Citizens Financial (CFG) 10-K 21 Feb 19 2018 FY Annual report Financial data

Document and Entity Information

Document and Entity Information - USD ($)	12 Months Ended
	Dec. 31, 2018	Feb. 01, 2019	Jun. 30, 2018
Document and Entity Information [Abstract]
Document Type	10-K
Entity Central Index Key	759,944
Amendment Flag	false
Document Period End Date	Dec. 31, 2018
Document Fiscal Year Focus	2,018
Document Fiscal Period Focus	FY
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 Shell Company	false
Entity Common Stock, Shares Outstanding		460,390,006
Entity Well-known Seasoned Issuer	Yes
Entity Voluntary Filers	No
Entity Current Reporting Status	Yes
Entity Public Float			$ 18,789,421,828

CONSOLIDATED BALANCE SHEETS

CONSOLIDATED BALANCE SHEETS - USD ($) $ in Millions		Dec. 31, 2018	Dec. 31, 2017
ASSETS:
Cash and due from banks		$ 1,081	$ 987
Interest-bearing cash and due from banks		2,993	2,045
Interest-bearing deposits in banks		148	192
Debt securities available for sale, at fair value (including $363 and $91 pledged to creditors, respectively)	[1]	19,895	20,157
Debt securities held to maturity (fair value of $4,041 and $4,668, respectively)		4,165	4,685
Other investment securities, at fair value		181	169
Other investment securities, at cost		834	722
Loans held for sale, at fair value		1,219	497
Other loans held for sale		101	221
Loans and leases	[2],[3]	116,660	110,617
Less: Allowance for loan and lease losses		(1,242)	(1,236)
Net loans and leases		115,418	109,381
Derivative assets		317	617
Premises and equipment, net		791	685
Bank-owned life insurance		1,698	1,656
Goodwill		6,923	6,887
Due from broker		0	6
Other assets		4,754	3,429
TOTAL ASSETS		160,518	152,336
Deposits:
Noninterest-bearing		29,458	29,279
Interest-bearing		90,117	85,810
Total deposits		119,575	115,089
Federal funds purchased and securities sold under agreements to repurchase		1,156	815
Other short-term borrowed funds		1,653	1,856
Derivative liabilities		292	310
Deferred taxes, net		573	571
Long-term borrowed funds		14,433	11,765
Other liabilities		2,019	1,660
TOTAL LIABILITIES		139,701	132,066
Contingencies (refer to Note 18)
STOCKHOLDERS’ EQUITY:
Preferred stock, $25.00 par value, authorized 100,000,000 shares		840	247
Common stock:
$0.01 par value, 1,000,000,000 shares authorized; 566,819,863 shares issued and 466,007,984 shares outstanding at December 31, 2018 and 565,850,984 shares issued and 490,812,912 shares outstanding at December 31, 2017		6	6
Additional paid-in capital		18,815	18,781
Retained earnings		5,385	4,164
Treasury stock, at cost, 100,811,879 and 75,038,072 shares at December 31, 2018 and December 31, 2017, respectively		(3,133)	(2,108)
Accumulated other comprehensive loss		(1,096)	(820)
TOTAL STOCKHOLDERS’ EQUITY		20,817	20,270
TOTAL LIABILITIES AND STOCKHOLDERS’ EQUITY		$ 160,518	$ 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 December 31, 2018 and 2017, respectively.
[3]	Mortgage loans serviced for others by the Company’s subsidiaries are not included above, and amounted to $69.6 billion and $20.3 billion at December 31, 2018 and 2017, respectively.

CONSOLIDATED BALANCE SHEETS (Pa

CONSOLIDATED BALANCE SHEETS (Parenthetical) - USD ($) $ in Millions	Dec. 31, 2018	Dec. 31, 2017
ASSETS:
Securities held-to-maturity, fair value	$ 4,041	$ 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)	566,819,863	565,850,984
Common stock, outstanding (in shares)	466,007,984	490,812,912
Treasury stock (in shares)	100,811,879	75,038,072
Available-for-sale Securities
ASSETS:
Securities, pledged to creditors	$ 363	$ 91
Held-to-maturity Securities
ASSETS:
Securities held-to-maturity, fair value	$ 4,041	$ 4,668

CONSOLIDATED STATEMENTS OF OPER

CONSOLIDATED STATEMENTS OF OPERATIONS - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
INTEREST INCOME:
Interest and fees on loans and leases	$ 5,010	$ 4,249	$ 3,653
Interest and fees on loans held for sale, at fair value	37	18	15
Interest and fees on other loans held for sale	10	10	6
Investment securities	672	625	584
Interest-bearing deposits in banks	29	18	8
Total interest income	5,758	4,920	4,266
INTEREST EXPENSE:
Deposits	785	441	270
Federal funds purchased and securities sold under agreements to repurchase	6	3	2
Other short-term borrowed funds	57	31	40
Long-term borrowed funds	378	272	196
Total interest expense	1,226	747	508
Net interest income	4,532	4,173	3,758
Provision for credit losses	326	321	369
Net interest income after provision for credit losses	4,206	3,852	3,389
NONINTEREST INCOME:
Service charges and fees	513	516	522
Card fees	244	233	203
Capital markets fees	179	194	136
Trust and investment services fees	171	158	146
Mortgage banking fees	152	108	112
Letter of credit and loan fees	128	121	112
Foreign exchange and interest rate products	126	109	103
Securities gains, net	19	11	16
Net securities impairment losses recognized in earnings	(3)	(7)	(12)
Other income	67	91	159
Total noninterest income	1,596	1,534	1,497
NONINTEREST EXPENSE:
Salaries and employee benefits	1,880	1,766	1,714
Outside services	447	404	377
Occupancy	333	319	307
Equipment expense	275	263	263
Amortization of software	189	180	170
Other operating expense	495	542	521
Total noninterest expense	3,619	3,474	3,352
Income before income tax expense	2,183	1,912	1,534
Income tax expense	462	260	489
NET INCOME	1,721	1,652	1,045
Net income available to common stockholders	$ 1,692	$ 1,638	$ 1,031
Weighted-average common shares outstanding:
Basic (in shares)	478,822,072	502,157,440	522,093,545
Diluted (in shares)	480,430,741	503,685,091	523,930,718
Per common share information:
Basic earnings (in dollars per share)	$ 3.54	$ 3.26	$ 1.97
Diluted earnings (in dollars per share)	$ 3.52	$ 3.25	$ 1.97

CONSOLIDATED STATEMENTS OF COMP

CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Statement of Comprehensive Income [Abstract]
Net income	$ 1,721	$ 1,652	$ 1,045
Other comprehensive loss:
Net unrealized derivative instrument losses arising during the periods, net of income taxes of ($11), ($9) and ($38), respectively	(33)	(14)	(62)
Reclassification adjustment for net derivative losses (gains) included in net income, net of income taxes of $10, ($9) and ($22), respectively	33	(16)	(36)
Net unrealized debt securities losses arising during the periods, net of income taxes of ($79), ($4) and ($82), respectively	(239)	(6)	(139)
Other-than-temporary impairment not recognized in earnings on debt securities, net of income taxes of ($1), $0 and ($10), respectively	(3)	0	(17)
Reclassification of net debt securities gains to net income, net of income taxes of ($4), ($2) and ($2), respectively	(12)	(2)	(2)
Employee benefit plans:
Actuarial (loss) gain, net of income taxes of ($14), $12 and ($20), respectively	(35)	19	(34)
Amortization of actuarial loss, net of income taxes of $3, $5 and $6, respectively	14	13	10
Amortization of prior service cost, net of income taxes of $0, $0 and $0, respectively	(1)	(1)	(1)
Total other comprehensive loss, net of income taxes	(276)	(7)	(281)
Total comprehensive income	$ 1,445	$ 1,645	$ 764

CONSOLIDATED STATEMENTS OF CO_2

CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME (Parenthetical) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Statement of Comprehensive Income [Abstract]
Net unrealized derivative instrument losses arising during the periods, tax	$ (11)	$ (9)	$ (38)
Reclassification adjustment for net derivative losses (gains) included in net income, tax	10	(9)	(22)
Net unrealized debt securities losses arising during the periods, tax	(79)	(4)	(82)
Other-than-temporary impairment not recognized in earnings on debt securities, tax	(1)	0	(10)
Reclassification of net debt securities gains to net income, tax	(4)	(2)	(2)
Actuarial (loss) gain, tax	(14)	12	(20)
Amortization of actuarial loss, tax	3	5	6
Amortization of prior service credit, tax	$ 0	$ 0	$ 0

CONSOLIDATED STATEMENTS OF CHAN

CONSOLIDATED STATEMENTS OF CHANGES IN STOCKHOLDERS' EQUITY - 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, 2015		0	528,000,000
Beginning balance at Dec. 31, 2015	$ 19,646	$ 247	$ 6	$ 18,725	$ 1,913	$ (858)	$ (387)
Increase (Decrease) in Stockholders' Equity [Roll Forward]
Dividends to common stockholders	(241)				(241)
Dividends to preferred stockholders	(14)				(14)
Treasury stock purchased (in shares)			(17,000,000)
Treasury stock purchased	(430)			(25)		(405)
Share-based compensation plans (in shares)			1,000,000
Share-based compensation plans	12			12
Employee stock purchase plan shares purchased	10			10
Net income	1,045				1,045
Total comprehensive income:
Other comprehensive loss	(281)						(281)
Total comprehensive income	764				1,045		(281)
Ending balance (in shares) at Dec. 31, 2016		0	512,000,000
Ending 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	(322)				(322)
Dividends to preferred stockholders	$ (14)				(14)
Treasury stock purchased (in shares)	(22,362,401)		(22,000,000)
Treasury stock purchased	$ (820)			25		(845)
Share-based compensation plans (in shares)			1,000,000
Share-based compensation plans	22			22
Employee stock purchase plan shares purchased	12			12
Net income	1,652				1,652
Total comprehensive income:
Other comprehensive loss	(7)						(7)
Total comprehensive income	1,645				1,652		(7)
Reclassification of tax effects resulting from the 2017 Tax Legislation	0				145		(145)	[1]
Ending balance (in shares) at Dec. 31, 2017		0	491,000,000
Ending 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	(471)				(471)
Dividends to preferred stockholders	(29)				(29)
Issuance of preferred stock (in shares)		1,000,000
Issuance of preferred stock	$ 593	$ 593
Treasury stock purchased (in shares)	(25,773,807)		(26,000,000)
Treasury stock purchased	$ (1,025)			0		(1,025)
Share-based compensation plans (in shares)			1,000,000
Share-based compensation plans	20			20
Employee stock purchase plan shares purchased	14			14
Net income	1,721				1,721
Total comprehensive income:
Other comprehensive loss	(276)						(276)
Total comprehensive income	1,445				1,721		(276)
Ending balance (in shares) at Dec. 31, 2018		1,000,000	466,000,000
Ending balance at Dec. 31, 2018	$ 20,817	$ 840	$ 6	$ 18,815	$ 5,385	$ (3,133)	$ (1,096)
[1]	As of December 31, 2017, the balance of AOCI reflects the retrospective adoption of FASB ASU 2018-02, Income Statement-Reporting Comprehensive Income (Topic 220): Reclassification of Certain Tax Effects from Accumulated Other Comprehensive Income. For further discussion, see Note 22 “Income Taxes.”

CONSOLIDATED STATEMENTS OF CASH

CONSOLIDATED STATEMENTS OF CASH FLOWS - USD ($) $ in Millions		12 Months Ended
		Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
OPERATING ACTIVITIES
Net income		$ 1,721	$ 1,652	$ 1,045
Adjustments to reconcile net income to net cash provided by operating activities:
Provision for credit losses		326	321	369
Originations of mortgage loans held for sale		(8,036)	(2,911)	(2,829)
Proceeds from sales of mortgage loans held for sale		8,149	3,161	2,652
Purchases of commercial loans held for sale		(1,944)	(2,057)	(1,355)
Proceeds from sales of commercial loans held for sale		1,857	1,963	1,335
Depreciation, amortization and accretion		489	487	515
Mortgage servicing rights valuation recovery		(3)	(2)	(4)
Debt securities impairment		3	7	12
Deferred income taxes		97	(136)	153
Share-based compensation		41	48	23
Net gain on sales of:
Debt securities		(19)	(11)	(16)
Equity securities		0	(1)	(3)
Premises and equipment		0	0	(2)
Other loans held for sale		0	(17)	(72)
Increase in other assets		(1,217)	(502)	(274)
Increase (decrease) in other liabilities		303	(119)	(59)
Net cash provided by operating activities		1,767	1,883	1,490
Investment securities:
Purchases of securities available for sale		(4,270)	(5,394)	(7,664)
Proceeds from maturities and paydowns of debt securities available for sale		3,258	3,470	3,785
Proceeds from sales of debt securities available for sale		998	1,257	1,966
Purchases of debt securities held to maturity		0	(171)	(523)
Proceeds from maturities and paydowns of debt securities held to maturity		522	561	720
Purchases of equity securities, at fair value		(162)	(326)	(246)
Proceeds from sales of equity securities, at fair value		150	253	220
Purchases of equity securities, at cost		(754)	(400)	(166)
Proceeds from sales of equity securities, at cost		642	637	87
Net decrease (increase) in interest-bearing deposits in banks		44	247	(83)
Purchases of mortgage servicing rights		(16)	(28)	0
Acquisition, net of cash acquired		(533)	0	0
Net increase in loans and leases		(6,445)	(3,634)	(9,074)
Net increase in bank-owned life insurance		(42)	(44)	(48)
Premises and equipment:
Purchases		(232)	(253)	(138)
Proceeds from sales		0	0	3
Capitalization of software		(237)	(159)	(165)
Net cash used in investing activities		(7,077)	(3,984)	(11,326)
FINANCING ACTIVITIES
Net increase in deposits		4,486	5,285	7,265
Net increase (decrease) in federal funds purchased and securities sold under agreements to repurchase		341	(333)	346
Net decrease in other short-term borrowed funds		(5,211)	(4,959)	(3,186)
Proceeds from issuance of long-term borrowed funds		22,503	15,363	15,144
Repayments of long-term borrowed funds		(14,837)	(12,751)	(8,429)
Treasury stock purchased		(1,025)	(820)	(430)
Net proceeds from issuance of preferred stock		593	0	0
Dividends declared and paid to common stockholders		(471)	(322)	(241)
Dividends declared and paid to preferred stockholders		(14)	(14)	(14)
Payments of employee tax withholding for share-based compensation		(13)	(20)	0
Net cash provided by financing activities		6,352	1,429	10,455
Increase (Decrease) in cash and cash equivalents	[1]	1,042	(672)	619
Cash and cash equivalents at beginning of period	[1]	3,032	3,704	3,085
Cash and cash equivalents at end of period	[1]	4,074	3,032	3,704
Supplemental disclosures:
Interest paid		1,184	716	505
Income taxes paid		241	371	94
Non-cash items:
Loans securitized and transferred to securities available for sale		142	134	68
Stock issued for share-based compensation plans		20	22	12
Stock issued for Employee Stock Purchase Plan		14	12	10
Due from broker for securities sold but not settled		$ 0	$ 6	$ 0
[1]	Cash and cash equivalents include 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	12 Months Ended
	Dec. 31, 2018
Organization, Consolidation and Presentation of Financial Statements [Abstract]
BASIS OF PRESENTATION	BASIS OF PRESENTATION The accounting and reporting policies of Citizens Financial Group, Inc. conform to GAAP. The Company’s principal business activity is banking, conducted through its subsidiaries Citizens Bank, National Association and Citizens Bank of Pennsylvania. On January 2, 2019, we consolidated our banking subsidiaries via a merger of CBPA into CBNA in order to streamline governance and enterprise risk management, improve CBNA’s risk profile and gain operational efficiencies. CBNA is now our primary subsidiary and our sole banking subsidiary. Basis of Presentation The Consolidated Financial Statements include the accounts of Citizens and subsidiaries in which Citizens 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 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 allowance for credit losses and the fair value of MSRs. Significant Accounting Policies Interest Income Recognition Interest income on loans and securities classified as AFS or HTM is determined using the effective interest method. This method calculates periodic interest income at a constant effective yield on the net investment in the loan or security, to provide a constant rate of return over the terms of the financial assets. Transfer of Financial Assets A transfer of financial assets is accounted for as a sale when control over the assets transferred is surrendered. Assets transferred that satisfy the conditions of a sale are derecognized, and all assets obtained and liabilities incurred in a purchase are recognized and measured at fair value. Servicing rights retained in the transfer of financial assets are initially recognized at fair value. Subsequent to the initial recognition date, servicing rights are accounted for either at the lower of cost or market or fair value. For servicing rights accounted for at the lower of cost or market, Citizens recognizes periodic amortization expense of servicing rights and assesses servicing rights for impairment. The following table identifies the Company’s significant accounting policies and the Note and Page where a detailed description of each policy can be found. Note Page Cash and Due From Banks Note 2 Securities Note 3 Loans and Leases Note 4 Allowance for Credit Losses Note 5 Premises, Equipment and Software Note 6 Operating Lease Assets Note 6 Mortgage Servicing Rights Note 8 Goodwill Note 9 Variable Interest Entities Note 10 Derivative Instruments Note 13 Employee Benefits Note 14 Treasury Stock Note 16 Employee Share-Based Compensation Note 17 Fair Value Measurement Note 19 Revenue Recognition Note 20 Income Taxes Note 22 Earnings Per Share Note 23 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 8 “Mortgage Banking” for more information. The Company initially recognized goodwill of $59 million and other intangibles of $32 million related to the transaction. As of December 31, 2018 , the Company recognized goodwill of $36 million , after a $23 million purchase price allocation adjustment given higher value attributed to purchased net assets, and other intangibles of $30 million , net of $2 million of amortization expense. Refer to Note 9 “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 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. • Citizens adopted the new standard on December 31, 2018. • Adoption did not have a material impact on the Company’s Consolidated 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. • Citizens 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. Citizens 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. • Citizens 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. • Citizens retrospectively adopted the new standard as of January 1, 2018. • Adoption did not have an impact on the Company’s net income. • Citizens reclassified prior period amounts in the Consolidated Statements 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. • Citizens 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. • Citizens 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 will not adopt the guidance prior to the required effective date. • Upon adoption, the Company elected to transfer $755 million of securities eligible to be hedged under the last-of-layer method from the HTM portfolio to the AFS portfolio. At the time of the transfer, $15 million of unrealized losses were recognized in OCI. The remaining 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 will not adopt the guidance prior to the effective date. • The Company occupies certain banking offices and equipment under non-cancelable operating lease agreements, which currently are not reflected on its Consolidated Balance Sheets. • The Company will 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. • Upon adoption, the Company will recognize a right-of-use asset and corresponding lease liability of approximately $750 million in its Consolidated Balance Sheets for non-cancelable operating lease agreements. • Adoption of the guidance will not result in 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 will not 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, revising policies and procedures and completing the development and configuration 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, how the reasonable and supportable forecast period will be determined and documented as well as the impacts of that decision in different parts of the credit cycle, and expects to begin parallel testing in the second half of 2019. • 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 does not intend to 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.

CASH AND DUE FROM BANKS

CASH AND DUE FROM BANKS	12 Months Ended
	Dec. 31, 2018
Cash and Cash Equivalents [Abstract]
CASH AND DUE FROM BANKS	CASH AND DUE FROM BANKS For the purposes of reporting cash flows, cash and cash equivalents have original maturities of three months or less and include cash and due from banks and interest-bearing cash and due from banks, primarily at the FRB. The Company’s subsidiary banks maintain certain average reserve balances and compensating balances for check clearing and other services with the FRB. At December 31, 2018 and 2017 , the balance of deposits at the FRB amounted to $3.0 billion and $2.0 billion , respectively. Average balances maintained with the FRB during the years ended December 31, 2018 , 2017 , and 2016 exceeded amounts required by law for the FRB’s requirements. All amounts, both required and excess reserves, held at the FRB currently earn interest at a fixed rate of 240 basis points . Citizens recorded interest income on FRB deposits of $28 million , $16 million , and $7 million for the years ended December 31, 2018 , 2017 , and 2016 , respectively, in interest-bearing deposits in banks in the Consolidated Statements of Operations.

SECURITIES

SECURITIES	12 Months Ended
	Dec. 31, 2018
Investments, Debt and Equity Securities [Abstract]
SECURITIES	SECURITIES Investments include debt and marketable equity securities and other investment securities. Citizens classifies debt securities as AFS, HTM, or trading based on management’s intent to hold to maturity at the time of purchase, and marketable equity securities as trading. Securities that will be held for indefinite periods of time and may be sold in response to changes in interest rates, changes in prepayment risk, or other factors considered in managing the Company’s asset/liability strategy are classified as AFS and reported at fair value, with unrealized gains and losses reported in OCI as a separate component of stockholders’ equity, net of taxes. Gains and losses on the sales of securities are recognized in noninterest income and are computed using the specific identification method. Debt securities for which the Company has the ability and intent to hold to maturity are classified as HTM. The securities are reported at amortized cost. Transfers of debt securities to the HTM classification are recognized at fair value at the date of transfer. For debt securities classified as AFS or HTM, interest income is recorded on the accrual basis including the amortization of premiums and the accretion of discounts. Premiums and discounts on debt securities are amortized or accreted using the effective interest method over the estimated lives of the individual securities. Citizens uses actual prepayment experience and estimates of future prepayments to determine the constant effective yield necessary to apply the effective interest method of income recognition. Estimates of future prepayments are based on the underlying collateral characteristics of each security and are derived from market sources. Judgment is involved in making determinations about prepayment expectations and in changing those expectations in response to changes in interest rates and macroeconomic conditions. The amortization of premiums and discounts associated with mortgage-backed securities may be significantly impacted by changes in prepayment assumptions. Securities classified as trading are bought and held principally for selling them in the near term and carried at fair value, with changes in fair value recognized in earnings. When applicable, realized and unrealized gains and losses on such assets are reported in noninterest income in the Consolidated Statements of Operations. Other investment securities are primarily composed of FHLB stock and FRB stock (which are carried at cost) and money market mutual fund investments held by the Company’s broker-dealers (which are carried at fair value, with changes in fair value recognized in noninterest income). Other investment securities that are carried at cost are reviewed at least annually for impairment, with valuation adjustments recognized in noninterest income. The following table presents the major components of securities at amortized cost and fair value: December 31, 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 $24 $— $— $24 $12 $— $— $12 State and political subdivisions 5 — — 5 6 — — 6 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities 20,211 28 (605 ) 19,634 20,065 40 (277 ) 19,828 Other/non-agency 236 3 (7 ) 232 311 7 (7 ) 311 Total mortgage-backed securities 20,447 31 (612 ) 19,866 20,376 47 (284 ) 20,139 Total debt securities available for sale, at fair value $20,476 $31 ($612 ) $19,895 $20,394 $47 ($284 ) $20,157 Debt Securities Held to Maturity Mortgage-backed securities: Federal agencies and U.S. government sponsored entities $3,425 $— ($132 ) $3,293 $3,853 $7 ($46 ) $3,814 Other/non-agency 740 8 — 748 832 22 — 854 Total mortgage-backed securities 4,165 8 (132 ) 4,041 4,685 29 (46 ) 4,668 Total debt securities held to maturity $4,165 $8 ($132 ) $4,041 $4,685 $29 ($46 ) $4,668 Equity Securities, at Fair Value Money market mutual fund investments $181 $— $— $181 $165 $— $— $165 Other investments — — — — 4 — — 4 Total equity securities, at fair value $181 $— $— $181 $169 $— $— $169 Equity Securities, at Cost Federal Reserve Bank stock $463 $— $— $463 $463 $— $— $463 Federal Home Loan Bank stock 364 — — 364 252 — — 252 Other equity securities 7 — — 7 7 — — 7 Total equity securities, at cost $834 $— $— $834 $722 $— $— $722 The amortized cost and fair value of debt securities by contractual maturity 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. 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 $24 $— $— $— $24 State and political subdivisions — — — 5 5 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — 281 1,540 18,390 20,211 Other/non-agency 1 10 — 225 236 Total debt securities available for sale 25 291 1,540 18,620 20,476 Debt securities held to maturity: Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — — — 3,425 3,425 Other/non-agency — — — 740 740 Total debt securities held to maturity — — — 4,165 4,165 Total amortized cost of debt securities $25 $291 $1,540 $22,785 $24,641 Fair Value: Debt securities available for sale U.S. Treasury and other $24 $— $— $— $24 State and political subdivisions — — — 5 5 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — 274 1,505 17,855 19,634 Other/non-agency 1 10 — 221 232 Total debt securities available for sale 25 284 1,505 18,081 19,895 Debt securities held to maturity Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — — — 3,293 3,293 Other/non-agency — — — 748 748 Total debt securities held to maturity — — — 4,041 4,041 Total fair value of debt securities $25 $284 $1,505 $22,122 $23,936 Taxable interest income from investment securities as presented on the Consolidated Statements of Operations was $672 million , $625 million and $584 million for the years ended December 31, 2018 , 2017 and 2016 , respectively. Realized gains and losses on securities are presented below: Year Ended December 31, (in millions) 2018 2017 2016 Gains on sale of debt securities $19 $11 $18 Losses on sale of debt securities — — (2 ) Debt securities gains, net $19 $11 $16 Equity securities gains $— $1 $3 The amortized cost and fair value of debt securities pledged are presented below: December 31, 2018 December 31, 2017 (in millions) Amortized Cost Fair Value Amortized Cost Fair Value Pledged against repurchase agreements $344 $338 $358 $357 Pledged against FHLB borrowed funds 745 752 839 861 Pledged against derivatives, to qualify for fiduciary powers, and to secure public and other deposits as required by law 3,592 3,460 3,113 3,082 Citizens 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. Citizens recognized no offsetting of short-term receivables or payables as of December 31, 2018 or 2017 . Citizens offsets certain derivative assets and derivative liabilities on the Consolidated Balance Sheets. For further information see Note 13 “Derivatives.” Securitizations of mortgage loans retained in the investment portfolio for the years ended December 31, 2018 , 2017 and 2016 , were $142 million , $134 million and $68 million , respectively. These securitizations include a substantive guarantee by a third party. In 2018 and 2017, the guarantors were FNMA, FHLMC, and GNMA. In 2016, the guarantors were FNMA and GNMA. The debt securities received from the guarantors are classified as AFS. Impairment Citizens reviews its securities for other-than-temporary impairment on a quarterly basis or more frequently if a potential loss triggering event occurs. The initial indicator of other-than-temporary impairment for both debt and equity securities is a decline in fair value below its recorded investment amount, as well as the severity and duration of the decline. For a security of which there has been a decline in fair value below the cost basis, the Company recognizes other-than-temporary impairment if (i) management has the intent to sell the security, (ii) it is more likely than not it will be required to sell the security before recovery of its amortized cost basis, or (iii) the Company does not expect to recover the entire cost basis of the security. Estimating the recovery of the amortized cost basis of a debt security is based upon an assessment of the cash flows expected to be collected. If the present value of cash flows expected to be collected, discounted at the security’s original effective yield, is less than amortized cost, other-than-temporary impairment is considered to have occurred. In addition to these cash flow projections, several other characteristics of each debt security are reviewed when determining whether a credit loss exists and the period over which the debt security is expected to recover. These characteristics include: (i) the type of investment, (ii) various market factors affecting the fair value of the security (e.g., interest rates, spread levels, liquidity in the sector, etc.), (iii) the length and severity of impairment, and (iv) the public credit rating of the instrument. Citizens estimates the portion of loss attributable to credit using a collateral loss model and integrated cash flow engine. The model calculates prepayment, default and loss severity assumptions using collateral performance data. These assumptions are used to produce cash flows that generate loss projections. These loss projections are reviewed on a quarterly basis by a cross-functional governance committee to determine whether security impairments are other-than-temporary. If the Company intends to sell an impaired security, or if it is more likely than not it will be required to sell the security before recovery, the impairment loss recognized in current period earnings equals the difference between the amortized cost basis and the fair value of the security. If the Company does not intend to sell the impaired security, and it is not likely that the Company will be required to sell the impaired security, the other-than-temporary impairment write-down is separated into an amount representing the credit loss, which is recognized in current period earnings and the amount related to all other factors, is recognized in OCI. The following table presents the net securities impairment losses recognized in earnings: Year Ended December 31, (in millions) 2018 2017 2016 Other-than-temporary impairment: Total other-than-temporary impairment losses ($7 ) ($7 ) ($39 ) Portions of loss recognized in other comprehensive income (before taxes) 4 — 27 Net securities impairment losses recognized in earnings ($3 ) ($7 ) ($12 ) 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: December 31, 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 166 $4,881 ($89 ) 429 $15,124 ($648 ) 595 $20,005 ($737 ) Other/non-agency 10 139 (1 ) 11 72 (6 ) 21 211 (7 ) Total 176 $5,020 ($90 ) 440 $15,196 ($654 ) 616 $20,216 ($744 ) 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: Year Ended December 31, (in millions) 2018 2017 2016 Cumulative balance at beginning of period $80 $75 $66 Credit impairments recognized in earnings on debt securities that have been previously impaired 3 7 12 Reductions due to increases in cash flow expectations on impaired debt securities (1) (2 ) (2 ) (3 ) Cumulative balance at end of period $81 $80 $75 (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 December 31, 2018 , 2017 and 2016 were $81 million , $80 million and $75 million , respectively. There were no credit losses recognized in earnings for the Company’s HTM portfolio as of December 31, 2018 , 2017 and 2016 . For the years ended December 31, 2018 , 2017 and 2016 , Citizens incurred non-agency MBS credit related other-than-temporary impairment losses in earnings of $3 million , $7 million and $12 million , respectively. There were no credit-impaired debt securities sold during the years ended December 31, 2018 , 2017 and 2016 , respectively. Citizens 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. Citizens 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 December 31, 2018 . The unrealized losses on these debt securities reflect non-credit-related factors such as changing interest rates and market liquidity. Therefore, Citizens 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. Additionally, as of December 31, 2018 and 2016 , there were $4 million and $27 million pre-tax non-credit related losses deferred in AOCI, respectively, and there was no pre-tax non-credit related losses deferred in AOCI for the year ended December 31, 2017 .

