured at fair value on a recurring basis and classified as Level 3 for the three and nine months ended September 30, 2017. For the Three Months Ended September 30, (in millions) Mortgage Servicing Rights Balance at July 1, 2018 $— Acquired MSRs 590 Amount capitalized 29 Change in unpaid principal balance during the period (1) (12 ) Change in fair value during the period (2) 5 Balance at September 30, 2018 $612 For the Nine Months Ended September 30, (in millions) Mortgage Servicing Rights Balance at January 1, 2018 $— Acquired MSRs 590 Amount capitalized 29 Change in unpaid principal balance during the period (1) (12 ) Change in fair value during the period (2) 5 Balance at September 30, 2018 $612 (1) Represents changes in value of the MSRs due to i) passage of time including the impact from both regularly scheduled loan principal payments and partial paydowns, and ii) loans that paid off during the period. (2) Represents changes in value primarily due to market driven changes in interest rates and prepayment speeds. Nonrecurring Fair Value Measurements Fair value is also used on a nonrecurring basis to evaluate certain assets for impairment or for disclosure purposes. Examples of nonrecurring uses of fair value include MSRs accounted for by the amortization method and loan impairments for certain loans and leases. The following valuation techniques are utilized to measure significant assets for which the Company utilizes fair value on a nonrecurring basis: Impaired Loans The carrying amount of collateral-dependent impaired loans is compared to the appraised value of the collateral less costs to dispose and is classified as Level 2. Any excess of carrying amount over the appraised value is charged to the ALLL. Mortgage Servicing Rights - Amortization Method MSRs do not trade in an active market with readily observable prices. MSRs are classified as Level 3 since the valuation methodology utilizes significant unobservable inputs. The fair value was calculated using a discounted cash flow model which used assumptions, including weighted-average life, weighted-average constant prepayment rate and weighted-average discount rate. Refer to Note 5 “Mortgage Banking” for more information. See also Note 8 “Mortgage Banking” to the Company’s audited Consolidated Financial Statements in the Annual Report on Form 10-K for the year ended December 31, 2017. Foreclosed assets Foreclosed assets consist primarily of residential properties. Foreclosed assets are carried at the lower of cost or fair value less costs to sell. Fair value is based upon independent market prices or appraised values of the collateral and is classified as Level 2. Leased assets The fair value of assets under operating leases is determined using collateral specific pricing digests, external appraisals, broker opinions, recent sales data from industry equipment dealers, and discounted cash flows derived from the underlying lease agreement. As market data for similar assets and lease agreements is available and used in the valuation, these assets are classified as Level 2 fair value measurement. The following table presents gains (losses) on assets and liabilities measured at fair value on a nonrecurring basis and recorded in earnings: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Impaired collateral-dependent loans ($3 ) ($4 ) ($9 ) ($31 ) MSRs — — 3 (1 ) Foreclosed assets (1 ) (1 ) (2 ) (3 ) Leased assets (4 ) — (6 ) (15 ) The following table presents assets and liabilities measured at fair value on a nonrecurring basis: September 30, 2018 December 31, 2017 (in millions) Total Level 1 Level 2 Level 3 Total Level 1 Level 2 Level 3 Impaired collateral-dependent loans $336 $— $336 $— $393 $— $393 $— MSRs 261 — — 261 218 — — 218 Foreclosed assets 25 — 25 — 31 — 31 — Leased assets 93 — 93 — 112 — 112 — Disclosures about Fair Value of Financial Instruments Following is a description of valuation methodologies used to estimate the fair value of financial instruments for disclosure purposes (these instruments are not recorded in the financial statements at fair value): Debt securities held to maturity The fair values of debt securities classified as HTM are estimated under the market or income approach using the same pricing models as those used to measure the fair value of the Company’s AFS securities. For more information, see “Recurring Fair Value Measurements — Debt securities Available for Sale,” within this Note. Equity securities, at cost The cost basis of equity securities, at cost, such as FHLB stock and FRB stock, is assumed to approximate the fair value of these securities. As a member of the FHLB and FRB, the Company is required to hold FHLB and FRB stock. The stock can be sold only to the FHLB and FRB upon termination of membership, or redeemed at the FHLB’s or FRB’s sole discretion. The stock may only be sold or redeemed at par, and therefore the cost basis represents the best estimate of fair value. Loans and leases For loans and leases not recorded at fair value on a recurring basis that are not accounted for as collateral-dependent impaired loans, fair value is estimated by using one of two methods: a discounted cash flow method or a securitization method. The discounted cash flow method involves discounting the expected future cash flows using current rates which a market participant would likely use to value similar pools of loans. Inputs used in this method include observable information such as contractual cash flows (net of servicing cost) and unobservable information such as estimated prepayment speeds, credit loss exposures, and discount rates. The securitization method involves utilizing market securitization data to value the assets as if a securitization transaction had been executed. Inputs used include observable market-based MBS data and pricing adjustments based on unobservable data reflecting the liquidity risk, credit loss exposure and other characteristics of the underlying loans. The internal risk-weighted balances of loans are grouped by product type for purposes of these estimated valuations. For nonaccruing loans, fair value is estimated by discounting management’s estimate of future cash flows with a discount rate commensurate with the risk associated with such assets. Fair value of collateral-dependent loans is primarily based on the appraised value of the collateral. Other loans held for sale Balances represent loans that were transferred to other loans held for sale and are reported at the lower of cost or fair value. When applicable, the fair value of other loans held for sale is estimated using one of two methods: a discounted cash flow method or a securitization method (as described above). Deposits The fair value of demand deposits, checking with interest accounts, regular savings, money market accounts and other deposits is the amount payable on demand at the balance sheet date. The fair value of term deposits is estimated by discounting the expected future cash flows using rates currently offered for deposits of similar remaining maturities. Federal funds purchased and securities sold under agreements to repurchase, other short-term borrowed funds, and long-term borrowed funds Rates currently available to the Company for debt of similar terms and remaining maturities are used to discount the expected cash flows of existing debt. The following table presents the estimated fair value for financial instruments not recorded at fair value in the unaudited interim Consolidated Financial Statements. The carrying amounts are recorded in the Consolidated Balance Sheets under the indicated captions: September 30, 2018 Total Level 1 Level 2 Level 3 (in millions) Carrying Value Estimated Fair Value Carrying Value Estimated Fair Value Carrying Value Estimated Fair Value Carrying Value Estimated Fair Value Financial Assets: Securities held to maturity $4,284 $4,102 $— $— $4,284 $4,102 $— $— Equity securities, at cost 874 874 — — 874 874 — — Other loans held for sale 27 27 — — — — 27 27 Loans and leases 114,720 113,913 — — 336 336 114,384 113,577 Financial Liabilities: Deposits 117,075 116,892 — — 117,075 116,892 — — Federal funds purchased and securities sold under agreements to repurchase 374 374 — — 374 374 — — Other short-term borrowed funds 2,006 2,006 — — 2,006 2,006 — — Long-term borrowed funds 15,639 15,630 — — 15,639 15,630 — — December 31, 2017 Total Level 1 Level 2 Level 3 (in millions) Carrying Value Estimated Fair Value Carrying Value Estimated Fair Value Carrying Value Estimated Fair Value Carrying Value Estimated Fair Value Financial Assets: Securities held to maturity $4,685 $4,668 $— $— $4,685 $4,668 $— $— Equity securities, at cost 722 722 — — 722 722 — — Other loans held for sale 221 221 — — — — 221 221 Loans and leases 110,617 111,168 — — 393 393 110,224 110,775 Financial Liabilities: Deposits 115,089 115,039 — — 115,089 115,039 — — Federal funds purchased and securities sold under agreements to repurchase 815 815 — — 815 815 — — Other short-term borrowed funds 1,856 1,856 — — 1,856 1,856 — — Long-term borrowed funds 11,765 11,891 — — 11,765 11,891 — —

NONINTEREST INCOME

NONINTEREST INCOME	9 Months Ended
	Sep. 30, 2018
Other Income and Expenses [Abstract]
NONINTEREST INCOME	NONINTEREST INCOME The following table presents noninterest income, segregated between revenue from contracts with customers and revenue from other sources: (in millions) Three Months Ended September 30, 2018 Nine Months Ended September 30, 2018 Revenue from contracts with customers $285 $833 Revenue from other sources 131 342 Noninterest income $416 $1,175 Revenues from Contracts with Customers The Company recognizes revenue from contracts with customers in the amount of consideration it expects to receive upon the transfer of control of a good or service. The timing of recognition is dependent on whether the Company satisfies a performance obligation by transferring control of the product or service to a customer over time or at a point in time. Judgments are made in the recognition of income including the timing of satisfaction of performance obligations and determination of the transaction price. The following table presents the components of revenue from contracts with customers disaggregated by revenue stream and business operating segment: Three Months Ended September 30, 2018 Nine Months Ended September 30, 2018 (in millions) Consumer Banking Commercial Banking Consolidated (1) Consumer Banking Commercial Banking Consolidated (1) Service charges and fees $105 $26 $131 $303 $79 $382 Card fees 51 10 61 154 28 182 Capital markets fees — 46 46 — 134 134 Trust and investment services fees 45 — 45 128 — 128 Other banking fees — 2 2 — 7 7 Total revenue from contracts with customers $201 $84 $285 $585 $248 $833 (1) There is no revenue from contracts with customers included in Other non-segment operations. The Company does not have any material contract assets, liabilities, or other receivables recorded on its Consolidated Balance Sheets related to revenues from contracts with customers as of September 30, 2018 . The Company has elected the practical expedient to exclude disclosure of unsatisfied performance obligations for (i) contracts with an original expected length of one year or less and (ii) contracts for which the Company recognized revenue at the amount to which the Company has the right to invoice for services performed. A description of the above components of revenue from contracts with customers is presented below: Service Charges and Fees Service charges and fees include fees earned from deposit products in lieu of compensating balances, service charges for transactions performed upon depositors’ request, as well as fees earned from performing cash management activities. Service charges on deposit products are recognized over the period in which the related service is provided, typically monthly. Service fees are recognized at a point in time upon completion of the requested service transaction. Fees on cash management products are recognized over time (typically monthly) as services are provided. Card Fees Card fees include interchange income from credit and debit card transactions and are recognized at a point in time upon settlement by the association network. Interchange rates are generally set by the association network based on purchase volume and other factors. Other card-related fees are recognized at a point in time upon completion of the transaction. Costs related to card rewards programs are recognized in current earnings as the rewards are earned by the customer and are presented as a reduction to card fees on the Consolidated Statements of Operations. Capital Markets Fees Capital markets fees include fees received from leading or participating in loan syndications, underwriting services and advisory fees. Loan syndication and underwriting fees are recognized as revenue at a point in time when the Company has rendered all services to, and is entitled to collect the fee from, the borrower or the issuer, and there are no other contingencies associated with the fee. Underwriting expenses passed through from the lead underwriter are recognized within other operating expense on the Consolidated Statements of Operations. Advisory fees for merger and acquisitions are recognized over time, while valuation services and fairness opinions are recognized at a point in time upon completion of the advisory service. Trust and Investment Services Fees Trust and investment services fees include fees from investment management services and brokerage services. Fees from investment management services are based on asset market values and are recognized over the period in which the related service is provided. Brokerage services include custody fees, commission income, trailing commissions and other investment securities. Custody fees are recognized on a monthly basis for customers that are assessed custody fees. Commission income is recognized at a point in time on trade date. Trailing commissions such as 12b-1 fees, insurance renewal income, and income based on asset or investment levels in future periods are recognized at a point in time when the asset balance is known, or the renewal occurs and the income is no longer constrained. For the three and nine months ended September 30, 2018 , the Company recognized trailing commissions of $4 million and $12 million , respectively, related to services provided in previous reporting periods. Fees from other investment services are recognized at a point in time upon completion of the service. O ther Banking Fees Other banking fees include fees for various transactional banking activities such as letter of credit fees, foreign wire transfers and other transactional services. These fees are recognized in a manner that reflects the timing of when transactions occur and as services are provided. Revenue from Other Sources Letter of Credit and Loan Fees Letter of credit and loan fees primarily includes fees received related to letter of credit agreements as well as loan fees received from lending activities that are not deferrable. These fees are generally recognized upon execution of the contract. Foreign Exchange and Interest Rate Products Foreign exchange and interest rate products primarily includes the fees received from foreign exchange and interest rate derivative contracts executed with customers to meet their hedging and financing needs. These fees are generally recognized upon execution of the contracts. Foreign exchange and interest rate products also include the mark-to-market gains and losses recognized on (i) these customer contracts and (ii) offsetting derivative contracts that are executed with external counterparties to hedge the foreign exchange and interest rate risk associated with the customer contracts. Mortgage Banking Fees Mortgage banking fees primarily include gains on sales of residential mortgages originated with the intent to sell and servicing fees on mortgages where the Company is the servicer. Mortgage banking fees also include valuation adjustments for mortgage loans held-for-sale that are measured at the lower of cost or fair value, as well as mortgage loans originated with the intent to sell that are measured at fair value under the fair value option. Changes in the value of MSRs are reported in mortgage fees and related income. For a further discussion of MSRs, see Note 5 “Mortgage Banking.” Net interest income from mortgage loans is recorded in interest income. Other Income Bank-owned life insurance is stated at its cash surrender value. The Company is the beneficiary of the life insurance policies on current and former officers and selected employees of the Company. Net changes in the carrying amount of the cash surrender value are an adjustment of premiums paid in determining the expense or income to be recognized under the life insurance policy for the period. Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Bank-owned life insurance $14 $14 $42 $40

OTHER OPERATING EXPENSE

OTHER OPERATING EXPENSE	9 Months Ended
	Sep. 30, 2018
Other Income and Expenses [Abstract]
OTHER OPERATING EXPENSE	OTHER OPERATING EXPENSE The following table presents the details of other operating expense: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Deposit insurance $29 $34 $88 $102 Promotional expense 36 27 95 82 Settlements and operating losses 11 18 35 43 Other 55 54 160 178 Other operating expense $131 $133 $378 $405

INCOME TAXES

INCOME TAXES	9 Months Ended
	Sep. 30, 2018
Income Tax Disclosure [Abstract]
INCOME TAXES	INCOME TAXES Income Tax Expense Income tax expense was $133 million and $165 million for the three months ended September 30, 2018 and 2017 , respectively, resulting in effective income tax rates of 23.2% and 32.2% , respectively. Income tax expense was $370 million and $423 million for the nine months ended September 30, 2018 and 2017 , respectively, resulting in effective income tax rates of 22.8% and 30.0% , respectively. For the nine months ended September 30, 2018 , the effective income tax rate of 22.8% was higher than the statutory rate of 21% primarily as a result of state taxes and permanently disallowed expenses, partially offset by permanent benefits from tax credits and tax-exempt income. For the nine months ended September 30, 2017 , the effective income tax rate of 30.0% compared favorably to the statutory rate of 35% primarily as a result of the impact of the settlement of certain state tax matters and the permanent benefits from tax credits and tax-exempt income. Deferred Tax Liability At September 30, 2018 , the Company reported a net deferred tax liability of $430 million , compared to $571 million as of December 31, 2017 . The decrease in the net deferred tax liability was primarily attributable to the tax effect of net unrealized losses on securities and derivatives.

EARNINGS PER SHARE

EARNINGS PER SHARE	9 Months Ended
	Sep. 30, 2018
Earnings Per Share [Abstract]
EARNINGS PER SHARE	EARNINGS PER SHARE Three Months Ended September 30, Nine Months Ended September 30, (in millions, except share and per-share data) 2018 2017 2018 2017 Numerator (basic and diluted): Net income $443 $348 $1,256 $986 Less: Preferred stock dividends 7 7 14 14 Net income available to common stockholders $436 $341 $1,242 $972 Denominator: Weighted-average common shares outstanding - basic 475,957,526 500,861,076 482,691,884 505,529,991 Dilutive common shares: share-based awards 1,642,391 1,296,308 1,558,959 1,532,814 Weighted-average common shares outstanding - diluted 477,599,917 502,157,384 484,250,843 507,062,805 Earnings per common share: Basic $0.92 $0.68 $2.57 $1.92 Diluted 0.91 0.68 2.57 1.92 Potential dilutive common shares are excluded from the computation of diluted EPS in the periods where the effect would be antidilutive. The diluted EPS computation for the three and nine months ended September 30, 2018 did no t have any antidilutive shares. The diluted EPS computation for the three and nine months ended September 30, 2017 excluded 4 thousand and 378 thousand average share-based awards, respectively, because their inclusion would have been antidilutive.

REGULATORY MATTERS

REGULATORY MATTERS	9 Months Ended
	Sep. 30, 2018
Banking and Thrift [Abstract]
REGULATORY MATTERS	REGULATORY MATTERS As a bank holding company, the Company is subject to regulation and supervision by the FRB. The primary subsidiaries of the Company are its two insured depository institutions CBNA, a national banking association whose primary federal regulator is the OCC, and CBPA, a Pennsylvania-chartered savings bank regulated by the Department of Banking of the Commonwealth of Pennsylvania and supervised by the FDIC, its primary federal regulator. Under the U.S. Basel III capital framework, the Company and its banking subsidiaries must meet specific minimum requirements for the following ratios: common equity tier 1 capital, tier 1 capital, total capital, and tier 1 leverage. In addition, the Company must not be subject to a written agreement, order or capital directive with any of its regulators. Failure to meet minimum capital requirements can result in the initiation of certain actions that, if undertaken, could have a material effect on the Company’s Consolidated Financial Statements. The following table presents the Company’s capital and capital ratios under U.S. Basel III Standardized rules. The Company has declared itself as an “AOCI opt-out” institution, which means the Company is not required to recognize in regulatory capital the impacts of net unrealized gains and losses included within AOCI for securities that are available for sale or held to maturity, accumulated net gains and losses on cash-flow hedges, and certain defined benefit pension plan assets. Actual Minimum Capital Adequacy (in millions, except ratio data) Amount Ratio Amount Ratio (5) September 30, 2018 Common equity tier 1 capital (1) $14,435 10.8 % $8,495 6.375 % Tier 1 capital (2) 14,978 11.2 10,493 7.875 Total capital (3) 17,810 13.4 13,158 9.875 Tier 1 leverage (4) 14,978 9.9 6,029 4.000 December 31, 2017 Common equity tier 1 capital (1) $14,309 11.2 % $7,342 5.750 % Tier 1 capital (2) 14,556 11.4 9,258 7.250 Total capital (3) 17,781 13.9 11,812 9.250 Tier 1 leverage (4) 14,556 10.0 5,824 4.000 (1) “Common equity tier 1 capital ratio” represents CET1 capital divided by total risk-weighted assets as defined under U.S. Basel III Standardized approach. (2) “Tier 1 capital ratio” is tier 1 capital, which includes CET1 capital plus non-cumulative perpetual preferred equity that qualifies as additional tier 1 capital, divided by total risk-weighted assets as defined under U.S. Basel III Standardized approach. (3) “Total capital ratio” is total capital divided by total risk-weighted assets as defined under U.S. Basel III Standardized approach. (4) “Tier 1 leverage ratio” is tier 1 capital divided by quarterly average total assets as defined under U.S. Basel III Standardized approach. (5) “Minimum Capital ratio” includes capital conservation buffer of 1.875% for 2018 and 1.250% for 2017 ; N/A to Tier 1 leverage. Under the FRB’s Capital Plan Rule, the Company may only make capital distributions, including payment of dividends and share repurchases, in accordance with a capital plan that has been reviewed by the FRB with no objection. In accordance with federal and state banking regulations, dividends paid by the Company’s banking subsidiaries to the Parent Company are generally limited to the retained earnings of the respective banking subsidiaries unless specifically approved by the appropriate bank regulator. On April 5, 2018, the Company submitted its 2018 Capital Plan, Capital Policy and annual stress test results to the FRB as part of the 2018 CCAR process. On June 28, 2018, the FRB did not object to the Company’s 2018 Capital Plan including its proposed capital actions in the period beginning July 1, 2018 and ending June 30, 2019. The Company’s 2018 Capital Plan includes an increase in quarterly common dividends from $0.22 to $0.27 per share in the third quarter of 2018, with the potential to raise quarterly common dividends to $0.32 per share beginning in 2019, and common share repurchases of up to $1.02 billion through the second quarter of 2019. All future capital distributions are subject to consideration and approval by the Board of Directors prior to execution. The timing and exact amount of future dividends and share repurchases will depend on various factors, including the Company’s capital position, financial performance and market conditions. During the three months ended September 30, 2018 and 2017 , the Company declared and paid dividends on common stock of $129 million and $90 million , respectively, and declared semi-annual preferred dividends of $7 million for both periods. During the nine months ended September 30, 2018 and 2017 , the Company declared and paid dividends on common stock of $344 million and $233 million , respectively, and declared semi-annual preferred dividends of $14 million for both periods. During the three months ended September 30, 2018 and 2017 , the Parent Company repurchased $400 million and $225 million of its outstanding common stock, respectively. During the nine months ended September 30, 2018 and 2017 , the Parent Company repurchased $725 million and $485 million of its outstanding common stock, respectively.

BUSINESS OPERATING SEGMENTS

BUSINESS OPERATING SEGMENTS	9 Months Ended
	Sep. 30, 2018
Segment Reporting [Abstract]
BUSINESS OPERATING SEGMENTS	BUSINESS OPERATING SEGMENTS The Company is managed by its Chief Executive Officer on a segment basis. The Company’s two business operating segments are Consumer Banking and Commercial Banking. The business segments are determined based on the products and services provided, or the type of customer served. Each segment has one or more segment heads who report directly to the Chief Executive Officer. The Chief Executive Officer has final authority over resource allocation decisions and performance assessment. The business segments reflect this management structure and the manner in which financial information is currently evaluated by the Chief Executive Officer. Reportable Segments Segment results are determined based upon the Company’s management reporting system, which assigns balance sheet and statement of operations items to each of the business segments. The process is designed around the Company’s organizational and management structure and accordingly, the results derived are not necessarily comparable with similar information published by other financial institutions. A description of each reportable segment and table of financial results is presented below: Consumer Banking The Consumer Banking segment focuses on retail customers and small businesses with annual revenues of up to $25 million . It offers traditional banking products and services, including checking, savings, home loans, education loans, credit cards, business loans, and unsecured product finance and personal loans in addition to financial management services. It also operates an indirect auto financing business, providing financing for both new and used vehicles through auto dealerships. The segment’s distribution channels include a branch network, ATMs and a work force of experienced specialists ranging from financial consultants, mortgage loan officers and business banking officers to private bankers. The Company’s Consumer Banking value proposition is based on providing simple, easy to understand product offerings and a convenient banking experience with a more personalized approach. Commercial Banking The Commercial Banking segment primarily targets companies with annual revenues from $25 million to $2.5 billion and provides a full complement of financial products and solutions, including loans, leases, trade financing, deposits, cash management, commercial cards, foreign exchange, interest rate risk management, corporate finance and capital markets advisory capabilities. It focuses on middle-market companies, large corporations and institutions and has dedicated teams with industry expertise in government banking, not-for-profit, healthcare, technology, professionals, oil and gas, asset finance, franchise finance, asset-based lending, commercial real estate, private equity and sponsor finance. While the segment’s business development efforts are predominantly focused in the Company’s footprint, some of its specialized industry businesses also operate selectively on a national basis (such as healthcare, asset finance and franchise finance). A key component of Commercial Banking’s growth strategy is to bring ideas to clients that help their businesses thrive, and in doing so, expand the loan portfolio and ancillary product sales. Non-segment Operations Other Non-segment operations are classified as Other, which includes corporate functions, the Treasury function, the securities portfolio, wholesale funding activities, intangible assets, community development, non-core assets (including legacy Royal Bank of Scotland Group plc aircraft loans and leases placed in runoff in the third quarter of 2016), and other unallocated assets, liabilities, capital, revenues, provision for credit losses and expenses, including income tax expense. In addition to non-segment operations, Other includes goodwill and any associated goodwill impairment charges. For impairment testing purposes, the Company allocates goodwill to its Consumer Banking and Commercial Banking reporting units. As of and for the Three Months Ended September 30, 2018 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $776 $380 ($8 ) $1,148 Noninterest income 258 140 18 416 Total revenue 1,034 520 10 1,564 Noninterest expense 686 202 22 910 Profit (loss) before provision for credit losses 348 318 (12 ) 654 Provision for credit losses 71 14 (7 ) 78 Income (loss) before income tax expense (benefit) 277 304 (5 ) 576 Income tax expense (benefit) 70 70 (7 ) 133 Net income $207 $234 $2 $443 Total average assets $62,974 $52,871 $39,779 $155,624 As of and for the Three Months Ended September 30, 2017 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $674 $354 $34 $1,062 Noninterest income 227 136 18 381 Total revenue 901 490 52 1,443 Noninterest expense 648 195 15 858 Profit before provision for credit losses 253 295 37 585 Provision for credit losses 65 — 7 72 Income before income tax expense 188 295 30 513 Income tax expense 66 94 5 165 Net income $122 $201 $25 $348 Total average assets $60,012 $49,833 $40,167 $150,012 As of and for the Nine Months Ended September 30, 2018 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $2,268 $1,113 ($21 ) $3,360 Noninterest income 708 405 62 1,175 Total revenue 2,976 1,518 41 4,535 Noninterest expense 2,000 610 58 2,668 Profit (loss) before provision for credit losses 976 908 (17 ) 1,867 Provision for credit losses 209 19 13 241 Income (loss) before income tax expense (benefit) 767 889 (30 ) 1,626 Income tax expense (benefit) 193 203 (26 ) 370 Net income (loss) $574 $686 ($4 ) $1,256 Total average assets $61,857 $51,820 $39,805 $153,482 As of and for the Nine Months Ended September 30, 2017 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $1,969 $1,044 $80 $3,093 Noninterest income 676 400 54 1,130 Total revenue 2,645 1,444 134 4,223 Noninterest expense 1,939 577 60 2,576 Profit before provision for credit losses 706 867 74 1,647 Provision for credit losses 189 20 29 238 Income before income tax expense (benefit) 517 847 45 1,409 Income tax expense (benefit) 182 279 (38 ) 423 Net income $335 $568 $83 $986 Total average assets $59,310 $49,604 $40,649 $149,563 Management accounting practices utilized by the Company as the basis of presentation for segment results include the following: FTP adjustments The Company utilizes an FTP system to eliminate the effect of interest rate risk from the segments’ net interest income because such risk is centrally managed within the Treasury function. The FTP system credits (or charges) the segments with the economic value of the funds created (or used) by the segments. The FTP system provides a funds credit for sources of funds and a funds charge for the use of funds by each segment. The sum of the interest income/expense and FTP charges/credits for each segment is its designated net interest income. The variance between the Company’s cumulative FTP charges and cumulative FTP credits is offset in Other. The Company periodically evaluates and refines its methodologies used to measure financial performance of its business operating segments. In the first quarter of 2018, the Company enhanced its assumptions for the liquidity and deposit component within its FTP methodology. The enhancement largely provides increased credit for the stability of deposit composition, and an increased charge for unused commitments under lending arrangements. Prior periods have not been adjusted for this change. Provision for credit losses allocations Provision for credit losses is allocated to each business segment based on actual net charge-offs recognized by the business segment. The difference between the consolidated provision for credit losses and the business segments’ net charge-offs is reflected in Other. Income tax allocations Income taxes are assessed to each line of business at a standard tax rate with the residual tax expense or benefit to arrive at the consolidated effective tax rate included in Other. Expense allocations Noninterest expenses incurred by centrally managed operations or business lines that directly support another business line’s operations are charged to the applicable business line based on its utilization of those services. Substantially all revenues generated and long-lived assets held by the Company’s business segments are derived from clients that reside in the United States. Neither business segment earns revenue from a single external customer that represents ten percent or more of the Company’s total revenues.