LOANS AND LEASES

LOANS AND LEASES	12 Months Ended
	Dec. 31, 2018
Receivables [Abstract]
LOANS AND LEASES	LOANS AND LEASES Loans held for investment are reported at the amount of their outstanding principal, net of charge-offs, unearned income, deferred loan origination fees and costs, and unamortized premiums or discounts on purchased loans. Deferred loan origination fees and costs and purchase premiums and discounts are amortized as an adjustment of yield over the life of the loan, using the effective interest method. Unamortized amounts remaining upon prepayment or sale are recorded as interest income or gain (loss) on sale, respectively. Credit card receivables include billed and uncollected interest and fees. Interest income on loans is determined using the effective interest method. This method calculates periodic interest income at a constant effective yield on the net investment in the loan, to provide a constant rate of return over the term. Loans accounted for using the fair value option, are measured at fair value with corresponding changes recognized in noninterest income. Loan commitment fees for loans that are likely to be drawn down, and other credit related fees, are deferred (together with any incremental costs) and recognized as an adjustment to the effective interest rate over the loan term. When it is unlikely that a loan will be drawn down, the loan commitment fees are recognized over the commitment period on a straight-line basis. Leases are classified at the inception of the lease. Direct financing lease receivables are reported at the aggregate of minimum lease payments receivable plus the estimated residual value of the leased property, less unearned and deferred income, including unamortized investment credits. Leveraged leases, which are a form of direct financing leases, are recorded net of related non-recourse debt. Lease residual values are reviewed at least annually for other-than-temporary impairment; with valuation adjustments recognized currently against other income for direct financing and leveraged leases. Unearned income is recognized as a constant percentage of outstanding lease financing balances over the lease term in interest income. 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 now services a portion of internally. A summary of the loans and leases portfolio is presented below: December 31, (in millions) 2018 2017 Commercial $40,857 $37,562 Commercial real estate 13,023 11,308 Leases 2,903 3,161 Total commercial loans and leases 56,783 52,031 Residential mortgages 18,978 17,045 Home equity loans 1,073 1,392 Home equity lines of credit 12,710 13,483 Home equity loans serviced by others 399 542 Home equity lines of credit serviced by others 104 149 Automobile 12,106 13,204 Education 8,900 8,134 Credit cards 1,991 1,848 Other retail 3,616 2,789 Total retail loans 59,877 58,586 Total loans and leases (1)(2) $116,660 $110,617 (1) Excluded from the table above are loans held for sale totaling $1.3 billion and $718 million as of December 31, 2018 and 2017 , respectively. (2) Mortgage loans serviced for others by the Company’s subsidiaries are not included above, and amounted to $69.6 billion and $20.3 billion at December 31, 2018 and 2017 , respectively. Loans are classified upon origination or acquisition as either held-for-investment or held-for-sale. This classification is based on management’s initial intent and ability to hold the loans for the foreseeable future. Loans held for sale are carried at the lower of cost or fair value, with any write-downs or subsequent recoveries charged to other income. Citizens accounts for certain loans held for sale, including those loans associated with its mortgage banking business and secondary loan trading desk, under the fair value option at fair value. Refer to Note 19, “Fair Value Measurements” for additional discussion. During the year ended December 31, 2018 the Company purchased $457 million of education loans. During the year ended December 31, 2017 , Citizens purchased $862 million of education loans and $153 million of automobile loans. During the year ended December 31, 2018 , the Company sold $553 million of commercial loans. During the year ended December 31, 2017 , the Company sold $603 million of commercial loans, $254 million of residential mortgage loans and $29 million of home equity loans. Also during the year ended December 31, 2017 , Citizens sold $78 million of TDRs, including $49 million of residential mortgages and $29 million of home equity loans, which resulted in a pre-tax gain of $17 million reported in other income on the Consolidated Statements of Operations. Loans held for sale at fair value totaled $1.2 billion and $497 million at December 31, 2018 and 2017 , respectively. The December 31, 2018 balance consisted of residential mortgages originated for sale of $967 million and loans in the commercial trading portfolio of $252 million . The December 31, 2017 balance 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 $101 million and $221 million as of December 31, 2018 and 2017 , respectively, and consisted of loans associated with the Company’s syndication business. Loans pledged as collateral for FHLB borrowed funds, primarily residential mortgages and home equity loans, totaled $25.6 billion and $24.9 billion at December 31, 2018 and 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 $16.8 billion and $18.1 billion at December 31, 2018 and 2017 , respectively. Citizens is engaged in the leasing of equipment for commercial use, with primary lease concentrations to Fortune 1000 companies for large capital equipment acquisitions. A lessee is evaluated from a credit perspective using the same underwriting standards and procedures as for a loan borrower. A lessee is expected to make rental payments based on its cash flows and the viability of its operations. Leases are usually not evaluated as collateral-based transactions, and therefore the lessee’s overall financial strength is the most important credit evaluation factor. A summary of the investment in leases, before the ALLL, is presented below: December 31, (in millions) 2018 2017 Direct financing leases $2,863 $3,122 Leveraged leases 40 39 Total leases $2,903 $3,161 The components of the investment in leases, before the ALLL, are presented below: December 31, (in millions) 2018 2017 Total future minimum lease rentals $2,075 $2,347 Estimated residual value of leased equipment (non-guaranteed) 1,091 1,072 Initial direct costs 13 15 Unearned income on minimum lease rentals and estimated residual value of leased equipment (276 ) (273 ) Total leases $2,903 $3,161 The future minimum lease rentals on direct financing and leveraged leases at December 31, 2018 are presented below: Year (in millions) 2019 $589 2020 461 2021 340 2022 258 2023 180 Thereafter 247 Total $2,075

ALLOWANCE FOR CREDIT LOSSES, NO

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK	12 Months Ended
	Dec. 31, 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 Allowance for Credit Losses Management’s estimate of probable losses in the Company’s loan and lease portfolios is recorded in the ALLL and the reserve for unfunded lending commitments. On a quarterly basis, Citizens evaluates the adequacy of the ALLL by performing reviews of certain individual loans and leases, analyzing changes in the composition, size and delinquency of the portfolio, reviewing previous loss experience and considering current and anticipated economic factors. The ALLL is established in accordance with the Company’s credit reserve policies, as approved by the Audit Committee of the Board of Directors. The Chief Financial Officer and Chief Risk Officer review the adequacy of the ALLL each quarter, together with risk management. In addition, various regulatory agencies, as an integral part of their examination process, periodically review the Company’s allowance for credit losses. The ALLL is maintained at a level that management considers reflective of probable losses, and is established through charges to earnings in the form of a provision for credit losses. The ALLL may be adjusted to reflect the Company’s current assessment of various qualitative risks, factors and events that may not be measured in the statistical analysis. Such factors include trends in economic conditions, loan growth, back testing results, credit underwriting policy exceptions, regulatory and audit findings, and peer comparisons. Amounts determined to be uncollectible are deducted from the ALLL and subsequent recoveries, if any, are added to the ALLL. While management uses available information to estimate loan and lease losses, future additions to the ALLL may be necessary based on changes in economic conditions. There were no material changes in assumptions or estimation techniques compared with prior years that impacted the determination of the current year’s ALLL and the reserve for unfunded lending commitments. The evaluation of the adequacy of the commercial, commercial real estate, and lease ALLL and reserve for unfunded lending commitments is primarily based on risk rating models that assess probability of default, loss given default and exposure at default on an individual loan basis. The models are primarily driven by individual customer financial characteristics and are validated against historical experience. Additionally, qualitative factors are included in the risk rating models. After the aggregation of individual borrower incurred loss, additional overlays can be made based on back-testing against historical losses. For non-impaired retail loans, the ALLL is based upon an incurred loss model utilizing the probability of default, loss given default and exposure at default on an individual loan basis. When developing these factors, the Company may consider the loan product and collateral type, delinquency status, LTV ratio, lien position, borrower’s credit, age of the loan, geographic location and incurred loss period. Certain retail portfolios, including education, unsecured personal loans, SBO home equity loans and commercial credit card receivables utilize roll rate or vintage models to estimate the ALLL. For nonaccruing commercial and commercial real estate loans with an outstanding balance of $3 million or greater and for all commercial and commercial real estate TDRs (regardless of size), the Company conducts further analysis to determine the probable amount of loss and establishes a specific allowance for the loan, if appropriate. Citizens estimates the impairment amount by comparing the loan’s carrying amount to the estimated present value of its future cash flows, the fair value of its underlying collateral, or the loan’s observable market price. For collateral-dependent impaired commercial and commercial real estate loans, the excess of the Company’s recorded investment in the loan over the fair value of the collateral, less cost to sell, is charged off to the ALLL. For retail TDRs that are not collateral-dependent, allowances are developed using the present value of expected future cash flows compared to the recorded investment in the loans. Expected re-default factors are considered in this analysis. Retail TDRs that are deemed collateral-dependent are written down to fair market value less cost to sell. The fair value of collateral is periodically monitored subsequent to the modification. In addition to the ALLL, the Company also estimates probable credit losses associated with off-balance sheet financial instruments such as standby letters of credit, financial guarantees and binding unfunded loan commitments. Off-balance sheet financial instruments are subject to individual reviews and are analyzed and segregated by risk according to the Company’s internal risk rating scale. These risk classifications, in conjunction with historical loss experience, economic conditions and performance trends within specific portfolio segments, result in the estimate of the reserve for unfunded lending commitments. The ALLL and the reserve for unfunded lending commitments are reported on the Consolidated Balance Sheets in the allowance for loan and lease losses and in other liabilities, respectively. Provision for credit losses related to the loans and leases portfolio and the unfunded lending commitments are reported in the Consolidated Statements of Operations as provision for credit losses. Loan Charge-Offs Commercial loans are charged off when it is highly certain that a loss has been realized, including situations where a loan is determined to be both impaired and collateral-dependent. The determination of whether to recognize a charge-off involves many factors, including the prioritization of the Company’s claim in bankruptcy, expectations of the workout/restructuring of the loan and valuation of the borrower’s equity or the loan collateral. Retail loans are generally fully charged-off or written down to the net realizable value of the underlying collateral, with an offset to the ALLL, upon reaching specified stages of delinquency in accordance with standards established by the FFIEC. Residential real estate loans, credit card loans and unsecured open end loans are generally charged off in the month in which the account becomes 180 days past due. Auto loans, education loans and unsecured closed end loans are generally charged off in the month in which the account becomes 120 days past due. Certain retail loans will be charged off earlier than the FFIEC standards in the following circumstances: • A charge-off is recognized when a loan is modified in a TDR if the loan is determined to be collateral-dependent. A loan is considered to be collateral-dependent when repayment of the loan is expected to be provided solely by the underlying collateral, rather than by cash flows from the borrower’s operations, income or other resources. • Loans to borrowers who have experienced an event (e.g. bankruptcy) that suggests a loss is either known or highly certain are subject to accelerated charge-off standards. Residential real estate and auto loans are charged down to the net realizable value when the loan becomes 60 days past due, or sooner if the loan is determined to be collateral-dependent. Credit card loans are fully charged off within 60 days of receiving notification of the bankruptcy filing or other event. Education loans are generally charged off when the loan becomes 60 days past due after receiving notification of a bankruptcy. • Auto loans are written down to net realizable value upon repossession of the collateral. A summary of changes in the ACL is presented below: Year Ended December 31, 2018 (in millions) Commercial Retail Total Allowance for loan and lease losses, beginning of period $685 $551 $1,236 Charge-offs (52 ) (442 ) (494 ) Recoveries 19 158 177 Net charge-offs (33 ) (284 ) (317 ) Provision charged to income 38 285 323 Allowance for loan and lease losses, end of period 690 552 1,242 Reserve for unfunded lending commitments, beginning of period 88 — 88 Provision for unfunded lending commitments 3 — 3 Reserve for unfunded lending commitments, end of period 91 — 91 Total allowance for credit losses, end of period $781 $552 $1,333 Year Ended December 31, 2017 (in millions) Commercial Retail Total Allowance for loan and lease losses, beginning of period $663 $573 $1,236 Charge-offs (75 ) (437 ) (512 ) Recoveries 40 167 207 Net charge-offs (35 ) (270 ) (305 ) Provision charged to income (1) 57 248 305 Allowance for loan and lease losses, end of period 685 551 1,236 Reserve for unfunded lending commitments, beginning of period 72 — 72 Provision for unfunded lending commitments 16 — 16 Reserve for unfunded lending commitments, end of period 88 — 88 Total allowance for credit losses, end of period $773 $551 $1,324 (1) Includes an increase of approximately $50 million to commercial and corresponding decrease to retail for the impact of the enhancement to the assessment of qualitative risks, factors and events that may not be measured in the modeled results. Year Ended December 31, 2016 (in millions) Commercial Retail Total Allowance for loan and lease losses, beginning of period $596 $620 $1,216 Charge-offs (79 ) (457 ) (536 ) Recoveries 33 168 201 Net charge-offs (46 ) (289 ) (335 ) Provision charged to income 113 242 355 Allowance for loan and lease losses, end of period 663 573 1,236 Reserve for unfunded lending commitments, beginning of period 58 — 58 Provision for unfunded lending commitments 14 — 14 Reserve for unfunded lending commitments, end of period 72 — 72 Total allowance for credit losses, end of period $735 $573 $1,308 The recorded investment in loans and leases based on the Company’s evaluation methodology is presented below: December 31, 2018 December 31, 2017 (in millions) Commercial Retail Total Commercial Retail Total Individually evaluated $391 $723 $1,114 $370 $761 $1,131 Formula-based evaluation 56,392 59,154 115,546 51,661 57,825 109,486 Total loans and leases $56,783 $59,877 $116,660 $52,031 $58,586 $110,617 A summary of the ACL by evaluation method is presented below: December 31, 2018 December 31, 2017 (in millions) Commercial Retail Total Commercial Retail Total Individually evaluated $38 $26 $64 $47 $34 $81 Formula-based evaluation 743 526 1,269 726 517 1,243 Allowance for credit losses $781 $552 $1,333 $773 $551 $1,324 For commercial loans and leases, Citizens 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: December 31, 2018 Criticized (in millions) Pass Special Mention Substandard Doubtful Total Commercial $38,600 $1,231 $828 $198 $40,857 Commercial real estate 12,523 412 82 6 13,023 Leases 2,823 39 41 — 2,903 Total commercial loans and leases $53,946 $1,682 $951 $204 $56,783 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: December 31, 2018 Days Past Due (in millions) Current 1-29 30-59 60-89 90 or More Total Residential mortgages $18,664 $131 $37 $13 $133 $18,978 Home equity loans 945 75 12 3 38 1,073 Home equity lines of credit 12,042 386 65 22 195 12,710 Home equity loans serviced by others 355 21 7 3 13 399 Home equity lines of credit serviced by others 79 15 2 1 7 104 Automobile 10,729 1,039 207 59 72 12,106 Education 8,694 159 23 13 11 8,900 Credit cards 1,894 53 14 10 20 1,991 Other retail 3,481 76 26 18 15 3,616 Total retail loans $56,883 $1,955 $393 $142 $504 $59,877 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 Nonperforming loans and leases are those on which accrual of interest has been suspended. Loans (other than certain retail loans insured by U.S. government agencies) are placed on nonaccrual status and considered nonperforming when full payment of principal and interest is in doubt, unless the loan is both well secured and in the process of collection. When the Company places a loan on nonaccrual status, the accrued unpaid interest receivable is reversed against interest income and amortization of any net deferred fees is suspended. Interest collections on nonaccruing loans and leases for which the ultimate collectability of principal is uncertain are generally applied to first reduce the carrying value of the loan. Otherwise, interest income may be recognized to the extent of the cash received. A loan may be returned to accrual status if (i) principal and interest payments have been brought current, and the Company expects repayment of the remaining contractual principal and interest, (ii) the loan or lease has otherwise become well-secured and in the process of collection, or (iii) the borrower has been making regularly scheduled payments in full for the prior six months and the Company is reasonably assured that the loan or lease will be brought fully current within a reasonable period. Commercial loans, commercial real estate loans, and leases are generally placed on nonaccrual status when contractually past due 90 days or more, or earlier if management believes that the probability of collection is insufficient to warrant further accrual. Some of these loans and leases may remain on accrual status when contractually past due 90 days or more if management considers the loan collectible. Residential mortgages are generally placed on nonaccrual status when past due 120 days, or sooner if determined to be collateral-dependent, unless repayment of the loan is guaranteed by the Federal Housing Administration. Credit card balances are placed on nonaccrual status when past due 90 days or more and are restored to accruing status if they subsequently become less than 90 days past due. All other retail loans are generally placed on nonaccrual status when past due 90 days or more, or earlier if management believes that the probability of collection is insufficient to warrant further accrual. Loans less than 90 days past due may be placed on nonaccrual status upon the death of the borrower, fraud or bankruptcy. The following table presents nonperforming loans and leases and loans accruing and 90 days or more past due: Nonperforming (1) Accruing and 90 days or more past due (in millions) December 31, 2018 December 31, 2017 December 31, 2018 December 31, 2017 Commercial $194 $238 $1 $5 Commercial real estate 7 27 — 3 Leases — — — — Total commercial loans and leases 201 265 1 8 Residential mortgages (1) 136 128 15 16 Home equity loans 50 72 — — Home equity lines of credit 231 233 — — Home equity loans serviced by others 17 25 — — Home equity lines of credit serviced by others 15 18 — — Automobile 81 70 — — Education 38 38 2 3 Credit card 20 17 — — Other retail 8 5 7 5 Total retail loans 596 606 24 24 Total $797 $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 $12 million and $15 million as of December 31, 2018 and 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 $133 million and $30 million as of December 31, 2018 and 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 $34 million and $36 million as of December 31, 2018 and 2017 , respectively. A summary of nonperforming loan and lease key performance indicators is presented below: December 31, 2018 2017 Nonperforming commercial loans and leases as a percentage of total loans and leases 0.17 % 0.24 % Nonperforming retail loans as a percentage of total loans and leases 0.51 0.55 Total nonperforming loans and leases as a percentage of total loans and leases 0.68 % 0.79 % Nonperforming commercial assets as a percentage of total assets 0.13 % 0.17 % Nonperforming retail assets as a percentage of total assets 0.39 0.43 Total nonperforming assets as a percentage of total assets 0.52 % 0.60 % The recorded investment in mortgage loans collateralized by residential real estate property for which formal foreclosure proceedings are in-process was $172 million and $181 million as of December 31, 2018 and 2017 , respectively. An analysis of the age of both accruing and nonaccruing loan and lease past due amounts is presented below: December 31, 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 $85 $3 $78 $166 $26 $4 $243 $273 Commercial real estate 8 32 5 45 38 20 30 88 Leases 7 — — 7 4 1 — 5 Total commercial loans and leases 100 35 83 218 68 25 273 366 Residential mortgages 37 13 133 183 46 18 120 184 Home equity loans 12 3 38 53 20 4 54 78 Home equity lines of credit 65 22 195 282 78 23 188 289 Home equity loans serviced by others 7 3 13 23 10 4 22 36 Home equity lines of credit serviced by others 2 1 7 10 4 1 7 12 Automobile 207 59 72 338 220 55 60 335 Education 23 13 11 47 23 12 41 76 Credit cards 14 10 20 44 12 9 17 38 Other retail 26 18 15 59 20 12 10 42 Total retail loans 393 142 504 1,039 433 138 519 1,090 Total $493 $177 $587 $1,257 $501 $163 $792 $1,456 Impaired Loans A loan is considered to be impaired when, based on current information and events, it is probable that the Company will be unable to collect all of the contractual interest and principal payments as scheduled in the loan agreement. This evaluation is generally based on delinquency information, an assessment of the borrower’s financial condition and the adequacy of collateral, if any. 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. When a loan is identified as impaired, the impairment is measured on an individual loan level as the difference between the recorded investment in the loan (net of previous charge-offs, deferred loan fees or costs and unamortized premium or discount) and the present value of expected future cash flows, discounted at the loan’s effective interest rate. When collateral is the sole source of repayment for the impaired loan, rather than the borrower’s income or other sources of repayment, the Company charges down the loan to its net realizable value. A summary of impaired loans by class is presented below: December 31, 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 $186 $31 $167 $450 $353 Commercial real estate 32 7 6 38 38 Leases — — — — — Total commercial loans and leases 218 38 173 488 391 Residential mortgages 28 2 127 201 155 Home equity loans 34 3 76 148 110 Home equity lines of credit 21 1 181 244 202 Home equity loans serviced by others 22 1 19 54 41 Home equity lines of credit serviced by others 1 — 7 11 8 Automobile 1 — 22 31 23 Education 130 11 23 153 153 Credit cards 24 7 1 25 25 Other retail 4 1 2 8 6 Total retail loans 265 26 458 875 723 Total $483 $64 $631 $1,363 $1,114 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: Year Ended December 31, 2018 2017 2016 (in millions) Interest Income Recognized Average Recorded Investment Interest Income Recognized Average Recorded Investment Interest Income Recognized Average Recorded Investment Commercial $9 $312 $4 $380 $5 $295 Commercial real estate 1 32 — 37 — 53 Leases — — — — — 3 Total commercial loans and leases 10 344 4 417 5 351 Residential mortgages 5 146 4 136 4 161 Home equity loans 6 107 6 121 7 144 Home equity lines of credit 7 181 6 176 6 178 Home equity loans serviced by others 3 42 3 49 3 60 Home equity lines of credit serviced by others — 9 — 9 — 9 Automobile 1 20 1 18 — 14 Education 8 154 9 173 7 150 Credit cards 1 21 2 22 2 23 Other retail — 7 — 9 1 12 Total retail loans 31 687 31 713 30 751 Total $41 $1,031 $35 $1,130 $35 $1,102 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 with the borrower. 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. Retail and commercial loans whose contractual terms have been modified in a TDR and are current at the time of restructuring may remain on accrual status if there is demonstrated performance prior to the restructuring and payment in full under the restructured terms is expected. Retail loans that were discharged in bankruptcy and not reaffirmed by the borrower are deemed to be collateral-dependent TDRs and are generally charged off to the fair value of the collateral, less cost to sell, and less amounts recoverable under a government guarantee (if any). Cash receipts on nonaccruing impaired loans, including nonaccruing loans involved in TDRs, are generally applied to reduce the unpaid principal balance. Certain TDRs that are current in payment status are classified as nonaccrual in accordance with regulatory guidance. Income on these loans is generally recognized on a cash basis if management believes that the remaining book value of the loan is realizable. Nonaccruing TDRs that meet the guidelines above for accrual status can be returned to accruing if supported by a well-documented evaluation of the borrowers’ financial condition, and if they have been current for at least six months. Because TDRs are impaired loans, Citizens 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 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: December 31, (in millions) 2018 2017 Commercial $304 $129 Retail 723 761 Unfunded commitments related to TDRs 30 39 The table below summarizes how loans were modified during the year ended December 31, 2018 , the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during 2018 and were paid off in full, charged off, or sold prior to December 31, 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 7 $1 $1 49 $23 $22 Commercial real estate — — — 3 31 31 Total commercial loans 7 1 1 52 54 53 Residential mortgages 35 4 4 61 8 8 Home equity loans 43 3 4 1 — — Home equity lines of credit 76 6 7 178 25 26 Home equity loans serviced by others 4 — — — — — Home equity lines of credit serviced by others 5 — — 1 — — Automobile 158 4 3 46 1 1 Education — — — — — — Credit cards 2,312 13 13 — — — Other retail 1 — — — — — Total retail loans 2,634 30 31 287 34 35 Total 2,641 $31 $32 339 $88 $88 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 53 $202 $200 $— $— Commercial real estate 2 31 31 — — Total commercial loans 55 233 231 — — Residential mortgages 142 17 17 (1 ) — Home equity loans 134 5 5 — — Home equity lines of credit 413 29 29 — 1 Home equity loans serviced by others 23 1 1 — — Home equity lines of credit serviced by others 14 1 1 — — Automobile 1,189 21 17 — 4 Education 355 7 7 1 — Credit cards — — — 4 — Other retail 9 — — (1 ) — Total retail loans 2,279 81 77 3 5 Total 2,334 $314 $308 $3 $5 (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 year ended December 31, 2017 , the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during 2017 and were paid off in full, charged off, or sold prior to December 31, 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 $1 $1 45 $22 $22 Commercial real estate — — — 1 — — Total commercial loans 7 1 1 46 22 22 Residential mortgages 71 9 10 73 12 13 Home equity loans 82 5 6 1 — — Home equity lines of credit 50 3 3 235 30 30 Home equity loans serviced by others 15 1 1 — — — Home equity lines of credit serviced by others 5 — — 2 — — Automobile 130 2 2 29 1 1 Education — — — — — — Credit cards 2,363 13 13 — — — Other retail 1 — — — — — Total retail loans 2,717 33 35 340 43 44 Total 2,724 $34 $36 386 $65 $66 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 15 $70 $71 ($1 ) $— Commercial real estate 1 — — — — Total commercial loans 16 70 71 (1 ) — Residential mortgages 171 19 19 (1 ) — Home equity loans 232 13 13 — — Home equity lines of credit 395 27 27 — 1 Home equity loans serviced by others 52 2 2 — — Home equity lines of credit serviced by others 26 2 2 — — Automobile 1,336 24 20 — 4 Education 329 7 7 2 — Credit cards — — — 3 — Other retail 5 — — (2 ) — Total retail loans 2,546 94 90 2 5 Total 2,562 $164 $161 $1 $5 (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 year ended December 31, 2016 , the charge-offs related to the modifications, and the impact on t

PREMISES, EQUIPMENT, AND SOFTWA

PREMISES, EQUIPMENT, AND SOFTWARE	12 Months Ended
	Dec. 31, 2018
Property, Plant and Equipment [Abstract]
PREMISES, EQUIPMENT, AND SOFTWARE	PREMISES, EQUIPMENT AND SOFTWARE Premises and Equipment Premises and equipment are stated at cost, less accumulated depreciation and amortization. Depreciation and amortization have been computed using the straight-line method over the estimated useful lives of the assets. Leasehold improvements are amortized over the life of the lease (including renewal options if exercise of those options is reasonably assured) or their estimated useful life, whichever is shorter. Additions to premises and equipment are recorded at cost. The cost of major additions, improvements and betterments is capitalized. Normal repairs and maintenance and other costs that do not improve the property, extend the useful life or otherwise do not meet capitalization criteria are charged to expense as incurred. Citizens evaluates premises and equipment for impairment when events or changes in circumstances indicate that the carrying value of such assets may not be recoverable. A summary of the carrying value of premises and equipment is presented below: December 31, (dollars in millions) Useful Lives (years) 2018 2017 Land and land improvements 10 - 75 $112 $47 Buildings and leasehold improvements 5 - 60 852 719 Furniture, fixtures and equipment 5 - 20 1,019 1,465 Construction in progress 292 359 Total premises and equipment, gross 2,275 2,590 Accumulated depreciation (1,484 ) (1,905 ) Total premises and equipment, net $791 $685 Depreciation charged to noninterest expense totaled $117 million , $124 million , and $130 million for the years ended December 31, 2018 , 2017 , and 2016 , respectively, and is presented in the Consolidated Statements of Operations in both occupancy and equipment expense. Software Costs related to computer software developed or obtained for internal use are capitalized if the projects improve functionality and provide long-term future operational benefits. Capitalized costs are amortized using the straight-line method over the asset’s expected useful life, based upon the basic pattern of consumption and economic benefits provided by the asset. Citizens begins to amortize the software when the asset (or identifiable component of the asset) is substantially complete and ready for its intended use. All other costs incurred in connection with an internal-use software project are expensed as incurred. Capitalized software is included in other assets on the Consolidated Balance Sheets. Citizens had capitalized software assets of $1.8 billion and $1.7 billion and related accumulated amortization of $948 million and $869 million as of December 31, 2018 and 2017 , respectively. Amortization expense was $189 million , $180 million , and $170 million for the years ended December 31, 2018 , 2017 , and 2016 , respectively. The estimated future amortization expense for capitalized software assets is presented below: Year (in millions) 2019 $186 2020 155 2021 116 2022 80 2023 48 Thereafter 72 Total (1) $657 (1) Excluded from this balance is $188 million of in-process software at December 31, 2018 . Operating Lease Assets Other assets on the Consolidated Balance Sheets included assets subject to operating leases, where Citizens was the lessor, of $92 million and $112 million as of December 31, 2018 and 2017, respectively. Operating lease rental income for leased assets is recognized in other income on a straight-line basis over the lease term. Related depreciation expense is recorded on a straight-line basis over the estimated useful life, considering the estimated residual value of the leased asset and is included in other operating expense in the Consolidated Statements of Operations. On a periodic basis, leased assets are reviewed for impairment. Impairment loss is recognized in other operating expense if the carrying amount of the leased assets exceeds fair value and is not recoverable. The carrying amount of leased assets is not recoverable if it exceeds the sum of the undiscounted cash flows expected to result from the lease payments and the estimated residual value upon the eventual disposition of the asset.

LEASE COMMITMENTS

LEASE COMMITMENTS	12 Months Ended
	Dec. 31, 2018
Leases [Abstract]
LEASE COMMITMENTS	LEASE COMMITMENTS Citizens is committed under long-term leases for the rental of premises and equipment. These leases have varying renewal options and in certain instances, require the payment of insurance, real estate taxes and other operating expenses. At December 31, 2018 , the aggregate minimum rental commitments under these non-cancelable operating leases and capital leases, exclusive of renewals, are presented below for the years ended December 31: (in millions) Operating Leases Capital Leases 2019 $165 $3 2020 153 2 2021 136 2 2022 109 1 2023 85 — Thereafter 247 8 Total minimum lease payments $895 $16 Amounts representing interest — (8 ) Present value of net minimum lease $895 $8 Occupancy and equipment expense including rental expense for non-cancelable operating leases and capital leases totaled $212 million , $211 million , and $208 million for the years ended December 31, 2018 , 2017 , and 2016 , respectively.

MORTGAGE BANKING

MORTGAGE BANKING	12 Months Ended
	Dec. 31, 2018
Mortgage Banking [Abstract]
MORTGAGE BANKING	MORTGAGE BANKING In its mortgage banking business, Citizens sells residential mortgages to government-sponsored entities and other parties, who may issue securities backed by pools of such loans. Citizens retains no beneficial interests in these sales, but may retain the servicing rights for the loans sold. Citizens 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. Mortgage loans held for sale are accounted for at fair value on an individual loan basis. Changes in the fair value, and realized gains and losses on the sales of mortgage loans, are reported in mortgage banking fees. The following table summarizes activity related to the Company’s residential mortgage loan sales and the Company's mortgage banking activity: Year Ended December 31, (in millions) 2018 2017 2016 Residential mortgage loan sold with servicing retained $8,149 $3,161 $2,652 Gain on sales (1) 89 35 69 Contractually specified servicing, late and other ancillary fees (1) 118 53 51 (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. Citizens 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 FAMC portfolio, acquired on August 1, 2018, 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. Citizens 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: Amortization Method As of and for the Year Ended December 31, (in millions) 2018 2017 MSRs: Balance as of beginning of period $201 $167 Amount capitalized 36 37 Purchases 16 28 Amortization (32 ) (31 ) Carrying amount before valuation allowance 221 201 Valuation allowance for servicing assets: Balance as of beginning of period 3 5 Valuation recoveries (3 ) (2 ) Balance at end of period — 3 Net carrying value of MSRs $221 $198 Fair Value Method As of and for the Year Ended December 31, 2018 (in millions) MSRs: Fair value as of beginning of the period $— Acquired MSRs 590 Amounts capitalized 73 Changes in unpaid principal balance during the period (1) (32 ) Changes in fair value during the period (2) (31 ) Fair value at end of the period $600 (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 by 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: December 31, 2018 December 31, 2017 Actual Decline in fair value due to Actual Decline in fair value due to (dollars in millions) Fair value $243 50 bps adverse change 100 bps adverse change $218 50 bps adverse change 100 bps adverse change Weighted average life (in years) 6.5 5.9 Weighted average constant prepayment rate 8.5% $24 $56 10.0% $22 $46 Weighted average discount rate 9.3% 5 9 9.9% 4 8 For MSRs under the fair value method, the key economic assumptions used to estimate the fair value are presented below: December 31, 2018 Actual Decline in fair value due to (dollars in millions) Fair value $600 50 bps adverse change 100 bps adverse change Weighted average life (in years) 8.0 Weighted average constant prepayment rate 8.2% $68 $148 Weighted average option adjusted spread 609 bps 13 26 Citizens accounts for derivatives in its mortgage banking operations at fair value on the balance sheet as derivative assets or derivative liabilities, depending on whether the derivative had a positive (asset) or negative (liability) fair value as of the balance sheet date. The Company’s mortgage banking derivatives include commitments to originate mortgages held for sale, certain loan sale agreements, and other financial instruments that meet the definition of a derivative. Refer to Note 13 “Derivatives” for additional information.

GOODWILL AND INTANGIBLE ASSETS

GOODWILL AND INTANGIBLE ASSETS	12 Months Ended
	Dec. 31, 2018
Goodwill and Intangible Assets Disclosure [Abstract]
GOODWILL AND INTANGIBLE ASSETS	GOODWILL AND INTANGIBLE ASSETS Goodwill is the purchase premium 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. Citizens 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. Goodwill is not amortized, but is subject to annual impairment tests. The goodwill impairment analysis is a two-step test. The first step, used to identify potential impairment, involves comparing each reporting unit’s fair value to its carrying value, including goodwill. If the fair value of a reporting unit exceeds its carrying value, applicable goodwill is deemed to be not impaired. If the carrying value exceeds fair value, there is an indication of impairment and the second step is performed to measure the amount of impairment. The second step involves calculating an implied fair value of goodwill for each reporting unit for which the first step indicated impairment. The implied fair value of goodwill is determined in the same manner as the amount of goodwill recognized in a business combination, which is the excess of the fair value of the reporting unit, as determined in the first step, over the aggregate fair values of the individual assets, liabilities and identifiable intangible. If the implied fair value of goodwill exceeds the carrying value of goodwill assigned to the reporting unit, there is no impairment. If the carrying value of goodwill assigned to a reporting unit exceeds the implied fair value of the goodwill, an impairment charge is recorded for the excess. An impairment loss that is recognized cannot exceed the amount of goodwill assigned to a reporting unit, and the loss establishes a new basis in the goodwill. Subsequent reversal of goodwill impairment losses is not permitted. Citizens reviews goodwill for impairment annually as of October 31 st or more often if events or circumstances indicate that it is more likely than not that the fair value of one or more reporting units is below its carrying value. The fair values of the Company’s reporting units are determined using a combination of income and market-based approaches. Citizens relies on the income approach (discounted cash flow method) for determining fair value. Market and transaction approaches are used as benchmarks only to corroborate the value determined by the discounted cash flow method. Citizens relies on several assumptions when estimating the fair value of its reporting units using the discounted cash flow method. These assumptions include the discount rate, as well as projected loan loss, income tax and capital retention rates. Discount rates are estimated based on the Capital Asset Pricing Model, which considers the risk-free interest rate, market risk premium, beta, and size premium adjustments specific to a particular reporting unit. The discount rates are also calibrated on the assessment of the risks related to the projected cash flows of each reporting unit. Cash flow projections include estimates for projected loan loss, income tax and capital retention rates. Multi-year financial forecasts are developed for each reporting unit by considering several key business drivers such as new business initiatives, customer retention standards, market share changes, anticipated loan and deposit growth, forward interest rates, historical performance, and industry and economic trends, among other considerations. The long-term growth rate used in determining the terminal value of each reporting unit is estimated based on management’s assessment of the minimum expected terminal growth rate of each reporting unit, as well as broader economic considerations such as GDP and inflation. Citizens bases its fair value estimates on assumptions it believes to be representative of assumptions that a market participant would use in valuing the reporting unit but that are unpredictable and inherently uncertain, including estimates of future growth rates and operating margins and assumptions about the overall economic climate and the competitive environment for its reporting units. There can be no assurances that future estimates and assumptions made for purposes of goodwill testing will prove accurate predictions of the future. If the assumptions regarding business plans, competitive environments or anticipated growth rates are not achieved, Citizens may be required to record goodwill impairment charges in future periods. Since 1988, Citizens has completed more than 25 acquisitions of banks or assets of banks. In August 2018, Citizens acquired certain assets and assumed certain liabilities of FAMC, which resulted in an increase to goodwill of $36 million as of December 31, 2018 . Changes in the carrying value of goodwill for the years ended December 31, 2018 and 2017 are presented below: (in millions) Consumer Banking Commercial Banking Total Balance at December 31, 2016 $2,136 $4,740 $6,876 Business acquisition — 11 11 Balance at December 31, 2017 $2,136 $4,751 $6,887 Business acquisition 59 — 59 Adjustments (1) (23 ) — (23 ) Balance at December 31, 2018 $2,172 $4,751 $6,923 (1) Adjustments to goodwill are the result of an update to the purchase price allocation for the FAMC acquisition, given higher value attributed to purchased net assets. Accumulated impairment losses related to the Consumer Banking reporting unit totaled $5.9 billion at December 31, 2018 and 2017 . The accumulated impairment losses related to the Commercial Banking reporting unit totaled $50 million at December 31, 2018 and 2017 . No impairment was recorded for the years ended December 31, 2018 , 2017 and 2016 . 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 December 31, 2018 are $30 million in other intangibles, net of $2 million of amortization expense, related to the FAMC acquisition. December 31, 2018 December 31, 2017 (in millions) Amortizable Lives (years) Gross Accumulated Amortization Net Gross Accumulated Amortization Net Acquired technology 7 $20 $1 $19 $— $— $— Acquired relationships 5 - 15 11 1 10 2 — 2 Other 2 - 3 3 1 2 — — — Total $34 $3 $31 $2 $— $2 As of December 31, 2018 , all of the Company’s intangible assets were being amortized. Amortization expense recognized on intangible assets was $3 million for the year ended December 31, 2018 . There was no amortization expense recognized on intangible assets for the year s ended December 31, 2017 and 2016 . The Company’s projection of amortization expense is based on balances as of December 31, 2018 , and future amortization expense may vary from these projections. Estimated intangible asset amortization expense for the next five years is as follows: (in millions) Total 2019 $5 2020 5 2021 4 2022 3 2023 3

VARIABLE INTEREST ENTITIES

VARIABLE INTEREST ENTITIES	12 Months Ended
	Dec. 31, 2018
Variable Interest Entities [Abstract]
VARIABLE INTEREST ENTITIES	VARIABLE INTEREST ENTITIES Citizens makes equity investments in various entities that are considered VIEs, as defined by GAAP. A VIE typically does not have sufficient equity at risk to finance its activities without additional subordinated financial support from other parties. The Company’s variable interest arises from contractual, ownership or other monetary interests in the entity, which change with fluctuations in the fair value of the entity's net assets. Citizens consolidates a VIE if it is the primary beneficiary of the entity. Citizens is the primary beneficiary of a VIE if its variable interest provides it with the power to direct the activities that most significantly impact the VIE and the right to receive benefits (or the obligation to absorb losses) that could potentially be significant to the VIE. To determine whether or not a variable interest held could potentially be significant to the VIE, the company considers both qualitative and quantitative factors regarding the nature, size and form of its involvement with the VIE. Citizens assesses whether or not it is the primary beneficiary of a VIE on an ongoing basis. The Company’s 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: December 31, (in millions) 2018 2017 LIHTC investment included in other assets $1,236 $951 LIHTC unfunded commitments included in other liabilities 673 491 Renewable energy investments included in other assets 319 335 Lending to special purpose entities included in loans and leases 613 — 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. Citizens 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. Citizens 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: Year Ended December 31, (in millions) 2018 2017 2016 Tax credits included in income tax expense $101 $83 $59 Amortization expense included in income tax expense 110 94 59 Other tax benefits included in income tax expense 25 31 21 No LIHTC investment impairment losses were recognized during the years ended December 31, 2018 and 2017 . 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, Citizens 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, Citizens does not consolidate these VIEs and accounts for these investments in other assets on the Consolidated Balance Sheets. Lending to Special Purpose Entities Citizens 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, Citizens is not the primary beneficiary of these entities. Accordingly, Citizens does not consolidate these VIEs on the Consolidated Balance Sheets. As of December 31, 2018 , the lending facilities had aggregate unpaid principal balances of $613 million and undrawn commitments to extend credit of $584 million . Citizens did not provide these lending facilities as of December 31, 2017.

DEPOSITS

DEPOSITS	12 Months Ended
	Dec. 31, 2018
Banking and Thrift [Abstract]
DEPOSITS	DEPOSITS Interest-bearing deposits in banks are carried at cost and include deposits that mature within one year. The major components of deposits are presented below: December 31, (in millions) 2018 2017 Demand $29,458 $29,279 Checking with interest 23,067 22,229 Regular savings 12,007 9,518 Money market accounts 35,701 37,454 Term deposits 19,342 16,609 Total deposits $119,575 $115,089 The maturity distribution of term deposits as of December 31, 2018 is presented below: Year (in millions) 2019 $15,889 2020 2,519 2021 649 2022 174 2023 106 2024 and thereafter 5 Total $19,342 Of these deposits, the amount of term deposits with a denomination of $100,000 or more was $13.8 billion at December 31, 2018 . The remaining maturities of these deposits are presented below: (in millions) Three months or less $5,388 After three months through six months 2,676 After six months through twelve months 3,844 After twelve months 1,936 Total term deposits $13,844

BORROWED FUNDS

BORROWED FUNDS	12 Months Ended
	Dec. 31, 2018
Debt Disclosure [Abstract]
BORROWED FUNDS	BORROWED FUNDS A summary of the Company’s short-term borrowed funds is presented below: December 31, (in millions) 2018 2017 Federal funds purchased $820 $460 Securities sold under agreements to repurchase 336 355 Other short-term borrowed funds (1) 1,653 1,856 Total short-term borrowed funds $2,809 $2,671 (1) December 31, 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 ($8) 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 Year Ended December 31, (dollars in millions, except ratio data) 2018 2017 2016 Weighted-average interest rate at year-end: (1) Federal funds purchased and securities sold under agreements to repurchase 1.72 % 0.74 % 0.26 % Other short-term borrowed funds 2.50 1.72 0.94 Maximum amount outstanding at any month-end during the year: Federal funds purchased and securities sold under agreements to repurchase (2) $1,282 $1,174 $1,522 Other short-term borrowed funds 2,509 3,508 5,461 Average amount outstanding during the year: Federal funds purchased and securities sold under agreements to repurchase (2) $654 $776 $947 Other short-term borrowed funds 1,808 2,321 3,207 Weighted-average interest rate during the year: (1) Federal funds purchased and securities sold under agreements to repurchase 0.92 % 0.36 % 0.09 % Other short-term borrowed funds 2.42 1.32 0.64 (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: December 31, (in millions) 2018 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) (3) — 743 2.500% senior unsecured notes, due 2019 (2) (3) — 741 2.250% senior unsecured notes, due 2020 (2) 691 692 3.278% floating-rate senior unsecured notes, due 2020 (2) (4) 300 299 3.247% floating-rate senior unsecured notes, due 2020 (2) (4) 250 249 2.200% senior unsecured notes, due 2020 (2) 499 498 2.250% senior unsecured notes, due 2020 (2) 738 742 2.550% senior unsecured notes, due 2021 (2) 964 964 3.487% floating-rate senior unsecured notes, due 2022 (2) (4) 249 249 2.650% senior unsecured notes, due 2022 (2) 487 491 3.700% senior unsecured notes, due 2023 (2) 502 — 3.753% floating-rate senior unsecured notes, due 2023 (2) (4) 249 — Federal Home Loan Bank advances, 2.725% weighted average rate, due through 2038 7,508 3,761 Other 9 16 Total long-term borrowed funds $14,433 $11,765 (1) Redeemed on June 29, 2018. (2) Issued under CBNA’s Global Bank Note Program. (3) Reclassified to short-term borrowed funds. (4) Rate disclosed reflects the floating rate as of December 31, 2018. The Parent Company’s long-term borrowed funds as of December 31, 2018 and 2017 included principal balances of $2.0 billion and $2.3 billion , respectively, and unamortized deferred issuance costs and/or discounts of ($5) million for each period. The banking subsidiaries’ long-term borrowed funds as of December 31, 2018 and 2017 include principal balances of $12.5 billion and $9.5 billion , respectively, with unamortized deferred issuance costs and/or discounts of ($14) million and ($19) million , respectively, and hedging basis adjustments of ($58) million and ($63) million , respectively. See Note 13 “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 $13.0 billion and $9.4 billion at December 31, 2018 and 2017 , respectively. The Company’s available FHLB borrowing capacity was $4.8 billion and $8.0 billion at December 31, 2018 and 2017 , respectively. Citizens 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 December 31, 2018 , the Company’s unused secured borrowing capacity was approximately $36.2 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 December 31, 2018 is presented below: (in millions) Parent Company Banking Subsidiaries Consolidated Year 2019 $— $— $— 2020 — 9,982 9,982 2021 349 967 1,316 2022 348 739 1,087 2023 — 751 751 2024 and thereafter 1,290 7 1,297 Total $1,987 $12,446 $14,433

DERIVATIVES

DERIVATIVES	12 Months Ended
	Dec. 31, 2018
Derivative Instruments and Hedging Activities Disclosure [Abstract]
DERIVATIVES	DERIVATIVES In the normal course of business, Citizens 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 19 “Fair Value Measurements.” Derivative assets and derivative liabilities are netted by counterparty on the balance sheet if a “right of setoff” has been established in a master netting agreement between the Company and the counterparty. This netted derivative asset or liability position is also netted against the fair value of any cash collateral that has been pledged or received in accordance with a Credit Support Annex. The following table presents derivative instruments included on the Consolidated Balance Sheets in derivative assets and derivative liabilities: December 31, 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 $12,050 $5 $— $13,300 $— $— Derivatives not designated as hedging instruments: Interest rate contracts 117,076 301 277 80,180 538 379 Foreign exchange contracts 9,866 129 113 9,882 148 149 Other contracts 3,555 14 25 1,039 7 5 Total derivatives not designated as hedging instruments 444 415 693 533 Gross derivative fair values 449 415 693 533 Less: Gross amounts offset in the Consolidated Balance Sheets (2) (87 ) (87 ) (72 ) (72 ) Less: Cash collateral applied (2) (45 ) (36 ) (4 ) (151 ) Total net derivative fair values presented in the Consolidated Balance Sheets $317 $292 $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 as well as collateral paid and received. The Company’s derivative transactions are internally divided into three sub-groups: institutional, customer and residential loan. Institutional derivatives The institutional derivatives portfolio primarily consists of interest rate swap agreements that are used to hedge the interest rate risk associated with the Company’s loans and financing liabilities (i.e., borrowed funds, deposits, etc.). Citizens enters into certain interest rate swap agreements to hedge the risk associated with floating rate loans. By entering into receive-fixed/pay-floating interest rate swaps, the Company is able to minimize the variability in the cash flows of these assets due to changes in interest rates. Citizens also uses receive-fixed/pay-floating interest rate swaps to manage the interest rate exposure on its medium term borrowings by effectively converting a portion of the fixed rate debt to floating. Citizens has outstanding interest rate swap agreements designed to hedge a portion of the Company’s borrowed funds and deposit liabilities. By entering into a pay-fixed/receive-floating interest rate swap, a portion of these liabilities has been effectively converted to a fixed rate liability for the term of the interest rate swap agreement. The goal of the Company’s interest rate hedging activity is to manage interest rate sensitivity so that movements in interest rates do not significantly adversely affect net interest income. For derivatives designated for hedging purposes, net interest accruals are treated as an adjustment of interest income or interest expense of the item being hedged. Customer derivatives The customer derivatives portfolio consists of interest rate swap agreements and option contracts that are transacted to meet the financing needs of the Company’s customers. Swap agreements and interest rate option agreements are transacted to effectively minimize the Company’s market risk associated with the customer derivative products. The customer derivatives portfolio also includes foreign exchange contracts that are entered into on behalf of customers for the purpose of hedging exposure related to cash orders and loans and deposits denominated in foreign currencies. The primary risks associated with these transactions arise from exposure to changes in foreign currency exchange rates and the ability of the counterparties to meet the terms of the contract. To manage this market risk, Citizens enters into offsetting foreign exchange contracts. Residential loan derivatives Citizens enters into residential loan commitments that allow residential mortgage customers to lock in the interest rate on a residential mortgage while the loan undergoes the underwriting process. Citizens also uses forward sales contracts to protect the value of residential mortgage loans and loan commitments that are being underwritten for future sale to investors in the secondary market. Citizens also hedges the fair market value movements of certain mortgage servicing rights using various interest rate derivative contracts. Citizens 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. Citizens formally documents at inception all hedging relationships, as well as risk management objectives and strategies for undertaking various accounting hedges. Additionally, Citizens 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 If a derivative is designated as a fair value hedge, gains or losses attributable to the change in fair value of the derivative instrument, as well as the gains and losses attributable to the change in fair value of the hedged item, are recognized in other income in the period in which the change in fair value occurs. Hedge ineffectiveness is recognized as other income to the extent the changes in fair value of the derivative do not offset the changes in fair value of the hedged item. Changes in the fair value of derivatives that do not qualify as hedges are recognized immediately in other income. Citizens has entered into 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, specifically hedges of interest rate risk on borrowings using interest rate swaps, described above, in millions: Amounts Recognized in Other Income for the Year Ended December 31, 2018 2017 2016 Derivative Hedged Item Hedge Ineffectiveness Derivative Hedged Item Hedge Ineffectiveness Derivative Hedged Item Hedge Ineffectiveness $8 ($9 ) ($1 ) ($26 ) $27 $1 ($6 ) $5 ($1 ) Cash flow hedges Citizens 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 $15 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 Year Ended December 31, (in millions) 2018 2017 2016 Effective portion of loss recognized in OCI (1) ($44 ) ($23 ) ($100 ) Amount of net (loss) gain reclassified from OCI to interest income (2) (55 ) 25 90 Amount of net gain (loss) reclassified from OCI to interest expense (2) 12 — (27 ) Amounts reclassified from OCI to other income (3) — — (5 ) (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. (3) This includes gains and losses attributable to previously hedged cash flows where the likelihood occurrence of those cash flows is no longer probable. 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. Citizens also purchases interest rate floors primarily to hedge the exposure related to customer deposit products that have embedded minimum interest rate guarantees. Citizens 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. Citizens 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: Affected Line Item in the Consolidated Statements of Operations Amounts Recognized in Noninterest Income for the Year Ended December 31, (in millions) 2018 2017 2016 Economic Hedge Type Customer interest rate contracts Foreign exchange and interest rate products $5 $5 ($23 ) Customer foreign exchange contracts Foreign exchange and interest rate products (54 ) 172 (81 ) Derivatives transactions to hedge interest rate risk Foreign exchange and interest rate products 43 46 70 Derivatives transactions to hedge foreign exchange risk Foreign exchange and interest rate products 158 (151 ) 95 Residential loan commitments Mortgage banking fees (3 ) 2 (2 ) Forward sale contracts Mortgage banking fees 21 (8 ) 6 Interest rate derivative contracts used to hedge residential MSRs Mortgage banking fees 35 — — Total $205 $66 $65