BASIS OF PRESENTATION (Policies

BASIS OF PRESENTATION (Policies)	9 Months Ended
	Sep. 30, 2018
Organization, Consolidation and Presentation of Financial Statements [Abstract]
Basis of Presentation	The unaudited interim Consolidated Financial Statements, including the Notes thereto of Citizens Financial Group, Inc., have been prepared in accordance with GAAP interim reporting requirements, and therefore do not include all information and Notes included in the audited Consolidated Financial Statements in conformity with GAAP. These unaudited interim Consolidated Financial Statements and Notes thereto should be read in conjunction with the Company’s audited Consolidated Financial Statements and accompanying Notes included in the Company’s Annual Report on Form 10-K for the year ended December 31, 2017. The Company’s principal business activity is banking, conducted through its subsidiaries, Citizens Bank, National Association and Citizens Bank of Pennsylvania.
Consolidation	The unaudited interim Consolidated Financial Statements include the accounts of the Company and subsidiaries in which the Company has a controlling financial interest. All intercompany transactions and balances have been eliminated. The Company has evaluated its unconsolidated entities and does not believe that any entity in which it has an interest, but does not currently consolidate, meets the requirements to be consolidated as a variable interest entity.
Use of Estimates	The preparation of financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. Material estimates that are particularly susceptible to significant change in the near-term relate to the determination of the ACL, evaluation of unrealized losses on securities for other-than-temporary impairment, accounting for income taxes, the valuation of AFS and HTM securities, and derivatives.
Adopted and Pending Accounting Pronouncements	Accounting Pronouncements Adopted in 2018 Pronouncement Summary of Guidance Effects on Financial Statements Revenue Recognition: Revenue from Contracts with Customers Issued May 2014 • Requires that revenue from contracts with customers be recognized upon transfer of control of a good or service in the amount of consideration expected to be received. • Changes the accounting for certain contract costs including whether they may be offset against revenues in the Consolidated Statements of Operations. • Requires new qualitative and quantitative disclosures, including information about disaggregation of revenue and performance obligations. • May be adopted using a full retrospective approach or a modified cumulative effect approach wherein the guidance is applied only to existing contracts as of the date of initial adoption and to new contracts transacted after that date. • The Company adopted the new standard on January 1, 2018 under the modified retrospective method. Net interest income on financial assets and liabilities is explicitly excluded from the scope of the pronouncement. • Adoption of the new standard did not result in a change in the timing or amount of revenue recognized from contracts with customers. The Company did not recognize a cumulative adjustment to Retained Earnings upon adoption. • Effective January 1, 2018, underwriting fees are presented on a gross basis in capital market fees, while underwriting costs are presented in other operating expense. Prior to adoption, such costs were presented net of the related underwriting fees. Stock Compensation Issued May 2017 • Requires modification accounting unless the fair value, vesting conditions, and classification of the modified award are the same as the original award immediately before the modification. • Applied prospectively to all modifications of share-based awards after the adoption date. • The Company adopted the new standard as of January 1, 2018. • Adoption did not have an impact on the Company’s Consolidated Financial Statements. Presentation of Net Periodic Pension Cost and Net Periodic Postretirement Benefit Cost • Requires the service cost component of net periodic pension and postretirement benefit cost to be reported separately in the Consolidated Statements of Operations from the other components (e.g., expected return on assets, interest costs, amortization of gains/losses and prior service costs). • Requires presentation in the Consolidated Statements of Operations of the service cost component in the same line item as other employee compensation costs and presentation of the other components in a different line item from the service cost component. • Retrospective application is required for all periods presented. • The Company retrospectively adopted the new standard as of January 1, 2018. • Adoption did not have an impact on the Company’s net income. • The Company reclassified prior period amounts in the Consolidated Statement of Operations, which resulted in an immaterial increase in salaries and employee benefits and a corresponding decrease in other operating expense. Recognition and Measurement of Financial Assets and Financial Liabilities Issued January 2016 • Requires equity securities with readily determinable fair values to be measured at fair value on the balance sheet, with changes in the fair value recognized through earnings. • Requires separate presentation of financial assets and financial liabilities by measurement category and form of financial assets on the balance sheet or in the notes to the financial statements. • Makes several other targeted amendments to the existing accounting and disclosure requirements for financial instruments, including revised guidance related to valuation allowance assessments when recognizing deferred tax assets on unrealized losses on debt securities available for sale. • The Company adopted the new standard as of January 1, 2018. • Adoption had an immaterial impact on the Company’s Consolidated Financial Statements. Classification of Certain Cash Receipts and Cash Payments Issued August 2016 • Amends guidance on specific cashflows to determine the appropriate classification as operating, investing or financing activities which has required significant judgment. • The application of judgment has resulted in diversity in how certain cash receipts and cash payments are classified. • The Company adopted the new standard as of January 1, 2018. • Adoption did not have an impact on the Company’s Consolidated Financial Statements. Accounting Pronouncements Pending Adoption Pronouncement Summary of Guidance Effects on Financial Statements Derivatives and Hedging Issued August 2017 • Reduces the complexity and operational burdens of the current hedge accounting model and portrays more clearly the effects of hedge accounting in the financial statements. • Modifies current requirements to facilitate the application of hedge accounting to partial-term hedges, hedges of prepayable financial instruments, and other strategies. Adoption of these optional changes would occur on a prospective basis. • Requires the effects of fair value hedges to be classified in the same income statement line as the earnings effect of the hedged item. Adoption of this change will occur on a prospective basis. • Requires all effects of cash flow hedges to be deferred in other comprehensive income until the hedged cash flows affect earnings. Periodic hedge ineffectiveness will no longer be recognized in earnings. Adoption of this change will occur on a modified retrospective basis through a cumulative-effect adjustment directly to retained earnings as of the beginning of the period of adoption. • Required effective date: January 1, 2019. Early adoption is permitted. The Company does not intend to adopt the guidance prior to the required effective date. • The transition entries required upon adoption are not expected to have a material impact on the Company’s Consolidated Financial Statements. Leases Issued February 2016 • Requires lessees to recognize a right-of-use asset and corresponding lease liability for all leases with a lease term of greater than one year. • Requires lessees and lessors to classify most leases using principles similar to existing lease accounting, but eliminates the “bright line” classification tests. • Requires that for finance leases, a lessee recognize interest expense on the lease liability separately from the amortization of the right-of-use asset in the Consolidated Statements of Operations, while for operating leases, such amounts should be recognized as a combined expense. • Requires expanded disclosures about the nature and terms of lease agreements. • Provides the option to adopt using either a modified cumulative-effect approach wherein the guidance is applied to all periods presented, or through a cumulative-effect adjustment beginning in the period of adoption. • Requires companies with land easements to assess whether the easement meets the definition of a lease before applying other accounting guidance. • Required effective date: January 1, 2019. Early adoption is permitted. The Company does not intend to adopt the guidance prior to the effective date. • The Company intends to adopt the guidance through a cumulative-effect adjustment to retained earnings on January 1, 2019. Periods prior to January 1, 2019 will not be adjusted. • The Company occupies certain banking offices and equipment under non-cancelable operating lease agreements, which currently are not reflected on its Consolidated Balance Sheets. • Upon adoption, the Company expects to recognize a right-of-use asset and corresponding lease liability in the approximate range of $600 million to $750 million in its Consolidated Balance Sheets for non-cancelable operating lease agreements. • The evaluation of the impact of the leasing pronouncement will be adjusted based on execution of new leases, termination of existing leases prior to the effective date, and any changes to key lease assumptions such as renewals, extensions and discount rates. • The Company does not expect a material change to the timing of expense recognition on the Consolidated Statements of Operations. Financial Instruments - Credit Losses Issued June 2016 • Replaces existing incurred loss impairment guidance and establishes a single allowance framework for financial assets carried at amortized cost (including securities HTM), which will reflect management’s estimate of credit losses over the full remaining expected life of the financial assets. • Amends existing impairment guidance for securities AFS to incorporate an allowance, which will allow for reversals of impairment losses in the event that the credit of an issuer improves. • Requires a cumulative-effect adjustment to retained earnings as of the beginning of the reporting period of adoption. • Required effective date: January 1, 2020. Early adoption permitted on January 1, 2019. The Company does not intend to adopt the guidance prior to the required effective date. • A company-wide, cross-discipline governance structure to implement the new standard has been in place for more than 18 months. The Company is currently identifying and researching key interpretive issues and completing the development of most loss forecasting models to meet the requirements of the new guidance. The implementation team is also in the process of assessing forecast accuracy and potential macroeconomic factors that will be used to determine the reasonable and supportable forecast period. • The Company expects the standard will result in earlier recognition of credit losses and an increase in the ACL, as it will cover estimated credit losses over the full remaining expected life of loans and commitments and will consider future reasonable and supportable changes in macroeconomic conditions. Since the magnitude of the increase in the Company’s ACL will be impacted by economic conditions, forecasted economic conditions, credit quality and trends in the Company’s portfolio at the time of adoption, the quantitative impact cannot yet be reasonably estimated. Implementation Costs Incurred in a Cloud Computing Arrangement Issued August 2018 • Requires implementation costs incurred in a cloud computing arrangement that is a service contract be deferred and recognized over the term of the arrangement if those costs would be capitalized in a software licensing arrangement. • Requires amortization expense be presented in the same income statement line item as the related hosting service arrangement expense. • Permits adoption prospectively for all implementation costs incurred after adoption or retrospectively through a cumulative-effect adjustment as of the beginning of the first period presented. • Required effective date: January 1, 2020. Early adoption is permitted. The Company is evaluating whether it will adopt this guidance prior to the required effective date. • Adoption is not expected to have a material impact on the Company’s Consolidated Financial Statements. Disclosure Requirements - Fair Value Measurements Issued August 2018 • Amends disclosure requirements on fair value measurements. • The guidance eliminates requirements for certain disclosures that are no longer considered relevant or cost beneficial, requires new disclosures and modifies existing disclosures that are expected to enhance the usefulness of the financial statements. • Prospective application is required for new disclosure requirements. • Retrospective application is required for all other amendments for all periods presented. • Required effective date: January 1, 2020. Early adoption is permitted. The Company is evaluating whether it will adopt this guidance prior to the required effective date. • Adoption is not expected to have a material impact on the Company’s Consolidated Financial Statements. Disclosure Requirements - Defined Benefit Plan Issued August 2018 • Amends disclosure requirements for employers that sponsor defined benefit pension and/or other postretirement defined benefit plans. • The guidance eliminates requirements for certain disclosures that are no longer considered relevant or cost beneficial and requires new disclosures that are expected to enhance the usefulness of the financial statements. • Retrospective application is required for all periods presented. • Required effective date: January 1, 2021. Early adoption is permitted. The Company is evaluating whether it will adopt this guidance prior to the required effective date. • Adoption is not expected to have a material impact on the Company’s Consolidated Financial Statements.

SECURITIES (Tables)

SECURITIES (Tables)	9 Months Ended
	Sep. 30, 2018
Investments, Debt and Equity Securities [Abstract]
Schedule of securities held	The following table presents the major components of securities at amortized cost and fair value: September 30, 2018 December 31, 2017 (in millions) Amortized Cost Gross Unrealized Gains Gross Unrealized Losses Fair Value Amortized Cost Gross Unrealized Gains Gross Unrealized Losses Fair Value Debt Securities Available for Sale, at Fair Value U.S. Treasury and other $12 $— $— $12 $12 $— $— $12 State and political subdivisions 5 — — 5 6 — — 6 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities 20,703 8 (825 ) 19,886 20,065 40 (277 ) 19,828 Other/non-agency 251 4 (6 ) 249 311 7 (7 ) 311 Total mortgage-backed securities 20,954 12 (831 ) 20,135 20,376 47 (284 ) 20,139 Total debt securities available for sale, at fair value $20,971 $12 ($831 ) $20,152 $20,394 $47 ($284 ) $20,157 Debt Securities Held to Maturity Mortgage-backed securities: Federal agencies and U.S. government sponsored entities $3,525 $— ($177 ) $3,348 $3,853 $7 ($46 ) $3,814 Other/non-agency 759 1 (6 ) 754 832 22 — 854 Total mortgage-backed securities 4,284 1 (183 ) 4,102 4,685 29 (46 ) 4,668 Total debt securities held to maturity $4,284 $1 ($183 ) $4,102 $4,685 $29 ($46 ) $4,668 Equity Securities, at Fair Value Money market mutual fund investments $175 $— $— $175 $165 $— $— $165 Other investments — — — — 4 — — 4 Total equity securities, at fair value $175 $— $— $175 $169 $— $— $169 Equity Securities, at Cost Federal Reserve Bank stock $463 $— $— $463 $463 $— $— $463 Federal Home Loan Bank stock 404 — — 404 252 — — 252 Other equity securities 7 — — 7 7 — — 7 Total equity securities, at cost $874 $— $— $874 $722 $— $— $722
Schedule of investments classified by maturity date	The amortized cost and fair value of debt securities by contractual maturity as of September 30, 2018 are presented below. Expected maturities may differ from contractual maturities because issuers may have the right to call or prepay obligations with or without incurring penalties. September 30, 2018 Distribution of Maturities (in millions) 1 Year or Less 1-5 Years 5-10 Years After 10 Years Total Amortized Cost: Debt securities available for sale U.S. Treasury and other $12 $— $— $— $12 State and political subdivisions — — — 5 5 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — 312 1,595 18,796 20,703 Other/non-agency 2 11 — 238 251 Total debt securities available for sale 14 323 1,595 19,039 20,971 Debt securities held to maturity Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — — — 3,525 3,525 Other/non-agency — — — 759 759 Total debt securities held to maturity — — — 4,284 4,284 Total amortized cost of debt securities $14 $323 $1,595 $23,323 $25,255 Fair Value: Debt securities available for sale U.S. Treasury and other $12 $— $— $— $12 State and political subdivisions — — — 5 5 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — 306 1,555 18,025 19,886 Other/non-agency 2 11 — 236 249 Total debt securities available for sale 14 317 1,555 18,266 20,152 Debt securities held to maturity Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — — — 3,348 3,348 Other/non-agency — — — 754 754 Total debt securities held to maturity — — — 4,102 4,102 Total fair value of debt securities $14 $317 $1,555 $22,368 $24,254
Schedule of income recognized on investment securities	Realized gains and losses on securities are presented below: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Gains on sale of debt securities $3 $2 $13 $9 Losses on sale of debt securities — — — — Debt securities gains, net $3 $2 $13 $9 Equity securities gains $— $— $— $1
Schedule of financial instruments owned and pledged as collateral	The amortized cost and fair value of debt securities pledged are presented below: September 30, 2018 December 31, 2017 (in millions) Amortized Cost Fair Value Amortized Cost Fair Value Pledged against repurchase agreements $391 $376 $358 $357 Pledged against FHLB borrowed funds 764 760 839 861 Pledged against derivatives, to qualify for fiduciary powers, and to secure public and other deposits as required by law 3,699 3,519 3,113 3,082
Schedule of unrealized loss on investments	The following tables present mortgage-backed debt securities whose fair values are below carrying values, segregated by those that have been in a continuous unrealized loss position for less than twelve months and those that have been in a continuous unrealized loss position for twelve months or longer: September 30, 2018 Less than 12 Months 12 Months or Longer Total (dollars in millions) Number of Issues Fair Value Gross Unrealized Losses Number of Issues Fair Value Gross Unrealized Losses Number of Issues Fair Value Gross Unrealized Losses Federal agencies and U.S. government sponsored entities 493 $15,177 ($514 ) 159 $7,215 ($488 ) 652 $22,392 ($1,002 ) Other/non-agency 14 542 (6 ) 11 76 (6 ) 25 618 (12 ) Total 507 $15,719 ($520 ) 170 $7,291 ($494 ) 677 $23,010 ($1,014 ) December 31, 2017 Less than 12 Months 12 Months or Longer Total (dollars in millions) Number of Issues Fair Value Gross Unrealized Losses Number of Issues Fair Value Gross Unrealized Losses Number of Issues Fair Value Gross Unrealized Losses Federal agencies and U.S. government sponsored entities 294 $10,163 ($97 ) 152 $8,061 ($226 ) 446 $18,224 ($323 ) Other/non-agency 6 55 (1 ) 10 84 (6 ) 16 139 (7 ) Total 300 $10,218 ($98 ) 162 $8,145 ($232 ) 462 $18,363 ($330 )
Schedule of credit losses recognized in earnings	The following table presents the cumulative credit-related losses recognized in earnings on debt securities held by the Company: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Cumulative balance at beginning of period $81 $79 $80 $75 Credit impairments recognized in earnings on debt securities that have been previously impaired 1 1 3 6 Reductions due to increases in cash flow expectations on impaired debt securities (1) (1 ) — (2 ) (1 ) Cumulative balance at end of period $81 $80 $81 $80 (1) Reported in interest income from investment securities on the Consolidated Statements of Operations.

LOANS AND LEASES (Tables)

LOANS AND LEASES (Tables)	9 Months Ended
	Sep. 30, 2018
Receivables [Abstract]
Schedule of loans and leases	A summary of the loans and leases portfolio is presented below: (in millions) September 30, 2018 December 31, 2017 Commercial $39,770 $37,562 Commercial real estate 12,630 11,308 Leases 3,005 3,161 Total commercial loans and leases 55,405 52,031 Residential mortgages 18,493 17,045 Home equity loans 1,131 1,392 Home equity lines of credit 12,863 13,483 Home equity loans serviced by others 429 542 Home equity lines of credit serviced by others 114 149 Automobile 12,255 13,204 Education 8,712 8,134 Credit cards 1,911 1,848 Other retail 3,407 2,789 Total retail loans 59,315 58,586 Total loans and leases (1) (2) $114,720 $110,617 (1) Excluded from the table above are loans held for sale totaling $1.3 billion and $718 million as of September 30, 2018 and December 31, 2017 , respectively. (2) Mortgage loans serviced for others by the Company’s subsidiaries are not included above, and amounted to $67.5 billion and $20.3 billion at September 30, 2018 and December 31, 2017 , respectively.