EMPLOYEE BENEFITS

EMPLOYEE BENEFITS	12 Months Ended
	Dec. 31, 2018
Retirement Benefits [Abstract]
EMPLOYEE BENEFITS	EMPLOYEE BENEFITS Pension Plans Citizens maintains a non-contributory pension plan (the “Plan” or “qualified plan”) that was closed to new hires and re-hires effective January 1, 2009, and frozen to all participants effective December 31, 2012. Benefits under the Plan are based on employees’ years of service and highest five -year average of eligible compensation. The Plan is funded on a current basis, in compliance with the requirements of ERISA. Citizens also provides an unfunded, non-qualified supplemental retirement plan (the “non-qualified plan”), which was closed and frozen effective December 31, 2012. The qualified plan’s allocation by asset category is presented below: Target Asset Allocation Actual Asset Allocation Asset Category 2018 2018 2017 Equity securities 53% 51.3 % 54.0 % Debt securities 46% 47.6 % 45.0 % Other 1% 1.1 % 1.0 % Total 100.0 % 100.0 % The written Pension Plan Investment Policy, set forth by the CFG Retirement Committee, formulates investment principles and guidelines that are appropriate for the needs and objectives of the Plan, and defines the management, structure, and monitoring procedures adopted for the ongoing operation of the aggregate funds of the Plan. Stated goals and objectives are: • Achieve a total return, consistent with prudent investment management, that together with any new contributions from the Employer, will be sufficient to meet the benefits which the Plan seeks to provide. • The nominal return target for the overall Plan is to meet or exceed the Plan’s Policy Index; • Total portfolio risk exposure should generally rank in the mid-range of comparable funds. Risk-adjusted returns are expected to consistently rank in the top-half of comparable funds; and • Investment managers shall meet or exceed the return of the designated benchmark index and rank in the top-half of the appropriate asset class and style universe. The CFG Retirement Committee reviews, at least annually, the assets and net cash flow of the Plan, discusses the current economic outlook and the Plan’s investment strategy with the investment managers, reviews the current asset mix and its compliance with the Policy, and receives and considers statistics on the investment performance of the Plan and its managers. The equity investment mandates follow a global equity approach. Investments are made in broadly diversified portfolios that contain investments in U.S. and non-U.S. developed and developing economies. The fixed income investment mandates are US investment grade mandates and follow a long duration investment approach. Investment in high-yield bonds are not allowed unless an investment grade bond is downgraded to a non-investment grade category. The assets of the qualified plan may be invested in any or all of the following asset categories: • Equity-oriented investments: ◦ domestic and foreign common and preferred stocks, and related rights, warrants, convertible debentures, and other common share equivalents • Fixed income-oriented investments: ◦ domestic and foreign bonds, debentures and notes ◦ mortgages ◦ mortgage-backed securities ◦ asset-backed securities ◦ bank loans ◦ money market securities or cash ◦ financial futures and options on financial futures ◦ forward contracts In addition, derivatives may be employed under the guidelines established for individual managers in order to manage risk exposures and/or to increase the efficiency of strategies. The extent to which derivatives are utilized will be specified in the investment guidelines for each manager. The Plan will not be exposed to losses through derivatives that exceed the capital invested. In selecting the expected long-term rate of return on assets, the Company considers the average rate of earnings expected on the funds invested or to be invested to provide for the benefits of this Plan. This includes considering the trust’s asset allocation and the expected returns likely to be earned over the life of the Plan. This basis is consistent with the prior year. Changes in the fair value of defined benefit pension plan assets, projected benefit obligation, funded status, and accumulated benefit obligation are presented below: Year Ended December 31, Qualified Plan Non-Qualified Plan (in millions) 2018 2017 2018 2017 Fair value of plan assets as of January 1 $1,139 $1,015 $— $— Actual return on plan assets (81 ) 185 — — Employer contributions 50 — 8 8 Benefits and administrative expenses paid (58 ) (61 ) (8 ) (8 ) Fair value of plan assets as of December 31 1,050 1,139 — — Projected benefit obligation 972 1,089 95 106 Pension asset (obligation) $78 $50 ($95 ) ($106 ) Accumulated benefit obligation $972 $1,089 $95 $106 The defined benefit obligation experienced gains for the year ending December 31, 2018 due to the increase in the discount rate assumption and due to the change in future mortality improvement projection scale to Scale MP-2018 from Scale MP-2017. Citizens recognized actuarial gains and losses (for the qualified and non-qualified plans) in AOCI resulting in an ending balance of $618 million and $585 million at December 31, 2018 and 2017 , respectively. Other changes in plan assets and benefit obligations recognized in OCI (for the qualified, non-qualified and postretirement plans) are presented below: Year Ended December 31, (in millions) 2018 2017 2016 Net periodic pension income ($16 ) ($2 ) ($1 ) Net actuarial loss (gain) 49 (31 ) 54 Amortization of prior service credit 1 1 1 Amortization of net actuarial loss (17 ) (18 ) (16 ) Total recognized in other comprehensive income (loss) 33 (48 ) 39 Total recognized in net periodic pension cost and other comprehensive income (loss) $17 ($50 ) $38 Pension costs under defined benefit plans are actuarially computed and include current service costs and amortization of prior service costs over the participants’ average future working lifetime. The actuarial cost method used in determining the net periodic pension cost is the projected unit method. The components of net periodic pension (income) cost for the Company’s qualified and non-qualified plans are presented below: Year Ended December 31, Qualified Plan Non-Qualified Plan Total (in millions) 2018 2017 2016 2018 2017 2016 2018 2017 2016 Service cost $3 $3 $3 $— $— $— $3 $3 $3 Interest cost 39 42 44 4 4 4 43 46 48 Expected return on plan assets (79 ) (69 ) (68 ) — — — (79 ) (69 ) (68 ) Amortization of actuarial loss 15 16 14 2 2 2 17 18 16 Net periodic pension (income) cost (1) ($22 ) ($8 ) ($7 ) $6 $6 $6 ($16 ) ($2 ) ($1 ) (1) In the Consolidated Statements of Operations, service cost is presented in salaries and employee benefits, and all other components of net periodic pension (income) costs are presented in other operating expense. Weighted-average rates assumed in determining the actuarial present value of benefit obligations and net periodic benefit cost are presented below: As of and for the Year Ended December 31, 2018 2017 2016 Assumptions for benefit obligations Discount rate-qualified plan 4.330 % 3.670 % 4.190 % Discount rate-non-qualified plan 4.240 % 3.530 % 4.050 % Expected long-term rate of return on plan assets 7.000 % 7.000 % 7.500 % Assumptions for net periodic pension cost Discount rate-qualified plan 3.670 % 4.190 % 4.640 % Discount rate-non-qualified plan 3.530 % 4.050 % 4.540 % Expected long-term rate of return on plan assets 7.000 % 7.000 % 7.500 % On September 12, 2018, Citizens made a contribution of $50 million to the qualified plan. No contribution was made to the qualified plan in 2017. Citizens expects to contribute approximately $9 million to the non-qualified plan in 2019. No contribution to the qualified plan is planned in 2019. Expected future benefit payments for the qualified and non-qualified plans are presented below: (in millions) Expected benefit payments by fiscal year ending: December 31, 2019 $64 December 31, 2020 64 December 31, 2021 65 December 31, 2022 66 December 31, 2023 67 December 31, 2024 - 2028 340 Fair Value Measurements The following valuation techniques are used to measure the qualified pension plan assets at fair value: Cash and money market funds and U.S government obligations: Cash and money market funds represent instruments that generally mature in one year or less and are valued at cost, which approximates fair value. U.S. government obligations are valued at quoted prices in active markets for identical assets. These investments are classified as Level 1. Non-U.S government obligations, municipal obligations, corporate bonds, bank loans, and asset-backed securities: Non-U.S. government obligations, municipal obligations, corporate bonds, bank loans, and asset-backed securities are valued at the quoted market prices determined in the active markets in which the securities are traded. If quoted market prices are not available, the fair value for the security is estimated by using pricing models, quoted prices of securities with similar characteristics or discounted cash flows. These investments are classified as Level 2, because they currently trade in active markets for similar securities and the inputs to the valuations are observable. The following table presents qualified pension plan assets measured at fair value within the fair value hierarchy: Fair Value Measurements as of December 31, 2018 (in millions) Total Level 1 Level 2 Level 3 Assets: Cash and money market funds $12 $12 $— $— Managed portfolio assets: U.S. government obligations 5 5 — — Non-U.S. government obligations 1 — 1 — Municipal obligations 1 — 1 — Corporate bonds 99 — 99 — Bank loans 1 — 1 — Total assets in the fair value hierarchy 119 17 102 — Investments measured at net asset value (1) 931 Assets at fair value at measurement date of December 31, 2018 $1,050 $17 $102 $— (1) Certain investments that were measured at net asset value per share (or its equivalent) have not been classified in the fair value hierarchy. The following table presents qualified pension plan assets measured at fair value within the fair value hierarchy: Fair Value Measurements as of December 31, 2017 (in millions) Total Level 1 Level 2 Level 3 Assets: Managed portfolio assets U.S. government obligations $8 $— $8 $— Non-U.S. government obligations 2 — 2 — Municipal obligations 1 — 1 — Corporate bonds 102 — 102 — Asset-backed securities 1 — 1 — Total assets in the fair value hierarchy 114 — 114 — Investments measured at net asset value (1) 1,024 Assets at fair value at measurement date of December 31, 2017 $1,138 $— $114 $— (1) Certain investments that were measured at net asset value per share (or its equivalent) have not been classified in the fair value hierarchy. There were no transfers among Levels 2 or 3 during the years ended December 31, 2018 and 2017 . The fair values of participation units held in the common and collective funds and limited partnerships are based on NAV. The following table presents the unfunded commitments, redemption frequency and redemption notice period for Plan investments that utilize net asset value to determine fair value: Fair Value Estimated Using Net Asset Value per Share December 31, Unfunded Redemption Redemption Redemption Investment (dollars in millions) 2018 2017 Commitment Frequency Restrictions Notice Period Liquid Cash Fund $— $11 $— Daily None Same day before 5:30pm ET Common and Collective Funds: Global equities funds 399 472 — Daily None 3 days Balanced funds 221 214 — Daily None 2 days Fixed income fund 139 150 — Daily None 3 days Managed Portfolio - Fixed Income Mutual Fund (1) 32 35 — Daily None 1 days Limited Partnerships: Global equity fund 140 142 — Monthly None 3 days Total $931 $1,024 $— (1) The managed portfolio fixed income mutual fund seeks to outperform the Barclay’s U.S. Long Credit Index or similar benchmark. Postretirement Benefits Citizens provides health care insurance benefits to eligible retirees and their spouses, domestic partners and eligible dependents through age 65, at which time Medicare becomes the primary coverage provider. Employees enrolled in medical coverage immediately prior to retirement and meeting eligibility requirements can elect retiree medical coverage. Coverage must be elected at the time of retirement and cannot be elected at a future date. Spouses, domestic partners and eligible dependents may be covered only if covered at the time of the employee’s retirement. Citizens reviews coverage on an annual basis and reserves the right to modify or cancel coverage at any renewal date. Effective July 1, 2014, the Company utilizes a private health care exchange to provide medical and dental benefits to current and future Medicare-eligible plan participants. Citizens provides a fixed subsidy to a small, closed group of eligible participants based on the subsidy levels prior to July 1, 2014; eligible participants pay the cost of benefits in excess of the fixed subsidy. The cost of postretirement benefits other than pensions is recognized on an accrual basis during the periods employees provide services to earn those benefits. Expected future benefit payments for the postretirement benefit plan are presented below: (in millions) Expected benefit payments by fiscal year ending: December 31, 2019 $1 December 31, 2020 1 December 31, 2021 1 December 31, 2022 1 December 31, 2023 1 December 31, 2024 - 2028 5 Citizens expects to contribute approximately $1 million to the postretirement benefit plan during 2019 . The discount rate assumed in determining the actuarial present value of benefit obligations was 3.98% as of December 31, 2018 compared with 3.20% as of December 31, 2017 . For measurement purposes, the assumed annual rate of increase in the per capita cost of covered health care benefits was 6.5% in December 31, 2018 and is expected to decrease gradually to 5.0% by 2025. On December 31, 2017 the assumed annual rate of increase in the per capita cost of covered health care benefits was 7.0% and was expected to decrease gradually to 5.0% by 2022. Weighted-average rates assumed in determining the net periodic benefit cost of the postretirement benefits plan are as follows: For the Year Ended December 31, (dollars in millions) 2018 2017 Discount rate 3.200 % 3.530 % Rate of compensation increase N/A N/A 401(k) Plan Citizens sponsors a 401(k) plan under which employee tax-deferred/Roth after-tax contributions to the plan are matched by the Company after completion of one year of service. Effective January 1, 2015, contributions were matched at 100% up to an overall limitation of 4% on a pay period basis. Substantially all employees will receive an additional 2% of earnings after completion of one year of service, subject to limits set by the Internal Revenue Service. Amounts contributed and expensed by the Company were $68 million in 2018 compared to $61 million in 2017 and $55 million in 2016 .

RECLASSIFICATIONS OUT OF ACCUMU

RECLASSIFICATIONS OUT OF ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS)	12 Months Ended
	Dec. 31, 2018
Equity [Abstract]
RECLASSIFICATIONS OUT OF ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS)	RECLASSIFICATIONS OUT OF ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS) The following table presents the changes in the balances, net of income taxes, of each component of AOCI: (in millions) Net Unrealized (Losses) Gains on Derivatives Net Unrealized (Losses) Gains on Securities Employee Benefit Plans Total AOCI Balance at January 1, 2016 $10 ($28 ) ($369 ) ($387 ) Other comprehensive loss before reclassifications (62 ) (139 ) — (201 ) Other-than-temporary impairment not recognized in earnings on debt securities — (17 ) — (17 ) Amounts reclassified to the Consolidated Statements of Operations (36 ) (2 ) (25 ) (63 ) Net other comprehensive loss (98 ) (158 ) (25 ) (281 ) Balance at December 31, 2016 ($88 ) ($186 ) ($394 ) ($668 ) Other comprehensive loss before reclassifications (14 ) (6 ) — (20 ) Amounts reclassified to the Consolidated Statements of Operations (16 ) (2 ) 31 13 Net other comprehensive loss (30 ) (8 ) 31 (7 ) Reclassification of tax effects resulting from the 2017 Tax Legislation (1) ($25 ) ($42 ) ($78 ) ($145 ) Balance at December 31, 2017 ($143 ) ($236 ) ($441 ) ($820 ) Other comprehensive loss before reclassifications (33 ) (239 ) — (272 ) Other-than-temporary impairment not recognized in earnings on debt securities — (3 ) — (3 ) Amounts reclassified to the Consolidated Statements of Operations 33 (12 ) (22 ) (1 ) Net other comprehensive loss — (254 ) (22 ) (276 ) Balance at December 31, 2018 ($143 ) ($490 ) ($463 ) ($1,096 ) (1) As of December 31, 2017, the balance of AOCI reflects the retrospective adoption of FASB ASU 2018-02, Income Statement-Reporting Comprehensive Income (Topic 220): Reclassification of Certain Tax Effects from Accumulated Other Comprehensive Income . For further discussion, see Note 22 “Income Taxes.” The following table presents the amounts reclassified out of each component of AOCI and into the Consolidated Statements of Operations: Year Ended December 31, (in millions) 2018 2017 2016 Details about AOCI Components Affected Line Item in the Consolidated Statements of Operations Reclassification adjustment for net derivative (losses) gains included in net income: ($55 ) $25 $90 Interest income 12 — (27 ) Interest expense — — (5 ) Other income (43 ) 25 58 Income before income tax expense (10 ) 9 22 Income tax expense ($33 ) $16 $36 Net income Reclassification of net securities gains (losses) to net income: $19 $11 $16 Securities gains, net (3 ) (7 ) (12 ) Net debt securities impairment losses recognized in earnings 16 4 4 Income before income tax expense 4 2 2 Income tax expense $12 $2 $2 Net income Reclassification of changes related to the employee benefit plan: $33 ($48 ) $39 Salaries and employee benefits 33 (48 ) 39 Income before income tax expense 11 (17 ) 14 Income tax expense $22 ($31 ) $25 Net income Total reclassification gains (losses) $1 ($13 ) $63 Net income The following table presents the effects on net income of the amounts reclassified out of AOCI: Year Ended December 31, (in millions) 2018 2017 2016 Net interest income (includes ($43), $25 and $63 of AOCI reclassifications, respectively) $4,532 $4,173 $3,758 Provision for credit losses 326 321 369 Noninterest income (includes $16, $4 and ($1) of AOCI reclassifications, respectively) 1,596 1,534 1,497 Noninterest expense (includes ($33), $48 and ($39) of AOCI reclassifications, respectively) 3,619 3,474 3,352 Income before income tax expense 2,183 1,912 1,534 Income tax expense (includes $5, ($6) and $38 income tax net expense from reclassification items, respectively) 462 260 489 Net income $1,721 $1,652 $1,045

STOCKHOLDERS' EQUITY

STOCKHOLDERS' EQUITY	12 Months Ended
	Dec. 31, 2018
Equity [Abstract]
STOCKHOLDERS' EQUITY	STOCKHOLDERS’ EQUITY Preferred Stock The following table provides the number of authorized preferred shares, the number of issued and outstanding, the liquidation value per share and the carrying amount as of December 31: 2018 2017 (in millions, except per share and share data) Liquidation value per share Preferred Shares Carrying Amount Preferred Shares Carrying Amount Authorized ($25 par value) 100,000,000 100,000,000 Issued and outstanding Series A $1,000 250,000 $247 250,000 $247 Series B 1,000 300,000 296 — — Series C 1,000 300,000 297 — — Total issued and outstanding 850,000 $840 250,000 $247 The following table provides information related to the Company’s preferred stock outstanding as of December 31, 2018: (in millions, except per share and share data) Preferred Stock (1) Issue Date Number of Shares Issued Dividend Dates (2) Annual Per Share Dividend Rate Optional Redemption Date (3) Series A April 6, 2015 250,000 Semi-annually beginning October 6, 2015 until April 6, 2020 5.500% until April 6, 2020 April 6, 2020 Quarterly beginning July 6, 2020 3 Mo. LIBOR plus 3.960% beginning April 6, 2020 Series B May 24, 2018 300,000 Semi-annually beginning January 6, 2019 until July 6, 2023 6.000% until July 6, 2023 July 6, 2023 Quarterly beginning October 6, 2023 3 Mo. LIBOR plus 3.003% beginning July 6, 2023 Series C October 25, 2018 300,000 Quarterly beginning January 6, 2019 until April 6, 2024 6.375% until April 6, 2024 April 6, 2024 Quarterly beginning July 6, 2024 3 Mo. LIBOR plus 3.157% beginning April 6, 2024 (1) All outstanding series are non-cumulative fixed-to-floating rate perpetual preferred stock. Except in limited circumstances, the preferred stock does not have voting rights. (2) Dividends are payable when, and if, declared by the Company’s Board of Directors or an authorized committee thereof. (3) Redeemable at the Company’s option, in whole or in part, on any dividend payment date on or after the date stated, or in whole but not in part, at any time within 90 days following a regulatory capital treatment event a as defined in the applicable certificate of designations, in each case at a redemption price equal to $1,000 per share, plus any declared and unpaid dividends, without accumulation of any undeclared dividends. Under current rules, any redemption is subject to approval by the FRB. On January 29, 2019, the Company issued $300 million , or 12,000,000 depositary shares, each representing a 1/40th interest in a share of its 6.350% fixed-to-floating rate non-cumulative perpetual Series D Preferred Stock, liquidation preference of $1,000 per share (equivalent to $25 per depositary share) (the “Series D Preferred Stock”). The Company received net proceeds of $293 million after the underwriting discount and other expenses. The Series D 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 6.350% 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 3.642% , payable quarterly, in arrears, beginning July 6, 2024. The Series D 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 (equivalent to $25 per depositary share), plus any declared and unpaid dividends. The Company may not redeem shares of the Series D Preferred Stock without obtaining the prior approval of the FRB if then required under applicable capital guidelines. Except in certain limited circumstances, the Series D Preferred Stock does not have any voting rights. Dividends The following table provides information related to dividends per share and in the aggregate, declared and paid, for each type of stock issued and outstanding for the year ended December 31: 2018 2017 2016 (in millions, except per share and share data) Dividends per Share Dividends Declared Dividends Paid Dividends per Share Dividends Declared Dividends Paid Dividends per Share Dividends Declared Dividends Paid Common stock $0.98 $471 $471 $0.64 $322 $322 $0.46 $241 $241 Preferred stock Series A $55.00 $14 $14 $55.00 $14 $14 $55.00 $14 $14 Series B 37.00 11 — — — — — — — Series C 12.57 4 — — — — — — — Total preferred stock $29 $14 $14 $14 $14 $14 Treasury Stock The purchase of the Company’s common stock is recorded at cost. At the date of retirement or subsequent reissuance, treasury stock is reduced by the cost of such stock on a first-in, first-out basis with differences recorded in additional paid-in capital or retained earnings, as applicable. During the year ended December 31, 2018 , the Company paid $1.025 billion to repurchase 25,773,807 common shares at a weighted-average price of $39.77 ; $1.025 billion was recorded in treasury stock. The repurchased shares are held in treasury stock. During the year ended December 31, 2018, the Company recorded no shares of treasury stock associated with share-based compensation plan activity. During the year ended December 31, 2017 , the Company paid $820 million to repurchase 22,362,401 common shares at an average price of $36.67 ; $845 million was recorded in treasury stock and $25 million was recorded in additional paid in capital. The repurchased shares are held in treasury stock. During the year ended December 31, 2017, the Company recorded no shares of treasury stock associated with share-based compensation plan activity.

SHARE-BASED COMPENSATION

SHARE-BASED COMPENSATION	12 Months Ended
	Dec. 31, 2018
Disclosure of Compensation Related Costs, Share-based Payments [Abstract]
SHARE-BASED COMPENSATION	SHARE-BASED COMPENSATION Citizens has share-based employee compensation plans as outlined below, pursuant to which stock awards are granted to employees and non-employee directors. Employees of the Company hold time-based restricted stock units and performance-based restricted stock units. A restricted stock unit is the right to receive shares of stock on a future date, which may be subject to time-based vesting conditions and/or performance-based vesting conditions. If a dividend is paid on shares underlying the awards prior to the date such shares are distributed, those dividends will be distributed following vesting in the same form as the dividend that has been paid to common stockholders generally. Citizens Financial Group, Inc. 2014 Omnibus Incentive Plan. Certain employees of the Company hold time-based restricted stock units and performance-based restricted stock units granted under this plan. Time-based restricted stock units granted generally become vested ratably over a three -year period and performance-based restricted stock units granted generally become vested at the end of a three -year performance period, depending on the level of performance achieved during such period. Citizens Financial Group, Inc. 2014 Non-Employee Directors Compensation Plan. Non-employee directors receive grants of time-based restricted stock units under this plan as compensation for their services pursuant to the Citizens Financial Group, Inc. Directors Compensation Policy. Restricted stock units granted to directors are fully vested on the grant date, with settlement of the awards deferred until a director’s cessation of service. Citizens Financial Group, Inc. 2014 Employee Stock Purchase Plan. Citizens also maintains the Citizens Financial Group, Inc. Employee Stock Purchase Plan (the “ESPP”), which provides eligible employees an opportunity to purchase its common stock at a 10% discount, through accumulated payroll deductions. Eligible employees may contribute up to 10% of eligible compensation to the ESPP, up to a maximum purchase of $25,000 worth of stock in any calendar year. Offering periods under the ESPP are quarterly. Shares of CFG common stock are purchased for a participant on the last day of each quarter at a 10% discount from the fair market value (fair market value under the plan is defined as the closing price on the day of purchase). Prior to the date the shares are purchased, participants do not have any rights or privileges as a stockholder with respect to shares to be purchased at the end of the offering period. Summary of Share-Based Plans Activity The following table presents the activity related to the Company’s share-based plans (excluding the ESPP) for the year ended December 31, 2018 : Shares Weighted-Average Grant Price Outstanding, January 1 2,621,514 $33.30 Granted 1,174,501 39.54 Vested & Distributed (877,111 ) 30.50 Forfeited (25,623 ) 35.88 Outstanding, December 31 2,893,281 $34.04 During the years ended December 31, 2018, 2017 and 2016, the following number of CFG share awards were granted: 2018: ( 1,174,501 granted with a weighted-average grant price of $39.54 ); 2017 ( 1,256,816 granted with weighted-average grant price of $39.09 ); and 2016 ( 1,552,416 granted with weighted-average grant price of $24.53 ). In addition, the following number of CFG share awards became vested and distributed: 2018 ( 877,111 vested and distributed with a weighted-average grant price of $30.50 ); 2017 ( 1,426,850 vested with weighted-average grant price of $21.91 ); and 2016 ( 1,762,655 vested with weighted-average grant price of $22.14 ). There are 49,742,766 shares of Company common stock available for awards to be granted under the Omnibus Plan and Directors Plan. In addition, there are 6,255,128 shares available for awards under the ESPP. Upon settlement of share-based awards, the Company generally issues new shares, but may also issue shares from treasury stock. Compensation Expense Citizens measures compensation expense related to stock awards based upon the fair value of the awards on the grant date. Compensation expense is adjusted for forfeitures as they occur. The related expense is charged to earnings on a straight-line basis over the requisite service period (e.g., vesting period) of the award. With respect to performance-based stock awards, compensation expense is adjusted upward or downward based upon the probability of achievement of performance. Awards that continue to vest after retirement are expensed over the shorter of the period of time from grant date to the final vesting date or from the grant date to the date when an employee is retirement eligible. Awards granted to employees who are retirement eligible at the grant date are generally expensed immediately upon grant. Compensation expense related to the share plans (including the ESPP) was $41 million , $39 million , and $23 million for the years ended December 31, 2018 , 2017 , and 2016 , respectively. At December 31, 2018 , the total unrecognized compensation expense for nonvested equity awards granted was $41 million . This expense is expected to be recognized over a weighted-average period of two years . No share-based compensation costs were capitalized during the years ended December 31, 2018 , 2017 , and 2016 . The income tax benefit recognized in earnings based on the compensation expense recognized for all share-based compensation arrangements amounted to $3 million , $9 million and $8 million for the years ended December 31, 2018 , 2017 , and 2016 , respectively.