ALLOWANCE FOR CREDIT LOSSES, _2

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK (Tables)	9 Months Ended
	Sep. 30, 2018
Receivables [Abstract]
Schedule of changes in the allowance for credit losses	A summary of changes in the ACL is presented below: Three Months Ended September 30, 2018 Nine Months Ended September 30, 2018 (in millions) Commercial Retail Total Commercial Retail Total Allowance for loan and lease losses, beginning of period $715 $538 $1,253 $685 $551 $1,236 Charge-offs (18 ) (109 ) (127 ) (35 ) (328 ) (363 ) Recoveries 2 39 41 10 121 131 Net charge-offs (16 ) (70 ) (86 ) (25 ) (207 ) (232 ) Provision charged to income 8 67 75 47 191 238 Allowance for loan and lease losses, end of period 707 535 1,242 707 535 1,242 Reserve for unfunded lending commitments, beginning of period 88 — 88 88 — 88 Provision for unfunded lending commitments 3 — 3 3 — 3 Reserve for unfunded lending commitments, end of period 91 — 91 91 — 91 Total allowance for credit losses, end of period $798 $535 $1,333 $798 $535 $1,333 Three Months Ended September 30, 2017 Nine Months Ended September 30, 2017 (in millions) Commercial Retail Total Commercial Retail Total Allowance for loan and lease losses, beginning of period $614 $605 $1,219 $663 $573 $1,236 Charge-offs (12 ) (108 ) (120 ) (60 ) (321 ) (381 ) Recoveries 12 43 55 27 127 154 Net charge-offs — (65 ) (65 ) (33 ) (194 ) (227 ) Provision charged to income 24 46 70 8 207 215 Allowance for loan and lease losses, end of period 638 586 1,224 638 586 1,224 Reserve for unfunded lending commitments, beginning of period 93 — 93 72 — 72 Provision for unfunded lending commitments 2 — 2 23 — 23 Reserve for unfunded lending commitments, end of period 95 — 95 95 — 95 Total allowance for credit losses, end of period $733 $586 $1,319 $733 $586 $1,319
Schedule of loans and leases based on evaluation method	The recorded investment in loans and leases based on the Company’s evaluation methodology is presented below: September 30, 2018 December 31, 2017 (in millions) Commercial Retail Total Commercial Retail Total Individually evaluated $430 $735 $1,165 $370 $761 $1,131 Formula-based evaluation 54,975 58,580 113,555 51,661 57,825 109,486 Total loans and leases $55,405 $59,315 $114,720 $52,031 $58,586 $110,617
Schedule of allowance for credit losses by evaluation method	A summary of the ACL by evaluation method is presented below: September 30, 2018 December 31, 2017 (in millions) Commercial Retail Total Commercial Retail Total Individually evaluated $59 $27 $86 $47 $34 $81 Formula-based evaluation 739 508 1,247 726 517 1,243 Allowance for credit losses $798 $535 $1,333 $773 $551 $1,324
Schedule of classes of commercial loans and leases based on regulatory classifications	The recorded investment in commercial loans and leases based on regulatory classification ratings is presented below: September 30, 2018 Criticized (in millions) Pass Special Mention Substandard Doubtful Total Commercial $37,242 $1,441 $854 $233 $39,770 Commercial real estate 12,193 282 127 28 12,630 Leases 2,909 49 47 — 3,005 Total commercial loans and leases $52,344 $1,772 $1,028 $261 $55,405 December 31, 2017 Criticized (in millions) Pass Special Mention Substandard Doubtful Total Commercial $35,430 $1,143 $785 $204 $37,562 Commercial real estate 10,706 500 74 28 11,308 Leases 3,069 73 19 — 3,161 Total commercial loans and leases $49,205 $1,716 $878 $232 $52,031
Schedule of retail loan investments categorized by delinquency status	The recorded investment in classes of retail loans, categorized by delinquency status is presented below: September 30, 2018 Days Past Due (in millions) Current 1-29 30-59 60-89 90 or More Total Residential mortgages $18,173 $136 $37 $13 $134 $18,493 Home equity loans 999 79 11 3 39 1,131 Home equity lines of credit 12,214 383 55 25 186 12,863 Home equity loans serviced by others 382 24 6 2 15 429 Home equity lines of credit serviced by others 87 17 2 1 7 114 Automobile 10,849 1,109 189 51 57 12,255 Education 8,514 151 24 13 10 8,712 Credit cards 1,814 57 14 9 17 1,911 Other retail 3,291 69 20 15 12 3,407 Total retail loans $56,323 $2,025 $358 $132 $477 $59,315 December 31, 2017 Days Past Due (in millions) Current 1-29 30-59 60-89 90 or More Total Residential mortgages $16,714 $147 $46 $18 $120 $17,045 Home equity loans 1,212 102 20 4 54 1,392 Home equity lines of credit 12,756 438 78 23 188 13,483 Home equity loans serviced by others 477 29 10 4 22 542 Home equity lines of credit serviced by others 116 21 4 1 7 149 Automobile 11,596 1,273 220 55 60 13,204 Education 7,898 160 23 12 41 8,134 Credit cards 1,747 63 12 9 17 1,848 Other retail 2,679 68 20 12 10 2,789 Total retail loans $55,195 $2,301 $433 $138 $519 $58,586
Schedule of nonperforming loans and leases by class	The following table presents nonperforming loans and leases and loans accruing and 90 days or more past due: Nonperforming Accruing and 90 days or more past due (in millions) September 30, 2018 December 31, 2017 September 30, 2018 December 31, 2017 Commercial $228 $238 $— $5 Commercial real estate 30 27 — 3 Leases — — — — Total commercial loans and leases 258 265 — 8 Residential mortgages (1) 136 128 16 16 Home equity loans 53 72 — — Home equity lines of credit 221 233 — — Home equity loans serviced by others 19 25 — — Home equity lines of credit serviced by others 16 18 — — Automobile 67 70 — — Education 38 38 3 3 Credit card 17 17 — — Other retail 7 5 6 5 Total retail loans 574 606 25 24 Total $832 $871 $25 $32 (1) Nonperforming balances exclude first lien residential mortgage loans that are 100% guaranteed by the Federal Housing Administration. These loans, which are accruing and 90 days or more past due, totaled $13 million and $15 million as of September 30, 2018 and December 31, 2017 , respectively. Nonperforming balances also exclude guaranteed residential mortgage loans sold to GNMA for which the Company has the right, but not the obligation, to repurchase. These loans totaled $116 million and $30 million as of September 30, 2018 and December 31, 2017 , respectively. These loans are included in the Company’s Consolidated Balance Sheets.
Summary of key performance indicators	A summary of nonperforming loan and lease key performance indicators is presented below: September 30, 2018 December 31, 2017 Nonperforming commercial loans and leases as a percentage of total loans and leases 0.23 % 0.24 % Nonperforming retail loans as a percentage of total loans and leases 0.50 0.55 Total nonperforming loans and leases as a percentage of total loans and leases 0.73 % 0.79 % Nonperforming commercial assets as a percentage of total assets 0.16 % 0.17 % Nonperforming retail assets as a percentage of total assets 0.38 % 0.43 % Total nonperforming assets as a percentage of total assets 0.54 % 0.60 %
Analysis of age of past due amounts	An analysis of the age of both accruing and nonaccruing loan and lease past due amounts is presented below: September 30, 2018 December 31, 2017 Days Past Due Days Past Due (in millions) 30-59 60-89 90 or More Total 30-59 60-89 90 or More Total Commercial $46 $3 $94 $143 $26 $4 $243 $273 Commercial real estate 46 7 27 80 38 20 30 88 Leases — — — — 4 1 — 5 Total commercial loans and leases 92 10 121 223 68 25 273 366 Residential mortgages 37 13 134 184 46 18 120 184 Home equity loans 11 3 39 53 20 4 54 78 Home equity lines of credit 55 25 186 266 78 23 188 289 Home equity loans serviced by others 6 2 15 23 10 4 22 36 Home equity lines of credit serviced by others 2 1 7 10 4 1 7 12 Automobile 189 51 57 297 220 55 60 335 Education 24 13 10 47 23 12 41 76 Credit cards 14 9 17 40 12 9 17 38 Other retail 20 15 12 47 20 12 10 42 Total retail loans 358 132 477 967 433 138 519 1,090 Total $450 $142 $598 $1,190 $501 $163 $792 $1,456
Schedule of impaired loans by class	A summary of impaired loans by class is presented below: September 30, 2018 (in millions) Impaired Loans With a Related Allowance Allowance on Impaired Loans Impaired Loans Without a Related Allowance Unpaid Contractual Balance Total Recorded Investment in Impaired Loans Commercial $237 $52 $133 $439 $370 Commercial real estate 31 7 29 78 60 Leases — — — — — Total commercial loans and leases 268 59 162 517 430 Residential mortgages 28 2 128 201 156 Home equity loans 34 3 72 145 106 Home equity lines of credit 18 1 190 253 208 Home equity loans serviced by others 23 2 20 57 43 Home equity lines of credit serviced by others 2 — 7 12 9 Automobile 2 — 23 31 25 Education 134 11 23 158 157 Credit cards 24 7 — 25 24 Other retail 4 1 3 8 7 Total retail loans 269 27 466 890 735 Total $537 $86 $628 $1,407 $1,165 December 31, 2017 (in millions) Impaired Loans With a Related Allowance Allowance on Impaired Loans Impaired Loans Without a Related Allowance Unpaid Contractual Balance Total Recorded Investment in Impaired Loans Commercial $183 $42 $159 $403 $342 Commercial real estate 25 5 3 40 28 Leases — — — — — Total commercial loans and leases 208 47 162 443 370 Residential mortgages 25 2 126 197 151 Home equity loans 41 4 80 162 121 Home equity lines of credit 16 1 181 241 197 Home equity loans serviced by others 29 2 22 67 51 Home equity lines of credit serviced by others 2 — 7 14 9 Automobile 2 — 21 30 23 Education 154 17 21 175 175 Credit cards 24 7 1 25 25 Other retail 5 1 4 10 9 Total retail loans 298 34 463 921 761 Total $506 $81 $625 $1,364 $1,131
Schedule of additional information on impaired loans	Additional information on impaired loans is presented below: Three Months Ended September 30, 2018 2017 (in millions) Interest Income Recognized Average Recorded Investment Interest Income Recognized Average Recorded Investment Commercial $3 $334 $1 $391 Commercial real estate — 34 — 33 Leases — — — — Total commercial loans and leases 3 368 1 424 Residential mortgages 1 154 — 137 Home equity loans 1 107 1 125 Home equity lines of credit 2 202 2 192 Home equity loans serviced by others 1 43 — 51 Home equity lines of credit serviced by others — 9 — 9 Automobile — 23 — 21 Education 3 160 3 178 Credit cards — 24 — 25 Other retail — 7 — 10 Total retail loans 8 729 6 748 Total $11 $1,097 $7 $1,172 Nine Months Ended September 30, 2018 2017 (in millions) Interest Income Recognized Average Recorded Investment Interest Income Recognized Average Recorded Investment Commercial $7 $318 $3 $402 Commercial real estate — 33 — 39 Leases — — — — Total commercial loans and leases 7 351 3 441 Residential mortgages 4 148 3 128 Home equity loans 4 107 4 124 Home equity lines of credit 6 189 5 178 Home equity loans serviced by others 2 44 2 51 Home equity lines of credit serviced by others — 9 — 9 Automobile — 21 — 18 Education 7 159 7 178 Credit cards 1 22 1 23 Other retail — 7 — 10 Total retail loans 24 706 22 719 Total $31 $1,057 $25 $1,160
Troubled debt restructurings on financing receivables	The table below summarizes TDRs by class and total unfunded commitments: (in millions) September 30, 2018 December 31, 2017 Commercial $253 $129 Retail 735 761 Unfunded commitments tied to TDRs 28 39 The table below summarizes how loans were modified during the three months ended September 30, 2018 , the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during the three months ended September 30, 2018 and were paid off in full, charged off, or sold prior to September 30, 2018 . Primary Modification Types Interest Rate Reduction (1) Maturity Extension (2) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Commercial 1 $— $— 13 $1 $1 Commercial real estate — — — — — — Total commercial loans 1 — — 13 1 1 Residential mortgages 9 1 1 17 2 2 Home equity loans 10 — 1 — — — Home equity lines of credit 27 3 3 58 10 10 Home equity loans serviced by others 2 — — — — — Home equity lines of credit serviced by others 1 — — — — — Automobile 45 1 — 9 — — Education — — — — — — Credit cards 623 4 4 — — — Other retail — — — — — — Total retail loans 717 9 9 84 12 12 Total 718 $9 $9 97 $13 $13 Primary Modification Types Other (3) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Net Change to ALLL Resulting from Modification Charge-offs Resulting from Modification Commercial 1 $— $— $— $— Commercial real estate — — — — — Total commercial loans 1 — — — — Residential mortgages 31 4 3 (1 ) — Home equity loans 40 2 2 — — Home equity lines of credit 104 7 7 — — Home equity loans serviced by others 5 1 1 — — Home equity lines of credit serviced by others 8 — — — — Automobile 315 5 4 — 2 Education 45 1 1 1 — Credit cards — — — 1 — Other retail — — — — — Total retail loans 548 20 18 1 2 Total 549 $20 $18 $1 $2 (1) Includes modifications that consist of multiple concessions, one of which is an interest rate reduction. (2) Includes modifications that consist of multiple concessions, one of which is a maturity extension (unless one of the other concessions was an interest rate reduction). (3) Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forgiveness, and capitalizing arrearages. Also included are the following: deferrals, trial modifications, certain bankruptcies, loans in forbearance and prepayment plans. Modifications can include the deferral of accrued interest resulting in post modification balances being higher than pre-modification. The table below summarizes how loans were modified during the three months ended September 30, 2017 , the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during the three months ended September 30, 2017 and were paid off in full, charged off, or sold prior to September 30, 2017 . Primary Modification Types Interest Rate Reduction (1) Maturity Extension (2) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Commercial 3 $1 $1 17 $8 $7 Commercial real estate — — — 1 — — Total commercial loans 3 1 1 18 8 7 Residential mortgages 13 1 2 15 1 2 Home equity loans 25 2 1 — — — Home equity lines of credit 11 1 1 86 11 11 Home equity loans serviced by others 3 — — — — — Home equity lines of credit serviced by others — — — — — — Automobile 28 1 1 8 — — Education — — — — — — Credit cards 661 3 3 — — — Other retail — — — — — — Total retail loans 741 8 8 109 12 13 Total 744 $9 $9 127 $20 $20 Primary Modification Types Other (3) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Net Change to ALLL Resulting from Modification Charge-offs Resulting from Modification Commercial 7 $28 $30 $— $— Commercial real estate 1 — — — — Total commercial loans 8 28 30 — — Residential mortgages 38 3 3 (1 ) — Home equity loans 49 3 3 — — Home equity lines of credit 110 6 7 — 1 Home equity loans serviced by others 11 1 — — — Home equity lines of credit serviced by others 8 1 — — — Automobile 392 7 6 — 1 Education 67 2 2 — — Credit cards — — — 1 — Other retail 2 — — — — Total retail loans 677 23 21 — 2 Total 685 $51 $51 $— $2 (1) Includes modifications that consist of multiple concessions, one of which is an interest rate reduction. (2) Includes modifications that consist of multiple concessions, one of which is a maturity extension (unless one of the other concessions was an interest rate reduction). (3) Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forgiveness, and capitalizing arrearages. Also included are the following: deferrals, trial modifications, certain bankruptcies, loans in forbearance and prepayment plans. Modifications can include the deferral of accrued interest resulting in post modification balances being higher than pre-modification. The table below summarizes how loans were modified during the nine months ended September 30, 2018 , the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during the nine months ended September 30, 2018 and were paid off in full, charged off, or sold prior to September 30, 2018 . Primary Modification Types Interest Rate Reduction (1) Maturity Extension (2) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Commercial 6 $1 $1 23 $2 $2 Commercial real estate — — — 1 — — Total commercial loans 6 1 1 24 2 2 Residential mortgages 32 3 4 47 6 6 Home equity loans 32 2 3 1 — — Home equity lines of credit 55 5 5 147 21 21 Home equity loans serviced by others 3 — — — — — Home equity lines of credit serviced by others 5 — — 1 — — Automobile 122 3 2 42 1 1 Education — — — — — — Credit cards 1,776 10 10 — — — Other retail 1 — — — — — Total retail loans 2,026 23 24 238 28 28 Total 2,032 $24 $25 262 $30 $30 Primary Modification Types Other (3) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Net Change to ALLL Resulting from Modification Charge-offs Resulting from Modification Commercial 40 $155 $156 $— $— Commercial real estate 2 31 31 — — Total commercial loans 42 186 187 — — Residential mortgages 117 14 14 (1 ) — Home equity loans 106 5 5 — — Home equity lines of credit 310 22 21 — — Home equity loans serviced by others 20 1 1 — — Home equity lines of credit serviced by others 13 — — — — Automobile 893 15 13 — 3 Education 296 5 5 1 — Credit cards — — — 3 — Other retail 4 — — — — Total retail loans 1,759 62 59 3 3 Total 1,801 $248 $246 $3 $3 (1) Includes modifications that consist of multiple concessions, one of which is an interest rate reduction. (2) Includes modifications that consist of multiple concessions, one of which is a maturity extension (unless one of the other concessions was an interest rate reduction). (3) Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forgiveness, and capitalizing arrearages. Also included are the following: deferrals, trial modifications, certain bankruptcies, loans in forbearance and prepayment plans. Modifications can include the deferral of accrued interest resulting in post modification balances being higher than pre-modification. The table below summarizes how loans were modified during the nine months ended September 30, 2017 , the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during the nine months ended September 30, 2017 and were paid off in full, charged off, or sold prior to September 30, 2017 . Primary Modification Types Interest Rate Reduction (1) Maturity Extension (2) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Commercial 7 $2 $2 35 $22 $21 Commercial real estate — — — 1 — — Total commercial loans 7 2 2 36 22 21 Residential mortgages 56 6 7 50 9 10 Home equity loans 68 4 4 1 — — Home equity lines of credit 41 2 2 204 26 26 Home equity loans serviced by others 14 1 1 — — — Home equity lines of credit serviced by others 3 — — 2 — — Automobile 93 2 2 23 — — Education — — — — — — Credit cards 1,850 10 10 — — — Other retail 1 — — — — — Total retail loans 2,126 25 26 280 35 36 Total 2,133 $27 $28 316 $57 $57 Primary Modification Types Other (3) (dollars in millions) Number of Contracts Pre-Modification Outstanding Recorded Investment Post-Modification Outstanding Recorded Investment Net Change to ALLL Resulting from Modification Charge-offs Resulting from Modification Commercial 12 $64 $65 $1 $— Commercial real estate 1 — — — — Total commercial loans 13 64 65 1 — Residential mortgages 122 13 13 (1 ) — Home equity loans 192 11 11 — — Home equity lines of credit 295 20 20 — 1 Home equity loans serviced by others 41 2 1 — — Home equity lines of credit serviced by others 21 2 1 — — Automobile 1,017 18 16 — 3 Education 235 4 4 1 — Credit cards — — — 3 — Other retail 5 — — (1 ) — Total retail loans 1,928 70 66 2 4 Total 1,941 $134 $131 $3 $4 (1) Includes modifications that consist of multiple concessions, one of which is an interest rate reduction. (2) Includes modifications that consist of multiple concessions, one of which is a maturity extension (unless one of the other concessions was an interest rate reduction). (3) Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forgiveness, and capitalizing arrearages. Also included are the following: deferrals, trial modifications, certain bankruptcies, loans in forbearance and prepayment plans. Modifications can include the deferral of accrued interest resulting in post modification balances being higher than pre-modification.
Schedule of defaults	The table below summarizes TDRs that defaulted within 12 months of their modification date during the nine months ended September 30, 2018 and 2017 , respectively. For purposes of this table, a payment default refers to a loan that becomes 90 days or more past due under the modified terms. Amounts represent the loan’s recorded investment at the time of payment default. If a TDR of any loan type becomes 90 days past due after being modified, the loan is written down to the fair value of collateral less cost to sell. The amount written off is charged to the ALLL. Three Months Ended September 30, Nine Months Ended September 30, 2018 2017 2018 2017 (dollars in millions) Number of Contracts Balance Defaulted Number of Contracts Balance Defaulted Number of Contracts Balance Defaulted Number of Contracts Balance Defaulted Commercial 9 $32 2 $4 15 $52 7 $5 Commercial real estate — — — — 1 — 1 4 Total commercial loans 9 32 2 4 16 52 8 9 Residential mortgages 33 4 35 5 103 12 121 15 Home equity loans 6 — 12 — 24 1 35 1 Home equity lines of credit 59 5 55 4 165 13 152 11 Home equity loans serviced by others 3 — 6 — 13 — 16 — Home equity lines of credit serviced by others 2 — 4 — 3 — 8 — Automobile 40 — 42 — 116 1 103 1 Education 1 — 5 1 13 1 41 1 Credit cards 106 1 116 — 327 2 344 2 Other retail 1 — 2 — 1 — 4 — Total retail loans 251 10 277 10 765 30 824 31 Total 260 $42 279 $14 781 $82 832 $40
Schedule of loans that may increase credit exposure	The following tables present balances of loans with these characteristics: September 30, 2018 (in millions) Residential Mortgages Home Equity Loans and Lines of Credit Home Equity Products Serviced by Others Credit Cards Total High loan-to-value $339 $107 $174 $— $620 Interest-only/negative amortization 1,786 — — — 1,786 Low introductory rate — — — 211 211 Multiple characteristics and other 1 — — — 1 Total $2,126 $107 $174 $211 $2,618 December 31, 2017 (in millions) Residential Mortgages Home Equity Loans and Lines of Credit Home Equity Products Serviced by Others Credit Cards Education Total High loan-to-value $366 $166 $264 $— $— $796 Interest-only/negative amortization 1,763 — — — 1 1,764 Low introductory rate — — — 197 — 197 Multiple characteristics and other 1 — — — — 1 Total $2,130 $166 $264 $197 $1 $2,758

MORTGAGE BANKING (Tables)

MORTGAGE BANKING (Tables)	9 Months Ended
	Sep. 30, 2018
Mortgage Banking [Abstract]
Schedule of mortgage banking activities	The following table summarizes activity related to residential mortgage loans sold with servicing rights retained for the three and nine months ended September 30, 2018 and 2017. Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Residential mortgage loans sold with servicing retained $1,848 $828 $3,173 $2,372 Gain on sales (1) 29 25 59 54 Contractually specified servicing, late and other ancillary fees (1) 38 13 69 40 (1) Reported in mortgage banking fees in the Consolidated Statements of Operations.
Schedule of valuation allowance for impairment of recognized servicing assets	As of and for the Three Months Ended September 30, As of and for the Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 MSRs: Balance as of beginning of period $217 $170 $201 $167 Amount capitalized 11 9 26 28 Purchases — — 16 — Amortization (9 ) (8 ) (24 ) (24 ) Carrying amount before valuation allowance 219 171 219 171 Valuation allowance for servicing assets: Balance as of beginning of period — 4 3 5 Valuation recoveries — — (3 ) (1 ) Balance at end of period — 4 — 4 Net carrying value of MSRs $219 $167 $219 $167
Servicing asset at amortized cost	As of and for the Three Months Ended September 30, As of and for the Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 MSRs: Balance as of beginning of period $217 $170 $201 $167 Amount capitalized 11 9 26 28 Purchases — — 16 — Amortization (9 ) (8 ) (24 ) (24 ) Carrying amount before valuation allowance 219 171 219 171 Valuation allowance for servicing assets: Balance as of beginning of period — 4 3 5 Valuation recoveries — — (3 ) (1 ) Balance at end of period — 4 — 4 Net carrying value of MSRs $219 $167 $219 $167
Servicing asset at fair value	As of and for the Three Months Ended September 30, 2018 As of and for the Nine Months Ended September 30, 2018 (in millions) MSRs: Fair value as of beginning of the period $— $— Acquired MSRs 590 590 Amounts capitalized 29 29 Changes in unpaid principal balance during the period (1) (12 ) (12 ) Changes in fair value during the period (2) 5 5 Fair value at end of the period $612 $612 (1) Represents changes in value due to i) passage of time including the impact from both regularly scheduled loan principal payments and partial paydowns, and ii) loans that paid off during the period. (2) Represents changes in value primarily due to market driven changes in interest rates and prepayment speeds.
Schedule of fair value assumptions used to estimate the value of Mortgage Servicing Rights	For MSRs under the amortization method, the key economic assumptions used to estimate the fair value are presented below: September 30, 2018 December 31, 2017 Actual Decline in fair value due to Actual Decline in fair value due to (dollars in millions) Fair value $261 50 bps adverse change 100 bps adverse change $218 50 bps adverse change 100 bps adverse change Weighted average life (in years) 6.9 5.9 Weighted average constant prepayment rate 7.7% $18 $43 10.0% $22 $46 Weighted average discount rate 9.3% 5 10 9.9% 4 8 For MSRs under the fair value method, the key economic assumptions used to estimate the fair value are presented below: September 30, 2018 Actual Decline in fair value due to (dollars in millions) Fair value $612 50 bps adverse change 100 bps adverse change Weighted average life (in years) 8.7 Weighted average constant prepayment rate 7.3% $54 $123 Weighted average option adjusted spread 625 bps 14 27

GOODWILL AND INTANGIBLE ASSETS

GOODWILL AND INTANGIBLE ASSETS (Tables)	9 Months Ended
	Sep. 30, 2018
Goodwill and Intangible Assets Disclosure [Abstract]
Change in carrying value of goodwill	The change in the carrying value of goodwill for the nine months ended September 30, 2018 is presented below: (in millions) Consumer Banking Commercial Banking Total Balance at December 31, 2017 $2,136 $4,751 $6,887 Business acquisition 59 — 59 Balance at September 30, 2018 $2,195 $4,751 $6,946
Carrying value of intangible assets	A summary of the carrying value of intangible assets is presented below. Included in the carrying value at September 30, 2018 are $32 million in other intangibles related to the FAMC acquisition. September 30, 2018 December 31, 2017 (in millions) Amortizable Lives (years) Gross Accumulated Amortization Net Gross Accumulated Amortization Net Acquired technology 7 $20 $— $20 $— $— $— Acquired relationships 5 - 15 11 1 10 2 — 2 Other 2 - 3 3 — 3 — — — Total $34 $1 $33 $2 $— $2
Intangible assets future amortization expense	Estimated intangible asset amortization expense for the remainder of 2018 through 2022 is as follows: (in millions) Total Remainder of 2018 $1 2019 5 2020 5 2021 4 2022 4

VARIABLE INTEREST ENTITIES (Tab

VARIABLE INTEREST ENTITIES (Tables)	9 Months Ended
	Sep. 30, 2018
Equity Method Investments and Joint Ventures [Abstract]
Schedule of variable interest entities	A summary of these investments is presented below: (in millions) September 30, 2018 December 31, 2017 LIHTC investment included in other assets $1,211 $951 LIHTC unfunded commitments included in other liabilities 677 491 Renewable energy investments included in other assets 323 335 Lending to special purpose entities included in loans and leases 449 —
Schedule of Affordable Housing Tax Credit investments	The following table presents other information related to the Company’s affordable housing tax credit investments: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Tax credits included in income tax expense $28 $20 $79 $63 Amortization expense included in income tax expense 31 22 86 67 Other tax benefits included in income tax expense 7 7 19 22

BORROWED FUNDS (Tables)

BORROWED FUNDS (Tables)	9 Months Ended
	Sep. 30, 2018
Debt Disclosure [Abstract]
Schedule of short-term borrowed funds	A summary of the Company’s short-term borrowed funds is presented below: (in millions) September 30, 2018 December 31, 2017 Federal funds purchased $— $460 Securities sold under agreements to repurchase 374 355 Other short-term borrowed funds (1) 2,006 1,856 Total short-term borrowed funds $2,380 $2,671 (1) September 30, 2018 includes $1.5 billion of debt issued under CBNA’s Global Bank Note Program maturing within one year, with unamortized deferred issuance costs and/or discounts of ($1) million and other basis adjustments of ($5) million . December 31, 2017 includes $750 million of debt issued under CBNA’s Global Bank Note Program maturing within one year, with unamortized deferred issuance costs and/or discounts of ($1) million and other basis adjustments of ($4) million . Key data related to short-term borrowed funds is presented in the following table: As of and for the Three Months Ended September 30, As of and for the Nine Months Ended September 30, As of and for the Year Ended December 31, (dollars in millions) 2018 2017 2018 2017 2017 Weighted-average interest rate at period-end: (1) Federal funds purchased and securities sold under agreements to repurchase — % — % — % — % 0.74 % Other short-term borrowed funds 2.41 1.47 2.41 1.47 1.72 Maximum amount outstanding at any month-end during the period: Federal funds purchased and securities sold under agreements to repurchase (2) $382 $724 $1,045 $1,174 $1,174 Other short-term borrowed funds 2,502 1,755 2,502 3,508 3,508 Average amount outstanding during the period: Federal funds purchased and securities sold under agreements to repurchase (2) $643 $733 $598 $807 $776 Other short-term borrowed funds 2,239 1,624 1,802 2,283 2,321 Weighted-average interest rate during the period: (1) Federal funds purchased and securities sold under agreements to repurchase 0.91 % 0.47 % 0.76 % 0.34 % 0.36 % Other short-term borrowed funds 2.45 1.48 2.38 1.22 1.32 (1) Rates exclude certain hedging costs. (2) Balances are net of certain short-term receivables associated with reverse repurchase agreements, as applicable.
Schedule of long-term borrowed funds	A summary of the Company’s long-term borrowed funds is presented below: (in millions) September 30, 2018 December 31, 2017 Parent Company: 2.375% fixed-rate senior unsecured debt, due 2021 $349 $349 4.150% fixed-rate subordinated debt, due 2022 348 348 5.158% fixed-to-floating rate callable subordinated debt, due 2023 (1) — 333 3.750% fixed-rate subordinated debt, due 2024 250 250 4.023% fixed-rate subordinated debt, due 2024 42 42 4.350% fixed-rate subordinated debt, due 2025 249 249 4.300% fixed-rate subordinated debt, due 2025 749 749 Banking Subsidiaries: 2.450% senior unsecured notes, due 2019 (2) 742 743 2.500% senior unsecured notes, due 2019 (2) (3) — 741 2.250% senior unsecured notes, due 2020 (2) 687 692 Floating-rate senior unsecured notes, due 2020 (2) 300 299 Floating-rate senior unsecured notes, due 2020 (2) 250 249 2.200% senior unsecured notes, due 2020 (2) 499 498 2.250% senior unsecured notes, due 2020 (2) 731 742 2.550% senior unsecured notes, due 2021 (2) 951 964 Floating-rate senior unsecured notes, due 2022 (2) 249 249 2.650% senior unsecured notes, due 2022 (2) 478 491 3.700% senior unsecured notes, due 2023 (2) 492 — Floating-rate senior unsecured notes, due 2023 (2) 249 — Federal Home Loan Bank advances due through 2038 8,012 3,761 Other 12 16 Total long-term borrowed funds $15,639 $11,765 (1) Redeemed on June 29, 2018. (2) Issued under CBNA’s Global Bank Note Program. (3) Reclassified to short-term borrowed funds.
Schedule of maturities of long-term borrowed funds	A summary of maturities for the Company’s long-term borrowed funds at September 30, 2018 is presented below: (in millions) Parent Company Banking Subsidiaries Consolidated Year 2019 $— $3,244 $3,244 2020 — 7,972 7,972 2021 349 954 1,303 2022 348 732 1,080 2023 — 741 741 2024 and thereafter 1,290 9 1,299 Total $1,987 $13,652 $15,639

DERIVATIVES (Tables)

DERIVATIVES (Tables)	9 Months Ended
	Sep. 30, 2018
Derivative Instruments and Hedging Activities Disclosure [Abstract]
Schedule of derivative instruments in consolidated balance sheets	The following table presents derivative instruments included on the Consolidated Balance Sheets in derivative assets and derivative liabilities: September 30, 2018 December 31, 2017 (in millions) Notional Amount (1) Derivative Assets Derivative Liabilities Notional Amount (1) Derivative Assets Derivative Liabilities Derivatives designated as hedging instruments: Interest rate contracts $10,050 $5 $— $13,300 $— $— Derivatives not designated as hedging instruments: Interest rate contracts 111,837 160 469 80,180 538 379 Foreign exchange contracts 10,346 116 105 9,882 148 149 Other contracts 5,201 19 1 1,039 7 5 Total derivatives not designated as hedging instruments 295 575 693 533 Gross derivative fair values 300 575 693 533 Less: Gross amounts offset in the Consolidated Balance Sheets (2) (85 ) (85 ) (72 ) (72 ) Less: Cash collateral applied (2) (42 ) (41 ) (4 ) (151 ) Total net derivative fair values presented in the Consolidated Balance Sheets $173 $449 $617 $310 (1) The notional or contractual amount of interest rate derivatives and foreign exchange contracts is the amount upon which interest and other payments under the contract are based. For interest rate contracts, the notional amount is typically not exchanged. Therefore, notional amounts should not be taken as the measure of credit or market risk, as they do not measure the true economic risk of these contracts. (2) Amounts represent the impact of enforceable master netting agreements that allow the Company to net settle positive and negative positions.
Schedule of fair value hedges	The following table presents the effect on other income of fair value hedges described above: Amounts Recognized in Other Income for the Three Months Ended September 30, 2018 Three Months Ended September 30, 2017 (in millions) Derivative Hedged Item Hedge Ineffectiveness Derivative Hedged Item Hedge Ineffectiveness Hedges of interest rate risk on borrowings using interest rate swaps ($6 ) $7 $1 ($5 ) $4 ($1 ) Amounts Recognized in Other Income for the Nine Months Ended September 30, 2018 Nine Months Ended September 30, 2017 (in millions) Derivative Hedged Item Hedge Ineffectiveness Derivative Hedged Item Hedge Ineffectiveness Hedges of interest rate risk on borrowings using interest rate swaps ($32 ) $31 ($1 ) $5 ($5 ) $—
Schedule of effect of cash flow hedges on net income and stockholders' equity	The following table presents the effect of cash flow hedges on net income and stockholders' equity: Amounts Recognized for the Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Effective portion of (loss) gain recognized in OCI (1) ($35 ) ($2 ) ($122 ) $35 Amount of net (loss) gain reclassified from OCI to interest income (2) (17 ) 3 (36 ) 23 Amount of net gain (loss) reclassified from OCI to interest expense (2) 3 1 11 (2 ) (1) The cumulative effective gains and losses on the Company’s cash flow hedging activities are included on the accumulated other comprehensive loss line item on the Consolidated Balance Sheets. (2) This amount includes both (i) the amortization of effective gains and losses associated with the Company’s terminated cash flow hedges and (ii) the current reporting period’s interest settlements realized on the Company’s active cash flow hedges. Both (i) and (ii) were previously included on the accumulated other comprehensive loss line item on the Consolidated Balance Sheets and were subsequently recorded as adjustments to the interest income or expense of the underlying hedged item.
Schedule of effect of derivative Instruments on net income	The following table presents the effect of economic hedges on noninterest income: Amounts Recognized in Noninterest Income for the Affected Line Item in the Consolidated Statements of Operations Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Economic Hedge Type Customer interest rate contracts Foreign exchange and interest rate products ($84 ) $12 ($363 ) $92 Customer foreign exchange contracts Foreign exchange and interest rate products 30 61 (27 ) 157 Derivatives transactions to hedge interest rate risk Foreign exchange and interest rate products 97 (2 ) 403 (58 ) Derivatives transactions to hedge foreign exchange risk Foreign exchange and interest rate products 24 (55 ) 99 (140 ) Residential loan commitments Mortgage banking fees 6 — 6 3 Forward sale contracts Mortgage banking fees (13 ) (1 ) (15 ) (7 ) Interest rate derivative contracts used to hedge residential MSRs Mortgage banking fees (3 ) — (3 ) — Total $57 $15 $100 $47

RECLASSIFICATIONS OUT OF ACCU_2

RECLASSIFICATIONS OUT OF ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS) (Tables)	9 Months Ended
	Sep. 30, 2018
Equity [Abstract]
Schedule of other comprehensive income	The following tables present the changes in the balances, net of income taxes, of each component of AOCI: As of and for the Three Months Ended September 30, (in millions) Net Unrealized (Losses) Gains on Derivatives Net Unrealized (Losses) Gains on Debt Securities Employee Benefit Plans Total AOCI Balance at July 1, 2017 ($76 ) ($128 ) ($389 ) ($593 ) Other comprehensive income before reclassifications (1 ) 13 — 12 Other-than-temporary impairment not recognized in earnings on debt securities — — — — Amounts reclassified to the Consolidated Statements of Operations (2 ) (1 ) 3 — Net other comprehensive income (3 ) 12 3 12 Balance at September 30, 2017 ($79 ) ($116 ) ($386 ) ($581 ) Balance at July 1, 2018 ($200 ) ($575 ) ($435 ) ($1,210 ) Other comprehensive loss before reclassifications (26 ) (95 ) — (121 ) Other-than-temporary impairment not recognized in earnings on debt securities — — — — Amounts reclassified to the Consolidated Statements of Operations 11 (2 ) 4 13 Net other comprehensive loss (15 ) (97 ) 4 (108 ) Balance at September 30, 2018 ($215 ) ($672 ) ($431 ) ($1,318 ) As of and for the Nine Months Ended September 30, (in millions) Net Unrealized (Losses) Gains on Derivatives Net Unrealized (Losses) Gains on Debt Securities Employee Benefit Plans Total AOCI Balance at January 1, 2017 ($88 ) ($186 ) ($394 ) ($668 ) Other comprehensive income before reclassifications 22 74 — 96 Other-than-temporary impairment not recognized in earnings on debt securities — (2 ) — (2 ) Amounts reclassified to the Consolidated Statements of Operations (13 ) (2 ) 8 (7 ) Net other comprehensive income 9 70 8 87 Balance at September 30, 2017 ($79 ) ($116 ) ($386 ) ($581 ) Balance at January 1, 2018 ($143 ) ($236 ) ($441 ) ($820 ) Other comprehensive loss before reclassifications (91 ) (427 ) — (518 ) Other-than-temporary impairment not recognized in earnings on debt securities — (1 ) — (1 ) Amounts reclassified to the Consolidated Statements of Operations 19 (8 ) 10 21 Net other comprehensive loss (72 ) (436 ) 10 (498 ) Balance at September 30, 2018 ($215 ) ($672 ) ($431 ) ($1,318 )
Schedule of reclassification out of accumulated other comprehensive income	The following table presents the amounts reclassified out of each component of AOCI and into the Consolidated Statements of Operations: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Details about AOCI Components Affected Line Item in the Consolidated Statements of Operations Reclassification adjustment for net derivative (losses) gains included in net income: ($17 ) $3 ($36 ) $23 Interest income 3 1 11 (2 ) Interest expense (14 ) 4 (25 ) 21 Income before income tax expense (3 ) 2 (6 ) 8 Income tax expense ($11 ) $2 ($19 ) $13 Net income Reclassification of net debt securities gains (losses) to net income: $3 $2 $13 $9 Securities gains, net (1 ) (1 ) (3 ) (6 ) Net debt securities impairment losses recognized in earnings 2 1 10 3 Income before income tax expense — — 2 1 Income tax expense $2 $1 $8 $2 Net income Reclassification of changes related to the employee benefit plan: ($5 ) ($5 ) ($13 ) ($14 ) Other operating expense (5 ) (5 ) (13 ) (14 ) Income before income tax expense (1 ) (2 ) (3 ) (6 ) Income tax expense ($4 ) ($3 ) ($10 ) ($8 ) Net income Total reclassification (losses) gains ($13 ) $— ($21 ) $7 Net income The following table presents the effects on net income of the amounts reclassified out of AOCI: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Net interest income (includes ($14), $4, ($25) and $21 of AOCI reclassifications, respectively) $1,148 $1,062 $3,360 $3,093 Provision for credit losses 78 72 241 238 Noninterest income (includes $2, $1, $10 and $3 of AOCI reclassifications, respectively) 416 381 1,175 1,130 Noninterest expense includes $5, $5, $13 and $14 of AOCI reclassifications, respectively) 910 858 2,668 2,576 Income before income tax expense 576 513 1,626 1,409 Income tax expense (includes ($4), $0, ($7) and $3 income tax net expense from reclassification items, respectively) 133 165 370 423 Net income $443 $348 $1,256 $986

COMMITMENTS AND CONTINGENCIES (

COMMITMENTS AND CONTINGENCIES (Tables)	9 Months Ended
	Sep. 30, 2018
Commitments and Contingencies Disclosure [Abstract]
Schedule of outstanding off balance sheet arrangements	A summary of outstanding off-balance sheet arrangements is presented below: (in millions) September 30, 2018 December 31, 2017 Undrawn commitments to extend credit $66,729 $62,959 Financial standby letters of credit 1,934 2,036 Performance letters of credit 131 47 Commercial letters of credit 74 53 Marketing rights 37 41 Risk participation agreements 14 16 Residential mortgage loans sold with recourse 6 7 Total $68,925 $65,159

FAIR VALUE MEASUREMENTS (Tables

FAIR VALUE MEASUREMENTS (Tables)	9 Months Ended
	Sep. 30, 2018
Fair Value Disclosures [Abstract]
Summary of difference between aggregated fair value and unpaid principal balance of loans held for sale	The following table presents the difference between the aggregate fair value and the aggregate unpaid principal balance of loans held for sale measured at fair value: September 30, 2018 December 31, 2017 (in millions) Aggregate Fair Value Aggregate Unpaid Principal Aggregate Fair Value Less Aggregate Unpaid Principal Aggregate Fair Value Aggregate Unpaid Principal Aggregate Fair Value Less Aggregate Unpaid Principal Residential mortgage loans held for sale, at fair value $1,140 $1,140 $— $326 $326 $— Commercial and commercial real estate loans held for sale, at fair value 163 163 — 171 171 —
Assets and liabilities measured on recurring basis	The following table presents assets and liabilities measured at fair value, including gross derivative assets and liabilities on a recurring basis at September 30, 2018 : (in millions) Total Level 1 Level 2 Level 3 Debt securities available for sale: Mortgage-backed securities $20,135 $— $20,135 $— State and political subdivisions 5 — 5 — U.S. Treasury and other 12 12 — — Total debt securities available for sale 20,152 12 20,140 — Loans held for sale, at fair value: Residential loans held for sale 1,140 — 1,140 — Commercial loans held for sale 163 — 163 — Total loans held for sale, at fair value 1,303 — 1,303 — Mortgage servicing rights 612 — — 612 Derivative assets: Interest rate contracts 165 — 165 — Foreign exchange contracts 116 — 116 — Other contracts 19 — 19 — Total derivative assets 300 — 300 — Equity securities, at fair value: Money market mutual fund investments 175 175 — — Other investments — — — — Total equity securities, at fair value 175 175 — — Total assets $22,542 $187 $21,743 $612 Derivative liabilities: Interest rate contracts $469 $— $469 $— Foreign exchange contracts 105 — 105 — Other contracts 1 — 1 — Total derivative liabilities 575 — 575 — Total liabilities $575 $— $575 $— The following table presents assets and liabilities measured at fair value, including gross derivative assets and liabilities on a recurring basis at December 31, 2017 : (in millions) Total Level 1 Level 2 Level 3 Debt securities available for sale: Mortgage-backed securities $20,139 $— $20,139 $— State and political subdivisions 6 — 6 — U.S. Treasury and other 12 12 — — Total debt securities available for sale 20,157 12 20,145 — Loans held for sale, at fair value: Residential loans held for sale 326 — 326 — Commercial loans held for sale 171 — 171 — Total loans held for sale, at fair value 497 — 497 — Derivative assets: Interest rate contracts 538 — 538 — Foreign exchange contracts 148 — 148 — Other contracts 7 — 7 — Total derivative assets 693 — 693 — Equity securities, at fair value: Money market mutual fund investments 165 165 — — Other investments 4 — 4 — Total equity securities, at fair value 169 165 4 — Total assets $21,516 $177 $21,339 $— Derivative liabilities: Interest rate contracts $379 $— $379 $— Foreign exchange contracts 149 — 149 — Other contracts 5 — 5 — Total derivative liabilities 533 — 533 — Total liabilities $533 $— $533 $—
Asses measured at fair value on recurring basis and classified as Level 3	The following tables present a rollforward of the balance sheet amounts for assets measured at fair value on a recurring basis and classified as Level 3 for the three and nine months ended September 30, 2018. There were no assets measured at fair value on a recurring basis and classified as Level 3 for the three and nine months ended September 30, 2017. For the Three Months Ended September 30, (in millions) Mortgage Servicing Rights Balance at July 1, 2018 $— Acquired MSRs 590 Amount capitalized 29 Change in unpaid principal balance during the period (1) (12 ) Change in fair value during the period (2) 5 Balance at September 30, 2018 $612 For the Nine Months Ended September 30, (in millions) Mortgage Servicing Rights Balance at January 1, 2018 $— Acquired MSRs 590 Amount capitalized 29 Change in unpaid principal balance during the period (1) (12 ) Change in fair value during the period (2) 5 Balance at September 30, 2018 $612 (1) Represents changes in value of the MSRs due to i) passage of time including the impact from both regularly scheduled loan principal payments and partial paydowns, and ii) loans that paid off during the period. (2) Represents changes in value primarily due to market driven changes in interest rates and prepayment speeds.
Gains (losses) on assets and liabilities measured on a nonrecurring basis included in earnings	The following table presents gains (losses) on assets and liabilities measured at fair value on a nonrecurring basis and recorded in earnings: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Impaired collateral-dependent loans ($3 ) ($4 ) ($9 ) ($31 ) MSRs — — 3 (1 ) Foreclosed assets (1 ) (1 ) (2 ) (3 ) Leased assets (4 ) — (6 ) (15 )
Fair value of assets and liabilities measured on a nonrecurring basis	The following table presents assets and liabilities measured at fair value on a nonrecurring basis: September 30, 2018 December 31, 2017 (in millions) Total Level 1 Level 2 Level 3 Total Level 1 Level 2 Level 3 Impaired collateral-dependent loans $336 $— $336 $— $393 $— $393 $— MSRs 261 — — 261 218 — — 218 Foreclosed assets 25 — 25 — 31 — 31 — Leased assets 93 — 93 — 112 — 112 —
Assets and liabilities measured at fair value	The following table presents the estimated fair value for financial instruments not recorded at fair value in the unaudited interim Consolidated Financial Statements. The carrying amounts are recorded in the Consolidated Balance Sheets under the indicated captions: September 30, 2018 Total Level 1 Level 2 Level 3 (in millions) Carrying Value Estimated Fair Value Carrying Value Estimated Fair Value Carrying Value Estimated Fair Value Carrying Value Estimated Fair Value Financial Assets: Securities held to maturity $4,284 $4,102 $— $— $4,284 $4,102 $— $— Equity securities, at cost 874 874 — — 874 874 — — Other loans held for sale 27 27 — — — — 27 27 Loans and leases 114,720 113,913 — — 336 336 114,384 113,577 Financial Liabilities: Deposits 117,075 116,892 — — 117,075 116,892 — — Federal funds purchased and securities sold under agreements to repurchase 374 374 — — 374 374 — — Other short-term borrowed funds 2,006 2,006 — — 2,006 2,006 — — Long-term borrowed funds 15,639 15,630 — — 15,639 15,630 — — December 31, 2017 Total Level 1 Level 2 Level 3 (in millions) Carrying Value Estimated Fair Value Carrying Value Estimated Fair Value Carrying Value Estimated Fair Value Carrying Value Estimated Fair Value Financial Assets: Securities held to maturity $4,685 $4,668 $— $— $4,685 $4,668 $— $— Equity securities, at cost 722 722 — — 722 722 — — Other loans held for sale 221 221 — — — — 221 221 Loans and leases 110,617 111,168 — — 393 393 110,224 110,775 Financial Liabilities: Deposits 115,089 115,039 — — 115,089 115,039 — — Federal funds purchased and securities sold under agreements to repurchase 815 815 — — 815 815 — — Other short-term borrowed funds 1,856 1,856 — — 1,856 1,856 — — Long-term borrowed funds 11,765 11,891 — — 11,765 11,891 — —

NONINTEREST INCOME (Tables)

NONINTEREST INCOME (Tables)	9 Months Ended
	Sep. 30, 2018
Other Income and Expenses [Abstract]
Noninterest income	The following table presents noninterest income, segregated between revenue from contracts with customers and revenue from other sources: (in millions) Three Months Ended September 30, 2018 Nine Months Ended September 30, 2018 Revenue from contracts with customers $285 $833 Revenue from other sources 131 342 Noninterest income $416 $1,175
Components of revenue from contracts with customers	The following table presents the components of revenue from contracts with customers disaggregated by revenue stream and business operating segment: Three Months Ended September 30, 2018 Nine Months Ended September 30, 2018 (in millions) Consumer Banking Commercial Banking Consolidated (1) Consumer Banking Commercial Banking Consolidated (1) Service charges and fees $105 $26 $131 $303 $79 $382 Card fees 51 10 61 154 28 182 Capital markets fees — 46 46 — 134 134 Trust and investment services fees 45 — 45 128 — 128 Other banking fees — 2 2 — 7 7 Total revenue from contracts with customers $201 $84 $285 $585 $248 $833 (1) There is no revenue from contracts with customers included in Other non-segment operations.
Details of other income	Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Bank-owned life insurance $14 $14 $42 $40

OTHER OPERATING EXPENSE (Tables

OTHER OPERATING EXPENSE (Tables)	9 Months Ended
	Sep. 30, 2018
Other Income and Expenses [Abstract]
Schedule of other operating expense	The following table presents the details of other operating expense: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2018 2017 2018 2017 Deposit insurance $29 $34 $88 $102 Promotional expense 36 27 95 82 Settlements and operating losses 11 18 35 43 Other 55 54 160 178 Other operating expense $131 $133 $378 $405

EARNINGS PER SHARE (Tables)

EARNINGS PER SHARE (Tables)	9 Months Ended
	Sep. 30, 2018
Earnings Per Share [Abstract]
Schedule of earnings per share	Three Months Ended September 30, Nine Months Ended September 30, (in millions, except share and per-share data) 2018 2017 2018 2017 Numerator (basic and diluted): Net income $443 $348 $1,256 $986 Less: Preferred stock dividends 7 7 14 14 Net income available to common stockholders $436 $341 $1,242 $972 Denominator: Weighted-average common shares outstanding - basic 475,957,526 500,861,076 482,691,884 505,529,991 Dilutive common shares: share-based awards 1,642,391 1,296,308 1,558,959 1,532,814 Weighted-average common shares outstanding - diluted 477,599,917 502,157,384 484,250,843 507,062,805 Earnings per common share: Basic $0.92 $0.68 $2.57 $1.92 Diluted 0.91 0.68 2.57 1.92

REGULATORY MATTERS (Tables)

REGULATORY MATTERS (Tables)	9 Months Ended
	Sep. 30, 2018
Banking and Thrift [Abstract]
Schedule of compliance with regulatory capital requirements under banking regulations	The following table presents the Company’s capital and capital ratios under U.S. Basel III Standardized rules. The Company has declared itself as an “AOCI opt-out” institution, which means the Company is not required to recognize in regulatory capital the impacts of net unrealized gains and losses included within AOCI for securities that are available for sale or held to maturity, accumulated net gains and losses on cash-flow hedges, and certain defined benefit pension plan assets. Actual Minimum Capital Adequacy (in millions, except ratio data) Amount Ratio Amount Ratio (5) September 30, 2018 Common equity tier 1 capital (1) $14,435 10.8 % $8,495 6.375 % Tier 1 capital (2) 14,978 11.2 10,493 7.875 Total capital (3) 17,810 13.4 13,158 9.875 Tier 1 leverage (4) 14,978 9.9 6,029 4.000 December 31, 2017 Common equity tier 1 capital (1) $14,309 11.2 % $7,342 5.750 % Tier 1 capital (2) 14,556 11.4 9,258 7.250 Total capital (3) 17,781 13.9 11,812 9.250 Tier 1 leverage (4) 14,556 10.0 5,824 4.000 (1) “Common equity tier 1 capital ratio” represents CET1 capital divided by total risk-weighted assets as defined under U.S. Basel III Standardized approach. (2) “Tier 1 capital ratio” is tier 1 capital, which includes CET1 capital plus non-cumulative perpetual preferred equity that qualifies as additional tier 1 capital, divided by total risk-weighted assets as defined under U.S. Basel III Standardized approach. (3) “Total capital ratio” is total capital divided by total risk-weighted assets as defined under U.S. Basel III Standardized approach. (4) “Tier 1 leverage ratio” is tier 1 capital divided by quarterly average total assets as defined under U.S. Basel III Standardized approach. (5) “Minimum Capital ratio” includes capital conservation buffer of 1.875% for 2018 and 1.250% for 2017 ; N/A to Tier 1 leverage.

BUSINESS OPERATING SEGMENTS (Ta

BUSINESS OPERATING SEGMENTS (Tables)	9 Months Ended
	Sep. 30, 2018
Segment Reporting [Abstract]
Schedule of segment reporting information	As of and for the Three Months Ended September 30, 2018 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $776 $380 ($8 ) $1,148 Noninterest income 258 140 18 416 Total revenue 1,034 520 10 1,564 Noninterest expense 686 202 22 910 Profit (loss) before provision for credit losses 348 318 (12 ) 654 Provision for credit losses 71 14 (7 ) 78 Income (loss) before income tax expense (benefit) 277 304 (5 ) 576 Income tax expense (benefit) 70 70 (7 ) 133 Net income $207 $234 $2 $443 Total average assets $62,974 $52,871 $39,779 $155,624 As of and for the Three Months Ended September 30, 2017 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $674 $354 $34 $1,062 Noninterest income 227 136 18 381 Total revenue 901 490 52 1,443 Noninterest expense 648 195 15 858 Profit before provision for credit losses 253 295 37 585 Provision for credit losses 65 — 7 72 Income before income tax expense 188 295 30 513 Income tax expense 66 94 5 165 Net income $122 $201 $25 $348 Total average assets $60,012 $49,833 $40,167 $150,012 As of and for the Nine Months Ended September 30, 2018 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $2,268 $1,113 ($21 ) $3,360 Noninterest income 708 405 62 1,175 Total revenue 2,976 1,518 41 4,535 Noninterest expense 2,000 610 58 2,668 Profit (loss) before provision for credit losses 976 908 (17 ) 1,867 Provision for credit losses 209 19 13 241 Income (loss) before income tax expense (benefit) 767 889 (30 ) 1,626 Income tax expense (benefit) 193 203 (26 ) 370 Net income (loss) $574 $686 ($4 ) $1,256 Total average assets $61,857 $51,820 $39,805 $153,482 As of and for the Nine Months Ended September 30, 2017 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $1,969 $1,044 $80 $3,093 Noninterest income 676 400 54 1,130 Total revenue 2,645 1,444 134 4,223 Noninterest expense 1,939 577 60 2,576 Profit before provision for credit losses 706 867 74 1,647 Provision for credit losses 189 20 29 238 Income before income tax expense (benefit) 517 847 45 1,409 Income tax expense (benefit) 182 279 (38 ) 423 Net income $335 $568 $83 $986 Total average assets $59,310 $49,604 $40,649 $149,563

BASIS OF PRESENTATION Operating

BASIS OF PRESENTATION Operating Leases (Details) - USD ($) $ in Millions	Aug. 01, 2018	Dec. 31, 2018	Sep. 30, 2018	Dec. 31, 2017
Operating Leased Assets [Line Items]
Goodwill			$ 6,946	$ 6,887
Accounting Standards Update 2016-02 | Scenario, Forecast | Minimum
Operating Leased Assets [Line Items]
Right of use asset		$ 600
Operating lease liability		600
Accounting Standards Update 2016-02 | Scenario, Forecast | Maximum
Operating Leased Assets [Line Items]
Right of use asset		750
Operating lease liability		$ 750
Franklin American Mortgage Company
Operating Leased Assets [Line Items]
Consideration transferred	$ 582
Goodwill	59
Intangible assets acquired	32
Residential mortgages | Franklin American Mortgage Company
Operating Leased Assets [Line Items]
MSR portfolio fair value	$ 590

SECURITIES - Narrative (Details

SECURITIES - Narrative (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017	Jun. 30, 2018	Dec. 31, 2017	Jun. 30, 2017	Dec. 31, 2016
Debt Securities, Available-for-sale [Line Items]
Taxable interest income from securities	$ 167	$ 155	$ 500	$ 469
Impaired debt securities sold	0	0	0	0
Mortgage-backed securities
Debt Securities, Available-for-sale [Line Items]
Securitizations of mortgage loans	32	38	87	82
Available-for-sale Securities
Debt Securities, Available-for-sale [Line Items]
Cumulative credit losses recognized in earnings	81	80	81	80	$ 81	$ 80	$ 79	$ 75
OTTI in earnings	1	1	3	6
Held-to-maturity Securities
Debt Securities, Available-for-sale [Line Items]
Cumulative credit losses recognized in earnings	$ 0	$ 0	$ 0	$ 0

SECURITIES - Schedule of Invest

SECURITIES - Schedule of Investments (Details) - USD ($) $ in Millions		Sep. 30, 2018	Dec. 31, 2017
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-sale, Fair Value	[1]	$ 20,152	$ 20,157
Debt Securities Held-to-maturity, Amortized Cost		4,284	4,685
Debt Securities Held-to-maturity, Gross Unrealized Gain		1	29
Debt Securities Held-to-maturity, Gross Unrealized Losses		(183)	(46)
Debt Securities held-to-maturity, Fair Value		4,102	4,668
Money market mutual fund, Amortized Cost		175	165
Money Market Mutual Fund, Gross Unrealized Gain		0	0
Money Market Mutual Fund, Gross Unrealized Loss		0	0
Money market mutual fund, Fair Value		175	165
Total other investment securities, at fair value, Amortized Cost		175	169
Total other investments securities, at fair value, at cost, Gross Unrealized Gains		0	0
Total other investments securities, at fair value, Gross Unrealized Losses		0	0
Total other investment securities, at fair value, Fair Value		175	169
Other Equity Securities, at Cost, Amortized Cost		7	7
Other Equity Securities, at Cost, Gross Unrealized Gain		0	0
Other Equity Securities, at Cost, Gross Unrealized Loss		0	0
Other Equity Securities, at Cost, Fair Value		7	7
Total equity securities, at cost		874	722
Total equity securities, at cost, Gross Unrealized Gain		0	0
Total equity securities, at cost, Gross Unrealized Losses		0	0
Total equity securities, at cost, Fair Value		874	722
U.S. Treasury and other
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-sale, Amortized Cost		12	12
Debt Securities Available-for-sale, Gross Unrealized Gains		0	0
Debt Securities Available-for-sale, Gross Unrealized Losses		0	0
Debt Securities Available-for-sale, Fair Value		12	12
State and political subdivisions
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-sale, Amortized Cost		5	6
Debt Securities Available-for-sale, Gross Unrealized Gains		0	0
Debt Securities Available-for-sale, Gross Unrealized Losses		0	0
Debt Securities Available-for-sale, Fair Value		5	6
Federal agencies and U.S. government sponsored entities
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-sale, Amortized Cost		20,703	20,065
Debt Securities Available-for-sale, Gross Unrealized Gains		8	40
Debt Securities Available-for-sale, Gross Unrealized Losses		(825)	(277)
Debt Securities Available-for-sale, Fair Value		19,886	19,828
Debt Securities Held-to-maturity, Amortized Cost		3,525	3,853
Debt Securities Held-to-maturity, Gross Unrealized Gain		0	7
Debt Securities Held-to-maturity, Gross Unrealized Losses		(177)	(46)
Debt Securities held-to-maturity, Fair Value		3,348	3,814
Other/non-agency
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-sale, Amortized Cost		251	311
Debt Securities Available-for-sale, Gross Unrealized Gains		4	7
Debt Securities Available-for-sale, Gross Unrealized Losses		(6)	(7)
Debt Securities Available-for-sale, Fair Value		249	311
Debt Securities Held-to-maturity, Amortized Cost		759	832
Debt Securities Held-to-maturity, Gross Unrealized Gain		1	22
Debt Securities Held-to-maturity, Gross Unrealized Losses		(6)	0
Debt Securities held-to-maturity, Fair Value		754	854
Total mortgage-backed securities
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-sale, Amortized Cost		20,954	20,376
Debt Securities Available-for-sale, Gross Unrealized Gains		12	47
Debt Securities Available-for-sale, Gross Unrealized Losses		(831)	(284)
Debt Securities Available-for-sale, Fair Value		20,135	20,139
Debt Securities Held-to-maturity, Amortized Cost		4,284	4,685
Debt Securities Held-to-maturity, Gross Unrealized Gain		1	29
Debt Securities Held-to-maturity, Gross Unrealized Losses		(183)	(46)
Debt Securities held-to-maturity, Fair Value		4,102	4,668
Total debt securities available for sale, at fair value
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-sale, Amortized Cost		20,971	20,394
Debt Securities Available-for-sale, Gross Unrealized Gains		12	47
Debt Securities Available-for-sale, Gross Unrealized Losses		(831)	(284)
Debt Securities Available-for-sale, Fair Value		20,152	20,157
Other investments
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Other Investments, Amortized Cost		0	4
Other Investments, Gross Unrealized Gain		0	0
Other Investments, Gross Unrealized Loss		0	0
Other Investments, Fair Value		0	4
Federal Reserve Bank stock
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Federal Reserve Bank stock, Amortized Cost		463	463
Federal Reserve Bank stock, Gross Unrealized Gains		0	0
Federal Reserve Bank stock, Gross Unrealized Losses		0	0
Federal Reserve Bank stock, Fair Value		463	463
Federal Home Loan Bank stock
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Federal Home Loan Bank stock, Amortized Cost		404	252
Federal Home Loan Bank stock, Gross Unrealized Gain		0	0
Federal Home Loan Bank stock, Gross Unrealized Losses		0	0
Federal Home Loan Bank stock, Fair Value		$ 404	$ 252
[1]	Includes only collateral pledged by the Company where counterparties have the right to sell or pledge the collateral.