COMMITMENTS AND CONTINGENCIES

COMMITMENTS AND CONTINGENCIES	12 Months Ended
	Dec. 31, 2018
Commitments and Contingencies Disclosure [Abstract]
COMMITMENTS AND CONTINGENCIES	COMMITMENTS AND CONTINGENCIES A summary of outstanding off-balance sheet arrangements is presented below: December 31, (in millions) 2018 2017 Undrawn commitments to extend credit $69,553 $62,959 Letters of credit 2,125 2,136 Marketing rights 37 41 Risk participation agreements 19 16 Residential mortgage loans sold with recourse 5 7 Total $71,739 $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 Letters of credit in the table above reflect commercial, standby financial and standby performance 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. Citizens 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 $3 million at December 31, 2018 and 2017 . Marketing Rights During 2003, Citizens entered into a 25 -year agreement to acquire the naming and marketing rights of a baseball stadium in Pennsylvania. The Company paid $4 million and $3 million for the years ended December 31, 2018 and 2017 , respectively, and 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 December 31, 2018 and 2017 is $19 million and $16 million , respectively. The current amount of credit exposure is spread out over 84 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 Citizens 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 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 $68 million and $161 million , respectively, at December 31, 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 19 “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 Consolidated Financial Statements.

FAIR VALUE MEASUREMENTS

FAIR VALUE MEASUREMENTS	12 Months Ended
	Dec. 31, 2018
Fair Value Disclosures [Abstract]
FAIR VALUE MEASUREMENTS	FAIR VALUE MEASUREMENTS Citizens 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. Citizens 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. Fair Value Option Citizens 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. 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 $6 million , $6 million , and ($5) million for the years ended December 31, 2018 , 2017 and 2016 , 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, Citizens 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 December 31, 2018 . 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 18 “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. Citizens recognized ($2) million , $4 million and $4 million for the years ended December 31, 2018 , 2017 and 2016 , respectively, in other noninterest income related to its commercial trading portfolio. 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: December 31, 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 $967 $967 $— $326 $326 $— Commercial and commercial real estate loans held for sale, at fair value 252 252 — 171 171 — Recurring Fair Value Measurements Citizens measures fair value using the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. Fair value is based upon quoted market prices in an active market, where available. If quoted prices are not available, observable market-based inputs or independently sourced parameters are used to develop fair value, whenever possible. Such inputs may include prices of similar assets or liabilities, yield curves, interest rates, prepayment speeds, and foreign exchange rates. A portion of the Company’s assets and liabilities is carried at fair value, including securities available for sale, derivative instruments and other investment securities. In addition, the Company elects to account for its loans associated with its mortgage banking business and secondary loan trading desk at fair value. Citizens classifies its assets and liabilities that are carried at fair value in accordance with the three-level valuation hierarchy: • Level 1. Quoted prices (unadjusted) in active markets for identical assets or liabilities. • Level 2. Observable inputs other than Level 1 prices, such as quoted prices for similar instruments, quoted prices in markets that are not active, or other inputs that are observable or can be corroborated by market data for substantially the full term of the asset or liability. • Level 3. Unobservable inputs that are supported by little or no market information and that are significant to the fair value measurement. Classification in the hierarchy is based upon the lowest level input that is significant to the fair value measurement of the asset or liability. For instruments classified in Levels 1 and 2 where inputs are primarily based upon observable market data, there is less judgment applied in arriving at the fair value. For instruments classified in Level 3, management judgment is more significant due to the lack of observable market data. Citizens reviews and updates the fair value hierarchy classifications on a quarterly basis. Changes from one quarter to the next related to the observability of inputs in fair value measurements may result in a reclassification between the fair value hierarchy levels and are recognized based on period-end balances. Citizens 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. Citizens 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 8 “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. Citizens 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. Citizens 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 December 31, 2018 : (in millions) Total Level 1 Level 2 Level 3 Debt securities available for sale: Mortgage-backed securities $19,866 $— $19,866 $— State and political subdivisions 5 — 5 — U.S. Treasury and other 24 24 — — Total debt securities available for sale 19,895 24 19,871 — Loans held for sale, at fair value: Residential loans held for sale 967 — 967 — Commercial loans held for sale 252 — 252 — Total loans held for sale, at fair value 1,219 — 1,219 — Mortgage servicing rights 600 — — 600 Derivative assets Interest rate contracts 306 — 306 — Foreign exchange contracts 129 — 129 — Other contracts 14 — 14 — Total derivative assets 449 — 449 — Equity securities, at fair value: Money market mutual fund investments 181 181 — — Other investments — — — — Total equity securities, at fair value 181 181 — — Total assets $22,344 $205 $21,539 $600 Derivative liabilities Interest rate contracts $277 $— $277 $— Foreign exchange contracts 113 — 113 — Other contracts 25 — 25 — Total derivative liabilities 415 — 415 — Total liabilities $415 $— $415 $— 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 table 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 year ended December 31, 2018. There were no assets measured at fair value on a recurring basis and classified as Level 3 for the year ended December 31, 2017. For the Year Ended December 31, (in millions) Mortgage Servicing Rights Balance at January 1, 2018 $— Acquired MSRs 590 Amount capitalized 73 Change in unpaid principal balance during the period (1) (32 ) Change in fair value during the period (2) (31 ) Balance at December 31, 2018 $600 (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 8 “Mortgage Banking” for more information. 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: Year Ended December 31, (in millions) 2018 2017 2016 Impaired collateral-dependent loans ($13 ) ($35 ) ($33 ) MSRs 3 (2 ) (4 ) Foreclosed assets (2 ) (3 ) (3 ) Leased assets (7 ) (15 ) 11 The following table presents assets and liabilities measured at fair value on a nonrecurring basis: December 31, 2018 December 31, 2017 (in millions) Total Level 1 Level 2 Level 3 Total Level 1 Level 2 Level 3 Impaired collateral-dependent loans $338 $— $338 $— $393 $— $393 $— MSRs 243 — — 243 218 — — 218 Foreclosed assets 29 — 29 — 31 — 31 — Leased assets 92 — 92 — 112 — 112 — Disclosures about Fair Value of Financial Instruments The following table presents the estimated fair value for financial instruments not recorded at fair value in the Consolidated Financial Statements. The carrying amounts are recorded in the Consolidated Balance Sheets under the indicated captions: December 31, 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 $4,165 $4,041 $— $— $4,165 $4,041 $— $— Equity securities, at cost 834 834 — — 834 834 — — Other loans held for sale 101 101 — — — — 101 101 Loans and leases 116,660 116,627 — — 338 338 116,322 116,289 Financial Liabilities: Deposits 119,575 119,503 — — 119,575 119,503 — — Federal funds purchased and securities sold under agreements to repurchase 1,156 1,156 — — 1,156 1,156 — — Other short-term borrowed funds 1,653 1,653 — — 1,653 1,653 — — Long-term borrowed funds 14,433 14,390 — — 14,433 14,390 — — 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	12 Months Ended
	Dec. 31, 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) Year Ended December 31, 2018 Revenue from contracts with customers $1,119 Revenue from other sources 477 Noninterest income $1,596 Revenues from Contracts with Customers Citizens 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: Year Ended December 31, 2018 (in millions) Consumer Banking Commercial Banking Consolidated (1) Service charges and fees $408 $105 $513 Card fees 207 37 244 Capital markets fees — 181 181 Trust and investment services fees 171 — 171 Other banking fees — 10 10 Total revenue from contracts with customers $786 $333 $1,119 (1) There is no revenue from contracts with customers included in Other non-segment operations. Citizens 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 December 31, 2018 . Citizens 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 year ended December 31, 2018 , the Company recognized trailing commissions of $16 million , 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 8 “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. Citizens 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. Year Ended December 31, (in millions) 2018 2017 2016 Bank-owned life insurance $56 $54 $54

OTHER OPERATING EXPENSE

OTHER OPERATING EXPENSE	12 Months Ended
	Dec. 31, 2018
Other Income and Expenses [Abstract]
OTHER OPERATING EXPENSE	OTHER OPERATING EXPENSE The following table presents the details of other operating expense: Year Ended December 31, (in millions) 2018 2017 2016 Deposit insurance $104 $137 $120 Promotional expense 129 105 98 Settlements and operating losses 47 54 62 Other 215 246 241 Other operating expense $495 $542 $521

INCOME TAXES

INCOME TAXES	12 Months Ended
	Dec. 31, 2018
Income Tax Disclosure [Abstract]
INCOME TAXES	INCOME TAXES Citizens uses an asset and liability (balance sheet) approach for financial accounting and reporting of income taxes. This results in two components of income tax expense: current and deferred. Current income tax expense approximates taxes to be paid or refunded for the current period. Deferred income tax expense results from changes in deferred tax assets and liabilities between periods. These gross deferred tax assets and liabilities represent decreases or increases in taxes expected to be paid in the future because of future reversals of temporary differences in the bases of assets and liabilities, as measured by tax laws, and their bases, as reported in the Consolidated Financial Statements. Citizens also assesses the probability that the positions taken, or expected to be taken, in its income tax returns will be sustained by taxing authorities. A “more likely than not” (more than 50 percent) recognition threshold must be met before a tax benefit can be recognized. Tax positions that are more likely than not to be sustained are reflected in the Company’s Consolidated Financial Statements. Total income tax expense is presented below: Year Ended December 31, (in millions) 2018 2017 2016 Income tax expense $462 $260 $489 Tax effect of changes in OCI (96 ) (7 ) (168 ) Total comprehensive income tax expense $366 $253 $321 Components of income tax expense are presented below: (in millions) Current Deferred Total Year Ended December 31, 2018 U.S. federal $271 $90 $361 State and local 94 7 101 Total $365 $97 $462 Year Ended December 31, 2017 U.S. federal $376 ($142 ) $234 State and local 20 6 26 Total $396 ($136 ) $260 Year Ended December 31, 2016 U.S. federal $292 $159 $451 State and local 44 (6 ) 38 Total $336 $153 $489 The effective income tax rate differed from the U.S. federal income tax rate of 21% for the year ended December 31, 2018 , and 35% for the years ended December 31, 2017 and 2016 , as presented below: Year Ended December 31, 2018 2017 2016 (in millions, except ratio data) Amount Rate Amount Rate Amount Rate U.S. Federal income tax expense and tax rate $459 21.0 % $669 35.0 % $537 35.0 % Increase (decrease) resulting from: Federal rate change (34 ) (1.6 ) (331 ) (17.3 ) — — State and local income taxes (net of federal benefit) 89 4.1 46 2.4 38 2.5 Bank-owned life insurance (12 ) (0.5 ) (19 ) (1.0 ) (19 ) (1.2 ) Tax-exempt interest (15 ) (0.7 ) (21 ) (1.1 ) (19 ) (1.3 ) Tax advantaged investments (including related credits) (44 ) (2.0 ) (51 ) (2.7 ) (31 ) (2.0 ) Other tax credits (8 ) (0.4 ) (3 ) (0.1 ) (14 ) (0.9 ) Adjustments for uncertain tax positions 1 0.1 (23 ) (1.2 ) — — Non-deductible FDIC premiums 21 1.0 — — — — Other 5 0.2 (7 ) (0.4 ) (3 ) (0.2 ) Total income tax expense and tax rate $462 21.2 % $260 13.6 % $489 31.9 % The tax effects of temporary differences that give rise to significant portions of the deferred tax assets and liabilities are presented below: December 31, (in millions) 2018 2017 Deferred tax assets: Other comprehensive income $366 $271 Allowance for credit losses 308 310 State net operating loss carryforwards 90 88 Accrued expenses not currently deductible 36 40 Investment and other tax credit carryforwards 74 65 Fair value adjustments 28 27 Total deferred tax assets 902 801 Valuation allowance (110 ) (105 ) Deferred tax assets, net of valuation allowance 792 696 Deferred tax liabilities: Leasing transactions 527 525 Amortization of intangibles 364 352 Depreciation 195 182 Pension and other employee compensation plans 127 110 Partnerships 51 37 Deferred Income 50 27 MSRs 51 34 Total deferred tax liabilities 1,365 1,267 Net deferred tax liability $573 $571 Deferred tax assets are recognized for net operating loss carryforwards and tax credit carryforwards. Valuation allowances are recorded as necessary to reduce deferred tax assets to the amounts that management concludes are more likely than not to be realized. At December 31, 2018 , the Company had state tax net operating loss carryforwards of $1.4 billion . Limitations on the ability to realize these carryforwards are reflected in the associated valuation allowance. At December 31, 2018 , the Company had a valuation allowance of $110 million against various deferred tax assets related to state net operating losses and state tax credits, as it is management’s current assessment that it is more likely than not that the Company will not recognize a portion of the deferred tax assets related to these items. The valuation allowance increased $5 million during the year ended December 31, 2018 . Effective with the fiscal year ended September 30, 1997, the reserve method for bad debts was no longer permitted for tax purposes. The repeal of the reserve method required the recapture of the reserve balance in excess of certain base year reserve amounts attributable to years ended prior to 1988. At December 31, 2018 , the Company’s base year loan loss reserves attributable to years ended prior to 1988, for which no deferred income taxes have been provided, was $557 million . This base year reserve may become taxable if certain distributions are made with respect to the stock of the Company or if the Company ceases to qualify as a bank for tax purposes. No actions are planned that would cause this reserve to become wholly or partially taxable. Citizens files income tax returns in the U.S. federal jurisdiction and various state and local jurisdictions. With few exceptions, the Company is no longer subject to U.S. federal or state and local income tax examinations by major tax authorities for years before 2015. A reconciliation of the beginning and ending amount of unrecognized tax benefits is presented below: December 31, (in millions) 2018 2017 2016 Balance at the beginning of the year $5 $42 $62 Gross increase for tax positions related to current year 3 — — Gross decrease for tax positions related to prior years — (27 ) (19 ) Gross increase for tax positions related to prior years — — 1 Decreases for tax positions as a result of the lapse of the statutes of limitations — (1 ) (2 ) Decreases for tax positions related to settlements with taxing authorities — (9 ) — Balance at end of year $8 $5 $42 Tax positions are measured as the largest amount of tax benefit that is greater than 50 percent likely of being realized upon settlement with a taxing authority that has full knowledge of all relevant information. The difference between the benefit recognized for a position and the tax benefit claimed on a tax return is referred to as an unrecognized tax benefit. Included in the total amount of unrecognized tax benefits at December 31, 2018 , are potential benefits of $6 million that, if recognized, would impact the effective tax rate. Citizens classifies interest and penalties related to unrecognized tax benefits as a component of income taxes. There was no interest expense accrued as of December 31, 2018 . The Company released $8 million and accrued $8 million of interest expense for the years ended December 31, 2017 and 2016 , respectively. Citizens had approximately $2 million , $1 million , and $22 million accrued for the payment of interest at December 31, 2018 , 2017 , and 2016 , respectively. There were no amounts accrued for penalties as of December 31, 2018 , 2017 , and 2016 , and there were no penalties recognized during the years ended December 31, 2018 , 2017 , and 2016 .

EARNINGS PER SHARE

EARNINGS PER SHARE	12 Months Ended
	Dec. 31, 2018
Earnings Per Share [Abstract]
EARNINGS PER SHARE	EARNINGS PER SHARE Basic EPS is computed by dividing net income available to common stockholders by the weighted-average number of common shares outstanding during each period. Net income available to common stockholders represents net income after preferred stock dividends, accretion of the discount on preferred stock issuances, and gains or losses from any repurchases of preferred stock. Diluted EPS is computed by dividing net income available to common stockholders by the weighted-average number of common shares outstanding during each period, plus potential dilutive shares such as share-based payment awards and warrants using the treasury stock method. Year Ended December 31, (in millions, except share and per-share data) 2018 2017 2016 Numerator (basic and diluted): Net income $1,721 $1,652 $1,045 Less: Preferred stock dividends 29 14 14 Net income available to common stockholders $1,692 $1,638 $1,031 Denominator: Weighted-average common shares outstanding - basic 478,822,072 502,157,440 522,093,545 Dilutive common shares: share-based awards 1,608,669 1,527,651 1,837,173 Weighted-average common shares outstanding - diluted 480,430,741 503,685,091 523,930,718 Earnings per common share: Basic $3.54 $3.26 $1.97 Diluted 3.52 3.25 1.97 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 year ended December 31, 2018 and 2016 did no t have any antidilutive shares. The diluted EPS computation for the year ended December 31, 2017 excluded 533 average share-based awards because their inclusion would have been antidilutive.

REGULATORY MATTERS

REGULATORY MATTERS	12 Months Ended
	Dec. 31, 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. As of December 31, 2018, the Company’s primary subsidiaries were 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 as its primary federal regulator. On January 2, 2019, the Company consolidated its banking subsidiaries via a merger of CBPA into CBNA in order to streamline governance and enterprise risk management, improve CBNA’s risk profile and gain operational efficiencies. CBNA is now the Company’s primary subsidiary and sole banking subsidiary. Under the U.S. Basel III capital framework, the Company and CBNA 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) As of December 31, 2018 Common equity tier 1 capital (1) $14,485 10.6 $8,683 6.375 % Tier 1 capital (2) 15,325 11.3 10,726 7.875 Total capital (3) 18,157 13.3 13,450 9.875 Tier 1 leverage (4) 15,325 10.0 6,121 4.000 As of 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 1.25% 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 or as otherwise authorized by the FRB. 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 for the period beginning July 1, 2018 and ending June 30, 2019. The Company’s 2018 Capital Plan includes quarterly common dividends of $0.27 per share in third and fourth quarter 2018, increasing to $0.32 per share in first and second quarter 2019, and common share repurchases of up to $1.02 billion through the second quarter of 2019. 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. All future capital distributions are subject to consideration and approval by the Board of Directors prior to execution. For the year ended December 31, 2018 , the Company redeemed $333 million of its 5.158% fixed-to-floating callable subordinated debt due 2023, issued Series B and Series C preferred stock for $296 million and $297 million , respectively and repurchased outstanding common shares for $1.025 billion compared to $820 million for the year ended December 31, 2017 . For the year ended December 31, 2018, the Company declared and paid common dividends of $471 million , declared and paid semi-annual Series A preferred dividends of $14 million , and declared semi-annual Series B and quarterly Series C preferred dividends of $11 million and $4 million , respectively. This compared to $322 million of common dividends declared and paid and $14 million of semi-annual Series A preferred dividend declared and paid for the year ended December 31, 2017. Dividends payable by CBNA, as a national bank subsidiary, are limited to the lesser of the amount calculated under a “recent earnings” test and an “undivided profits” test. Under the recent earnings test, a dividend may not be paid if the total of all dividends declared by a bank in any calendar year is in excess of the current year’s net income combined with the retained net income of the two preceding years, less any required transfers to surplus, unless the national bank obtains the approval of the OCC. Under the undivided profits test, a dividend may not be paid in excess of the entity’s “undivided profits” (generally, accumulated net profits that have not been paid out as dividends or transferred to surplus). Federal bank regulatory agencies have issued policy statements which provide that FDIC-insured depository institutions and their holding companies should generally pay dividends only out of their current operating earnings.

BUSINESS OPERATING SEGMENTS

BUSINESS OPERATING SEGMENTS	12 Months Ended
	Dec. 31, 2018
Segment Reporting [Abstract]
BUSINESS OPERATING SEGMENTS	BUSINESS OPERATING SEGMENTS Citizens 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 Year Ended December 31, 2018 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $3,064 $1,497 ($29 ) $4,532 Noninterest income 973 545 78 1,596 Total revenue 4,037 2,042 49 6,128 Noninterest expense 2,723 813 83 3,619 Profit before provision for credit losses 1,314 1,229 (34 ) 2,509 Provision for credit losses 289 26 11 326 Income (loss) before income tax expense (benefit) 1,025 1,203 (45 ) 2,183 Income tax expense (benefit) 258 276 (72 ) 462 Net income $767 $927 $27 $1,721 Total average assets $62,444 $52,362 $39,747 $154,553 As of and for the Year Ended December 31, 2017 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $2,651 $1,411 $111 $4,173 Noninterest income 905 538 91 1,534 Total revenue 3,556 1,949 202 5,707 Noninterest expense 2,593 772 109 3,474 Profit before provision for credit losses 963 1,177 93 2,233 Provision for credit losses 265 19 37 321 Income before income tax expense (benefit) 698 1,158 56 1,912 Income tax expense (benefit) 246 384 (370 ) 260 Net income $452 $774 $426 $1,652 Total average assets $59,714 $49,747 $40,492 $149,953 As of and for the Year Ended December 31, 2016 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $2,443 $1,288 $27 $3,758 Noninterest income 883 466 148 1,497 Total revenue 3,326 1,754 175 5,255 Noninterest expense 2,547 741 64 3,352 Profit before provision for credit losses 779 1,013 111 1,903 Provision for credit losses 243 47 79 369 Income before income tax expense (benefit) 536 966 32 1,534 Income tax expense (benefit) 191 335 (37 ) 489 Net income $345 $631 $69 $1,045 Total average assets $56,388 $47,159 $39,636 $143,183 Management accounting practices utilized by the Company as the basis of presentation for segment results include the following: FTP adjustments Citizens 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. Citizens periodically evaluates and refines its methodologies used to measure financial performance of its business operating segments. In the first quarter of 2018, Citizens 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. Goodwill For impairment testing purposes, the Company allocates goodwill to its Consumer Banking and Commercial Banking reporting units. For management reporting purposes, the Company presents the goodwill balance (and any related impairment charges) in Other. 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.

PARENT COMPANY FINANCIALS

PARENT COMPANY FINANCIALS	12 Months Ended
	Dec. 31, 2018
Condensed Financial Information Disclosure [Abstract]
PARENT COMPANY FINANCIALS	PARENT COMPANY FINANCIALS Condensed Statements of Operations Year Ended December 31, (in millions) 2018 2017 2016 OPERATING INCOME: Income from consolidated subsidiaries and excluding equity in undistributed earnings: Dividends from banking subsidiaries $1,650 $1,055 $555 Interest 46 43 53 Management and service fees 22 31 26 Income from nonbank subsidiaries and excluding equity in undistributed earnings: Dividends from nonbank subsidiaries 5 4 — Interest 2 1 — Equity securities gains — 1 3 All other operating income 1 1 7 Total operating income 1,726 1,136 644 OPERATING EXPENSE: Salaries and employee benefits 25 40 37 Interest expense 89 97 99 All other expenses 23 22 15 Total operating expense 137 159 151 Income before taxes and undistributed income 1,589 977 493 Income taxes (13 ) (10 ) (26 ) Income before undistributed earnings of subsidiaries 1,602 987 519 Equity in undistributed earnings of subsidiaries: Bank 109 655 522 Nonbank 10 10 4 Net income $1,721 $1,652 $1,045 Other comprehensive income (loss), net of income taxes: Net pension plan activity arising during the period $5 ($1 ) ($2 ) Net unrealized derivative instrument gains (losses) arising during the period 2 1 (8 ) Other comprehensive income (loss) activity of the Parent Company, net of income taxes 7 — (10 ) Other comprehensive loss activity of Bank subsidiaries, net of income taxes (283 ) (7 ) (271 ) Total other comprehensive loss, net of income taxes (276 ) (7 ) (281 ) Total comprehensive income $1,445 $1,645 $764 In accordance with federal and state banking regulations, dividends paid by the Company’s banking subsidiaries to the Company are generally limited to the retained earnings of the respective banking subsidiaries unless specifically approved by the appropriate bank regulator. Citizens declared and paid total common stock dividends of $471 million , $322 million and $241 million for the years ended December 31, 2018 , 2017 and 2016 , respectively. Citizens also declared and paid preferred stock dividends of $14 million for the years ended December 31, 2018 , 2017 and 2016 . Condensed Balance Sheets (in millions) December 31, 2018 December 31, 2017 ASSETS: Cash and due from banks $961 $563 Loans and advances to: Bank subsidiaries 1,158 1,160 Nonbank subsidiaries 70 70 Investments in subsidiaries: Bank subsidiaries 20,590 20,765 Nonbank subsidiaries 83 73 Other assets 117 125 TOTAL ASSETS $22,979 $22,756 LIABILITIES: Long-term borrowed funds due to: Unaffiliated companies $1,987 $2,320 Other liabilities 175 166 TOTAL LIABILITIES 2,162 2,486 TOTAL STOCKHOLDERS’ EQUITY 20,817 20,270 TOTAL LIABILITIES AND STOCKHOLDERS’ EQUITY $22,979 $22,756 Condensed Cash Flow Statements Year Ended December 31, (in millions) 2018 2017 2016 OPERATING ACTIVITIES Net income $1,721 $1,652 $1,045 Adjustments to reconcile net income to net cash provided by operating activities: Deferred income taxes 17 (11 ) 5 Gain on sales of assets — (1 ) (3 ) Equity in undistributed earnings of subsidiaries (120 ) (665 ) (526 ) Increase (decrease) in other liabilities 11 99 (19 ) (Increase) decrease in other assets (7 ) 5 35 Other operating, net 40 (1 ) (4 ) Total adjustments (59 ) (574 ) (512 ) Net cash provided by operating activities 1,662 1,078 533 INVESTING ACTIVITIES Investments in and advances to subsidiaries — (230 ) (40 ) Repayment of investments in and advances to subsidiaries — 167 588 Other investing, net (1 ) (1 ) (2 ) Net cash (used) provided by investing activities (1 ) (64 ) 546 FINANCING ACTIVITIES Proceeds from issuance of long-term borrowed funds — — 349 Repayments of long-term borrowed funds (333 ) — (625 ) Proceeds from issuance of common stock — 34 22 Treasury stock purchased (1,025 ) (820 ) (430 ) Net proceeds from issuance of preferred stock 593 — — Dividends declared and paid to common stockholders (471 ) (322 ) (241 ) Dividends declared and paid to preferred stockholders (14 ) (14 ) (14 ) Other financing, net (13 ) — — Net cash used by financing activities (1,263 ) (1,122 ) (939 ) Increase (decrease) in cash and due from banks 398 (108 ) 140 Cash and due from banks at beginning of year 563 671 531 Cash and due from banks at end of year $961 $563 $671