SECURITIES - Schedule of Availa

SECURITIES - Schedule of Available for Sale Securities Debt Maturities (Details) $ in Millions	Sep. 30, 2018USD ($)
Amortized Cost:
Amortized Cost, Debt securities available for sale, Maturity of 1 Year or Less	$ 14
Amortized Cost, Debt securities available for sale, Maturity of 1-5 Years	323
Amortized Cost, Debt securities available for sale, Maturity of 5-10 Years	1,595
Amortized Cost, Debt securities available for sale, Maturity After 10 Years	19,039
Amortized Cost, Debt securities available for sale, Total	20,971
Amortized Cost, Debt securities held to maturity, Maturity of 1 Year or Less	0
Amortized Cost, Debt securities held to maturity, Maturity of 1-5 Years	0
Amortized Cost, Debt securities held to maturity, Maturity of 5-10 Years	0
Amortized Cost, Debt securities held to maturity, Maturity After 10 Years	4,284
Amortized Cost, Debt securities held to maturity, Total	4,284
Total amortized cost of debt securities, Maturity of 1 Year or Less	14
Total amortized cost of debt securities, Maturity of 1-5 Years	323
Total amortized cost of debt securities, Maturity of 5-10 Years	1,595
Total amortized cost of debt securities, Maturity After 10 Years	23,323
Total amortized cost of debt securities, Total	25,255
Fair Value:
Fair Value, Debt securities available for sale, Maturity of 1 Year or Less	14
Fair Value, Debt securities available for sale, Maturity of 1-5 Years	317
Fair Value, Debt securities available for sale, Maturity of 5-10 Years	1,555
Fair Value, Debt securities available for sale, Maturity After 10 Years	18,266
Fair Value, Debt securities available for sale, Total	20,152
Fair Value, Debt securities held to maturity, Maturity of 1 Year or Less	0
Fair Value, Debt securities held to maturity, Maturity of 1-5 Years	0
Fair Value, Debt securities held to maturity, Maturity of 5-10 Years	0
Fair Value, Debt securities held to maturity, Maturity After 10 Years	4,102
Fair Value, Debt securities held to maturity, Total	4,102
Total fair value of debt securities, Maturity of 1 Year or Less	14
Total fair value of debt securities, Maturity of 1-5 Years	317
Total fair value of debt securities, Maturity of 5-10 Years	1,555
Total fair value of debt securities, Maturity After 10 Years	22,368
Total fair value of debt securities, Total	24,254
U.S. Treasury and other
Amortized Cost:
Amortized Cost, Debt securities available for sale, Maturity of 1 Year or Less	12
Amortized Cost, Debt securities available for sale, Maturity of 1-5 Years	0
Amortized Cost, Debt securities available for sale, Maturity of 5-10 Years	0
Amortized Cost, Debt securities available for sale, Maturity After 10 Years	0
Amortized Cost, Debt securities available for sale, Total	12
Fair Value:
Fair Value, Debt securities available for sale, Maturity of 1 Year or Less	12
Fair Value, Debt securities available for sale, Maturity of 1-5 Years	0
Fair Value, Debt securities available for sale, Maturity of 5-10 Years	0
Fair Value, Debt securities available for sale, Maturity After 10 Years	0
Fair Value, Debt securities available for sale, Total	12
State and political subdivisions
Amortized Cost:
Amortized Cost, Debt securities available for sale, Maturity of 1 Year or Less	0
Amortized Cost, Debt securities available for sale, Maturity of 1-5 Years	0
Amortized Cost, Debt securities available for sale, Maturity of 5-10 Years	0
Amortized Cost, Debt securities available for sale, Maturity After 10 Years	5
Amortized Cost, Debt securities available for sale, Total	5
Fair Value:
Fair Value, Debt securities available for sale, Maturity of 1 Year or Less	0
Fair Value, Debt securities available for sale, Maturity of 1-5 Years	0
Fair Value, Debt securities available for sale, Maturity of 5-10 Years	0
Fair Value, Debt securities available for sale, Maturity After 10 Years	5
Fair Value, Debt securities available for sale, Total	5
Federal agencies and U.S. government sponsored entities
Amortized Cost:
Amortized Cost, Debt securities available for sale, Maturity of 1 Year or Less	0
Amortized Cost, Debt securities available for sale, Maturity of 1-5 Years	312
Amortized Cost, Debt securities available for sale, Maturity of 5-10 Years	1,595
Amortized Cost, Debt securities available for sale, Maturity After 10 Years	18,796
Amortized Cost, Debt securities available for sale, Total	20,703
Amortized Cost, Debt securities held to maturity, Maturity of 1 Year or Less	0
Amortized Cost, Debt securities held to maturity, Maturity of 1-5 Years	0
Amortized Cost, Debt securities held to maturity, Maturity of 5-10 Years	0
Amortized Cost, Debt securities held to maturity, Maturity After 10 Years	3,525
Amortized Cost, Debt securities held to maturity, Total	3,525
Fair Value:
Fair Value, Debt securities available for sale, Maturity of 1 Year or Less	0
Fair Value, Debt securities available for sale, Maturity of 1-5 Years	306
Fair Value, Debt securities available for sale, Maturity of 5-10 Years	1,555
Fair Value, Debt securities available for sale, Maturity After 10 Years	18,025
Fair Value, Debt securities available for sale, Total	19,886
Fair Value, Debt securities held to maturity, Maturity of 1 Year or Less	0
Fair Value, Debt securities held to maturity, Maturity of 1-5 Years	0
Fair Value, Debt securities held to maturity, Maturity of 5-10 Years	0
Fair Value, Debt securities held to maturity, Maturity After 10 Years	3,348
Fair Value, Debt securities held to maturity, Total	3,348
Other/non-agency
Amortized Cost:
Amortized Cost, Debt securities available for sale, Maturity of 1 Year or Less	2
Amortized Cost, Debt securities available for sale, Maturity of 1-5 Years	11
Amortized Cost, Debt securities available for sale, Maturity of 5-10 Years	0
Amortized Cost, Debt securities available for sale, Maturity After 10 Years	238
Amortized Cost, Debt securities available for sale, Total	251
Amortized Cost, Debt securities held to maturity, Maturity of 1 Year or Less	0
Amortized Cost, Debt securities held to maturity, Maturity of 1-5 Years	0
Amortized Cost, Debt securities held to maturity, Maturity of 5-10 Years	0
Amortized Cost, Debt securities held to maturity, Maturity After 10 Years	759
Amortized Cost, Debt securities held to maturity, Total	759
Fair Value:
Fair Value, Debt securities available for sale, Maturity of 1 Year or Less	2
Fair Value, Debt securities available for sale, Maturity of 1-5 Years	11
Fair Value, Debt securities available for sale, Maturity of 5-10 Years	0
Fair Value, Debt securities available for sale, Maturity After 10 Years	236
Fair Value, Debt securities available for sale, Total	249
Fair Value, Debt securities held to maturity, Maturity of 1 Year or Less	0
Fair Value, Debt securities held to maturity, Maturity of 1-5 Years	0
Fair Value, Debt securities held to maturity, Maturity of 5-10 Years	0
Fair Value, Debt securities held to maturity, Maturity After 10 Years	754
Fair Value, Debt securities held to maturity, Total	$ 754

SECURITIES - Income Recognized

SECURITIES - Income Recognized from Investment Securities (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Gain (Loss) on Sale of Investments [Abstract]
Gains on sale of debt securities	$ 3	$ 2	$ 13	$ 9
Losses on sale of debt securities	0	0	0	0
Debt securities gains, net	3	2	13	9
Equity securities gains	$ 0	$ 0	$ 0	$ 1

SECURITIES - Schedule of Securi

SECURITIES - Schedule of Securities Pledged (Details) - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
Investments, Debt and Equity Securities [Abstract]
Pledged against repurchase agreements, Amortized Cost	$ 391	$ 358
Pledged against FHLB borrowed funds, Amortized Cost	764	839
Pledged against derivatives to qualify for fiduciary powers, and to secure public and other deposits as required by law, Amortized Cost	3,699	3,113
Pledged against repurchase agreements, Fair Value	376	357
Pledged against FHLB borrowed funds, Fair Value	760	861
Pledged against derivatives to qualify for fiduciary powers, and to secure public and other deposits as required by law, Fair Value	$ 3,519	$ 3,082

SECURITIES - Schedule of Inve_2

SECURITIES - Schedule of Investments in Continuous Loss Positions (Details) $ in Millions	Sep. 30, 2018USD ($)Securities	Dec. 31, 2017USD ($)Securities
Number of Issues
Less than 12 Months | Securities	507	300
12 Months or Longer | Securities	170	162
Total | Securities	677	462
Fair Value
Less than 12 Months	$ 15,719	$ 10,218
12 Months or Longer	7,291	8,145
Total	23,010	18,363
Gross Unrealized Losses
Less than 12 Months	(520)	(98)
12 Months or Longer	(494)	(232)
Total	$ (1,014)	$ (330)
Federal agencies and U.S. government sponsored entities
Number of Issues
Less than 12 Months | Securities	493	294
12 Months or Longer | Securities	159	152
Total | Securities	652	446
Fair Value
Less than 12 Months	$ 15,177	$ 10,163
12 Months or Longer	7,215	8,061
Total	22,392	18,224
Gross Unrealized Losses
Less than 12 Months	(514)	(97)
12 Months or Longer	(488)	(226)
Total	$ (1,002)	$ (323)
Other/non-agency
Number of Issues
Less than 12 Months | Securities	14	6
12 Months or Longer | Securities	11	10
Total | Securities	25	16
Fair Value
Less than 12 Months	$ 542	$ 55
12 Months or Longer	76	84
Total	618	139
Gross Unrealized Losses
Less than 12 Months	(6)	(1)
12 Months or Longer	(6)	(6)
Total	$ (12)	$ (7)

SECURITIES - Schedule of Cumula

SECURITIES - Schedule of Cumulative Credit Losses Recognized in Earnings (Details) - Available-for-sale Securities - USD ($) $ in Millions		3 Months Ended		9 Months Ended
		Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Other than Temporary Impairment, Credit Losses Recognized in Earnings [Roll Forward]
Cumulative balance at beginning of period		$ 81	$ 79	$ 80	$ 75
Credit impairments recognized in earnings on debt securities that have been previously impaired		1	1	3	6
Reductions due to increases in cash flow expectations on impaired securities	[1]	(1)	0	(2)	(1)
Cumulative balance at end of period		$ 81	$ 80	$ 81	$ 80
[1]	Reported in interest income from investment securities on the Consolidated Statements of Operations.

LOANS AND LEASES - Narrative (D

LOANS AND LEASES - Narrative (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017	Dec. 31, 2017
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans held for sale	$ 1,303		$ 1,303		$ 497
Other loans held for sale	27		27		221
Level 2
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans held for sale	1,303		1,303		497
Other loans held for sale	0		0		0
Residential loans held for sale | Level 2
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans held for sale	1,140		1,140		326
Commercial real estate loans held for sale | Level 2
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans held for sale	163		163		171
Retail | Education
Accounts, Notes, Loans and Financing Receivable [Line Items]
Payments for purchase of loans	98	$ 63	321	$ 795
Retail | Residential mortgages
Accounts, Notes, Loans and Financing Receivable [Line Items]
Proceeds from sale of loans		$ 0		206
Retail | Automobile
Accounts, Notes, Loans and Financing Receivable [Line Items]
Payments for purchase of loans				153
Retail | Residential mortgages
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans pledged as collateral for FHLB borrowed funds	25,300		25,300		24,900
Loans pledged as collateral to support the contingent ability to borrow at the FRB discount window	$ 18,700		18,700		$ 18,100
Commercial | Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
Proceeds from sale of loans			$ 553	$ 596

LOANS AND LEASES - Summary of L

LOANS AND LEASES - Summary of Loans and Leases Portfolio (Details) - USD ($) $ in Millions		Sep. 30, 2018	Dec. 31, 2017
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	[1],[2]	$ 114,720	$ 110,617
Loans receivable held for sale		1,300	718
Mortgage loans serviced for others | Banking Subsidiaries
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		67,500	20,300
Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		55,405	52,031
Commercial | Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		39,770	37,562
Commercial | Commercial real estate
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		12,630	11,308
Commercial | Leases
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		3,005	3,161
Retail
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		59,315	58,586
Retail | Residential mortgages
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		18,493	17,045
Retail | Home equity loans
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		1,131	1,392
Retail | Home equity lines of credit
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		12,863	13,483
Retail | Home equity loans serviced by others
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		429	542
Retail | Home equity lines of credit serviced by others
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		114	149
Retail | Automobile
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		12,255	13,204
Retail | Education
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		8,712	8,134
Retail | Credit cards
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		1,911	1,848
Retail | Other retail
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		$ 3,407	$ 2,789
[1]	Excluded from the table above are loans held for sale totaling $1.3 billion and $718 million as of September 30, 2018 and December 31, 2017, respectively.
[2]	Mortgage loans serviced for others by the Company’s subsidiaries are not included above, and amounted to $67.5 billion and $20.3 billion at September 30, 2018 and December 31, 2017, respectively.

ALLOWANCE FOR CREDIT LOSSES, _3

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Narrative (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended		12 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017	Dec. 31, 2017
Financing Receivable, Modifications [Line Items]
Provision charged to income			$ 241	$ 238
Nonperforming assets, net of valuation allowance	$ 31		31		$ 36
Mortgage loans collateralized by OREO	174		174		181
Larger balance commercial loans minimum balance (greater than)	3		$ 3
High loan to value criteria (exceeds)			90.00%
Allowance for loan and lease losses
Financing Receivable, Modifications [Line Items]
Provision charged to income	75	$ 70	$ 238	215
Allowance for loan and lease losses | Commercial
Financing Receivable, Modifications [Line Items]
Provision charged to income	$ 8	$ 24	$ 47	$ 8
Scenario, Adjustment | Allowance for loan and lease losses | Commercial
Financing Receivable, Modifications [Line Items]
Provision charged to income					$ 50

ALLOWANCE FOR CREDIT LOSSES, _4

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Summary of Changes in Allowance for Credit Losses (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended		12 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017	Dec. 31, 2017
Allowance for Loan and Lease Losses [Roll Forward]
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Beginning balance			$ 1,236
Provision charged to income			241	$ 238
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	$ 1,242		1,242		$ 1,236
Allowance for loan and lease losses
Allowance for Loan and Lease Losses [Roll Forward]
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Beginning balance	1,253	$ 1,219	1,236	1,236	1,236
Charge-offs	(127)	(120)	(363)	(381)
Recoveries	41	55	131	154
Net charge-offs	(86)	(65)	(232)	(227)
Provision charged to income	75	70	238	215
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	1,242	1,224	1,242	1,224	1,236
Reserve for unfunded lending commitments
Allowance for Loan and Lease Losses [Roll Forward]
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Beginning balance	88	93	88	72	72
Provision for unfunded lending commitments	3	2	3	23
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	91	95	91	95	88
Allowance for loan and lease losses and reserve for off-balance sheet activities, total
Allowance for Loan and Lease Losses [Roll Forward]
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	1,333	1,319	1,333	1,319
Commercial | Allowance for loan and lease losses
Allowance for Loan and Lease Losses [Roll Forward]
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Beginning balance	715	614	685	663	663
Charge-offs	(18)	(12)	(35)	(60)
Recoveries	2	12	10	27
Net charge-offs	(16)	0	(25)	(33)
Provision charged to income	8	24	47	8
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	707	638	707	638	685
Commercial | Reserve for unfunded lending commitments
Allowance for Loan and Lease Losses [Roll Forward]
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Beginning balance	88	93	88	72	72
Provision for unfunded lending commitments	3	2	3	23
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	91	95	91	95	88
Commercial | Allowance for loan and lease losses and reserve for off-balance sheet activities, total
Allowance for Loan and Lease Losses [Roll Forward]
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	798	733	798	733
Retail | Allowance for loan and lease losses
Allowance for Loan and Lease Losses [Roll Forward]
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Beginning balance	538	605	551	573	573
Charge-offs	(109)	(108)	(328)	(321)
Recoveries	39	43	121	127
Net charge-offs	(70)	(65)	(207)	(194)
Provision charged to income	67	46	191	207
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	535	586	535	586	551
Retail | Reserve for unfunded lending commitments
Allowance for Loan and Lease Losses [Roll Forward]
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Beginning balance	0	0	0	0	0
Provision for unfunded lending commitments	0	0	0	0
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	0	0	0	0	$ 0
Retail | Allowance for loan and lease losses and reserve for off-balance sheet activities, total
Allowance for Loan and Lease Losses [Roll Forward]
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	$ 535	$ 586	$ 535	$ 586

ALLOWANCE FOR CREDIT LOSSES, _5

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Recorded Investment in Loan and Leases (Details) - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment [Line Items]
Individually evaluated	$ 1,165	$ 1,131
Formula-based evaluation	113,555	109,486
Total	114,720	110,617
Commercial
Financing Receivable, Recorded Investment [Line Items]
Individually evaluated	430	370
Formula-based evaluation	54,975	51,661
Total	55,405	52,031
Retail
Financing Receivable, Recorded Investment [Line Items]
Individually evaluated	735	761
Formula-based evaluation	58,580	57,825
Total	$ 59,315	$ 58,586

ALLOWANCE FOR CREDIT LOSSES, _6

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Summary of Allowance for Credit Losses by Evaluation Method (Details) - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
Financing Receivable, Allowance for Credit Losses [Line Items]
Individually evaluated	$ 86	$ 81
Formula-based evaluation	1,247	1,243
Allowance for credit losses	1,333	1,324
Commercial
Financing Receivable, Allowance for Credit Losses [Line Items]
Individually evaluated	59	47
Formula-based evaluation	739	726
Allowance for credit losses	798	773
Retail
Financing Receivable, Allowance for Credit Losses [Line Items]
Individually evaluated	27	34
Formula-based evaluation	508	517
Allowance for credit losses	$ 535	$ 551

ALLOWANCE FOR CREDIT LOSSES, _7

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Recorded Investment in Commercial Loans and Leases by Regulatory Classification Ratings (Details) - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment [Line Items]
Total	$ 114,720	$ 110,617
Commercial
Financing Receivable, Recorded Investment [Line Items]
Total	55,405	52,031
Commercial | Pass
Financing Receivable, Recorded Investment [Line Items]
Total	52,344	49,205
Commercial | Special Mention
Financing Receivable, Recorded Investment [Line Items]
Total	1,772	1,716
Commercial | Substandard
Financing Receivable, Recorded Investment [Line Items]
Total	1,028	878
Commercial | Doubtful
Financing Receivable, Recorded Investment [Line Items]
Total	261	232
Commercial | Commercial
Financing Receivable, Recorded Investment [Line Items]
Total	39,770	37,562
Commercial | Commercial | Pass
Financing Receivable, Recorded Investment [Line Items]
Total	37,242	35,430
Commercial | Commercial | Special Mention
Financing Receivable, Recorded Investment [Line Items]
Total	1,441	1,143
Commercial | Commercial | Substandard
Financing Receivable, Recorded Investment [Line Items]
Total	854	785
Commercial | Commercial | Doubtful
Financing Receivable, Recorded Investment [Line Items]
Total	233	204
Commercial | Commercial real estate
Financing Receivable, Recorded Investment [Line Items]
Total	12,630	11,308
Commercial | Commercial real estate | Pass
Financing Receivable, Recorded Investment [Line Items]
Total	12,193	10,706
Commercial | Commercial real estate | Special Mention
Financing Receivable, Recorded Investment [Line Items]
Total	282	500
Commercial | Commercial real estate | Substandard
Financing Receivable, Recorded Investment [Line Items]
Total	127	74
Commercial | Commercial real estate | Doubtful
Financing Receivable, Recorded Investment [Line Items]
Total	28	28
Commercial | Leases
Financing Receivable, Recorded Investment [Line Items]
Total	3,005	3,161
Commercial | Leases | Pass
Financing Receivable, Recorded Investment [Line Items]
Total	2,909	3,069
Commercial | Leases | Special Mention
Financing Receivable, Recorded Investment [Line Items]
Total	49	73
Commercial | Leases | Substandard
Financing Receivable, Recorded Investment [Line Items]
Total	47	19
Commercial | Leases | Doubtful
Financing Receivable, Recorded Investment [Line Items]
Total	$ 0	$ 0

ALLOWANCE FOR CREDIT LOSSES, _8

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Recorded Investment in Retail Loans by Delinquency Status (Details) - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	$ 1,190	$ 1,456
Total	114,720	110,617
Financing Receivables, 30 to 59 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	450	501
Financing Receivables 60 To 89 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	142	163
Financing Receivables 90 Days or More Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	598	792
Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	56,323	55,195
Past Due	967	1,090
Total	59,315	58,586
Retail | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	18,173	16,714
Past Due	184	184
Total	18,493	17,045
Retail | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	999	1,212
Past Due	53	78
Total	1,131	1,392
Retail | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	12,214	12,756
Past Due	266	289
Total	12,863	13,483
Retail | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	382	477
Past Due	23	36
Total	429	542
Retail | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	87	116
Past Due	10	12
Total	114	149
Retail | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	10,849	11,596
Past Due	297	335
Total	12,255	13,204
Retail | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	8,514	7,898
Past Due	47	76
Total	8,712	8,134
Retail | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	1,814	1,747
Past Due	40	38
Total	1,911	1,848
Retail | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	3,291	2,679
Past Due	47	42
Total	3,407	2,789
Retail | Financing Receivables, 1 to 29 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	2,025	2,301
Retail | Financing Receivables, 1 to 29 Days Past Due | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	136	147
Retail | Financing Receivables, 1 to 29 Days Past Due | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	79	102
Retail | Financing Receivables, 1 to 29 Days Past Due | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	383	438
Retail | Financing Receivables, 1 to 29 Days Past Due | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	24	29
Retail | Financing Receivables, 1 to 29 Days Past Due | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	17	21
Retail | Financing Receivables, 1 to 29 Days Past Due | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	1,109	1,273
Retail | Financing Receivables, 1 to 29 Days Past Due | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	151	160
Retail | Financing Receivables, 1 to 29 Days Past Due | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	57	63
Retail | Financing Receivables, 1 to 29 Days Past Due | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	69	68
Retail | Financing Receivables, 30 to 59 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	358	433
Retail | Financing Receivables, 30 to 59 Days Past Due | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	37	46
Retail | Financing Receivables, 30 to 59 Days Past Due | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	11	20
Retail | Financing Receivables, 30 to 59 Days Past Due | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	55	78
Retail | Financing Receivables, 30 to 59 Days Past Due | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	6	10
Retail | Financing Receivables, 30 to 59 Days Past Due | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	2	4
Retail | Financing Receivables, 30 to 59 Days Past Due | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	189	220
Retail | Financing Receivables, 30 to 59 Days Past Due | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	24	23
Retail | Financing Receivables, 30 to 59 Days Past Due | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	14	12
Retail | Financing Receivables, 30 to 59 Days Past Due | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	20	20
Retail | Financing Receivables 60 To 89 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	132	138
Retail | Financing Receivables 60 To 89 Days Past Due | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	13	18
Retail | Financing Receivables 60 To 89 Days Past Due | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	3	4
Retail | Financing Receivables 60 To 89 Days Past Due | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	25	23
Retail | Financing Receivables 60 To 89 Days Past Due | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	2	4
Retail | Financing Receivables 60 To 89 Days Past Due | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	1	1
Retail | Financing Receivables 60 To 89 Days Past Due | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	51	55
Retail | Financing Receivables 60 To 89 Days Past Due | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	13	12
Retail | Financing Receivables 60 To 89 Days Past Due | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	9	9
Retail | Financing Receivables 60 To 89 Days Past Due | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	15	12
Retail | Financing Receivables 90 Days or More Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	477	519
Retail | Financing Receivables 90 Days or More Past Due | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	134	120
Retail | Financing Receivables 90 Days or More Past Due | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	39	54
Retail | Financing Receivables 90 Days or More Past Due | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	186	188
Retail | Financing Receivables 90 Days or More Past Due | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	15	22
Retail | Financing Receivables 90 Days or More Past Due | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	7	7
Retail | Financing Receivables 90 Days or More Past Due | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	57	60
Retail | Financing Receivables 90 Days or More Past Due | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	10	41
Retail | Financing Receivables 90 Days or More Past Due | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	17	17
Retail | Financing Receivables 90 Days or More Past Due | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	$ 12	$ 10

ALLOWANCE FOR CREDIT LOSSES, _9

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Nonperforming Loans and Leases by Class (Details) - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	$ 832	$ 871
Loans accruing and 90 days or more past due	25	32
GNMA
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans sold with right to repurchase	116	30
Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Loans accruing and 90 days or more past due	13	15
Commercial | Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	228	238
Loans accruing and 90 days or more past due	0	5
Commercial | Commercial real estate
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	30	27
Loans accruing and 90 days or more past due	0	3
Commercial | Leases
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	0	0
Loans accruing and 90 days or more past due	0	0
Commercial | Commercial Banking
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	258	265
Loans accruing and 90 days or more past due	0	8
Retail | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	136	128
Loans accruing and 90 days or more past due	16	16
Retail | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	53	72
Loans accruing and 90 days or more past due	0	0
Retail | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	221	233
Loans accruing and 90 days or more past due	0	0
Retail | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	19	25
Loans accruing and 90 days or more past due	0	0
Retail | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	16	18
Loans accruing and 90 days or more past due	0	0
Retail | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	67	70
Loans accruing and 90 days or more past due	0	0
Retail | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	38	38
Loans accruing and 90 days or more past due	3	3
Retail | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	17	17
Loans accruing and 90 days or more past due	0	0
Retail | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	7	5
Loans accruing and 90 days or more past due	6	5
Retail | Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	574	606
Loans accruing and 90 days or more past due	$ 25	$ 24

ALLOWANCE FOR CREDIT LOSSES,_10

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Performance Indicators for Nonperforming Assets (Details)	Sep. 30, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment, Past Due [Line Items]
Total nonperforming loans and leases as a percentage of total loans and leases	0.73%	0.79%
Total nonperforming assets as a percentage of total assets	0.54%	0.60%
Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Total nonperforming loans and leases as a percentage of total loans and leases	0.23%	0.24%
Total nonperforming assets as a percentage of total assets	0.16%	0.17%
Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Total nonperforming loans and leases as a percentage of total loans and leases	0.50%	0.55%
Total nonperforming assets as a percentage of total assets	0.38%	0.43%

ALLOWANCE FOR CREDIT LOSSES,_11

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Accruing and Nonaccruing Past Due Amounts (Details) - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	$ 1,190	$ 1,456
Financing Receivables, 30 to 59 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	450	501
Financing Receivables 60 To 89 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	142	163
Financing Receivables 90 Days or More Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	598	792
Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	223	366
Commercial | Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	143	273
Commercial | Commercial real estate
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	80	88
Commercial | Leases
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	0	5
Commercial | Financing Receivables, 30 to 59 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	92	68
Commercial | Financing Receivables, 30 to 59 Days Past Due | Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	46	26
Commercial | Financing Receivables, 30 to 59 Days Past Due | Commercial real estate
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	46	38
Commercial | Financing Receivables, 30 to 59 Days Past Due | Leases
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	0	4
Commercial | Financing Receivables 60 To 89 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	10	25
Commercial | Financing Receivables 60 To 89 Days Past Due | Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	3	4
Commercial | Financing Receivables 60 To 89 Days Past Due | Commercial real estate
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	7	20
Commercial | Financing Receivables 60 To 89 Days Past Due | Leases
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	0	1
Commercial | Financing Receivables 90 Days or More Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	121	273
Commercial | Financing Receivables 90 Days or More Past Due | Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	94	243
Commercial | Financing Receivables 90 Days or More Past Due | Commercial real estate
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	27	30
Commercial | Financing Receivables 90 Days or More Past Due | Leases
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	0	0
Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	967	1,090
Retail | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	184	184
Retail | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	53	78
Retail | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	266	289
Retail | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	23	36
Retail | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	10	12
Retail | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	297	335
Retail | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	47	76
Retail | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	40	38
Retail | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	47	42
Retail | Financing Receivables, 30 to 59 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	358	433
Retail | Financing Receivables, 30 to 59 Days Past Due | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	37	46
Retail | Financing Receivables, 30 to 59 Days Past Due | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	11	20
Retail | Financing Receivables, 30 to 59 Days Past Due | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	55	78
Retail | Financing Receivables, 30 to 59 Days Past Due | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	6	10
Retail | Financing Receivables, 30 to 59 Days Past Due | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	2	4
Retail | Financing Receivables, 30 to 59 Days Past Due | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	189	220
Retail | Financing Receivables, 30 to 59 Days Past Due | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	24	23
Retail | Financing Receivables, 30 to 59 Days Past Due | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	14	12
Retail | Financing Receivables, 30 to 59 Days Past Due | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	20	20
Retail | Financing Receivables 60 To 89 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	132	138
Retail | Financing Receivables 60 To 89 Days Past Due | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	13	18
Retail | Financing Receivables 60 To 89 Days Past Due | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	3	4
Retail | Financing Receivables 60 To 89 Days Past Due | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	25	23
Retail | Financing Receivables 60 To 89 Days Past Due | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	2	4
Retail | Financing Receivables 60 To 89 Days Past Due | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	1	1
Retail | Financing Receivables 60 To 89 Days Past Due | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	51	55
Retail | Financing Receivables 60 To 89 Days Past Due | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	13	12
Retail | Financing Receivables 60 To 89 Days Past Due | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	9	9
Retail | Financing Receivables 60 To 89 Days Past Due | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	15	12
Retail | Financing Receivables 90 Days or More Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	477	519
Retail | Financing Receivables 90 Days or More Past Due | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	134	120
Retail | Financing Receivables 90 Days or More Past Due | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	39	54
Retail | Financing Receivables 90 Days or More Past Due | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	186	188
Retail | Financing Receivables 90 Days or More Past Due | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	15	22
Retail | Financing Receivables 90 Days or More Past Due | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	7	7
Retail | Financing Receivables 90 Days or More Past Due | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	57	60
Retail | Financing Receivables 90 Days or More Past Due | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	10	41
Retail | Financing Receivables 90 Days or More Past Due | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	17	17
Retail | Financing Receivables 90 Days or More Past Due | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	$ 12	$ 10

ALLOWANCE FOR CREDIT LOSSES,_12

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Impaired Loans by Class (Details) - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	$ 537	$ 506
Allowance on Impaired Loans	86	81
Impaired Loans Without a Related Allowance	628	625
Unpaid Contractual Balance	1,407	1,364
Total Recorded Investment in Impaired Loans	1,165	1,131
Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	268	208
Allowance on Impaired Loans	59	47
Impaired Loans Without a Related Allowance	162	162
Unpaid Contractual Balance	517	443
Total Recorded Investment in Impaired Loans	430	370
Commercial | Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	237	183
Allowance on Impaired Loans	52	42
Impaired Loans Without a Related Allowance	133	159
Unpaid Contractual Balance	439	403
Total Recorded Investment in Impaired Loans	370	342
Commercial | Commercial real estate
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	31	25
Allowance on Impaired Loans	7	5
Impaired Loans Without a Related Allowance	29	3
Unpaid Contractual Balance	78	40
Total Recorded Investment in Impaired Loans	60	28
Commercial | Leases
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	0	0
Allowance on Impaired Loans	0	0
Impaired Loans Without a Related Allowance	0	0
Unpaid Contractual Balance	0	0
Total Recorded Investment in Impaired Loans	0	0
Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	269	298
Allowance on Impaired Loans	27	34
Impaired Loans Without a Related Allowance	466	463
Unpaid Contractual Balance	890	921
Total Recorded Investment in Impaired Loans	735	761
Retail | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	28	25
Allowance on Impaired Loans	2	2
Impaired Loans Without a Related Allowance	128	126
Unpaid Contractual Balance	201	197
Total Recorded Investment in Impaired Loans	156	151
Retail | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	34	41
Allowance on Impaired Loans	3	4
Impaired Loans Without a Related Allowance	72	80
Unpaid Contractual Balance	145	162
Total Recorded Investment in Impaired Loans	106	121
Retail | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	18	16
Allowance on Impaired Loans	1	1
Impaired Loans Without a Related Allowance	190	181
Unpaid Contractual Balance	253	241
Total Recorded Investment in Impaired Loans	208	197
Retail | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	23	29
Allowance on Impaired Loans	2	2
Impaired Loans Without a Related Allowance	20	22
Unpaid Contractual Balance	57	67
Total Recorded Investment in Impaired Loans	43	51
Retail | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	2	2
Allowance on Impaired Loans	0	0
Impaired Loans Without a Related Allowance	7	7
Unpaid Contractual Balance	12	14
Total Recorded Investment in Impaired Loans	9	9
Retail | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	2	2
Allowance on Impaired Loans	0	0
Impaired Loans Without a Related Allowance	23	21
Unpaid Contractual Balance	31	30
Total Recorded Investment in Impaired Loans	25	23
Retail | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	134	154
Allowance on Impaired Loans	11	17
Impaired Loans Without a Related Allowance	23	21
Unpaid Contractual Balance	158	175
Total Recorded Investment in Impaired Loans	157	175
Retail | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	24	24
Allowance on Impaired Loans	7	7
Impaired Loans Without a Related Allowance	0	1
Unpaid Contractual Balance	25	25
Total Recorded Investment in Impaired Loans	24	25
Retail | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	4	5
Allowance on Impaired Loans	1	1
Impaired Loans Without a Related Allowance	3	4
Unpaid Contractual Balance	8	10
Total Recorded Investment in Impaired Loans	$ 7	$ 9

ALLOWANCE FOR CREDIT LOSSES,_13

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Additional Impaired Loan Information (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	$ 11	$ 7	$ 31	$ 25
Average Recorded Investment	1,097	1,172	1,057	1,160
Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	3	1	7	3
Average Recorded Investment	368	424	351	441
Commercial | Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	3	1	7	3
Average Recorded Investment	334	391	318	402
Commercial | Commercial real estate
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	0	0	0	0
Average Recorded Investment	34	33	33	39
Commercial | Leases
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	0	0	0	0
Average Recorded Investment	0	0	0	0
Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	8	6	24	22
Average Recorded Investment	729	748	706	719
Retail | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	1	0	4	3
Average Recorded Investment	154	137	148	128
Retail | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	1	1	4	4
Average Recorded Investment	107	125	107	124
Retail | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	2	2	6	5
Average Recorded Investment	202	192	189	178
Retail | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	1	0	2	2
Average Recorded Investment	43	51	44	51
Retail | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	0	0	0	0
Average Recorded Investment	9	9	9	9
Retail | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	0	0	0	0
Average Recorded Investment	23	21	21	18
Retail | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	3	3	7	7
Average Recorded Investment	160	178	159	178
Retail | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	0	0	1	1
Average Recorded Investment	24	25	22	23
Retail | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	0	0	0	0
Average Recorded Investment	$ 7	$ 10	$ 7	$ 10

ALLOWANCE FOR CREDIT LOSSES,_14

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Unfunded Commitments (Details) - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
Accounts, Notes, Loans and Financing Receivable [Line Items]
Unfunded commitments tied to TDRs	$ 28	$ 39
Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
TDR balance included in impaired loans	253	129
Retail
Accounts, Notes, Loans and Financing Receivable [Line Items]
TDR balance included in impaired loans	$ 735	$ 761

ALLOWANCE FOR CREDIT LOSSES,_15

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Troubled Debt Restructuring (Details) $ in Millions		3 Months Ended		9 Months Ended
		Sep. 30, 2018USD ($)contract	Sep. 30, 2017USD ($)contract	Sep. 30, 2018USD ($)contract	Sep. 30, 2017USD ($)contract
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		$ 1	$ 0	$ 3	$ 3
Charge-offs Resulting from Modification		$ 2	$ 2	$ 3	$ 4
Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	718	744	2,032	2,133
Pre-Modification Outstanding Recorded Investment	[1]	$ 9	$ 9	$ 24	$ 27
Post-Modification Outstanding Recorded Investment	[1]	$ 9	$ 9	$ 25	$ 28
Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	97	127	262	316
Pre-Modification Outstanding Recorded Investment	[2]	$ 13	$ 20	$ 30	$ 57
Post-Modification Outstanding Recorded Investment	[2]	$ 13	$ 20	$ 30	$ 57
Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	549	685	1,801	1,941
Pre-Modification Outstanding Recorded Investment	[3]	$ 20	$ 51	$ 248	$ 134
Post-Modification Outstanding Recorded Investment	[3]	18	51	246	131
Commercial
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	0	1
Charge-offs Resulting from Modification		$ 0	$ 0	$ 0	$ 0
Commercial | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	1	3	6	7
Pre-Modification Outstanding Recorded Investment	[1]	$ 0	$ 1	$ 1	$ 2
Post-Modification Outstanding Recorded Investment	[1]	$ 0	$ 1	$ 1	$ 2
Commercial | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	13	18	24	36
Pre-Modification Outstanding Recorded Investment	[2]	$ 1	$ 8	$ 2	$ 22
Post-Modification Outstanding Recorded Investment	[2]	$ 1	$ 7	$ 2	$ 21
Commercial | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	1	8	42	13
Pre-Modification Outstanding Recorded Investment	[3]	$ 0	$ 28	$ 186	$ 64
Post-Modification Outstanding Recorded Investment	[3]	0	30	187	65
Commercial | Commercial
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	0	1
Charge-offs Resulting from Modification		$ 0	$ 0	$ 0	$ 0
Commercial | Commercial | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	1	3	6	7
Pre-Modification Outstanding Recorded Investment	[1]	$ 0	$ 1	$ 1	$ 2
Post-Modification Outstanding Recorded Investment	[1]	$ 0	$ 1	$ 1	$ 2
Commercial | Commercial | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	13	17	23	35
Pre-Modification Outstanding Recorded Investment	[2]	$ 1	$ 8	$ 2	$ 22
Post-Modification Outstanding Recorded Investment	[2]	$ 1	$ 7	$ 2	$ 21
Commercial | Commercial | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	1	7	40	12
Pre-Modification Outstanding Recorded Investment	[3]	$ 0	$ 28	$ 155	$ 64
Post-Modification Outstanding Recorded Investment	[3]	0	30	156	65
Commercial | Commercial real estate
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	0	0
Charge-offs Resulting from Modification		$ 0	$ 0	$ 0	$ 0
Commercial | Commercial real estate | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	0	0	0	0
Pre-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0	$ 0
Commercial | Commercial real estate | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	0	1	1	1
Pre-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0	$ 0
Commercial | Commercial real estate | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	0	1	2	1
Pre-Modification Outstanding Recorded Investment	[3]	$ 0	$ 0	$ 31	$ 0
Post-Modification Outstanding Recorded Investment	[3]	0	0	31	0
Retail
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		1	0	3	2
Charge-offs Resulting from Modification		$ 2	$ 2	$ 3	$ 4
Retail | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	717	741	2,026	2,126
Pre-Modification Outstanding Recorded Investment	[1]	$ 9	$ 8	$ 23	$ 25
Post-Modification Outstanding Recorded Investment	[1]	$ 9	$ 8	$ 24	$ 26
Retail | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	84	109	238	280
Pre-Modification Outstanding Recorded Investment	[2]	$ 12	$ 12	$ 28	$ 35
Post-Modification Outstanding Recorded Investment	[2]	$ 12	$ 13	$ 28	$ 36
Retail | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	548	677	1,759	1,928
Pre-Modification Outstanding Recorded Investment	[3]	$ 20	$ 23	$ 62	$ 70
Post-Modification Outstanding Recorded Investment	[3]	18	21	59	66
Retail | Residential mortgages
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		(1)	(1)	(1)	(1)
Charge-offs Resulting from Modification		$ 0	$ 0	$ 0	$ 0
Retail | Residential mortgages | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	9	13	32	56
Pre-Modification Outstanding Recorded Investment	[1]	$ 1	$ 1	$ 3	$ 6
Post-Modification Outstanding Recorded Investment	[1]	$ 1	$ 2	$ 4	$ 7
Retail | Residential mortgages | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	17	15	47	50
Pre-Modification Outstanding Recorded Investment	[2]	$ 2	$ 1	$ 6	$ 9
Post-Modification Outstanding Recorded Investment	[2]	$ 2	$ 2	$ 6	$ 10
Retail | Residential mortgages | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	31	38	117	122
Pre-Modification Outstanding Recorded Investment	[3]	$ 4	$ 3	$ 14	$ 13
Post-Modification Outstanding Recorded Investment	[3]	3	3	14	13
Retail | Home equity loans
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	0	0
Charge-offs Resulting from Modification		$ 0	$ 0	$ 0	$ 0
Retail | Home equity loans | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	10	25	32	68
Pre-Modification Outstanding Recorded Investment	[1]	$ 0	$ 2	$ 2	$ 4
Post-Modification Outstanding Recorded Investment	[1]	$ 1	$ 1	$ 3	$ 4
Retail | Home equity loans | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	0	0	1	1
Pre-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0	$ 0
Retail | Home equity loans | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	40	49	106	192
Pre-Modification Outstanding Recorded Investment	[3]	$ 2	$ 3	$ 5	$ 11
Post-Modification Outstanding Recorded Investment	[3]	2	3	5	11
Retail | Home equity lines of credit
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	0	0
Charge-offs Resulting from Modification		$ 0	$ 1	$ 0	$ 1
Retail | Home equity lines of credit | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	27	11	55	41
Pre-Modification Outstanding Recorded Investment	[1]	$ 3	$ 1	$ 5	$ 2
Post-Modification Outstanding Recorded Investment	[1]	$ 3	$ 1	$ 5	$ 2
Retail | Home equity lines of credit | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	58	86	147	204
Pre-Modification Outstanding Recorded Investment	[2]	$ 10	$ 11	$ 21	$ 26
Post-Modification Outstanding Recorded Investment	[2]	$ 10	$ 11	$ 21	$ 26
Retail | Home equity lines of credit | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	104	110	310	295
Pre-Modification Outstanding Recorded Investment	[3]	$ 7	$ 6	$ 22	$ 20
Post-Modification Outstanding Recorded Investment	[3]	7	7	21	20
Retail | Home equity loans serviced by others
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	0	0
Charge-offs Resulting from Modification		$ 0	$ 0	$ 0	$ 0
Retail | Home equity loans serviced by others | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	2	3	3	14
Pre-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0	$ 1
Post-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0	$ 1
Retail | Home equity loans serviced by others | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	0	0	0	0
Pre-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0	$ 0
Retail | Home equity loans serviced by others | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	5	11	20	41
Pre-Modification Outstanding Recorded Investment	[3]	$ 1	$ 1	$ 1	$ 2
Post-Modification Outstanding Recorded Investment	[3]	1	0	1	1
Retail | Home equity lines of credit serviced by others
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	0	0
Charge-offs Resulting from Modification		$ 0	$ 0	$ 0	$ 0
Retail | Home equity lines of credit serviced by others | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	1	0	5	3
Pre-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0	$ 0
Retail | Home equity lines of credit serviced by others | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	0	0	1	2
Pre-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0	$ 0
Retail | Home equity lines of credit serviced by others | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	8	8	13	21
Pre-Modification Outstanding Recorded Investment	[3]	$ 0	$ 1	$ 0	$ 2
Post-Modification Outstanding Recorded Investment	[3]	0	0	0	1
Retail | Automobile
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	0	0
Charge-offs Resulting from Modification		$ 2	$ 1	$ 3	$ 3
Retail | Automobile | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	45	28	122	93
Pre-Modification Outstanding Recorded Investment	[1]	$ 1	$ 1	$ 3	$ 2
Post-Modification Outstanding Recorded Investment	[1]	$ 0	$ 1	$ 2	$ 2
Retail | Automobile | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	9	8	42	23
Pre-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 1	$ 0
Post-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 1	$ 0
Retail | Automobile | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	315	392	893	1,017
Pre-Modification Outstanding Recorded Investment	[3]	$ 5	$ 7	$ 15	$ 18
Post-Modification Outstanding Recorded Investment	[3]	4	6	13	16
Retail | Education
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		1	0	1	1
Charge-offs Resulting from Modification		$ 0	$ 0	$ 0	$ 0
Retail | Education | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	0	0	0	0
Pre-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0	$ 0
Retail | Education | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	0	0	0	0
Pre-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0	$ 0
Retail | Education | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	45	67	296	235
Pre-Modification Outstanding Recorded Investment	[3]	$ 1	$ 2	$ 5	$ 4
Post-Modification Outstanding Recorded Investment	[3]	1	2	5	4
Retail | Credit cards
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		1	1	3	3
Charge-offs Resulting from Modification		$ 0	$ 0	$ 0	$ 0
Retail | Credit cards | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	623	661	1,776	1,850
Pre-Modification Outstanding Recorded Investment	[1]	$ 4	$ 3	$ 10	$ 10
Post-Modification Outstanding Recorded Investment	[1]	$ 4	$ 3	$ 10	$ 10
Retail | Credit cards | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	0	0	0	0
Pre-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0	$ 0
Retail | Credit cards | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	0	0	0	0
Pre-Modification Outstanding Recorded Investment	[3]	$ 0	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[3]	0	0	0	0
Retail | Other retail
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	0	(1)
Charge-offs Resulting from Modification		$ 0	$ 0	$ 0	$ 0
Retail | Other retail | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	0	0	1	1
Pre-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0	$ 0
Retail | Other retail | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	0	0	0	0
Pre-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0	$ 0
Retail | Other retail | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	0	2	4	5
Pre-Modification Outstanding Recorded Investment	[3]	$ 0	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[3]	$ 0	$ 0	$ 0	$ 0
[1]	Includes modifications that consist of multiple concessions, one of which is an interest rate reduction.
[2]	Includes modifications that consist of multiple concessions, one of which is a maturity extension (unless one of the other concessions was an interest rate reduction).
[3]	Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forgiveness, and capitalizing arrearages. Also included are the following: deferrals, trial modifications, certain bankruptcies, loans in forbearance and prepayment plans. Modifications can include the deferral of accrued interest resulting in post modification balances being higher than pre-modification.

ALLOWANCE FOR CREDIT LOSSES,_16

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Default of Modified Debt Agreements (Details) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018USD ($)contract	Sep. 30, 2017USD ($)contract	Sep. 30, 2018USD ($)contract	Sep. 30, 2017USD ($)contract
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	260	279	781	832
Balance Defaulted | $	$ 42	$ 14	$ 82	$ 40
Commercial
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	9	2	16	8
Balance Defaulted | $	$ 32	$ 4	$ 52	$ 9
Commercial | Commercial
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	9	2	15	7
Balance Defaulted | $	$ 32	$ 4	$ 52	$ 5
Commercial | Commercial real estate
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	0	0	1	1
Balance Defaulted | $	$ 0	$ 0	$ 0	$ 4
Retail
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	251	277	765	824
Balance Defaulted | $	$ 10	$ 10	$ 30	$ 31
Retail | Residential mortgages
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	33	35	103	121
Balance Defaulted | $	$ 4	$ 5	$ 12	$ 15
Retail | Home equity loans
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	6	12	24	35
Balance Defaulted | $	$ 0	$ 0	$ 1	$ 1
Retail | Home equity lines of credit
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	59	55	165	152
Balance Defaulted | $	$ 5	$ 4	$ 13	$ 11
Retail | Home equity loans serviced by others
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	3	6	13	16
Balance Defaulted | $	$ 0	$ 0	$ 0	$ 0
Retail | Home equity lines of credit serviced by others
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	2	4	3	8
Balance Defaulted | $	$ 0	$ 0	$ 0	$ 0
Retail | Automobile
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	40	42	116	103
Balance Defaulted | $	$ 0	$ 0	$ 1	$ 1
Retail | Education
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	1	5	13	41
Balance Defaulted | $	$ 0	$ 1	$ 1	$ 1
Retail | Credit cards
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	106	116	327	344
Balance Defaulted | $	$ 1	$ 0	$ 2	$ 2
Retail | Other retail
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	1	2	1	4
Balance Defaulted | $	$ 0	$ 0	$ 0	$ 0

ALLOWANCE FOR CREDIT LOSSES,_17

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Loans with Indicators of High Credit Risk (Details) - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment [Line Items]
Total	$ 114,720	$ 110,617
High loan-to-value
Financing Receivable, Recorded Investment [Line Items]
Total	620	796
High loan-to-value | Residential Mortgages
Financing Receivable, Recorded Investment [Line Items]
Total	339	366
High loan-to-value | Home Equity Loans and Lines of Credit
Financing Receivable, Recorded Investment [Line Items]
Total	107	166
High loan-to-value | Home Equity Products Serviced by Others
Financing Receivable, Recorded Investment [Line Items]
Total	174	264
High loan-to-value | Credit Cards
Financing Receivable, Recorded Investment [Line Items]
Total	0	0
High loan-to-value | Education
Financing Receivable, Recorded Investment [Line Items]
Total		0
Interest-only/negative amortization
Financing Receivable, Recorded Investment [Line Items]
Total	1,786	1,764
Interest-only/negative amortization | Residential Mortgages
Financing Receivable, Recorded Investment [Line Items]
Total	1,786	1,763
Interest-only/negative amortization | Home Equity Loans and Lines of Credit
Financing Receivable, Recorded Investment [Line Items]
Total	0	0
Interest-only/negative amortization | Home Equity Products Serviced by Others
Financing Receivable, Recorded Investment [Line Items]
Total	0	0
Interest-only/negative amortization | Credit Cards
Financing Receivable, Recorded Investment [Line Items]
Total	0	0
Interest-only/negative amortization | Education
Financing Receivable, Recorded Investment [Line Items]
Total		1
Low introductory rate
Financing Receivable, Recorded Investment [Line Items]
Total	211	197
Low introductory rate | Residential Mortgages
Financing Receivable, Recorded Investment [Line Items]
Total	0	0
Low introductory rate | Home Equity Loans and Lines of Credit
Financing Receivable, Recorded Investment [Line Items]
Total	0	0
Low introductory rate | Home Equity Products Serviced by Others
Financing Receivable, Recorded Investment [Line Items]
Total	0	0
Low introductory rate | Credit Cards
Financing Receivable, Recorded Investment [Line Items]
Total	211	197
Low introductory rate | Education
Financing Receivable, Recorded Investment [Line Items]
Total		0
Multiple characteristics and other
Financing Receivable, Recorded Investment [Line Items]
Total	1	1
Multiple characteristics and other | Residential Mortgages
Financing Receivable, Recorded Investment [Line Items]
Total	1	1
Multiple characteristics and other | Home Equity Loans and Lines of Credit
Financing Receivable, Recorded Investment [Line Items]
Total	0	0
Multiple characteristics and other | Home Equity Products Serviced by Others
Financing Receivable, Recorded Investment [Line Items]
Total	0	0
Multiple characteristics and other | Credit Cards
Financing Receivable, Recorded Investment [Line Items]
Total	0	0
Multiple characteristics and other | Education
Financing Receivable, Recorded Investment [Line Items]
Total		0
Credit risk, loans with increased credit exposure
Financing Receivable, Recorded Investment [Line Items]
Total	2,618	2,758
Credit risk, loans with increased credit exposure | Residential Mortgages
Financing Receivable, Recorded Investment [Line Items]
Total	2,126	2,130
Credit risk, loans with increased credit exposure | Home Equity Loans and Lines of Credit
Financing Receivable, Recorded Investment [Line Items]
Total	107	166
Credit risk, loans with increased credit exposure | Home Equity Products Serviced by Others
Financing Receivable, Recorded Investment [Line Items]
Total	174	264
Credit risk, loans with increased credit exposure | Credit Cards
Financing Receivable, Recorded Investment [Line Items]
Total	$ 211	197
Credit risk, loans with increased credit exposure | Education
Financing Receivable, Recorded Investment [Line Items]
Total		$ 1

MORTGAGE BANKING - Residential

MORTGAGE BANKING - Residential Mortgage Loan Sales (Details) - USD ($) $ in Millions		3 Months Ended		9 Months Ended
		Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
SEC Schedule, 12-29, Real Estate Companies, Investment in Mortgage Loans on Real Estate [Line Items]
Residential mortgage loans sold with servicing retained				$ 4,259	$ 2,372
Residential mortgages
SEC Schedule, 12-29, Real Estate Companies, Investment in Mortgage Loans on Real Estate [Line Items]
Residential mortgage loans sold with servicing retained		$ 1,848	$ 828	3,173	2,372
Mortgage banking fees
SEC Schedule, 12-29, Real Estate Companies, Investment in Mortgage Loans on Real Estate [Line Items]
Gain on sales	[1]	29	25	59	54
Contractually specified servicing, late and other anciliary fees	[1]	$ 38	$ 13	$ 69	$ 40
[1]	Reported in mortgage banking fees in the Consolidated Statements of Operations.

MORTGAGE BANKING - Changes Rela

MORTGAGE BANKING - Changes Related to MSRs - Amortization Method (Details) - Residential mortgages - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
MSRs:
Balance as of beginning of period	$ 217	$ 170	$ 201	$ 167
Amount capitalized	11	9	26	28
Purchases	0	0	16	0
Amortization	(9)	(8)	(24)	(24)
Carrying amount before valuation allowance	219	171	219	171
Valuation allowance for servicing assets:
Balance at beginning of period	0	4	3	5
Valuation recoveries	0	0	(3)	(1)
Balance at end of period	0	4	0	4
Net carrying value of MSRs	$ 219	$ 167	$ 219	$ 167

MORTGAGE BANKING - Changes Re_2

MORTGAGE BANKING - Changes Related to MSRs - Fair Value Method (Details) - USD ($) $ in Millions		3 Months Ended	9 Months Ended
		Sep. 30, 2018	Sep. 30, 2018
MSRs
Fair value at end of the period		$ 612	$ 612
Residential mortgages
MSRs
Fair value as of beginning of period		0	0
Acquired MSRs		590	590
Amounts capitalized		29	29
Changes in unpaid principal balance during the period	[1]	(12)	(12)
Changes in fair value during the period	[2]	5	5
Fair value at end of the period		$ 612	$ 612
[1]	Represents changes in value due to i) passage of time including the impact from both regularly scheduled loan principal payments and partial paydowns, and ii) loans that paid off during the period.
[2]	Represents changes in value primarily due to market driven changes in interest rates and prepayment speeds.