BASIS OF PRESENTATION (Policies

BASIS OF PRESENTATION (Policies)	12 Months Ended
	Dec. 31, 2018
Organization, Consolidation and Presentation of Financial Statements [Abstract]
Basis of Presentation	The Consolidated Financial Statements include the accounts of Citizens and subsidiaries in which Citizens 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 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 allowance for credit losses and the fair value of MSRs.
Interest Income Recognition	Interest Income Recognition Interest income on loans and securities classified as AFS or HTM is determined using the effective interest method. This method calculates periodic interest income at a constant effective yield on the net investment in the loan or security, to provide a constant rate of return over the terms of the financial assets.
Transfer of Financial Assets	Transfer of Financial Assets A transfer of financial assets is accounted for as a sale when control over the assets transferred is surrendered. Assets transferred that satisfy the conditions of a sale are derecognized, and all assets obtained and liabilities incurred in a purchase are recognized and measured at fair value. Servicing rights retained in the transfer of financial assets are initially recognized at fair value. Subsequent to the initial recognition date, servicing rights are accounted for either at the lower of cost or market or fair value. For servicing rights accounted for at the lower of cost or market, Citizens recognizes periodic amortization expense of servicing rights and assesses servicing rights for impairment.
Accounting and Reporting Developments	Accounting Pronouncements Adopted in 2018 Pronouncement Summary of Guidance Effects on 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. • Citizens adopted the new standard on December 31, 2018. • Adoption did not have a material impact on the Company’s Consolidated 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. • Citizens 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. Citizens 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. • Citizens 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. • Citizens retrospectively adopted the new standard as of January 1, 2018. • Adoption did not have an impact on the Company’s net income. • Citizens reclassified prior period amounts in the Consolidated Statements 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. • Citizens 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. • Citizens 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 will not adopt the guidance prior to the required effective date. • Upon adoption, the Company elected to transfer $755 million of securities eligible to be hedged under the last-of-layer method from the HTM portfolio to the AFS portfolio. At the time of the transfer, $15 million of unrealized losses were recognized in OCI. The remaining 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 will not adopt the guidance prior to the effective date. • The Company occupies certain banking offices and equipment under non-cancelable operating lease agreements, which currently are not reflected on its Consolidated Balance Sheets. • The Company will 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. • Upon adoption, the Company will recognize a right-of-use asset and corresponding lease liability of approximately $750 million in its Consolidated Balance Sheets for non-cancelable operating lease agreements. • Adoption of the guidance will not result in 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 will not 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, revising policies and procedures and completing the development and configuration 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, how the reasonable and supportable forecast period will be determined and documented as well as the impacts of that decision in different parts of the credit cycle, and expects to begin parallel testing in the second half of 2019. • 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 does not intend to 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.
Cash and Cash Equivalents	For the purposes of reporting cash flows, cash and cash equivalents have original maturities of three months or less and include cash and due from banks and interest-bearing cash and due from banks, primarily at the FRB.
Securities	Investments include debt and marketable equity securities and other investment securities. Citizens classifies debt securities as AFS, HTM, or trading based on management’s intent to hold to maturity at the time of purchase, and marketable equity securities as trading. Securities that will be held for indefinite periods of time and may be sold in response to changes in interest rates, changes in prepayment risk, or other factors considered in managing the Company’s asset/liability strategy are classified as AFS and reported at fair value, with unrealized gains and losses reported in OCI as a separate component of stockholders’ equity, net of taxes. Gains and losses on the sales of securities are recognized in noninterest income and are computed using the specific identification method. Debt securities for which the Company has the ability and intent to hold to maturity are classified as HTM. The securities are reported at amortized cost. Transfers of debt securities to the HTM classification are recognized at fair value at the date of transfer. For debt securities classified as AFS or HTM, interest income is recorded on the accrual basis including the amortization of premiums and the accretion of discounts. Premiums and discounts on debt securities are amortized or accreted using the effective interest method over the estimated lives of the individual securities. Citizens uses actual prepayment experience and estimates of future prepayments to determine the constant effective yield necessary to apply the effective interest method of income recognition. Estimates of future prepayments are based on the underlying collateral characteristics of each security and are derived from market sources. Judgment is involved in making determinations about prepayment expectations and in changing those expectations in response to changes in interest rates and macroeconomic conditions. The amortization of premiums and discounts associated with mortgage-backed securities may be significantly impacted by changes in prepayment assumptions. Securities classified as trading are bought and held principally for selling them in the near term and carried at fair value, with changes in fair value recognized in earnings. When applicable, realized and unrealized gains and losses on such assets are reported in noninterest income in the Consolidated Statements of Operations. Other investment securities are primarily composed of FHLB stock and FRB stock (which are carried at cost) and money market mutual fund investments held by the Company’s broker-dealers (which are carried at fair value, with changes in fair value recognized in noninterest income). Other investment securities that are carried at cost are reviewed at least annually for impairment, with valuation adjustments recognized in noninterest income. Citizens reviews its securities for other-than-temporary impairment on a quarterly basis or more frequently if a potential loss triggering event occurs. The initial indicator of other-than-temporary impairment for both debt and equity securities is a decline in fair value below its recorded investment amount, as well as the severity and duration of the decline. For a security of which there has been a decline in fair value below the cost basis, the Company recognizes other-than-temporary impairment if (i) management has the intent to sell the security, (ii) it is more likely than not it will be required to sell the security before recovery of its amortized cost basis, or (iii) the Company does not expect to recover the entire cost basis of the security. Estimating the recovery of the amortized cost basis of a debt security is based upon an assessment of the cash flows expected to be collected. If the present value of cash flows expected to be collected, discounted at the security’s original effective yield, is less than amortized cost, other-than-temporary impairment is considered to have occurred. If the Company intends to sell an impaired security, or if it is more likely than not it will be required to sell the security before recovery, the impairment loss recognized in current period earnings equals the difference between the amortized cost basis and the fair value of the security. If the Company does not intend to sell the impaired security, and it is not likely that the Company will be required to sell the impaired security, the other-than-temporary impairment write-down is separated into an amount representing the credit loss, which is recognized in current period earnings and the amount related to all other factors, is recognized in OCI.
Loans and Leases	Loans held for investment are reported at the amount of their outstanding principal, net of charge-offs, unearned income, deferred loan origination fees and costs, and unamortized premiums or discounts on purchased loans. Deferred loan origination fees and costs and purchase premiums and discounts are amortized as an adjustment of yield over the life of the loan, using the effective interest method. Unamortized amounts remaining upon prepayment or sale are recorded as interest income or gain (loss) on sale, respectively. Credit card receivables include billed and uncollected interest and fees. Interest income on loans is determined using the effective interest method. This method calculates periodic interest income at a constant effective yield on the net investment in the loan, to provide a constant rate of return over the term. Loans accounted for using the fair value option, are measured at fair value with corresponding changes recognized in noninterest income. Loan commitment fees for loans that are likely to be drawn down, and other credit related fees, are deferred (together with any incremental costs) and recognized as an adjustment to the effective interest rate over the loan term. When it is unlikely that a loan will be drawn down, the loan commitment fees are recognized over the commitment period on a straight-line basis. Leases are classified at the inception of the lease. Direct financing lease receivables are reported at the aggregate of minimum lease payments receivable plus the estimated residual value of the leased property, less unearned and deferred income, including unamortized investment credits. Leveraged leases, which are a form of direct financing leases, are recorded net of related non-recourse debt. Lease residual values are reviewed at least annually for other-than-temporary impairment; with valuation adjustments recognized currently against other income for direct financing and leveraged leases. Unearned income is recognized as a constant percentage of outstanding lease financing balances over the lease term in interest income. 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 now services a portion of internally. Loans are classified upon origination or acquisition as either held-for-investment or held-for-sale. This classification is based on management’s initial intent and ability to hold the loans for the foreseeable future. Loans held for sale are carried at the lower of cost or fair value, with any write-downs or subsequent recoveries charged to other income. Citizens accounts for certain loans held for sale, including those loans associated with its mortgage banking business and secondary loan trading desk, under the fair value option at fair value.
Allowance for Credit Losses	Management’s estimate of probable losses in the Company’s loan and lease portfolios is recorded in the ALLL and the reserve for unfunded lending commitments. On a quarterly basis, Citizens evaluates the adequacy of the ALLL by performing reviews of certain individual loans and leases, analyzing changes in the composition, size and delinquency of the portfolio, reviewing previous loss experience and considering current and anticipated economic factors. The ALLL is established in accordance with the Company’s credit reserve policies, as approved by the Audit Committee of the Board of Directors. The Chief Financial Officer and Chief Risk Officer review the adequacy of the ALLL each quarter, together with risk management. In addition, various regulatory agencies, as an integral part of their examination process, periodically review the Company’s allowance for credit losses. The ALLL is maintained at a level that management considers reflective of probable losses, and is established through charges to earnings in the form of a provision for credit losses. The ALLL may be adjusted to reflect the Company’s current assessment of various qualitative risks, factors and events that may not be measured in the statistical analysis. Such factors include trends in economic conditions, loan growth, back testing results, credit underwriting policy exceptions, regulatory and audit findings, and peer comparisons. Amounts determined to be uncollectible are deducted from the ALLL and subsequent recoveries, if any, are added to the ALLL. While management uses available information to estimate loan and lease losses, future additions to the ALLL may be necessary based on changes in economic conditions. There were no material changes in assumptions or estimation techniques compared with prior years that impacted the determination of the current year’s ALLL and the reserve for unfunded lending commitments. The evaluation of the adequacy of the commercial, commercial real estate, and lease ALLL and reserve for unfunded lending commitments is primarily based on risk rating models that assess probability of default, loss given default and exposure at default on an individual loan basis. The models are primarily driven by individual customer financial characteristics and are validated against historical experience. Additionally, qualitative factors are included in the risk rating models. After the aggregation of individual borrower incurred loss, additional overlays can be made based on back-testing against historical losses. For non-impaired retail loans, the ALLL is based upon an incurred loss model utilizing the probability of default, loss given default and exposure at default on an individual loan basis. When developing these factors, the Company may consider the loan product and collateral type, delinquency status, LTV ratio, lien position, borrower’s credit, age of the loan, geographic location and incurred loss period. Certain retail portfolios, including education, unsecured personal loans, SBO home equity loans and commercial credit card receivables utilize roll rate or vintage models to estimate the ALLL. For nonaccruing commercial and commercial real estate loans with an outstanding balance of $3 million or greater and for all commercial and commercial real estate TDRs (regardless of size), the Company conducts further analysis to determine the probable amount of loss and establishes a specific allowance for the loan, if appropriate. Citizens estimates the impairment amount by comparing the loan’s carrying amount to the estimated present value of its future cash flows, the fair value of its underlying collateral, or the loan’s observable market price. For collateral-dependent impaired commercial and commercial real estate loans, the excess of the Company’s recorded investment in the loan over the fair value of the collateral, less cost to sell, is charged off to the ALLL. For retail TDRs that are not collateral-dependent, allowances are developed using the present value of expected future cash flows compared to the recorded investment in the loans. Expected re-default factors are considered in this analysis. Retail TDRs that are deemed collateral-dependent are written down to fair market value less cost to sell. The fair value of collateral is periodically monitored subsequent to the modification. In addition to the ALLL, the Company also estimates probable credit losses associated with off-balance sheet financial instruments such as standby letters of credit, financial guarantees and binding unfunded loan commitments. Off-balance sheet financial instruments are subject to individual reviews and are analyzed and segregated by risk according to the Company’s internal risk rating scale. These risk classifications, in conjunction with historical loss experience, economic conditions and performance trends within specific portfolio segments, result in the estimate of the reserve for unfunded lending commitments. The ALLL and the reserve for unfunded lending commitments are reported on the Consolidated Balance Sheets in the allowance for loan and lease losses and in other liabilities, respectively. Provision for credit losses related to the loans and leases portfolio and the unfunded lending commitments are reported in the Consolidated Statements of Operations as provision for credit losses.
Loan Charge-Offs	Commercial loans are charged off when it is highly certain that a loss has been realized, including situations where a loan is determined to be both impaired and collateral-dependent. The determination of whether to recognize a charge-off involves many factors, including the prioritization of the Company’s claim in bankruptcy, expectations of the workout/restructuring of the loan and valuation of the borrower’s equity or the loan collateral. Retail loans are generally fully charged-off or written down to the net realizable value of the underlying collateral, with an offset to the ALLL, upon reaching specified stages of delinquency in accordance with standards established by the FFIEC. Residential real estate loans, credit card loans and unsecured open end loans are generally charged off in the month in which the account becomes 180 days past due. Auto loans, education loans and unsecured closed end loans are generally charged off in the month in which the account becomes 120 days past due. Certain retail loans will be charged off earlier than the FFIEC standards in the following circumstances: • A charge-off is recognized when a loan is modified in a TDR if the loan is determined to be collateral-dependent. A loan is considered to be collateral-dependent when repayment of the loan is expected to be provided solely by the underlying collateral, rather than by cash flows from the borrower’s operations, income or other resources. • Loans to borrowers who have experienced an event (e.g. bankruptcy) that suggests a loss is either known or highly certain are subject to accelerated charge-off standards. Residential real estate and auto loans are charged down to the net realizable value when the loan becomes 60 days past due, or sooner if the loan is determined to be collateral-dependent. Credit card loans are fully charged off within 60 days of receiving notification of the bankruptcy filing or other event. Education loans are generally charged off when the loan becomes 60 days past due after receiving notification of a bankruptcy. • Auto loans are written down to net realizable value upon repossession of the collateral.
Nonperforming Loans and Leases	Nonperforming loans and leases are those on which accrual of interest has been suspended. Loans (other than certain retail loans insured by U.S. government agencies) are placed on nonaccrual status and considered nonperforming when full payment of principal and interest is in doubt, unless the loan is both well secured and in the process of collection. When the Company places a loan on nonaccrual status, the accrued unpaid interest receivable is reversed against interest income and amortization of any net deferred fees is suspended. Interest collections on nonaccruing loans and leases for which the ultimate collectability of principal is uncertain are generally applied to first reduce the carrying value of the loan. Otherwise, interest income may be recognized to the extent of the cash received. A loan may be returned to accrual status if (i) principal and interest payments have been brought current, and the Company expects repayment of the remaining contractual principal and interest, (ii) the loan or lease has otherwise become well-secured and in the process of collection, or (iii) the borrower has been making regularly scheduled payments in full for the prior six months and the Company is reasonably assured that the loan or lease will be brought fully current within a reasonable period. Commercial loans, commercial real estate loans, and leases are generally placed on nonaccrual status when contractually past due 90 days or more, or earlier if management believes that the probability of collection is insufficient to warrant further accrual. Some of these loans and leases may remain on accrual status when contractually past due 90 days or more if management considers the loan collectible. Residential mortgages are generally placed on nonaccrual status when past due 120 days, or sooner if determined to be collateral-dependent, unless repayment of the loan is guaranteed by the Federal Housing Administration. Credit card balances are placed on nonaccrual status when past due 90 days or more and are restored to accruing status if they subsequently become less than 90 days past due. All other retail loans are generally placed on nonaccrual status when past due 90 days or more, or earlier if management believes that the probability of collection is insufficient to warrant further accrual. Loans less than 90 days past due may be placed on nonaccrual status upon the death of the borrower, fraud or bankruptcy.
Impaired Loans	A loan is considered to be impaired when, based on current information and events, it is probable that the Company will be unable to collect all of the contractual interest and principal payments as scheduled in the loan agreement. This evaluation is generally based on delinquency information, an assessment of the borrower’s financial condition and the adequacy of collateral, if any. 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. When a loan is identified as impaired, the impairment is measured on an individual loan level as the difference between the recorded investment in the loan (net of previous charge-offs, deferred loan fees or costs and unamortized premium or discount) and the present value of expected future cash flows, discounted at the loan’s effective interest rate. When collateral is the sole source of repayment for the impaired loan, rather than the borrower’s income or other sources of repayment, the Company charges down the loan to its net realizable value.
Troubled Debt Restructuring	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 with the borrower. 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. Retail and commercial loans whose contractual terms have been modified in a TDR and are current at the time of restructuring may remain on accrual status if there is demonstrated performance prior to the restructuring and payment in full under the restructured terms is expected. Retail loans that were discharged in bankruptcy and not reaffirmed by the borrower are deemed to be collateral-dependent TDRs and are generally charged off to the fair value of the collateral, less cost to sell, and less amounts recoverable under a government guarantee (if any). Cash receipts on nonaccruing impaired loans, including nonaccruing loans involved in TDRs, are generally applied to reduce the unpaid principal balance. Certain TDRs that are current in payment status are classified as nonaccrual in accordance with regulatory guidance. Income on these loans is generally recognized on a cash basis if management believes that the remaining book value of the loan is realizable. Nonaccruing TDRs that meet the guidelines above for accrual status can be returned to accruing if supported by a well-documented evaluation of the borrowers’ financial condition, and if they have been current for at least six months. Because TDRs are impaired loans, Citizens 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 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.
Premises and Equipment	Premises and equipment are stated at cost, less accumulated depreciation and amortization. Depreciation and amortization have been computed using the straight-line method over the estimated useful lives of the assets. Leasehold improvements are amortized over the life of the lease (including renewal options if exercise of those options is reasonably assured) or their estimated useful life, whichever is shorter. Additions to premises and equipment are recorded at cost. The cost of major additions, improvements and betterments is capitalized. Normal repairs and maintenance and other costs that do not improve the property, extend the useful life or otherwise do not meet capitalization criteria are charged to expense as incurred. Citizens evaluates premises and equipment for impairment when events or changes in circumstances indicate that the carrying value of such assets may not be recoverable.
Software	Costs related to computer software developed or obtained for internal use are capitalized if the projects improve functionality and provide long-term future operational benefits. Capitalized costs are amortized using the straight-line method over the asset’s expected useful life, based upon the basic pattern of consumption and economic benefits provided by the asset. Citizens begins to amortize the software when the asset (or identifiable component of the asset) is substantially complete and ready for its intended use. All other costs incurred in connection with an internal-use software project are expensed as incurred. Capitalized software is included in other assets on the Consolidated Balance Sheets.
Operating Lease Assets	Operating lease rental income for leased assets is recognized in other income on a straight-line basis over the lease term. Related depreciation expense is recorded on a straight-line basis over the estimated useful life, considering the estimated residual value of the leased asset and is included in other operating expense in the Consolidated Statements of Operations. On a periodic basis, leased assets are reviewed for impairment. Impairment loss is recognized in other operating expense if the carrying amount of the leased assets exceeds fair value and is not recoverable. The carrying amount of leased assets is not recoverable if it exceeds the sum of the undiscounted cash flows expected to result from the lease payments and the estimated residual value upon the eventual disposition of the asset.
Mortgage Banking	Mortgage loans held for sale are accounted for at fair value on an individual loan basis. Changes in the fair value, and realized gains and losses on the sales of mortgage loans, are reported in mortgage banking fees. Citizens accounts for derivatives in its mortgage banking operations at fair value on the balance sheet as derivative assets or derivative liabilities, depending on whether the derivative had a positive (asset) or negative (liability) fair value as of the balance sheet date. The Company’s mortgage banking derivatives include commitments to originate mortgages held for sale, certain loan sale agreements, and other financial instruments that meet the definition of a derivative.
Goodwill	Goodwill is the purchase premium 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. Citizens 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. Goodwill is not amortized, but is subject to annual impairment tests. The goodwill impairment analysis is a two-step test. The first step, used to identify potential impairment, involves comparing each reporting unit’s fair value to its carrying value, including goodwill. If the fair value of a reporting unit exceeds its carrying value, applicable goodwill is deemed to be not impaired. If the carrying value exceeds fair value, there is an indication of impairment and the second step is performed to measure the amount of impairment. The second step involves calculating an implied fair value of goodwill for each reporting unit for which the first step indicated impairment. The implied fair value of goodwill is determined in the same manner as the amount of goodwill recognized in a business combination, which is the excess of the fair value of the reporting unit, as determined in the first step, over the aggregate fair values of the individual assets, liabilities and identifiable intangible. If the implied fair value of goodwill exceeds the carrying value of goodwill assigned to the reporting unit, there is no impairment. If the carrying value of goodwill assigned to a reporting unit exceeds the implied fair value of the goodwill, an impairment charge is recorded for the excess. An impairment loss that is recognized cannot exceed the amount of goodwill assigned to a reporting unit, and the loss establishes a new basis in the goodwill. Subsequent reversal of goodwill impairment losses is not permitted. Citizens reviews goodwill for impairment annually as of October 31 st or more often if events or circumstances indicate that it is more likely than not that the fair value of one or more reporting units is below its carrying value. The fair values of the Company’s reporting units are determined using a combination of income and market-based approaches. Citizens relies on the income approach (discounted cash flow method) for determining fair value. Market and transaction approaches are used as benchmarks only to corroborate the value determined by the discounted cash flow method. Citizens relies on several assumptions when estimating the fair value of its reporting units using the discounted cash flow method. These assumptions include the discount rate, as well as projected loan loss, income tax and capital retention rates. Discount rates are estimated based on the Capital Asset Pricing Model, which considers the risk-free interest rate, market risk premium, beta, and size premium adjustments specific to a particular reporting unit. The discount rates are also calibrated on the assessment of the risks related to the projected cash flows of each reporting unit. Cash flow projections include estimates for projected loan loss, income tax and capital retention rates. Multi-year financial forecasts are developed for each reporting unit by considering several key business drivers such as new business initiatives, customer retention standards, market share changes, anticipated loan and deposit growth, forward interest rates, historical performance, and industry and economic trends, among other considerations. The long-term growth rate used in determining the terminal value of each reporting unit is estimated based on management’s assessment of the minimum expected terminal growth rate of each reporting unit, as well as broader economic considerations such as GDP and inflation. Citizens bases its fair value estimates on assumptions it believes to be representative of assumptions that a market participant would use in valuing the reporting unit but that are unpredictable and inherently uncertain, including estimates of future growth rates and operating margins and assumptions about the overall economic climate and the competitive environment for its reporting units. There can be no assurances that future estimates and assumptions made for purposes of goodwill testing will prove accurate predictions of the future. If the assumptions regarding business plans, competitive environments or anticipated growth rates are not achieved, Citizens may be required to record goodwill impairment charges in future periods.
Variable Interest Entities	Citizens makes equity investments in various entities that are considered VIEs, as defined by GAAP. A VIE typically does not have sufficient equity at risk to finance its activities without additional subordinated financial support from other parties. The Company’s variable interest arises from contractual, ownership or other monetary interests in the entity, which change with fluctuations in the fair value of the entity's net assets. Citizens consolidates a VIE if it is the primary beneficiary of the entity. Citizens is the primary beneficiary of a VIE if its variable interest provides it with the power to direct the activities that most significantly impact the VIE and the right to receive benefits (or the obligation to absorb losses) that could potentially be significant to the VIE. To determine whether or not a variable interest held could potentially be significant to the VIE, the company considers both qualitative and quantitative factors regarding the nature, size and form of its involvement with the VIE. Citizens assesses whether or not it is the primary beneficiary of a VIE on an ongoing basis.
Interest-Bearing Deposits in Banks	Interest-bearing deposits in banks are carried at cost and include deposits that mature within one year.
Derivatives	In the normal course of business, Citizens 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 19 “Fair Value Measurements.” Derivative assets and derivative liabilities are netted by counterparty on the balance sheet if a “right of setoff” has been established in a master netting agreement between the Company and the counterparty. This netted derivative asset or liability position is also netted against the fair value of any cash collateral that has been pledged or received in accordance with a Credit Support Annex. If a derivative is designated as a fair value hedge, gains or losses attributable to the change in fair value of the derivative instrument, as well as the gains and losses attributable to the change in fair value of the hedged item, are recognized in other income in the period in which the change in fair value occurs. Hedge ineffectiveness is recognized as other income to the extent the changes in fair value of the derivative do not offset the changes in fair value of the hedged item. Changes in the fair value of derivatives that do not qualify as hedges are recognized immediately in other income. For derivatives designated for hedging purposes, net interest accruals are treated as an adjustment of interest income or interest expense of the item being hedged.
Employee Benefits	The cost of postretirement benefits other than pensions is recognized on an accrual basis during the periods employees provide services to earn those benefits. Pension costs under defined benefit plans are actuarially computed and include current service costs and amortization of prior service costs over the participants’ average future working lifetime. The actuarial cost method used in determining the net periodic pension cost is the projected unit method.
Treasury Stock	Treasury Stock The purchase of the Company’s common stock is recorded at cost. At the date of retirement or subsequent reissuance, treasury stock is reduced by the cost of such stock on a first-in, first-out basis with differences recorded in additional paid-in capital or retained earnings, as applicable.
Share-Based Compensation	Citizens measures compensation expense related to stock awards based upon the fair value of the awards on the grant date. Compensation expense is adjusted for forfeitures as they occur. The related expense is charged to earnings on a straight-line basis over the requisite service period (e.g., vesting period) of the award. With respect to performance-based stock awards, compensation expense is adjusted upward or downward based upon the probability of achievement of performance. Awards that continue to vest after retirement are expensed over the shorter of the period of time from grant date to the final vesting date or from the grant date to the date when an employee is retirement eligible. Awards granted to employees who are retirement eligible at the grant date are generally expensed immediately upon grant.
Fair Value	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 measures fair value using the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. Fair value is based upon quoted market prices in an active market, where available. If quoted prices are not available, observable market-based inputs or independently sourced parameters are used to develop fair value, whenever possible. Such inputs may include prices of similar assets or liabilities, yield curves, interest rates, prepayment speeds, and foreign exchange rates. A portion of the Company’s assets and liabilities is carried at fair value, including securities available for sale, derivative instruments and other investment securities. In addition, the Company elects to account for its loans associated with its mortgage banking business and secondary loan trading desk at fair value. Citizens classifies its assets and liabilities that are carried at fair value in accordance with the three-level valuation hierarchy: • Level 1. Quoted prices (unadjusted) in active markets for identical assets or liabilities. • Level 2. Observable inputs other than Level 1 prices, such as quoted prices for similar instruments, quoted prices in markets that are not active, or other inputs that are observable or can be corroborated by market data for substantially the full term of the asset or liability. • Level 3. Unobservable inputs that are supported by little or no market information and that are significant to the fair value measurement. Classification in the hierarchy is based upon the lowest level input that is significant to the fair value measurement of the asset or liability. For instruments classified in Levels 1 and 2 where inputs are primarily based upon observable market data, there is less judgment applied in arriving at the fair value. For instruments classified in Level 3, management judgment is more significant due to the lack of observable market data. Citizens reviews and updates the fair value hierarchy classifications on a quarterly basis. Changes from one quarter to the next related to the observability of inputs in fair value measurements may result in a reclassification between the fair value hierarchy levels and are recognized based on period-end balances.
Revenue from Contract with Customer	Revenues from Contracts with Customers Citizens 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. 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 year ended December 31, 2018 , the Company recognized trailing commissions of $16 million , 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 8 “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. Citizens 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.
Income Taxes	Citizens uses an asset and liability (balance sheet) approach for financial accounting and reporting of income taxes. This results in two components of income tax expense: current and deferred. Current income tax expense approximates taxes to be paid or refunded for the current period. Deferred income tax expense results from changes in deferred tax assets and liabilities between periods. These gross deferred tax assets and liabilities represent decreases or increases in taxes expected to be paid in the future because of future reversals of temporary differences in the bases of assets and liabilities, as measured by tax laws, and their bases, as reported in the Consolidated Financial Statements. Citizens also assesses the probability that the positions taken, or expected to be taken, in its income tax returns will be sustained by taxing authorities. A “more likely than not” (more than 50 percent) recognition threshold must be met before a tax benefit can be recognized. Tax positions that are more likely than not to be sustained are reflected in the Company’s Consolidated Financial Statements. Deferred tax assets are recognized for net operating loss carryforwards and tax credit carryforwards. Valuation allowances are recorded as necessary to reduce deferred tax assets to the amounts that management concludes are more likely than not to be realized. Tax positions are measured as the largest amount of tax benefit that is greater than 50 percent likely of being realized upon settlement with a taxing authority that has full knowledge of all relevant information. The difference between the benefit recognized for a position and the tax benefit claimed on a tax return is referred to as an unrecognized tax benefit.
Earnings Per Share	Basic EPS is computed by dividing net income available to common stockholders by the weighted-average number of common shares outstanding during each period. Net income available to common stockholders represents net income after preferred stock dividends, accretion of the discount on preferred stock issuances, and gains or losses from any repurchases of preferred stock. Diluted EPS is computed by dividing net income available to common stockholders by the weighted-average number of common shares outstanding during each period, plus potential dilutive shares such as share-based payment awards and warrants using the treasury stock method.

SECURITIES (Tables)

SECURITIES (Tables)	12 Months Ended
	Dec. 31, 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: December 31, 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 $24 $— $— $24 $12 $— $— $12 State and political subdivisions 5 — — 5 6 — — 6 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities 20,211 28 (605 ) 19,634 20,065 40 (277 ) 19,828 Other/non-agency 236 3 (7 ) 232 311 7 (7 ) 311 Total mortgage-backed securities 20,447 31 (612 ) 19,866 20,376 47 (284 ) 20,139 Total debt securities available for sale, at fair value $20,476 $31 ($612 ) $19,895 $20,394 $47 ($284 ) $20,157 Debt Securities Held to Maturity Mortgage-backed securities: Federal agencies and U.S. government sponsored entities $3,425 $— ($132 ) $3,293 $3,853 $7 ($46 ) $3,814 Other/non-agency 740 8 — 748 832 22 — 854 Total mortgage-backed securities 4,165 8 (132 ) 4,041 4,685 29 (46 ) 4,668 Total debt securities held to maturity $4,165 $8 ($132 ) $4,041 $4,685 $29 ($46 ) $4,668 Equity Securities, at Fair Value Money market mutual fund investments $181 $— $— $181 $165 $— $— $165 Other investments — — — — 4 — — 4 Total equity securities, at fair value $181 $— $— $181 $169 $— $— $169 Equity Securities, at Cost Federal Reserve Bank stock $463 $— $— $463 $463 $— $— $463 Federal Home Loan Bank stock 364 — — 364 252 — — 252 Other equity securities 7 — — 7 7 — — 7 Total equity securities, at cost $834 $— $— $834 $722 $— $— $722
Schedule of investments classified by maturity date	The amortized cost and fair value of debt securities by contractual maturity 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. 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 $24 $— $— $— $24 State and political subdivisions — — — 5 5 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — 281 1,540 18,390 20,211 Other/non-agency 1 10 — 225 236 Total debt securities available for sale 25 291 1,540 18,620 20,476 Debt securities held to maturity: Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — — — 3,425 3,425 Other/non-agency — — — 740 740 Total debt securities held to maturity — — — 4,165 4,165 Total amortized cost of debt securities $25 $291 $1,540 $22,785 $24,641 Fair Value: Debt securities available for sale U.S. Treasury and other $24 $— $— $— $24 State and political subdivisions — — — 5 5 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — 274 1,505 17,855 19,634 Other/non-agency 1 10 — 221 232 Total debt securities available for sale 25 284 1,505 18,081 19,895 Debt securities held to maturity Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — — — 3,293 3,293 Other/non-agency — — — 748 748 Total debt securities held to maturity — — — 4,041 4,041 Total fair value of debt securities $25 $284 $1,505 $22,122 $23,936
Schedule of income recognized on investment securities	Realized gains and losses on securities are presented below: Year Ended December 31, (in millions) 2018 2017 2016 Gains on sale of debt securities $19 $11 $18 Losses on sale of debt securities — — (2 ) Debt securities gains, net $19 $11 $16 Equity securities gains $— $1 $3
Schedule of financial instruments owned and pledged as collateral	The amortized cost and fair value of debt securities pledged are presented below: December 31, 2018 December 31, 2017 (in millions) Amortized Cost Fair Value Amortized Cost Fair Value Pledged against repurchase agreements $344 $338 $358 $357 Pledged against FHLB borrowed funds 745 752 839 861 Pledged against derivatives, to qualify for fiduciary powers, and to secure public and other deposits as required by law 3,592 3,460 3,113 3,082
Other than temporary impairment recognized in earnings	The following table presents the net securities impairment losses recognized in earnings: Year Ended December 31, (in millions) 2018 2017 2016 Other-than-temporary impairment: Total other-than-temporary impairment losses ($7 ) ($7 ) ($39 ) Portions of loss recognized in other comprehensive income (before taxes) 4 — 27 Net securities impairment losses recognized in earnings ($3 ) ($7 ) ($12 )
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: December 31, 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 166 $4,881 ($89 ) 429 $15,124 ($648 ) 595 $20,005 ($737 ) Other/non-agency 10 139 (1 ) 11 72 (6 ) 21 211 (7 ) Total 176 $5,020 ($90 ) 440 $15,196 ($654 ) 616 $20,216 ($744 ) 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: Year Ended December 31, (in millions) 2018 2017 2016 Cumulative balance at beginning of period $80 $75 $66 Credit impairments recognized in earnings on debt securities that have been previously impaired 3 7 12 Reductions due to increases in cash flow expectations on impaired debt securities (1) (2 ) (2 ) (3 ) Cumulative balance at end of period $81 $80 $75 (1) Reported in interest income from investment securities on the Consolidated Statements of Operations.

LOANS AND LEASES (Tables)

LOANS AND LEASES (Tables)	12 Months Ended
	Dec. 31, 2018
Receivables [Abstract]
Schedule of loans and leases	A summary of the loans and leases portfolio is presented below: December 31, (in millions) 2018 2017 Commercial $40,857 $37,562 Commercial real estate 13,023 11,308 Leases 2,903 3,161 Total commercial loans and leases 56,783 52,031 Residential mortgages 18,978 17,045 Home equity loans 1,073 1,392 Home equity lines of credit 12,710 13,483 Home equity loans serviced by others 399 542 Home equity lines of credit serviced by others 104 149 Automobile 12,106 13,204 Education 8,900 8,134 Credit cards 1,991 1,848 Other retail 3,616 2,789 Total retail loans 59,877 58,586 Total loans and leases (1)(2) $116,660 $110,617 (1) Excluded from the table above are loans held for sale totaling $1.3 billion and $718 million as of December 31, 2018 and 2017 , respectively. (2) Mortgage loans serviced for others by the Company’s subsidiaries are not included above, and amounted to $69.6 billion and $20.3 billion at December 31, 2018 and 2017 , respectively.
Schedule of investment in leases, before the ALLL	A summary of the investment in leases, before the ALLL, is presented below: December 31, (in millions) 2018 2017 Direct financing leases $2,863 $3,122 Leveraged leases 40 39 Total leases $2,903 $3,161 The components of the investment in leases, before the ALLL, are presented below: December 31, (in millions) 2018 2017 Total future minimum lease rentals $2,075 $2,347 Estimated residual value of leased equipment (non-guaranteed) 1,091 1,072 Initial direct costs 13 15 Unearned income on minimum lease rentals and estimated residual value of leased equipment (276 ) (273 ) Total leases $2,903 $3,161
Schedule of future minimum lease rentals on direct financing and leveraged leases	The future minimum lease rentals on direct financing and leveraged leases at December 31, 2018 are presented below: Year (in millions) 2019 $589 2020 461 2021 340 2022 258 2023 180 Thereafter 247 Total $2,075

ALLOWANCE FOR CREDIT LOSSES, _2

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK (Tables)	12 Months Ended
	Dec. 31, 2018
Receivables [Abstract]
Schedule of changes in the allowance for credit losses	A summary of changes in the ACL is presented below: Year Ended December 31, 2018 (in millions) Commercial Retail Total Allowance for loan and lease losses, beginning of period $685 $551 $1,236 Charge-offs (52 ) (442 ) (494 ) Recoveries 19 158 177 Net charge-offs (33 ) (284 ) (317 ) Provision charged to income 38 285 323 Allowance for loan and lease losses, end of period 690 552 1,242 Reserve for unfunded lending commitments, beginning of period 88 — 88 Provision for unfunded lending commitments 3 — 3 Reserve for unfunded lending commitments, end of period 91 — 91 Total allowance for credit losses, end of period $781 $552 $1,333 Year Ended December 31, 2017 (in millions) Commercial Retail Total Allowance for loan and lease losses, beginning of period $663 $573 $1,236 Charge-offs (75 ) (437 ) (512 ) Recoveries 40 167 207 Net charge-offs (35 ) (270 ) (305 ) Provision charged to income (1) 57 248 305 Allowance for loan and lease losses, end of period 685 551 1,236 Reserve for unfunded lending commitments, beginning of period 72 — 72 Provision for unfunded lending commitments 16 — 16 Reserve for unfunded lending commitments, end of period 88 — 88 Total allowance for credit losses, end of period $773 $551 $1,324 (1) Includes an increase of approximately $50 million to commercial and corresponding decrease to retail for the impact of the enhancement to the assessment of qualitative risks, factors and events that may not be measured in the modeled results. Year Ended December 31, 2016 (in millions) Commercial Retail Total Allowance for loan and lease losses, beginning of period $596 $620 $1,216 Charge-offs (79 ) (457 ) (536 ) Recoveries 33 168 201 Net charge-offs (46 ) (289 ) (335 ) Provision charged to income 113 242 355 Allowance for loan and lease losses, end of period 663 573 1,236 Reserve for unfunded lending commitments, beginning of period 58 — 58 Provision for unfunded lending commitments 14 — 14 Reserve for unfunded lending commitments, end of period 72 — 72 Total allowance for credit losses, end of period $735 $573 $1,308
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: December 31, 2018 December 31, 2017 (in millions) Commercial Retail Total Commercial Retail Total Individually evaluated $391 $723 $1,114 $370 $761 $1,131 Formula-based evaluation 56,392 59,154 115,546 51,661 57,825 109,486 Total loans and leases $56,783 $59,877 $116,660 $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: December 31, 2018 December 31, 2017 (in millions) Commercial Retail Total Commercial Retail Total Individually evaluated $38 $26 $64 $47 $34 $81 Formula-based evaluation 743 526 1,269 726 517 1,243 Allowance for credit losses $781 $552 $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: December 31, 2018 Criticized (in millions) Pass Special Mention Substandard Doubtful Total Commercial $38,600 $1,231 $828 $198 $40,857 Commercial real estate 12,523 412 82 6 13,023 Leases 2,823 39 41 — 2,903 Total commercial loans and leases $53,946 $1,682 $951 $204 $56,783 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: December 31, 2018 Days Past Due (in millions) Current 1-29 30-59 60-89 90 or More Total Residential mortgages $18,664 $131 $37 $13 $133 $18,978 Home equity loans 945 75 12 3 38 1,073 Home equity lines of credit 12,042 386 65 22 195 12,710 Home equity loans serviced by others 355 21 7 3 13 399 Home equity lines of credit serviced by others 79 15 2 1 7 104 Automobile 10,729 1,039 207 59 72 12,106 Education 8,694 159 23 13 11 8,900 Credit cards 1,894 53 14 10 20 1,991 Other retail 3,481 76 26 18 15 3,616 Total retail loans $56,883 $1,955 $393 $142 $504 $59,877 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 (1) Accruing and 90 days or more past due (in millions) December 31, 2018 December 31, 2017 December 31, 2018 December 31, 2017 Commercial $194 $238 $1 $5 Commercial real estate 7 27 — 3 Leases — — — — Total commercial loans and leases 201 265 1 8 Residential mortgages (1) 136 128 15 16 Home equity loans 50 72 — — Home equity lines of credit 231 233 — — Home equity loans serviced by others 17 25 — — Home equity lines of credit serviced by others 15 18 — — Automobile 81 70 — — Education 38 38 2 3 Credit card 20 17 — — Other retail 8 5 7 5 Total retail loans 596 606 24 24 Total $797 $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 $12 million and $15 million as of December 31, 2018 and 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 $133 million and $30 million as of December 31, 2018 and 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: December 31, 2018 2017 Nonperforming commercial loans and leases as a percentage of total loans and leases 0.17 % 0.24 % Nonperforming retail loans as a percentage of total loans and leases 0.51 0.55 Total nonperforming loans and leases as a percentage of total loans and leases 0.68 % 0.79 % Nonperforming commercial assets as a percentage of total assets 0.13 % 0.17 % Nonperforming retail assets as a percentage of total assets 0.39 0.43 Total nonperforming assets as a percentage of total assets 0.52 % 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: December 31, 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 $85 $3 $78 $166 $26 $4 $243 $273 Commercial real estate 8 32 5 45 38 20 30 88 Leases 7 — — 7 4 1 — 5 Total commercial loans and leases 100 35 83 218 68 25 273 366 Residential mortgages 37 13 133 183 46 18 120 184 Home equity loans 12 3 38 53 20 4 54 78 Home equity lines of credit 65 22 195 282 78 23 188 289 Home equity loans serviced by others 7 3 13 23 10 4 22 36 Home equity lines of credit serviced by others 2 1 7 10 4 1 7 12 Automobile 207 59 72 338 220 55 60 335 Education 23 13 11 47 23 12 41 76 Credit cards 14 10 20 44 12 9 17 38 Other retail 26 18 15 59 20 12 10 42 Total retail loans 393 142 504 1,039 433 138 519 1,090 Total $493 $177 $587 $1,257 $501 $163 $792 $1,456
Schedule of impaired loans by class	A summary of impaired loans by class is presented below: December 31, 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 $186 $31 $167 $450 $353 Commercial real estate 32 7 6 38 38 Leases — — — — — Total commercial loans and leases 218 38 173 488 391 Residential mortgages 28 2 127 201 155 Home equity loans 34 3 76 148 110 Home equity lines of credit 21 1 181 244 202 Home equity loans serviced by others 22 1 19 54 41 Home equity lines of credit serviced by others 1 — 7 11 8 Automobile 1 — 22 31 23 Education 130 11 23 153 153 Credit cards 24 7 1 25 25 Other retail 4 1 2 8 6 Total retail loans 265 26 458 875 723 Total $483 $64 $631 $1,363 $1,114 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: Year Ended December 31, 2018 2017 2016 (in millions) Interest Income Recognized Average Recorded Investment Interest Income Recognized Average Recorded Investment Interest Income Recognized Average Recorded Investment Commercial $9 $312 $4 $380 $5 $295 Commercial real estate 1 32 — 37 — 53 Leases — — — — — 3 Total commercial loans and leases 10 344 4 417 5 351 Residential mortgages 5 146 4 136 4 161 Home equity loans 6 107 6 121 7 144 Home equity lines of credit 7 181 6 176 6 178 Home equity loans serviced by others 3 42 3 49 3 60 Home equity lines of credit serviced by others — 9 — 9 — 9 Automobile 1 20 1 18 — 14 Education 8 154 9 173 7 150 Credit cards 1 21 2 22 2 23 Other retail — 7 — 9 1 12 Total retail loans 31 687 31 713 30 751 Total $41 $1,031 $35 $1,130 $35 $1,102
Troubled debt restructurings on financing receivables	The table below summarizes TDRs by class and total unfunded commitments: December 31, (in millions) 2018 2017 Commercial $304 $129 Retail 723 761 Unfunded commitments related to TDRs 30 39 The table below summarizes how loans were modified during the year ended December 31, 2018 , the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during 2018 and were paid off in full, charged off, or sold prior to December 31, 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 7 $1 $1 49 $23 $22 Commercial real estate — — — 3 31 31 Total commercial loans 7 1 1 52 54 53 Residential mortgages 35 4 4 61 8 8 Home equity loans 43 3 4 1 — — Home equity lines of credit 76 6 7 178 25 26 Home equity loans serviced by others 4 — — — — — Home equity lines of credit serviced by others 5 — — 1 — — Automobile 158 4 3 46 1 1 Education — — — — — — Credit cards 2,312 13 13 — — — Other retail 1 — — — — — Total retail loans 2,634 30 31 287 34 35 Total 2,641 $31 $32 339 $88 $88 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 53 $202 $200 $— $— Commercial real estate 2 31 31 — — Total commercial loans 55 233 231 — — Residential mortgages 142 17 17 (1 ) — Home equity loans 134 5 5 — — Home equity lines of credit 413 29 29 — 1 Home equity loans serviced by others 23 1 1 — — Home equity lines of credit serviced by others 14 1 1 — — Automobile 1,189 21 17 — 4 Education 355 7 7 1 — Credit cards — — — 4 — Other retail 9 — — (1 ) — Total retail loans 2,279 81 77 3 5 Total 2,334 $314 $308 $3 $5 (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 year ended December 31, 2017 , the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during 2017 and were paid off in full, charged off, or sold prior to December 31, 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 $1 $1 45 $22 $22 Commercial real estate — — — 1 — — Total commercial loans 7 1 1 46 22 22 Residential mortgages 71 9 10 73 12 13 Home equity loans 82 5 6 1 — — Home equity lines of credit 50 3 3 235 30 30 Home equity loans serviced by others 15 1 1 — — — Home equity lines of credit serviced by others 5 — — 2 — — Automobile 130 2 2 29 1 1 Education — — — — — — Credit cards 2,363 13 13 — — — Other retail 1 — — — — — Total retail loans 2,717 33 35 340 43 44 Total 2,724 $34 $36 386 $65 $66 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 15 $70 $71 ($1 ) $— Commercial real estate 1 — — — — Total commercial loans 16 70 71 (1 ) — Residential mortgages 171 19 19 (1 ) — Home equity loans 232 13 13 — — Home equity lines of credit 395 27 27 — 1 Home equity loans serviced by others 52 2 2 — — Home equity lines of credit serviced by others 26 2 2 — — Automobile 1,336 24 20 — 4 Education 329 7 7 2 — Credit cards — — — 3 — Other retail 5 — — (2 ) — Total retail loans 2,546 94 90 2 5 Total 2,562 $164 $161 $1 $5 (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 year ended December 31, 2016 , the charge-offs related to the modifications, and the impact on the ALLL. The reported balances can include loans that became TDRs during 2016 and were paid off in full, charged off, or sold prior to December 31, 2016 . 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 12 $1 $1 81 $20 $21 Commercial real estate 1 — — 1 5 5 Total commercial loans 13 1 1 82 25 26 Residential mortgages 71 10 10 60 10 10 Home equity loans 97 6 6 39 4 5 Home equity lines of credit 49 4 4 121 13 12 Home equity loans serviced by others 18 1 1 — — — Home equity lines of credit serviced by others 8 — — 5 1 1 Automobile 138 3 3 41 1 1 Education — — — — — — Credit cards 2,187 12 12 — — — Other retail 4 — — — — — Total retail loans 2,572 36 36 266 29 29 Total 2,585 $37 $37 348 $54 $55 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 14 $48 $48 $3 $— Commercial real estate — — — — — Total commercial loans 14 48 48 3 — Residential mortgages 247 26 26 (1 ) — Home equity loans 279 18 17 (1 ) — Home equity lines of credit 304 23 22 — 1 Home equity loans serviced by others 60 2 2 — — Home equity lines of credit serviced by others 24 1 1 — — Automobile 1,081 20 18 — 3 Education 479 12 12 4 — Credit cards — — — 3 — Other retail 13 — — — — Total retail loans 2,487 102 98 5 4 Total 2,501 $150 $146 $8 $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 2018 , 2017 and 2016 . 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. Loan data includes loans meeting the criteria that were paid off in full, charged off, or sold prior to December 31, 2018 and 2017 . 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. Year Ended December 31, 2018 2017 2016 (dollars in millions) Number of Contracts Balance Defaulted Number of Contracts Balance Defaulted Number of Contracts Balance Defaulted Commercial 28 $63 8 $5 22 $13 Commercial real estate 1 — 1 4 1 — Total commercial loans 29 63 9 9 23 13 Residential mortgages 128 15 152 19 187 24 Home equity loans 31 2 43 2 50 3 Home equity lines of credit 238 18 200 14 155 13 Home equity loans serviced by others 15 — 23 — 37 1 Home equity lines of credit serviced by others 6 — 10 1 17 — Automobile 167 2 140 1 110 2 Education 23 1 44 1 59 1 Credit cards 465 2 491 3 433 3 Other retail 1 — 4 — 3 — Total retail loans 1,074 40 1,107 41 1,051 47 Total 1,103 $103 1,116 $50 1,074 $60
Schedule of loans that may increase credit exposure	The following tables present balances of loans with these characteristics: December 31, 2018 (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 $318 $87 $148 $— $— $553 Interest only/negative amortization 1,794 — — — 1 1,795 Low introductory rate — — — 217 — 217 Multiple characteristics and other 1 — — — — 1 Total $2,113 $87 $148 $217 $1 $2,566 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

PREMISES, EQUIPMENT, AND SOFT_2

PREMISES, EQUIPMENT, AND SOFTWARE (Tables)	12 Months Ended
	Dec. 31, 2018
Property, Plant and Equipment [Abstract]
Summary of the carrying value of premises and equipment	A summary of the carrying value of premises and equipment is presented below: December 31, (dollars in millions) Useful Lives (years) 2018 2017 Land and land improvements 10 - 75 $112 $47 Buildings and leasehold improvements 5 - 60 852 719 Furniture, fixtures and equipment 5 - 20 1,019 1,465 Construction in progress 292 359 Total premises and equipment, gross 2,275 2,590 Accumulated depreciation (1,484 ) (1,905 ) Total premises and equipment, net $791 $685
Schedule of estimated future amortization expense for capitalized software assets	The estimated future amortization expense for capitalized software assets is presented below: Year (in millions) 2019 $186 2020 155 2021 116 2022 80 2023 48 Thereafter 72 Total (1) $657 (1) Excluded from this balance is $188 million of in-process software at December 31, 2018 .

LEASE COMMITMENTS (Tables)

LEASE COMMITMENTS (Tables)	12 Months Ended
	Dec. 31, 2018
Leases [Abstract]
Schedule of aggregate minimum rental commitments	At December 31, 2018 , the aggregate minimum rental commitments under these non-cancelable operating leases and capital leases, exclusive of renewals, are presented below for the years ended December 31: (in millions) Operating Leases Capital Leases 2019 $165 $3 2020 153 2 2021 136 2 2022 109 1 2023 85 — Thereafter 247 8 Total minimum lease payments $895 $16 Amounts representing interest — (8 ) Present value of net minimum lease $895 $8

MORTGAGE BANKING (Tables)

MORTGAGE BANKING (Tables)	12 Months Ended
	Dec. 31, 2018
Mortgage Banking [Abstract]
Schedule of mortgage banking activities	The following table summarizes activity related to the Company’s residential mortgage loan sales and the Company's mortgage banking activity: Year Ended December 31, (in millions) 2018 2017 2016 Residential mortgage loan sold with servicing retained $8,149 $3,161 $2,652 Gain on sales (1) 89 35 69 Contractually specified servicing, late and other ancillary fees (1) 118 53 51 (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 Year Ended December 31, (in millions) 2018 2017 MSRs: Balance as of beginning of period $201 $167 Amount capitalized 36 37 Purchases 16 28 Amortization (32 ) (31 ) Carrying amount before valuation allowance 221 201 Valuation allowance for servicing assets: Balance as of beginning of period 3 5 Valuation recoveries (3 ) (2 ) Balance at end of period — 3 Net carrying value of MSRs $221 $198
Servicing asset at amortized cost	As of and for the Year Ended December 31, (in millions) 2018 2017 MSRs: Balance as of beginning of period $201 $167 Amount capitalized 36 37 Purchases 16 28 Amortization (32 ) (31 ) Carrying amount before valuation allowance 221 201 Valuation allowance for servicing assets: Balance as of beginning of period 3 5 Valuation recoveries (3 ) (2 ) Balance at end of period — 3 Net carrying value of MSRs $221 $198
Servicing asset at fair value	As of and for the Year Ended December 31, 2018 (in millions) MSRs: Fair value as of beginning of the period $— Acquired MSRs 590 Amounts capitalized 73 Changes in unpaid principal balance during the period (1) (32 ) Changes in fair value during the period (2) (31 ) Fair value at end of the period $600 (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: December 31, 2018 December 31, 2017 Actual Decline in fair value due to Actual Decline in fair value due to (dollars in millions) Fair value $243 50 bps adverse change 100 bps adverse change $218 50 bps adverse change 100 bps adverse change Weighted average life (in years) 6.5 5.9 Weighted average constant prepayment rate 8.5% $24 $56 10.0% $22 $46 Weighted average discount rate 9.3% 5 9 9.9% 4 8 For MSRs under the fair value method, the key economic assumptions used to estimate the fair value are presented below: December 31, 2018 Actual Decline in fair value due to (dollars in millions) Fair value $600 50 bps adverse change 100 bps adverse change Weighted average life (in years) 8.0 Weighted average constant prepayment rate 8.2% $68 $148 Weighted average option adjusted spread 609 bps 13 26

GOODWILL AND INTANGIBLE ASSETS

GOODWILL AND INTANGIBLE ASSETS (Tables)	12 Months Ended
	Dec. 31, 2018
Goodwill and Intangible Assets Disclosure [Abstract]
Schedule of goodwill	Changes in the carrying value of goodwill for the years ended December 31, 2018 and 2017 are presented below: (in millions) Consumer Banking Commercial Banking Total Balance at December 31, 2016 $2,136 $4,740 $6,876 Business acquisition — 11 11 Balance at December 31, 2017 $2,136 $4,751 $6,887 Business acquisition 59 — 59 Adjustments (1) (23 ) — (23 ) Balance at December 31, 2018 $2,172 $4,751 $6,923 (1) Adjustments to goodwill are the result of an update to the purchase price allocation for the FAMC acquisition, given higher value attributed to purchased net assets.
Carrying value of intangible assets	A summary of the carrying value of intangible assets is presented below. Included in the carrying value at December 31, 2018 are $30 million in other intangibles, net of $2 million of amortization expense, related to the FAMC acquisition. December 31, 2018 December 31, 2017 (in millions) Amortizable Lives (years) Gross Accumulated Amortization Net Gross Accumulated Amortization Net Acquired technology 7 $20 $1 $19 $— $— $— Acquired relationships 5 - 15 11 1 10 2 — 2 Other 2 - 3 3 1 2 — — — Total $34 $3 $31 $2 $— $2
Intangible assets future amortization expense	Estimated intangible asset amortization expense for the next five years is as follows: (in millions) Total 2019 $5 2020 5 2021 4 2022 3 2023 3

VARIABLE INTEREST ENTITIES VARI

VARIABLE INTEREST ENTITIES VARIABLE INTEREST ENTITIES (Tables)	12 Months Ended
	Dec. 31, 2018
Variable Interest Entities [Abstract]
Schedule of Variable Interest Entities	A summary of these investments is presented below: December 31, (in millions) 2018 2017 LIHTC investment included in other assets $1,236 $951 LIHTC unfunded commitments included in other liabilities 673 491 Renewable energy investments included in other assets 319 335 Lending to special purpose entities included in loans and leases 613 —
Schedule of Affordable Housing Tax Credit Investments	The following table presents other information related to the Company’s affordable housing tax credit investments: Year Ended December 31, (in millions) 2018 2017 2016 Tax credits included in income tax expense $101 $83 $59 Amortization expense included in income tax expense 110 94 59 Other tax benefits included in income tax expense 25 31 21

DEPOSITS (Tables)