MORTGAGE BANKING - Economic Ass

MORTGAGE BANKING - Economic Assumptions Used to Estimate Value of MSRs (Details) - USD ($) $ in Millions	9 Months Ended	12 Months Ended
	Sep. 30, 2018	Dec. 31, 2017
Servicing Assets And Servicing Liabilities At Amortized Cost, Assumptions Used To Estimate Fair Value [Abstract]
MRS portfolio fair value	$ 261	$ 218
Weighted average life (in years)	6 years 10 months 24 days	5 years 10 months 24 days
Weighted average constant prepayment rate	7.70%	10.00%
Weighted average discount rate	9.30%	9.90%
Servicing Assets and Servicing Liabilities at Fair Value, Assumptions Used to Estimate Fair Value [Abstract]
MSR portfolio fair value	$ 612
Weighted average life (in years)	8 years 8 months 12 days
Weighted average constant prepayment rate	7.30%
Weighted average option adjusted spread	6.25%
Minimum
Servicing Assets at Fair Value [Line Items]
Sensitivity analysis, basis spread	0.50%	0.50%
Servicing Assets And Servicing Liabilities At Amortized Cost, Assumptions Used To Estimate Fair Value [Abstract]
Decline in fair value due to 50 bps decrease in prepayment rate	$ 18	$ 22
Decline in fair value due to 50 bps decrease in discount rate	5	$ 4
Servicing Assets and Servicing Liabilities at Fair Value, Assumptions Used to Estimate Fair Value [Abstract]
Decline in fair value due to 50 bps decrease in prepayment rate	54
Decline in fair value due to 50 bps decrease in discount rate	$ 14
Maximum
Servicing Assets at Fair Value [Line Items]
Sensitivity analysis, basis spread	1.00%	1.00%
Servicing Assets And Servicing Liabilities At Amortized Cost, Assumptions Used To Estimate Fair Value [Abstract]
Decline in fair value due to 100 bps decrease in prepayment rate	$ 43	$ 46
Decline in fair value due to 100 bps decrease in discount rate	10	$ 8
Servicing Assets and Servicing Liabilities at Fair Value, Assumptions Used to Estimate Fair Value [Abstract]
Decline in fair value due to 100 bps decrease in prepayment rate	123
Decline in fair value due to 100 bps decrease in discount rate	$ 27

GOODWILL AND INTANGIBLE ASSET_2

GOODWILL AND INTANGIBLE ASSETS - Narrative (Details) $ in Millions	1 Months Ended	3 Months Ended		9 Months Ended
	Aug. 31, 2018USD ($)	Sep. 30, 2018USD ($)	Sep. 30, 2017USD ($)	Sep. 30, 2018USD ($)reporting_unit	Sep. 30, 2017USD ($)	Dec. 31, 2017USD ($)
Goodwill [Line Items]
Number of reporting units | reporting_unit				2
Increase in goodwill - acquisition				$ 59
Goodwill impairment loss		$ 0	$ 0	0	$ 0
Amortization of intangible assets		1	$ 0	1	$ 0
Franklin American Mortgage Company
Goodwill [Line Items]
Increase in goodwill - acquisition	$ 59
Intangible assets acquired	$ 32
Consumer Banking
Goodwill [Line Items]
Increase in goodwill - acquisition				59
Goodwill accumulated impairment loss		5,900		5,900		$ 5,900
Commercial Banking
Goodwill [Line Items]
Increase in goodwill - acquisition				0
Goodwill accumulated impairment loss		$ 50		$ 50		$ 50

GOODWILL AND INTANGIBLE ASSET_3

GOODWILL AND INTANGIBLE ASSETS - Goodwill Rollforward (Details) $ in Millions	9 Months Ended
	Sep. 30, 2018USD ($)
Goodwill [Roll Forward]
Balance at beginning of period	$ 6,887
Business acquisition	59
Balance at end of period	6,946
Consumer Banking
Goodwill [Roll Forward]
Balance at beginning of period	2,136
Business acquisition	59
Balance at end of period	2,195
Commercial Banking
Goodwill [Roll Forward]
Balance at beginning of period	4,751
Business acquisition	0
Balance at end of period	$ 4,751

GOODWILL AND INTANGIBLE ASSET_4

GOODWILL AND INTANGIBLE ASSETS - Intangible Assets (Details) - USD ($) $ in Millions	9 Months Ended
	Sep. 30, 2018	Dec. 31, 2017
Finite-Lived Intangible Assets, Net [Abstract]
Gross	$ 34	$ 2
Accumulated Amortization	1	0
Net	$ 33	2
Acquired technology
Finite-Lived Intangible Assets [Line Items]
Amortizable Lives	7 years
Finite-Lived Intangible Assets, Net [Abstract]
Gross	$ 20	0
Accumulated Amortization	0	0
Net	20	0
Acquired relationships
Finite-Lived Intangible Assets, Net [Abstract]
Gross	11	2
Accumulated Amortization	1	0
Net	10	2
Other
Finite-Lived Intangible Assets, Net [Abstract]
Gross	3	0
Accumulated Amortization	0	0
Net	$ 3	$ 0
Minimum | Acquired relationships
Finite-Lived Intangible Assets [Line Items]
Amortizable Lives	5 years
Minimum | Other
Finite-Lived Intangible Assets [Line Items]
Amortizable Lives	2 years
Maximum | Acquired relationships
Finite-Lived Intangible Assets [Line Items]
Amortizable Lives	15 years
Maximum | Other
Finite-Lived Intangible Assets [Line Items]
Amortizable Lives	3 years

GOODWILL AND INTANGIBLE ASSET_5

GOODWILL AND INTANGIBLE ASSETS - Intangible Assets Future Amortization Expense (Details) $ in Millions	Sep. 30, 2018USD ($)
Finite-Lived Intangible Assets, Net, Amortization Expense, Fiscal Year Maturity [Abstract]
Remainder of 2018	$ 1
2,019	5
2,020	5
2,021	4
2,022	$ 4

VARIABLE INTEREST ENTITIES - Na

VARIABLE INTEREST ENTITIES - Narrative (Details) - USD ($) $ in Millions		3 Months Ended		9 Months Ended
		Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017	Dec. 31, 2017
Variable Interest Entity
Lending to special purpose entities included in loans and leases	[1],[2]	$ 114,720		$ 114,720		$ 110,617
LIHTC Investments
Variable Interest Entity
Net impairment losses recognized in earnings		0	$ 0	0	$ 0
Commercial | Special Purpose Entities
Variable Interest Entity
Lending to special purpose entities included in loans and leases		449		449		$ 0
Undrawn commitments to extend credit | Special Purpose Entities
Variable Interest Entity
Commitment amount		$ 534		$ 534
[1]	Excluded from the table above are loans held for sale totaling $1.3 billion and $718 million as of September 30, 2018 and December 31, 2017, respectively.
[2]	Mortgage loans serviced for others by the Company’s subsidiaries are not included above, and amounted to $67.5 billion and $20.3 billion at September 30, 2018 and December 31, 2017, respectively.

VARIABLE INTEREST ENTITIES - Sc

VARIABLE INTEREST ENTITIES - Schedule of Variable Interest Entities (Details) - USD ($) $ in Millions		Sep. 30, 2018	Dec. 31, 2017
Variable Interest Entity
Lending to special purpose entities included in loans and leases	[1],[2]	$ 114,720	$ 110,617
LIHTC Investments
Variable Interest Entity
LIHTC investment included in other assets		1,211	951
LIHTC unfunded commitments included in other liabilities		677	491
Renewable Energy
Variable Interest Entity
Renewable energy investments included in other assets		323	335
Commercial | Special Purpose Entities
Variable Interest Entity
Lending to special purpose entities included in loans and leases		$ 449	$ 0
[1]	Excluded from the table above are loans held for sale totaling $1.3 billion and $718 million as of September 30, 2018 and December 31, 2017, respectively.
[2]	Mortgage loans serviced for others by the Company’s subsidiaries are not included above, and amounted to $67.5 billion and $20.3 billion at September 30, 2018 and December 31, 2017, respectively.

VARIABLE INTEREST ENTITIES - _2

VARIABLE INTEREST ENTITIES - Schedule of Affordable Housing Tax Credit Investments (Details) - LIHTC Investments - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Variable Interest Entity
Tax credits included in income tax expense	$ 28	$ 20	$ 79	$ 63
Amortization expense included in income tax expense	31	22	86	67
Other tax benefits included in income tax expense	$ 7	$ 7	$ 19	$ 22

BORROWED FUNDS - Narrative (Det

BORROWED FUNDS - Narrative (Details) - USD ($) $ in Millions	Sep. 30, 2018	Jun. 29, 2018	Dec. 31, 2017
Debt Instrument [Line Items]
Hedging basis adjustments	$ 300		$ 693
Short-term borrowed funds	2,380		2,671
Available borrowing capacity	36,300
Federal Home Loan Bank Advances and Letters of Credit | Secured Debt
Debt Instrument [Line Items]
Short-term borrowed funds	13,800		9,400
Federal Home Loan Bank advances
Debt Instrument [Line Items]
Available borrowing capacity	3,700		8,000
Parent Company
Debt Instrument [Line Items]
Principal balance	2,000		2,300
Unamortized deferred issuance costs and/or discounts	(5)		(5)
Banking Subsidiaries
Debt Instrument [Line Items]
Principal balance	13,800		9,500
Unamortized deferred issuance costs and/or discounts	(17)		(19)
Hedging basis adjustments	$ (105)		$ (63)
5.158% fixed-to-floating rate callable subordinated debt | Parent Company | Subordinated Debt
Debt Instrument [Line Items]
Interest rate		5.158%

BORROWED FUNDS - Short Term Deb

BORROWED FUNDS - Short Term Debt (Details) - USD ($) $ in Millions		Sep. 30, 2018	Dec. 31, 2017
Short-term Debt [Line Items]
Total short-term borrowed funds		$ 2,380	$ 2,671
Federal funds purchased
Short-term Debt [Line Items]
Total short-term borrowed funds		0	460
Securities sold under agreements to repurchase
Short-term Debt [Line Items]
Total short-term borrowed funds		374	355
Other short-term borrowed funds
Short-term Debt [Line Items]
Total short-term borrowed funds	[1]	2,006	1,856
CBNA Global Bank Note Program
Short-term Debt [Line Items]
Total short-term borrowed funds		1,500	750
Unamortized deferred issuance costs and/or discounts		(1)	(1)
Other basis adjustments		$ (5)	$ (4)
[1]	September 30, 2018 includes $1.5 billion of debt issued under CBNA’s Global Bank Note Program maturing within one year, with unamortized deferred issuance costs and/or discounts of ($1) million and other basis adjustments of ($5) million. December 31, 2017 includes $750 million of debt issued under CBNA’s Global Bank Note Program maturing within one year, with unamortized deferred issuance costs and/or discounts of ($1) million and other basis adjustments of ($4) million.

BORROWED FUNDS - Short Term Bor

BORROWED FUNDS - Short Term Borrowed Debt Key Data (Details) - USD ($) $ in Millions		3 Months Ended		9 Months Ended		12 Months Ended
		Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017	Dec. 31, 2017
Federal funds purchased and securities sold under agreements to repurchase
Short-term Debt [Line Items]
Weighted-average interest rate at period end	[1]	0.00%	0.00%	0.00%	0.00%	0.74%
Maximum amount outstanding at month-end during the period	[2]	$ 382	$ 724	$ 1,045	$ 1,174	$ 1,174
Average amount outstanding during the period	[2]	$ 643	$ 733	$ 598	$ 807	$ 776
Weighted-average interest rate during the period	[1]	0.91%	0.47%	0.76%	0.34%	0.36%
Other short-term borrowed funds
Short-term Debt [Line Items]
Weighted-average interest rate at period end	[1]	2.41%	1.47%	2.41%	1.47%	1.72%
Maximum amount outstanding at month-end during the period		$ 2,502	$ 1,755	$ 2,502	$ 3,508	$ 3,508
Average amount outstanding during the period		$ 2,239	$ 1,624	$ 1,802	$ 2,283	$ 2,321
Weighted-average interest rate during the period	[1]	2.45%	1.48%	2.38%	1.22%	1.32%
[1]	Rates exclude certain hedging costs.
[2]	Balances are net of certain short-term receivables associated with reverse repurchase agreements, as applicable.

BORROWED FUNDS - Long Term Debt

BORROWED FUNDS - Long Term Debt (Details) - USD ($) $ in Millions		Sep. 30, 2018	Jun. 29, 2018	Dec. 31, 2017
Debt Instrument [Line Items]
Long-term borrowed funds		$ 15,639		$ 11,765
Parent Company
Debt Instrument [Line Items]
Long-term borrowed funds		1,987
Parent Company | Subordinated Debt | 4.150% fixed-rate subordinated debt, due 2022
Debt Instrument [Line Items]
Long-term borrowed funds		$ 348		348
Interest rate		4.15%
Parent Company | Subordinated Debt | 5.158% fixed-to-floating rate callable subordinated debt
Debt Instrument [Line Items]
Long-term borrowed funds	[1]	$ 0		333
Interest rate			5.158%
Parent Company | Subordinated Debt | 3.750% fixed-rate subordinated debt, due 2024
Debt Instrument [Line Items]
Long-term borrowed funds		$ 250		250
Interest rate		3.75%
Parent Company | Subordinated Debt | 4.023% fixed-rate subordinated debt, due 2024
Debt Instrument [Line Items]
Long-term borrowed funds		$ 42		42
Interest rate		4.023%
Parent Company | Subordinated Debt | 4.350% fixed-rate subordinated debt, due 2025
Debt Instrument [Line Items]
Long-term borrowed funds		$ 249		249
Interest rate		4.35%
Parent Company | Subordinated Debt | 4.300% fixed-rate subordinated debt, due 2025
Debt Instrument [Line Items]
Long-term borrowed funds		$ 749		749
Interest rate		4.30%
Parent Company | Senior Unsecured Notes | 2.375% fixed-rate senior unsecured debt, due 2021
Debt Instrument [Line Items]
Long-term borrowed funds		$ 349		349
Interest rate		2.375%
Banking Subsidiaries
Debt Instrument [Line Items]
Long-term borrowed funds		$ 13,652
Banking Subsidiaries | Senior Unsecured Notes | 2.450% senior unsecured notes, due 2019
Debt Instrument [Line Items]
Long-term borrowed funds	[2]	$ 742		743
Interest rate		2.45%
Banking Subsidiaries | Senior Unsecured Notes | 2.500% senior unsecured notes, due 2019
Debt Instrument [Line Items]
Long-term borrowed funds	[2],[3]	$ 0		741
Interest rate		2.50%
Banking Subsidiaries | Senior Unsecured Notes | 2.250% senior unsecured notes, due 2020
Debt Instrument [Line Items]
Long-term borrowed funds	[2]	$ 687		692
Interest rate		2.25%
Banking Subsidiaries | Senior Unsecured Notes | Floating-rate senior unsecured notes, due 2020
Debt Instrument [Line Items]
Long-term borrowed funds	[2]	$ 300		299
Banking Subsidiaries | Senior Unsecured Notes | Floating-rate senior unsecured notes, due 2020
Debt Instrument [Line Items]
Long-term borrowed funds	[2]	250		249
Banking Subsidiaries | Senior Unsecured Notes | 2.200% senior unsecured notes, due 2020
Debt Instrument [Line Items]
Long-term borrowed funds	[2]	$ 499		498
Interest rate		2.20%
Banking Subsidiaries | Senior Unsecured Notes | 2.250% senior unsecured notes, due 2020
Debt Instrument [Line Items]
Long-term borrowed funds	[2]	$ 731		742
Interest rate		2.25%
Banking Subsidiaries | Senior Unsecured Notes | 2.550% senior unsecured notes, due 2021
Debt Instrument [Line Items]
Long-term borrowed funds	[2]	$ 951		964
Interest rate		2.55%
Banking Subsidiaries | Senior Unsecured Notes | Floating-rate senior unsecured notes, due 2022
Debt Instrument [Line Items]
Long-term borrowed funds	[2]	$ 249		249
Banking Subsidiaries | Senior Unsecured Notes | 2.650% senior unsecured notes, due 2022
Debt Instrument [Line Items]
Long-term borrowed funds	[2]	$ 478		491
Interest rate		2.65%
Banking Subsidiaries | Senior Unsecured Notes | 3.700% senior unsecured notes, due 2023
Debt Instrument [Line Items]
Long-term borrowed funds	[2]	$ 492		0
Interest rate		3.70%
Banking Subsidiaries | Senior Unsecured Notes | Floating-rate senior unsecured notes, due 2023
Debt Instrument [Line Items]
Long-term borrowed funds	[2]	$ 249		0
Banking Subsidiaries | Federal Home Loan Bank advances
Debt Instrument [Line Items]
Long-term borrowed funds		8,012		3,761
Banking Subsidiaries | Other
Debt Instrument [Line Items]
Long-term borrowed funds		$ 12		$ 16
[1]	Redeemed on June 29, 2018.
[2]	Issued under CBNA’s Global Bank Note Program.
[3]	Reclassified to short-term borrowed funds.

BORROWED FUNDS - Maturities of

BORROWED FUNDS - Maturities of Long-term Borrowed Funds (Details) - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
Debt Instrument [Line Items]
2,019	$ 3,244
2,020	7,972
2,021	1,303
2,022	1,080
2,023	741
2024 and thereafter	1,299
Total	15,639	$ 11,765
Parent Company
Debt Instrument [Line Items]
2,019	0
2,020	0
2,021	349
2,022	348
2,023	0
2024 and thereafter	1,290
Total	1,987
Banking Subsidiaries
Debt Instrument [Line Items]
2,019	3,244
2,020	7,972
2,021	954
2,022	732
2,023	741
2024 and thereafter	9
Total	$ 13,652

DERIVATIVES - Narrative (Detail

DERIVATIVES - Narrative (Details) $ in Millions	Sep. 30, 2018USD ($)
Derivative Instruments and Hedging Activities Disclosure [Abstract]
Net loss (pre-tax) on derivatives expected to be reclassified in next 12 months	$ 17

DERIVATIVES - Schedule of Deriv

DERIVATIVES - Schedule of Derivative Instruments (Details) - USD ($) $ in Millions		Sep. 30, 2018	Dec. 31, 2017
Derivative Assets
Derivative assets		$ 300	$ 693
Less: Gross amounts offset in the Consolidated Balance Sheets	[1]	(85)	(72)
Less: Cash collateral applied	[1]	(42)	(4)
Total net derivative fair values presented in the Consolidated Balance Sheets		173	617
Derivative Liabilities
Derivative Liabilities		575	533
Less: Gross amounts offset in the Consolidated Balance Sheets	[1]	(85)	(72)
Less: Cash collateral applied	[1]	(41)	(151)
Total net derivative fair values presented in the Consolidated Balance Sheets		449	310
Derivatives not designated as hedging instruments:
Derivative Assets
Derivative assets		295	693
Derivative Liabilities
Derivative Liabilities		575	533
Interest rate contracts
Derivative Assets
Derivative assets		165	538
Derivative Liabilities
Derivative Liabilities		469	379
Interest rate contracts | Derivatives designated as hedging instruments:
Derivatives, Fair Value [Line Items]
Notional amount	[2]	10,050	13,300
Derivative Assets
Derivative assets		5	0
Derivative Liabilities
Derivative Liabilities		0	0
Interest rate contracts | Derivatives not designated as hedging instruments:
Derivatives, Fair Value [Line Items]
Notional amount	[2]	111,837	80,180
Derivative Assets
Derivative assets		160	538
Derivative Liabilities
Derivative Liabilities		469	379
Foreign exchange contracts
Derivative Assets
Derivative assets		116	148
Derivative Liabilities
Derivative Liabilities		105	149
Foreign exchange contracts | Derivatives not designated as hedging instruments:
Derivatives, Fair Value [Line Items]
Notional amount	[2]	10,346	9,882
Derivative Assets
Derivative assets		116	148
Derivative Liabilities
Derivative Liabilities		105	149
Other contracts
Derivative Assets
Derivative assets		19	7
Derivative Liabilities
Derivative Liabilities		1	5
Other contracts | Derivatives not designated as hedging instruments:
Derivatives, Fair Value [Line Items]
Notional amount	[2]	5,201	1,039
Derivative Assets
Derivative assets		19	7
Derivative Liabilities
Derivative Liabilities		$ 1	$ 5
[1]	Amounts represent the impact of enforceable master netting agreements that allow the Company to net settle positive and negative positions.
[2]	The notional or contractual amount of interest rate derivatives and foreign exchange contracts is the amount upon which interest and other payments under the contract are based. For interest rate contracts, the notional amount is typically not exchanged. Therefore, notional amounts should not be taken as the measure of credit or market risk, as they do not measure the true economic risk of these contracts.

DERIVATIVES - Schedule of Fair

DERIVATIVES - Schedule of Fair Value Hedges (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Derivative Instruments, Gain (Loss) [Line Items]
Derivative	$ 57	$ 15	$ 100	$ 47
Hedge of interest rate risk | Other Income
Derivative Instruments, Gain (Loss) [Line Items]
Derivative	(6)	(5)	(32)	5
Hedged Item	7	4	31	(5)
Hedge Ineffectiveness	$ 1	$ (1)	$ (1)	$ 0

DERIVATIVES - Effect of Derivat

DERIVATIVES - Effect of Derivative Instruments on Net Income and Stockholders' Equity (Details) - USD ($) $ in Millions		3 Months Ended		9 Months Ended
		Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Derivative Instruments, Gain (Loss) [Line Items]
Amount of net gain (loss) reclassified from OCI to interest expense		$ (329)	$ (202)	$ (856)	$ (536)
Amount Reclassified from AOCI | Net Gain (Loss) Reclassified
Derivative Instruments, Gain (Loss) [Line Items]
Effective portion of (loss) gain recognized in OCI	[1]	(35)	(2)	(122)	35
Amounts of net (loss) gain reclassified from OCI to interest income	[2]	(17)	3	(36)	23
Amount of net gain (loss) reclassified from OCI to interest expense	[2]	$ 3	$ 1	$ 11	$ (2)
[1]	The cumulative effective gains and losses on the Company’s cash flow hedging activities are included on the accumulated other comprehensive loss line item on the Consolidated Balance Sheets.
[2]	This amount includes both (i) the amortization of effective gains and losses associated with the Company’s terminated cash flow hedges and (ii) the current reporting period’s interest settlements realized on the Company’s active cash flow hedges. Both (i) and (ii) were previously included on the accumulated other comprehensive loss line item on the Consolidated Balance Sheets and were subsequently recorded as adjustments to the interest income or expense of the underlying hedged item.

DERIVATIVES - Effect of Custome

DERIVATIVES - Effect of Customer Derivatives and Economic Hedges on Net Income (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	$ 57	$ 15	$ 100	$ 47
Economic hedges | Foreign exchange and interest rate products | Customer interest rate contracts
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	(84)	12	(363)	92
Economic hedges | Foreign exchange and interest rate products | Customer foreign exchange contracts
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	30	61	(27)	157
Economic hedges | Foreign exchange and interest rate products | Derivatives transactions to hedge interest rate risk
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	97	(2)	403	(58)
Economic hedges | Foreign exchange and interest rate products | Derivatives transactions to hedge foreign exchange risk
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	24	(55)	99	(140)
Economic hedges | Mortgage banking fees | Residential loan commitments
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	6	0	6	3
Economic hedges | Mortgage banking fees | Forward sale contracts
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	(13)	(1)	(15)	(7)
Economic hedges | Mortgage banking fees | Interest rate derivative contracts used to hedge residential MSRs
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	$ (3)	$ 0	$ (3)	$ 0

RECLASSIFICATIONS OUT OF ACCU_3

RECLASSIFICATIONS OUT OF ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS) - Schedule of Accumulated Other Comprehensive Income (Loss) (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance			$ 20,270	$ 19,747
Other comprehensive income before reclassifications	$ (121)	$ 12	(518)	96
Other-than-temporary impairment not recognized in earnings on debt securities	0	0	(1)	(2)
Amounts reclassified to the Consolidated Statements of Operations	13	0	21	(7)
Net other comprehensive income	(108)	12	(498)	87
Ending balance	20,276	20,109	20,276	20,109
Total AOCI
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance	(1,210)	(593)	(820)	(668)
Ending balance	(1,318)	(581)	(1,318)	(581)
Net Unrealized (Losses) Gains on Derivatives
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance	(200)	(76)	(143)	(88)
Other comprehensive income before reclassifications	(26)	(1)	(91)	22
Other-than-temporary impairment not recognized in earnings on debt securities	0	0	0	0
Amounts reclassified to the Consolidated Statements of Operations	11	(2)	19	(13)
Net other comprehensive income	(15)	(3)	(72)	9
Ending balance	(215)	(79)	(215)	(79)
Net Unrealized (Losses) Gains on Debt Securities
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance	(575)	(128)	(236)	(186)
Other comprehensive income before reclassifications	(95)	13	(427)	74
Other-than-temporary impairment not recognized in earnings on debt securities	0	0	(1)	(2)
Amounts reclassified to the Consolidated Statements of Operations	(2)	(1)	(8)	(2)
Net other comprehensive income	(97)	12	(436)	70
Ending balance	(672)	(116)	(672)	(116)
Employee Benefit Plans
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance	(435)	(389)	(441)	(394)
Other comprehensive income before reclassifications	0	0	0	0
Other-than-temporary impairment not recognized in earnings on debt securities	0	0	0	0
Amounts reclassified to the Consolidated Statements of Operations	4	3	10	8
Net other comprehensive income	4	3	10	8
Ending balance	$ (431)	$ (386)	$ (431)	$ (386)

RECLASSIFICATIONS OUT OF ACCU_4

RECLASSIFICATIONS OUT OF ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS) - Reclassifications out of Accumulated Other Comprehensive Income (Loss) (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Reclassification Adjustment out of Accumulated Other Comprehensive Income [Line Items]
Interest income	$ 1,477	$ 1,264	$ 4,216	$ 3,629
Interest expense	(329)	(202)	(856)	(536)
Securities gains, net	3	2	13	9
Net debt securities impairment losses recognized in earnings	(1)	(1)	(3)	(6)
Other operating expense	(131)	(133)	(378)	(405)
Income before income tax expense	576	513	1,626	1,409
Income tax expense	133	165	370	423
NET INCOME	443	348	1,256	986
Amount Reclassified from AOCI
Reclassification Adjustment out of Accumulated Other Comprehensive Income [Line Items]
Income tax expense	(4)	0	(7)	3
NET INCOME	(13)	0	(21)	7
Reclassification adjustment for net derivative (losses) gains included in net income: | Amount Reclassified from AOCI
Reclassification Adjustment out of Accumulated Other Comprehensive Income [Line Items]
Interest income	(17)	3	(36)	23
Interest expense	3	1	11	(2)
Income before income tax expense	(14)	4	(25)	21
Income tax expense	(3)	2	(6)	8
NET INCOME	(11)	2	(19)	13
Reclassification of net debt securities gains (losses) to net income: | Amount Reclassified from AOCI
Reclassification Adjustment out of Accumulated Other Comprehensive Income [Line Items]
Securities gains, net	3	2	13	9
Net debt securities impairment losses recognized in earnings	(1)	(1)	(3)	(6)
Income before income tax expense	2	1	10	3
Income tax expense	0	0	2	1
NET INCOME	2	1	8	2
Reclassification of changes related to the employee benefit plan: | Amount Reclassified from AOCI
Reclassification Adjustment out of Accumulated Other Comprehensive Income [Line Items]
Other operating expense	(5)	(5)	(13)	(14)
Income before income tax expense	(5)	(5)	(13)	(14)
Income tax expense	(1)	(2)	(3)	(6)
NET INCOME	$ (4)	$ (3)	$ (10)	$ (8)

RECLASSIFICATIONS OUT OF ACCU_5

RECLASSIFICATIONS OUT OF ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS) - Effects to Net Income of Amounts Reclassified Out of OCI (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Reclassification Adjustment out of Accumulated Other Comprehensive Income [Line Items]
Net interest income	$ 1,148	$ 1,062	$ 3,360	$ 3,093
Provision for credit losses	78	72	241	238
Noninterest income	416	381	1,175	1,130
Noninterest expense	910	858	2,668	2,576
Income before income tax expense	576	513	1,626	1,409
Income tax expense	133	165	370	423
NET INCOME	443	348	1,256	986
Amount Reclassified from AOCI
Reclassification Adjustment out of Accumulated Other Comprehensive Income [Line Items]
Net interest income	(14)	4	(25)	21
Noninterest income	2	1	10	3
Noninterest expense	5	5	13	14
Income tax expense	(4)	0	(7)	3
NET INCOME	$ (13)	$ 0	$ (21)	$ 7

STOCKHOLDERS' EQUITY (Details)

STOCKHOLDERS' EQUITY (Details) - USD ($) $ / shares in Units, $ in Millions	Oct. 25, 2018	May 24, 2018	Sep. 30, 2018	Sep. 30, 2017	Dec. 31, 2017
Preferred Stock
Preferred stock, authorized (in shares)			100,000,000		100,000,000
Preferred stock, outstanding (in shares)			550,000		250,000
Preferred stock, par value (in dollars per share)			$ 25		$ 25
Preferred stock, shares issued (in shares)			550,000		250,000
Preferred stock, carrying amount			$ 543		$ 247
Preferred stock issued			296
Treasury Stock
Treasury stock purchased			$ 725	$ 485
Treasury stock purchased (in shares)			17,527,586
Series B Preferred Stock
Preferred Stock
Preferred stock, par value (in dollars per share)		$ 25
Preferred stock issued		$ 300
Preferred stock issued (in shares)		300,000
Preferred stock, dividend rate		6.00%
Preferred stock, liquidation preference per share (in dollars per share)		$ 1,000
Preferred stock, redemption notice period		90 days
Preferred stock, redemption price per share (in dollars per share)		$ 1,000
Carrying amount of preferred stock		$ 296
Series A Preferred Stock
Preferred Stock
Preferred stock, shares issued (in shares)			250,000		250,000
Preferred stock, dividend rate			5.50%		5.50%
Preferred stock, liquidation preference per share (in dollars per share)			$ 1,000		$ 1,000
Carrying amount of preferred stock			$ 247		$ 247
LIBOR | Series B Preferred Stock
Preferred Stock
Preferred stock, dividend payment rate, basis spread on variable rate		3.003%
Subsequent Event [Member] | Series C Preferred Stock
Preferred Stock
Preferred stock, par value (in dollars per share)	$ 25
Preferred stock issued	$ 300
Preferred stock issued (in shares)	300,000
Preferred stock, dividend rate	6.375%
Preferred stock, liquidation preference per share (in dollars per share)	$ 1,000
Preferred stock, redemption notice period	90 days
Preferred stock, redemption price per share (in dollars per share)	$ 1,000
Carrying amount of preferred stock	$ 296
Subsequent Event [Member] | LIBOR | Series C Preferred Stock
Preferred Stock
Preferred stock, dividend payment rate, basis spread on variable rate	3.157%

COMMITMENTS AND CONTINGENCIES -

COMMITMENTS AND CONTINGENCIES - Narrative (Details) $ in Millions	9 Months Ended	12 Months Ended
	Sep. 30, 2018USD ($)counterparty	Dec. 31, 2017USD ($)	Dec. 31, 2003
Letters of Credit [Abstract]
Letters of credit outstanding, amount	$ 2	$ 3
Risk Participation Agreements [Abstract]
Risk participation agreements	$ 14	16
Risk participation agreements number of counterparties | counterparty	87
Risk participation agreements, Maximum term	10 years
Commercial real estate loans held for sale | Purchase commitment
Other Commitments [Abstract]
Unsettled commercial loan trade purchases	$ 87	65
Unsettled commercial loan trade sales	$ 121	132
Minimum
Risk Participation Agreements [Abstract]
Risk participation agreements, Average term	1 year
Maximum
Risk Participation Agreements [Abstract]
Risk participation agreements, Average term	5 years
Marketing rights
Marketing Rights [Abstract]
Commitment period			25 years
Payments made	$ 4	$ 3
Remaining obligation due	$ 37
Financial standby letters of credit
Letters of Credit [Abstract]
Letters of credit outstanding	10 years
Commercial letters of credit
Letters of Credit [Abstract]
Letters of credit outstanding	1 year
Purchase Of Education Loans
Other Commitments [Abstract]
Remaining maximum purchase commitment	$ 188
Termination fee	1
Purchase Of Education Loans | Minimum
Other Commitments [Abstract]
Commitment amount	425
Purchase Of Education Loans | Maximum
Other Commitments [Abstract]
Commitment amount	$ 700

COMMITMENTS AND CONTINGENCIES_2

COMMITMENTS AND CONTINGENCIES - Schedule of Outstanding Off-balance sheet Arrangements (Details) - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
Other Commitments [Line Items]
Commitment amount	$ 68,925	$ 65,159
Undrawn commitments to extend credit
Other Commitments [Line Items]
Commitment amount	66,729	62,959
Financial standby letters of credit
Other Commitments [Line Items]
Commitment amount	1,934	2,036
Performance letters of credit
Other Commitments [Line Items]
Commitment amount	131	47
Commercial letters of credit
Other Commitments [Line Items]
Commitment amount	74	53
Marketing rights
Other Commitments [Line Items]
Commitment amount	37	41
Risk participation agreements
Other Commitments [Line Items]
Commitment amount	14	16
Residential mortgage loans sold with recourse
Other Commitments [Line Items]
Commitment amount	$ 6	$ 7

FAIR VALUE MEASUREMENTS - Narra

FAIR VALUE MEASUREMENTS - Narrative (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017	Dec. 31, 2017
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Other income	$ 18	$ 19	$ 52	$ 50
Commercial real estate loans held for sale
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Loans in this portfolio that were 90 days or more past due or nonaccruing	0		0		$ 0
Other income		1	1	4
Mortgage banking fees | Residential loans held for sale
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Changes in fair value	$ (8)	$ (1)	$ (7)	$ 9

FAIR VALUE MEASUREMENTS - Resid

FAIR VALUE MEASUREMENTS - Residential Mortgage and Commercial Real Estate Loans Held For Sale (Details) - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Aggregate Fair Value	$ 1,303	$ 497
Level 2
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Aggregate Fair Value	1,303	497
Level 2 | Residential loans held for sale
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Aggregate Fair Value	1,140	326
Aggregate Unpaid Principal	1,140	326
Aggregate Fair Value Less Aggregate Unpaid Principal	0	0
Level 2 | Commercial and commercial real estate loans held for sale, at fair value
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Aggregate Fair Value	163	171
Aggregate Unpaid Principal	163	171
Aggregate Fair Value Less Aggregate Unpaid Principal	$ 0	$ 0

FAIR VALUE MEASUREMENTS - Sched

FAIR VALUE MEASUREMENTS - Schedule of Fair Value Measurements (Details) - USD ($) $ in Millions		Sep. 30, 2018	Dec. 31, 2017
Assets
Securities available for sale	[1]	$ 20,152	$ 20,157
Loans held for sale, at fair value		1,303	497
Mortgage servicing rights		612
Derivative assets		300	693
Money market mutual fund investments		175	165
Other investments		0	4
Total equity securities, at fair value		175	169
Total assets		22,542	21,516
Liabilities
Total derivative liabilities		575	533
Total liabilities		575	533
Interest rate contracts
Assets
Derivative assets		165	538
Liabilities
Total derivative liabilities		469	379
Foreign exchange contracts
Assets
Derivative assets		116	148
Liabilities
Total derivative liabilities		105	149
Other contracts
Assets
Derivative assets		19	7
Liabilities
Total derivative liabilities		1	5
Level 1
Assets
Securities available for sale		12	12
Loans held for sale, at fair value		0	0
Derivative assets		0	0
Money market mutual fund investments		175	165
Other investments		0	0
Total equity securities, at fair value		175	165
Total assets		187	177
Liabilities
Total derivative liabilities		0	0
Total liabilities		0	0
Level 1 | Interest rate contracts
Assets
Derivative assets		0	0
Liabilities
Total derivative liabilities		0	0
Level 1 | Foreign exchange contracts
Assets
Derivative assets		0	0
Liabilities
Total derivative liabilities		0	0
Level 1 | Other contracts
Assets
Derivative assets		0	0
Liabilities
Total derivative liabilities		0	0
Level 2
Assets
Securities available for sale		20,140	20,145
Loans held for sale, at fair value		1,303	497
Derivative assets		300	693
Money market mutual fund investments		0	0
Other investments		0	4
Total equity securities, at fair value		0	4
Total assets		21,743	21,339
Liabilities
Total derivative liabilities		575	533
Total liabilities		575	533
Level 2 | Interest rate contracts
Assets
Derivative assets		165	538
Liabilities
Total derivative liabilities		469	379
Level 2 | Foreign exchange contracts
Assets
Derivative assets		116	148
Liabilities
Total derivative liabilities		105	149
Level 2 | Other contracts
Assets
Derivative assets		19	7
Liabilities
Total derivative liabilities		1	5
Level 3
Assets
Securities available for sale		0	0
Loans held for sale, at fair value		0	0
Derivative assets		0	0
Money market mutual fund investments		0	0
Other investments		0	0
Total equity securities, at fair value		0	0
Total assets		612	0
Liabilities
Total derivative liabilities		0	0
Total liabilities		0	0
Level 3 | Interest rate contracts
Assets
Derivative assets		0	0
Liabilities
Total derivative liabilities		0	0
Level 3 | Foreign exchange contracts
Assets
Derivative assets		0	0
Liabilities
Total derivative liabilities		0	0
Level 3 | Other contracts
Assets
Derivative assets		0	0
Liabilities
Total derivative liabilities		0	0
Mortgage-backed securities
Assets
Securities available for sale		20,135	20,139
Mortgage-backed securities | Level 1
Assets
Securities available for sale		0	0
Mortgage-backed securities | Level 2
Assets
Securities available for sale		20,135	20,139
Mortgage-backed securities | Level 3
Assets
Securities available for sale		0	0
State and political subdivisions
Assets
Securities available for sale		5	6
State and political subdivisions | Level 1
Assets
Securities available for sale		0	0
State and political subdivisions | Level 2
Assets
Securities available for sale		5	6
State and political subdivisions | Level 3
Assets
Securities available for sale		0	0
U.S. Treasury and other
Assets
Securities available for sale		12	12
U.S. Treasury and other | Level 1
Assets
Securities available for sale		12	12
U.S. Treasury and other | Level 2
Assets
Securities available for sale		0	0
U.S. Treasury and other | Level 3
Assets
Securities available for sale		0	0
Residential loans held for sale
Assets
Loans held for sale, at fair value		1,140	326
Residential loans held for sale | Level 1
Assets
Loans held for sale, at fair value		0	0
Residential loans held for sale | Level 2
Assets
Loans held for sale, at fair value		1,140	326
Residential loans held for sale | Level 3
Assets
Loans held for sale, at fair value		0	0
Commercial loans held for sale
Assets
Loans held for sale, at fair value		163	171
Commercial loans held for sale | Level 1
Assets
Loans held for sale, at fair value		0	0
Commercial loans held for sale | Level 2
Assets
Loans held for sale, at fair value		163	171
Commercial loans held for sale | Level 3
Assets
Loans held for sale, at fair value		0	$ 0
Residential mortgages
Assets
Mortgage servicing rights		612
Residential mortgages | Level 1
Assets
Mortgage servicing rights		0
Residential mortgages | Level 2
Assets
Mortgage servicing rights		0
Residential mortgages | Level 3
Assets
Mortgage servicing rights		$ 612
[1]	Includes only collateral pledged by the Company where counterparties have the right to sell or pledge the collateral.

FAIR VALUE MEASUREMENTS - Sch_2

FAIR VALUE MEASUREMENTS - Schedule of Assets Measured on Recurring Basis Level 3 Rollforward (Details) - Residential mortgages - USD ($) $ in Millions		3 Months Ended	9 Months Ended
		Sep. 30, 2018	Sep. 30, 2018
Fair Value, Assets Measured on Recurring Basis, Unobservable Input Reconciliation, Calculation [Roll Forward]
Beginning balance		$ 0	$ 0
Acquired MSRs		590	590
Amount capitalized		29	29
Change in unpaid principal balance during the period	[1]	(12)	(12)
Change in fair value during the period	[2]	5	5
Ending balance		$ 612	$ 612
[1]	Represents changes in value of the MSRs due to i) passage of time including the impact from both regularly scheduled loan principal payments and partial paydowns, and ii) loans that paid off during the period. (2) Represents changes in value primarily due to market driven changes in interest rates and prepayment speeds.
[2]	Represents changes in value primarily due to market driven changes in interest rates and prepayment speeds.

FAIR VALUE MEASUREMENTS - Sch_3

FAIR VALUE MEASUREMENTS - Schedule of Gain (Loss) on Assets and Liabilities Measured on Nonrecurring Basis Included in Earnings (Details) - Nonrecurring measurement basis - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Impaired collateral-dependent loans
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Gain (loss) included in earnings on assets measured on a nonrecurring basis	$ (3)	$ (4)	$ (9)	$ (31)
MSRs
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Gain (loss) included in earnings on assets measured on a nonrecurring basis	0	0	3	(1)
Foreclosed assets
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Gain (loss) included in earnings on assets measured on a nonrecurring basis	(1)	(1)	(2)	(3)
Leased assets
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Gain (loss) included in earnings on assets measured on a nonrecurring basis	$ (4)	$ 0	$ (6)	$ (15)

FAIR VALUE MEASUREMENTS - Sch_4

FAIR VALUE MEASUREMENTS - Schedule of Fair Value Measurements on a Nonrecurring Basis (Details) - Nonrecurring measurement basis - USD ($) $ in Millions	Sep. 30, 2018	Dec. 31, 2017
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Impaired collateral-dependent loans	$ 336	$ 393
MSRs	261	218
Foreclosed assets	25	31
Leased assets	93	112
Level 1
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Impaired collateral-dependent loans	0	0
MSRs	0	0
Foreclosed assets	0	0
Leased assets	0	0
Level 2
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Impaired collateral-dependent loans	336	393
MSRs	0	0
Foreclosed assets	25	31
Leased assets	93	112
Level 3
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Impaired collateral-dependent loans	0	0
MSRs	261	218
Foreclosed assets	0	0
Leased assets	$ 0	$ 0

FAIR VALUE MEASUREMENTS - Sch_5

FAIR VALUE MEASUREMENTS - Schedule of Financial Instruments not Recorded at Fair Value (Details) - USD ($) $ in Millions		Sep. 30, 2018	Dec. 31, 2017
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Securities held to maturity, carrying value		$ 4,284	$ 4,685
Securities held-to-maturity, fair value		4,102	4,668
Equity securities, at cost, carrying value		874	722
Equity securities, at cost, fair value		874	722
Other loans held for sale, carrying value		27	221
Other loans held for sale, fair value		27	221
Loans and leases, carrying value	[1],[2]	114,720	110,617
Loans and leases, fair value		113,913	111,168
Deposits, carrying value		117,075	115,089
Deposits, fair value		116,892	115,039
Federal funds purchased and securities sold under agreements to repurchase, carrying value		374	815
Federal funds purchased and securities sold under agreements to repurchase, fair value		374	815
Other short-term borrowed funds, carrying value		2,006	1,856
Other short-term borrowed funds, fair value		2,006	1,856
Long-term borrowed funds, carrying value		15,639	11,765
Long-term borrowed funds, fair value		15,630	11,891
Level 1
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Securities held to maturity, carrying value		0	0
Securities held-to-maturity, fair value		0	0
Equity securities, at cost, carrying value		0	0
Equity securities, at cost, fair value		0	0
Other loans held for sale, carrying value		0	0
Other loans held for sale, fair value		0	0
Loans and leases, carrying value		0	0
Loans and leases, fair value		0	0
Deposits, carrying value		0	0
Deposits, fair value		0	0
Federal funds purchased and securities sold under agreements to repurchase, carrying value		0	0
Federal funds purchased and securities sold under agreements to repurchase, fair value		0	0
Other short-term borrowed funds, carrying value		0	0
Other short-term borrowed funds, fair value		0	0
Long-term borrowed funds, carrying value		0	0
Long-term borrowed funds, fair value		0	0
Level 2
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Securities held to maturity, carrying value		4,284	4,685
Securities held-to-maturity, fair value		4,102	4,668
Equity securities, at cost, carrying value		874	722
Equity securities, at cost, fair value		874	722
Other loans held for sale, carrying value		0	0
Other loans held for sale, fair value		0	0
Loans and leases, carrying value		336	393
Loans and leases, fair value		336	393
Deposits, carrying value		117,075	115,089
Deposits, fair value		116,892	115,039
Federal funds purchased and securities sold under agreements to repurchase, carrying value		374	815
Federal funds purchased and securities sold under agreements to repurchase, fair value		374	815
Other short-term borrowed funds, carrying value		2,006	1,856
Other short-term borrowed funds, fair value		2,006	1,856
Long-term borrowed funds, carrying value		15,639	11,765
Long-term borrowed funds, fair value		15,630	11,891
Level 3
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Securities held to maturity, carrying value		0	0
Securities held-to-maturity, fair value		0	0
Equity securities, at cost, carrying value		0	0
Equity securities, at cost, fair value		0	0
Other loans held for sale, carrying value		27	221
Other loans held for sale, fair value		27	221
Loans and leases, carrying value		114,384	110,224
Loans and leases, fair value		113,577	110,775
Deposits, carrying value		0	0
Deposits, fair value		0	0
Federal funds purchased and securities sold under agreements to repurchase, carrying value		0	0
Federal funds purchased and securities sold under agreements to repurchase, fair value		0	0
Other short-term borrowed funds, carrying value		0	0
Other short-term borrowed funds, fair value		0	0
Long-term borrowed funds, carrying value		0	0
Long-term borrowed funds, fair value		$ 0	$ 0
[1]	Excluded from the table above are loans held for sale totaling $1.3 billion and $718 million as of September 30, 2018 and December 31, 2017, respectively.
[2]	Mortgage loans serviced for others by the Company’s subsidiaries are not included above, and amounted to $67.5 billion and $20.3 billion at September 30, 2018 and December 31, 2017, respectively.

NONINTEREST INCOME - Narrative

NONINTEREST INCOME - Narrative (Details) - USD ($) $ in Millions	3 Months Ended	9 Months Ended
	Sep. 30, 2018	Sep. 30, 2018
Trust and investment services fees
Trailing commission income	$ 4	$ 12

NONINTEREST INCOME - Noninteres

NONINTEREST INCOME - Noninterest Income (Details) - USD ($) $ in Millions		3 Months Ended		9 Months Ended
		Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Other Income and Expenses [Abstract]
Revenue from contracts with customers	[1]	$ 285		$ 833
Revenue from other sources		131		342
Total noninterest income		$ 416	$ 381	$ 1,175	$ 1,130
[1]	There is no revenue from contracts with customers included in Other non-segment operations.

NONINTEREST INCOME - Components

NONINTEREST INCOME - Components of Revenue from Contracts with Customers (Details) - USD ($) $ in Millions		3 Months Ended	9 Months Ended
		Sep. 30, 2018	Sep. 30, 2018
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	[1]	$ 285	$ 833
Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers		201	585
Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers		84	248
Service charges and fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	[1]	131	382
Service charges and fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers		105	303
Service charges and fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers		26	79
Card fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	[1]	61	182
Card fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers		51	154
Card fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers		10	28
Capital markets fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	[1]	46	134
Capital markets fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers		0	0
Capital markets fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers		46	134
Trust and investment services fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	[1]	45	128
Trust and investment services fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers		45	128
Trust and investment services fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers		0	0
Other banking fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	[1]	2	7
Other banking fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers		0	0
Other banking fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers		$ 2	$ 7
[1]	There is no revenue from contracts with customers included in Other non-segment operations.

NONINTEREST INCOME - Other Inco

NONINTEREST INCOME - Other Income (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Other Income and Expenses [Abstract]
Bank-owned life insurance	$ 14	$ 14	$ 42	$ 40

OTHER OPERATING EXPENSE (Detail

OTHER OPERATING EXPENSE (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Other Income and Expenses [Abstract]
Deposit insurance	$ 29	$ 34	$ 88	$ 102
Promotional expense	36	27	95	82
Settlements and operating losses	11	18	35	43
Other	55	54	160	178
Other operating expense	$ 131	$ 133	$ 378	$ 405

INCOME TAXES - Narrative (Detai

INCOME TAXES - Narrative (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017	Dec. 31, 2017
Income Tax Disclosure [Abstract]
Income tax expense	$ 133	$ 165	$ 370	$ 423
Effective income tax rate	23.20%	32.20%	22.80%	30.00%
U.S. Federal income tax expense and tax rate			21.00%	35.00%
Deferred taxes, net	$ 430		$ 430		$ 571

EARNINGS PER SHARE (Details)

EARNINGS PER SHARE (Details) - USD ($) $ / shares in Units, $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Numerator (basic and diluted):
Net income	$ 443	$ 348	$ 1,256	$ 986
Less: Preferred stock dividends	7	7	14	14
Net income available to common stockholders	$ 436	$ 341	$ 1,242	$ 972
Denominator:
Weighted-average common shares outstanding - basic (in Shares)	475,957,526	500,861,076	482,691,884	505,529,991
Dilutive common shares: share-based awards (in Shares)	1,642,391	1,296,308	1,558,959	1,532,814
Weighted-average common shares outstanding - diluted (in Shares)	477,599,917	502,157,384	484,250,843	507,062,805
Earnings per common share:
Basic (in Dollars per Share)	$ 0.92	$ 0.68	$ 2.57	$ 1.92
Diluted (in Dollars per Share)	$ 0.91	$ 0.68	$ 2.57	$ 1.92
Share-based awards excluded from diluted earnings per share computation (in Shares)	0	4,000	0	378,000

REGULATORY MATTERS - Narrative

REGULATORY MATTERS - Narrative (Details) $ / shares in Units, $ in Millions	Apr. 05, 2018$ / shares	Mar. 31, 2019$ / shares	Sep. 30, 2018USD ($)subsidiary$ / shares	Sep. 30, 2017USD ($)$ / shares	Sep. 30, 2018USD ($)subsidiary$ / shares	Sep. 30, 2017USD ($)$ / shares	Jun. 30, 2019USD ($)
Compliance with Regulatory Capital Requirements under Banking Regulations [Line Items]
Common share dividends (in dollars per share) | $ / shares	$ 0.22		$ 0.27	$ 0.18	$ 0.71	$ 0.46
Common share dividends			$ 129	$ 90	$ 344	$ 233
Preferred share dividends			7	7	14	14
Treasury stock purchased			$ 400	$ 225	$ 725	$ 485
Banking Subsidiaries
Compliance with Regulatory Capital Requirements under Banking Regulations [Line Items]
Number of financial subsidiaries | subsidiary			2		2
Scenario, Forecast
Compliance with Regulatory Capital Requirements under Banking Regulations [Line Items]
Common share dividends (in dollars per share) | $ / shares		$ 0.32
Common share repurchases, authorized amount							$ 1,020

REGULATORY MATTERS - Capital an

REGULATORY MATTERS - Capital and Capital Ratio Information (Details) - USD ($) $ in Millions		Sep. 30, 2018	Dec. 31, 2017
Common Equity Tier 1 to Risk-Weighted Assets (Amount)
Actual	[1]	$ 14,435	$ 14,309
Minimum Capital Adequacy	[1]	$ 8,495	$ 7,342
Common Equity Tier 1 to Risk-Weighted Assets (Ratio)
Actual	[1]	10.80%	11.20%
Common Equity Tier1 Required For Capital Adequacy To Risk Weighted Assets	[1],[2]	6.375%	5.75%
Tier 1 Capital to Risk-Weighted Assets (Amount)
Actual	[3]	$ 14,978	$ 14,556
Minimum Capital Adequacy	[3]	$ 10,493	$ 9,258
Tier 1 Capital to Risk-Weighted Assets (Ratio)
Actual	[3]	11.20%	11.40%
Minimum Capital Adequacy	[2],[3]	7.875%	7.25%
Total Capital to Risk-Weighted Assets (Amount)
Actual	[4]	$ 17,810	$ 17,781
Minimum Capital Adequacy	[4]	$ 13,158	$ 11,812
Total Capital to Risk-Weighted Assets (Ratio)
Actual	[4]	13.40%	13.90%
Minimum Capital Adequacy	[2],[4]	9.875%	9.25%
Tier 1 Capital to Average Assets (Leverage) (Amount)
Actual	[5]	$ 14,978	$ 14,556
Minimum Capital Adequacy	[5]	$ 6,029	$ 5,824
Tier 1 Capital to Average Assets (Leverage) (Ratio)
Actual	[5]	9.90%	10.00%
Minimum Capital Adequacy	[2],[5]	4.00%	4.00%
Capital Conservation Buffer		1.875%	1.25%
[1]	“Common equity tier 1 capital ratio” represents CET1 capital divided by total risk-weighted assets as defined under U.S. Basel III Standardized approach.
[2]	“Minimum Capital ratio” includes capital conservation buffer of 1.875% for 2018 and 1.250% for 2017; N/A to Tier 1 leverage.
[3]	“Tier 1 capital ratio” is tier 1 capital, which includes CET1 capital plus non-cumulative perpetual preferred equity that qualifies as additional tier 1 capital, divided by total risk-weighted assets as defined under U.S. Basel III Standardized approach.
[4]	“Total capital ratio” is total capital divided by total risk-weighted assets as defined under U.S. Basel III Standardized approach.
[5]	“Tier 1 leverage ratio” is tier 1 capital divided by quarterly average total assets as defined under U.S. Basel III Standardized approach.

BUSINESS OPERATING SEGMENTS - N

BUSINESS OPERATING SEGMENTS - Narrative (Details) $ in Millions	9 Months Ended
	Sep. 30, 2018USD ($)segment
Segment Reporting Information [Line Items]
Number of segments | segment	2
Consumer Banking | Maximum
Segment Reporting Information [Line Items]
Customer revenue targets	$ 25
Commercial Banking | Minimum
Segment Reporting Information [Line Items]
Customer revenue targets	25
Commercial Banking | Maximum
Segment Reporting Information [Line Items]
Customer revenue targets	$ 2,500

BUSINESS OPERATING SEGMENTS (De

BUSINESS OPERATING SEGMENTS (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2018	Sep. 30, 2017	Sep. 30, 2018	Sep. 30, 2017
Segment Reporting Information [Line Items]
Net interest income	$ 1,148	$ 1,062	$ 3,360	$ 3,093
Noninterest income	416	381	1,175	1,130
Total revenue	1,564	1,443	4,535	4,223
Noninterest expense	910	858	2,668	2,576
Profit (loss) before provision for credit losses	654	585	1,867	1,647
Provision for credit losses	78	72	241	238
Income before income tax expense	576	513	1,626	1,409
Income tax expense (benefit)	133	165	370	423
NET INCOME	443	348	1,256	986
Total average assets	155,624	150,012	153,482	149,563
Operating Segments | Consumer Banking
Segment Reporting Information [Line Items]
Net interest income	776	674	2,268	1,969
Noninterest income	258	227	708	676
Total revenue	1,034	901	2,976	2,645
Noninterest expense	686	648	2,000	1,939
Profit (loss) before provision for credit losses	348	253	976	706
Provision for credit losses	71	65	209	189
Income before income tax expense	277	188	767	517
Income tax expense (benefit)	70	66	193	182
NET INCOME	207	122	574	335
Total average assets	62,974	60,012	61,857	59,310
Operating Segments | Commercial Banking
Segment Reporting Information [Line Items]
Net interest income	380	354	1,113	1,044
Noninterest income	140	136	405	400
Total revenue	520	490	1,518	1,444
Noninterest expense	202	195	610	577
Profit (loss) before provision for credit losses	318	295	908	867
Provision for credit losses	14	0	19	20
Income before income tax expense	304	295	889	847
Income tax expense (benefit)	70	94	203	279
NET INCOME	234	201	686	568
Total average assets	52,871	49,833	51,820	49,604
Other
Segment Reporting Information [Line Items]
Net interest income	(8)	34	(21)	80
Noninterest income	18	18	62	54
Total revenue	10	52	41	134
Noninterest expense	22	15	58	60
Profit (loss) before provision for credit losses	(12)	37	(17)	74
Provision for credit losses	(7)	7	13	29
Income before income tax expense	(5)	30	(30)	45
Income tax expense (benefit)	(7)	5	(26)	(38)
NET INCOME	2	25	(4)	83
Total average assets	$ 39,779	$ 40,167	$ 39,805	$ 40,649