DEPOSITS (Tables)	12 Months Ended
	Dec. 31, 2018
Banking and Thrift [Abstract]
Schedule of the major components of deposits	The major components of deposits are presented below: December 31, (in millions) 2018 2017 Demand $29,458 $29,279 Checking with interest 23,067 22,229 Regular savings 12,007 9,518 Money market accounts 35,701 37,454 Term deposits 19,342 16,609 Total deposits $119,575 $115,089
Schedule of maturity distribution of term deposits	The maturity distribution of term deposits as of December 31, 2018 is presented below: Year (in millions) 2019 $15,889 2020 2,519 2021 649 2022 174 2023 106 2024 and thereafter 5 Total $19,342
Schedule of maturities of term deposits greater than $100,000	The remaining maturities of these deposits are presented below: (in millions) Three months or less $5,388 After three months through six months 2,676 After six months through twelve months 3,844 After twelve months 1,936 Total term deposits $13,844

BORROWED FUNDS (Tables)

BORROWED FUNDS (Tables)	12 Months Ended
	Dec. 31, 2018
Debt Disclosure [Abstract]
Schedule of short-term borrowed funds	A summary of the Company’s short-term borrowed funds is presented below: December 31, (in millions) 2018 2017 Federal funds purchased $820 $460 Securities sold under agreements to repurchase 336 355 Other short-term borrowed funds (1) 1,653 1,856 Total short-term borrowed funds $2,809 $2,671 (1) December 31, 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 ($8) 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 Year Ended December 31, (dollars in millions, except ratio data) 2018 2017 2016 Weighted-average interest rate at year-end: (1) Federal funds purchased and securities sold under agreements to repurchase 1.72 % 0.74 % 0.26 % Other short-term borrowed funds 2.50 1.72 0.94 Maximum amount outstanding at any month-end during the year: Federal funds purchased and securities sold under agreements to repurchase (2) $1,282 $1,174 $1,522 Other short-term borrowed funds 2,509 3,508 5,461 Average amount outstanding during the year: Federal funds purchased and securities sold under agreements to repurchase (2) $654 $776 $947 Other short-term borrowed funds 1,808 2,321 3,207 Weighted-average interest rate during the year: (1) Federal funds purchased and securities sold under agreements to repurchase 0.92 % 0.36 % 0.09 % Other short-term borrowed funds 2.42 1.32 0.64 (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: December 31, (in millions) 2018 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) (3) — 743 2.500% senior unsecured notes, due 2019 (2) (3) — 741 2.250% senior unsecured notes, due 2020 (2) 691 692 3.278% floating-rate senior unsecured notes, due 2020 (2) (4) 300 299 3.247% floating-rate senior unsecured notes, due 2020 (2) (4) 250 249 2.200% senior unsecured notes, due 2020 (2) 499 498 2.250% senior unsecured notes, due 2020 (2) 738 742 2.550% senior unsecured notes, due 2021 (2) 964 964 3.487% floating-rate senior unsecured notes, due 2022 (2) (4) 249 249 2.650% senior unsecured notes, due 2022 (2) 487 491 3.700% senior unsecured notes, due 2023 (2) 502 — 3.753% floating-rate senior unsecured notes, due 2023 (2) (4) 249 — Federal Home Loan Bank advances, 2.725% weighted average rate, due through 2038 7,508 3,761 Other 9 16 Total long-term borrowed funds $14,433 $11,765 (1) Redeemed on June 29, 2018. (2) Issued under CBNA’s Global Bank Note Program. (3) Reclassified to short-term borrowed funds. (4) Rate disclosed reflects the floating rate as of December 31, 2018.
Schedule of maturities of long-term borrowed funds	A summary of maturities for the Company’s long-term borrowed funds at December 31, 2018 is presented below: (in millions) Parent Company Banking Subsidiaries Consolidated Year 2019 $— $— $— 2020 — 9,982 9,982 2021 349 967 1,316 2022 348 739 1,087 2023 — 751 751 2024 and thereafter 1,290 7 1,297 Total $1,987 $12,446 $14,433

DERIVATIVES (Tables)

DERIVATIVES (Tables)	12 Months Ended
	Dec. 31, 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: December 31, 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 $12,050 $5 $— $13,300 $— $— Derivatives not designated as hedging instruments: Interest rate contracts 117,076 301 277 80,180 538 379 Foreign exchange contracts 9,866 129 113 9,882 148 149 Other contracts 3,555 14 25 1,039 7 5 Total derivatives not designated as hedging instruments 444 415 693 533 Gross derivative fair values 449 415 693 533 Less: Gross amounts offset in the Consolidated Balance Sheets (2) (87 ) (87 ) (72 ) (72 ) Less: Cash collateral applied (2) (45 ) (36 ) (4 ) (151 ) Total net derivative fair values presented in the Consolidated Balance Sheets $317 $292 $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 as well as collateral paid and received.
Schedule of fair value hedges	The following table presents the effect on other income of fair value hedges, specifically hedges of interest rate risk on borrowings using interest rate swaps, described above, in millions: Amounts Recognized in Other Income for the Year Ended December 31, 2018 2017 2016 Derivative Hedged Item Hedge Ineffectiveness Derivative Hedged Item Hedge Ineffectiveness Derivative Hedged Item Hedge Ineffectiveness $8 ($9 ) ($1 ) ($26 ) $27 $1 ($6 ) $5 ($1 )
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 Year Ended December 31, (in millions) 2018 2017 2016 Effective portion of loss recognized in OCI (1) ($44 ) ($23 ) ($100 ) Amount of net (loss) gain reclassified from OCI to interest income (2) (55 ) 25 90 Amount of net gain (loss) reclassified from OCI to interest expense (2) 12 — (27 ) Amounts reclassified from OCI to other income (3) — — (5 ) (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. (3) This includes gains and losses attributable to previously hedged cash flows where the likelihood occurrence of those cash flows is no longer probable.
Schedule of effect of derivative Instruments on net income	The following table presents the effect of economic hedges on noninterest income: Affected Line Item in the Consolidated Statements of Operations Amounts Recognized in Noninterest Income for the Year Ended December 31, (in millions) 2018 2017 2016 Economic Hedge Type Customer interest rate contracts Foreign exchange and interest rate products $5 $5 ($23 ) Customer foreign exchange contracts Foreign exchange and interest rate products (54 ) 172 (81 ) Derivatives transactions to hedge interest rate risk Foreign exchange and interest rate products 43 46 70 Derivatives transactions to hedge foreign exchange risk Foreign exchange and interest rate products 158 (151 ) 95 Residential loan commitments Mortgage banking fees (3 ) 2 (2 ) Forward sale contracts Mortgage banking fees 21 (8 ) 6 Interest rate derivative contracts used to hedge residential MSRs Mortgage banking fees 35 — — Total $205 $66 $65

EMPLOYEE BENEFITS (Tables)

EMPLOYEE BENEFITS (Tables)	12 Months Ended
	Dec. 31, 2018
Defined Benefit Plans and Other Postretirement Benefit Plans Table Text Block [Line Items]
Schedule of Allocation of Plan Assets	The following table presents qualified pension plan assets measured at fair value within the fair value hierarchy: Fair Value Measurements as of December 31, 2018 (in millions) Total Level 1 Level 2 Level 3 Assets: Cash and money market funds $12 $12 $— $— Managed portfolio assets: U.S. government obligations 5 5 — — Non-U.S. government obligations 1 — 1 — Municipal obligations 1 — 1 — Corporate bonds 99 — 99 — Bank loans 1 — 1 — Total assets in the fair value hierarchy 119 17 102 — Investments measured at net asset value (1) 931 Assets at fair value at measurement date of December 31, 2018 $1,050 $17 $102 $— (1) Certain investments that were measured at net asset value per share (or its equivalent) have not been classified in the fair value hierarchy. The following table presents qualified pension plan assets measured at fair value within the fair value hierarchy: Fair Value Measurements as of December 31, 2017 (in millions) Total Level 1 Level 2 Level 3 Assets: Managed portfolio assets U.S. government obligations $8 $— $8 $— Non-U.S. government obligations 2 — 2 — Municipal obligations 1 — 1 — Corporate bonds 102 — 102 — Asset-backed securities 1 — 1 — Total assets in the fair value hierarchy 114 — 114 — Investments measured at net asset value (1) 1,024 Assets at fair value at measurement date of December 31, 2017 $1,138 $— $114 $— (1) Certain investments that were measured at net asset value per share (or its equivalent) have not been classified in the fair value hierarchy.
Changes in Projected Benefit Obligations, Fair Value of Plan Assets, and Funded Status of Plan	Changes in the fair value of defined benefit pension plan assets, projected benefit obligation, funded status, and accumulated benefit obligation are presented below: Year Ended December 31, Qualified Plan Non-Qualified Plan (in millions) 2018 2017 2018 2017 Fair value of plan assets as of January 1 $1,139 $1,015 $— $— Actual return on plan assets (81 ) 185 — — Employer contributions 50 — 8 8 Benefits and administrative expenses paid (58 ) (61 ) (8 ) (8 ) Fair value of plan assets as of December 31 1,050 1,139 — — Projected benefit obligation 972 1,089 95 106 Pension asset (obligation) $78 $50 ($95 ) ($106 ) Accumulated benefit obligation $972 $1,089 $95 $106
Schedule of Amounts Recognized in Other Comprehensive Income (Loss)	Other changes in plan assets and benefit obligations recognized in OCI (for the qualified, non-qualified and postretirement plans) are presented below: Year Ended December 31, (in millions) 2018 2017 2016 Net periodic pension income ($16 ) ($2 ) ($1 ) Net actuarial loss (gain) 49 (31 ) 54 Amortization of prior service credit 1 1 1 Amortization of net actuarial loss (17 ) (18 ) (16 ) Total recognized in other comprehensive income (loss) 33 (48 ) 39 Total recognized in net periodic pension cost and other comprehensive income (loss) $17 ($50 ) $38
Schedule of net periodic (income) cost	The components of net periodic pension (income) cost for the Company’s qualified and non-qualified plans are presented below: Year Ended December 31, Qualified Plan Non-Qualified Plan Total (in millions) 2018 2017 2016 2018 2017 2016 2018 2017 2016 Service cost $3 $3 $3 $— $— $— $3 $3 $3 Interest cost 39 42 44 4 4 4 43 46 48 Expected return on plan assets (79 ) (69 ) (68 ) — — — (79 ) (69 ) (68 ) Amortization of actuarial loss 15 16 14 2 2 2 17 18 16 Net periodic pension (income) cost (1) ($22 ) ($8 ) ($7 ) $6 $6 $6 ($16 ) ($2 ) ($1 ) (1) In the Consolidated Statements of Operations, service cost is presented in salaries and employee benefits, and all other components of net periodic pension (income) costs are presented in other operating expense.
Schedule of Expected Benefit Payments	Expected future benefit payments for the qualified and non-qualified plans are presented below: (in millions) Expected benefit payments by fiscal year ending: December 31, 2019 $64 December 31, 2020 64 December 31, 2021 65 December 31, 2022 66 December 31, 2023 67 December 31, 2024 - 2028 340
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share	The following table presents the unfunded commitments, redemption frequency and redemption notice period for Plan investments that utilize net asset value to determine fair value: Fair Value Estimated Using Net Asset Value per Share December 31, Unfunded Redemption Redemption Redemption Investment (dollars in millions) 2018 2017 Commitment Frequency Restrictions Notice Period Liquid Cash Fund $— $11 $— Daily None Same day before 5:30pm ET Common and Collective Funds: Global equities funds 399 472 — Daily None 3 days Balanced funds 221 214 — Daily None 2 days Fixed income fund 139 150 — Daily None 3 days Managed Portfolio - Fixed Income Mutual Fund (1) 32 35 — Daily None 1 days Limited Partnerships: Global equity fund 140 142 — Monthly None 3 days Total $931 $1,024 $— (1) The managed portfolio fixed income mutual fund seeks to outperform the Barclay’s U.S. Long Credit Index or similar benchmark.
Qualified Plan
Defined Benefit Plans and Other Postretirement Benefit Plans Table Text Block [Line Items]
Schedule of Allocation of Plan Assets	The qualified plan’s allocation by asset category is presented below: Target Asset Allocation Actual Asset Allocation Asset Category 2018 2018 2017 Equity securities 53% 51.3 % 54.0 % Debt securities 46% 47.6 % 45.0 % Other 1% 1.1 % 1.0 % Total 100.0 % 100.0 %
Postretirement Benefit Plan
Defined Benefit Plans and Other Postretirement Benefit Plans Table Text Block [Line Items]
Assumptions Used in Determining Benefit Obligations and Net Periodic Benefit Cost	Weighted-average rates assumed in determining the net periodic benefit cost of the postretirement benefits plan are as follows: For the Year Ended December 31, (dollars in millions) 2018 2017 Discount rate 3.200 % 3.530 % Rate of compensation increase N/A N/A
Schedule of Expected Benefit Payments	Expected future benefit payments for the postretirement benefit plan are presented below: (in millions) Expected benefit payments by fiscal year ending: December 31, 2019 $1 December 31, 2020 1 December 31, 2021 1 December 31, 2022 1 December 31, 2023 1 December 31, 2024 - 2028 5
Qualified and Non-Qualified Plans
Defined Benefit Plans and Other Postretirement Benefit Plans Table Text Block [Line Items]
Assumptions Used in Determining Benefit Obligations and Net Periodic Benefit Cost	Weighted-average rates assumed in determining the actuarial present value of benefit obligations and net periodic benefit cost are presented below: As of and for the Year Ended December 31, 2018 2017 2016 Assumptions for benefit obligations Discount rate-qualified plan 4.330 % 3.670 % 4.190 % Discount rate-non-qualified plan 4.240 % 3.530 % 4.050 % Expected long-term rate of return on plan assets 7.000 % 7.000 % 7.500 % Assumptions for net periodic pension cost Discount rate-qualified plan 3.670 % 4.190 % 4.640 % Discount rate-non-qualified plan 3.530 % 4.050 % 4.540 % Expected long-term rate of return on plan assets 7.000 % 7.000 % 7.500 %

RECLASSIFICATIONS OUT OF ACCU_2

RECLASSIFICATIONS OUT OF ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS) (Tables)	12 Months Ended
	Dec. 31, 2018
Equity [Abstract]
Schedule of other comprehensive income	The following table presents the changes in the balances, net of income taxes, of each component of AOCI: (in millions) Net Unrealized (Losses) Gains on Derivatives Net Unrealized (Losses) Gains on Securities Employee Benefit Plans Total AOCI Balance at January 1, 2016 $10 ($28 ) ($369 ) ($387 ) Other comprehensive loss before reclassifications (62 ) (139 ) — (201 ) Other-than-temporary impairment not recognized in earnings on debt securities — (17 ) — (17 ) Amounts reclassified to the Consolidated Statements of Operations (36 ) (2 ) (25 ) (63 ) Net other comprehensive loss (98 ) (158 ) (25 ) (281 ) Balance at December 31, 2016 ($88 ) ($186 ) ($394 ) ($668 ) Other comprehensive loss before reclassifications (14 ) (6 ) — (20 ) Amounts reclassified to the Consolidated Statements of Operations (16 ) (2 ) 31 13 Net other comprehensive loss (30 ) (8 ) 31 (7 ) Reclassification of tax effects resulting from the 2017 Tax Legislation (1) ($25 ) ($42 ) ($78 ) ($145 ) Balance at December 31, 2017 ($143 ) ($236 ) ($441 ) ($820 ) Other comprehensive loss before reclassifications (33 ) (239 ) — (272 ) Other-than-temporary impairment not recognized in earnings on debt securities — (3 ) — (3 ) Amounts reclassified to the Consolidated Statements of Operations 33 (12 ) (22 ) (1 ) Net other comprehensive loss — (254 ) (22 ) (276 ) Balance at December 31, 2018 ($143 ) ($490 ) ($463 ) ($1,096 ) (1) As of December 31, 2017, the balance of AOCI reflects the retrospective adoption of FASB ASU 2018-02, Income Statement-Reporting Comprehensive Income (Topic 220): Reclassification of Certain Tax Effects from Accumulated Other Comprehensive Income . For further discussion, see Note 22 “Income Taxes.”
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: Year Ended December 31, (in millions) 2018 2017 2016 Details about AOCI Components Affected Line Item in the Consolidated Statements of Operations Reclassification adjustment for net derivative (losses) gains included in net income: ($55 ) $25 $90 Interest income 12 — (27 ) Interest expense — — (5 ) Other income (43 ) 25 58 Income before income tax expense (10 ) 9 22 Income tax expense ($33 ) $16 $36 Net income Reclassification of net securities gains (losses) to net income: $19 $11 $16 Securities gains, net (3 ) (7 ) (12 ) Net debt securities impairment losses recognized in earnings 16 4 4 Income before income tax expense 4 2 2 Income tax expense $12 $2 $2 Net income Reclassification of changes related to the employee benefit plan: $33 ($48 ) $39 Salaries and employee benefits 33 (48 ) 39 Income before income tax expense 11 (17 ) 14 Income tax expense $22 ($31 ) $25 Net income Total reclassification gains (losses) $1 ($13 ) $63 Net income The following table presents the effects on net income of the amounts reclassified out of AOCI: Year Ended December 31, (in millions) 2018 2017 2016 Net interest income (includes ($43), $25 and $63 of AOCI reclassifications, respectively) $4,532 $4,173 $3,758 Provision for credit losses 326 321 369 Noninterest income (includes $16, $4 and ($1) of AOCI reclassifications, respectively) 1,596 1,534 1,497 Noninterest expense (includes ($33), $48 and ($39) of AOCI reclassifications, respectively) 3,619 3,474 3,352 Income before income tax expense 2,183 1,912 1,534 Income tax expense (includes $5, ($6) and $38 income tax net expense from reclassification items, respectively) 462 260 489 Net income $1,721 $1,652 $1,045

STOCKHOLDERS' EQUITY (Tables)

STOCKHOLDERS' EQUITY (Tables)	12 Months Ended
	Dec. 31, 2018
Equity [Abstract]
Schedule of preferred stock	The following table provides the number of authorized preferred shares, the number of issued and outstanding, the liquidation value per share and the carrying amount as of December 31: 2018 2017 (in millions, except per share and share data) Liquidation value per share Preferred Shares Carrying Amount Preferred Shares Carrying Amount Authorized ($25 par value) 100,000,000 100,000,000 Issued and outstanding Series A $1,000 250,000 $247 250,000 $247 Series B 1,000 300,000 296 — — Series C 1,000 300,000 297 — — Total issued and outstanding 850,000 $840 250,000 $247 The following table provides information related to the Company’s preferred stock outstanding as of December 31, 2018: (in millions, except per share and share data) Preferred Stock (1) Issue Date Number of Shares Issued Dividend Dates (2) Annual Per Share Dividend Rate Optional Redemption Date (3) Series A April 6, 2015 250,000 Semi-annually beginning October 6, 2015 until April 6, 2020 5.500% until April 6, 2020 April 6, 2020 Quarterly beginning July 6, 2020 3 Mo. LIBOR plus 3.960% beginning April 6, 2020 Series B May 24, 2018 300,000 Semi-annually beginning January 6, 2019 until July 6, 2023 6.000% until July 6, 2023 July 6, 2023 Quarterly beginning October 6, 2023 3 Mo. LIBOR plus 3.003% beginning July 6, 2023 Series C October 25, 2018 300,000 Quarterly beginning January 6, 2019 until April 6, 2024 6.375% until April 6, 2024 April 6, 2024 Quarterly beginning July 6, 2024 3 Mo. LIBOR plus 3.157% beginning April 6, 2024 (1) All outstanding series are non-cumulative fixed-to-floating rate perpetual preferred stock. Except in limited circumstances, the preferred stock does not have voting rights. (2) Dividends are payable when, and if, declared by the Company’s Board of Directors or an authorized committee thereof. (3) Redeemable at the Company’s option, in whole or in part, on any dividend payment date on or after the date stated, or in whole but not in part, at any time within 90 days following a regulatory capital treatment event a as defined in the applicable certificate of designations, in each case at a redemption price equal to $1,000 per share, plus any declared and unpaid dividends, without accumulation of any undeclared dividends. Under current rules, any redemption is subject to approval by the FRB.
Schedule of dividends	The following table provides information related to dividends per share and in the aggregate, declared and paid, for each type of stock issued and outstanding for the year ended December 31: 2018 2017 2016 (in millions, except per share and share data) Dividends per Share Dividends Declared Dividends Paid Dividends per Share Dividends Declared Dividends Paid Dividends per Share Dividends Declared Dividends Paid Common stock $0.98 $471 $471 $0.64 $322 $322 $0.46 $241 $241 Preferred stock Series A $55.00 $14 $14 $55.00 $14 $14 $55.00 $14 $14 Series B 37.00 11 — — — — — — — Series C 12.57 4 — — — — — — — Total preferred stock $29 $14 $14 $14 $14 $14

SHARE-BASED COMPENSATION (Table

SHARE-BASED COMPENSATION (Tables)	12 Months Ended
	Dec. 31, 2018
Disclosure of Compensation Related Costs, Share-based Payments [Abstract]
Summary of Share-Based Plans Activity	The following table presents the activity related to the Company’s share-based plans (excluding the ESPP) for the year ended December 31, 2018 : Shares Weighted-Average Grant Price Outstanding, January 1 2,621,514 $33.30 Granted 1,174,501 39.54 Vested & Distributed (877,111 ) 30.50 Forfeited (25,623 ) 35.88 Outstanding, December 31 2,893,281 $34.04

COMMITMENTS AND CONTINGENCIES (

COMMITMENTS AND CONTINGENCIES (Tables)	12 Months Ended
	Dec. 31, 2018
Commitments and Contingencies Disclosure [Abstract]
Schedule of outstanding off balance sheet arrangements	A summary of outstanding off-balance sheet arrangements is presented below: December 31, (in millions) 2018 2017 Undrawn commitments to extend credit $69,553 $62,959 Letters of credit 2,125 2,136 Marketing rights 37 41 Risk participation agreements 19 16 Residential mortgage loans sold with recourse 5 7 Total $71,739 $65,159

FAIR VALUE MEASUREMENTS (Tables

FAIR VALUE MEASUREMENTS (Tables)	12 Months Ended
	Dec. 31, 2018
Fair Value Disclosures [Abstract]
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 December 31, 2018 : (in millions) Total Level 1 Level 2 Level 3 Debt securities available for sale: Mortgage-backed securities $19,866 $— $19,866 $— State and political subdivisions 5 — 5 — U.S. Treasury and other 24 24 — — Total debt securities available for sale 19,895 24 19,871 — Loans held for sale, at fair value: Residential loans held for sale 967 — 967 — Commercial loans held for sale 252 — 252 — Total loans held for sale, at fair value 1,219 — 1,219 — Mortgage servicing rights 600 — — 600 Derivative assets Interest rate contracts 306 — 306 — Foreign exchange contracts 129 — 129 — Other contracts 14 — 14 — Total derivative assets 449 — 449 — Equity securities, at fair value: Money market mutual fund investments 181 181 — — Other investments — — — — Total equity securities, at fair value 181 181 — — Total assets $22,344 $205 $21,539 $600 Derivative liabilities Interest rate contracts $277 $— $277 $— Foreign exchange contracts 113 — 113 — Other contracts 25 — 25 — Total derivative liabilities 415 — 415 — Total liabilities $415 $— $415 $— 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 $—
Assets measured at fair value on recurring basis	The following table 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 year ended December 31, 2018. There were no assets measured at fair value on a recurring basis and classified as Level 3 for the year ended December 31, 2017. For the Year Ended December 31, (in millions) Mortgage Servicing Rights Balance at January 1, 2018 $— Acquired MSRs 590 Amount capitalized 73 Change in unpaid principal balance during the period (1) (32 ) Change in fair value during the period (2) (31 ) Balance at December 31, 2018 $600 (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.
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: December 31, 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 $967 $967 $— $326 $326 $— Commercial and commercial real estate loans held for sale, at fair value 252 252 — 171 171 —
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: Year Ended December 31, (in millions) 2018 2017 2016 Impaired collateral-dependent loans ($13 ) ($35 ) ($33 ) MSRs 3 (2 ) (4 ) Foreclosed assets (2 ) (3 ) (3 ) Leased assets (7 ) (15 ) 11
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: December 31, 2018 December 31, 2017 (in millions) Total Level 1 Level 2 Level 3 Total Level 1 Level 2 Level 3 Impaired collateral-dependent loans $338 $— $338 $— $393 $— $393 $— MSRs 243 — — 243 218 — — 218 Foreclosed assets 29 — 29 — 31 — 31 — Leased assets 92 — 92 — 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 Consolidated Financial Statements. The carrying amounts are recorded in the Consolidated Balance Sheets under the indicated captions: December 31, 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 $4,165 $4,041 $— $— $4,165 $4,041 $— $— Equity securities, at cost 834 834 — — 834 834 — — Other loans held for sale 101 101 — — — — 101 101 Loans and leases 116,660 116,627 — — 338 338 116,322 116,289 Financial Liabilities: Deposits 119,575 119,503 — — 119,575 119,503 — — Federal funds purchased and securities sold under agreements to repurchase 1,156 1,156 — — 1,156 1,156 — — Other short-term borrowed funds 1,653 1,653 — — 1,653 1,653 — — Long-term borrowed funds 14,433 14,390 — — 14,433 14,390 — — 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)	12 Months Ended
	Dec. 31, 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) Year Ended December 31, 2018 Revenue from contracts with customers $1,119 Revenue from other sources 477 Noninterest income $1,596
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: Year Ended December 31, 2018 (in millions) Consumer Banking Commercial Banking Consolidated (1) Service charges and fees $408 $105 $513 Card fees 207 37 244 Capital markets fees — 181 181 Trust and investment services fees 171 — 171 Other banking fees — 10 10 Total revenue from contracts with customers $786 $333 $1,119 (1) There is no revenue from contracts with customers included in Other non-segment operations.
Details of other income	Year Ended December 31, (in millions) 2018 2017 2016 Bank-owned life insurance $56 $54 $54

OTHER OPERATING EXPENSE (Tables

OTHER OPERATING EXPENSE (Tables)	12 Months Ended
	Dec. 31, 2018
Other Income and Expenses [Abstract]
Schedule of other operating expense	The following table presents the details of other operating expense: Year Ended December 31, (in millions) 2018 2017 2016 Deposit insurance $104 $137 $120 Promotional expense 129 105 98 Settlements and operating losses 47 54 62 Other 215 246 241 Other operating expense $495 $542 $521

INCOME TAXES (Tables)

INCOME TAXES (Tables)	12 Months Ended
	Dec. 31, 2018
Income Tax Disclosure [Abstract]
Schedule of Comprehensive Income Tax	Total income tax expense is presented below: Year Ended December 31, (in millions) 2018 2017 2016 Income tax expense $462 $260 $489 Tax effect of changes in OCI (96 ) (7 ) (168 ) Total comprehensive income tax expense $366 $253 $321
Schedule of Components of Income Tax Expense	Components of income tax expense are presented below: (in millions) Current Deferred Total Year Ended December 31, 2018 U.S. federal $271 $90 $361 State and local 94 7 101 Total $365 $97 $462 Year Ended December 31, 2017 U.S. federal $376 ($142 ) $234 State and local 20 6 26 Total $396 ($136 ) $260 Year Ended December 31, 2016 U.S. federal $292 $159 $451 State and local 44 (6 ) 38 Total $336 $153 $489
Schedule of Effective Income Tax Rate Reconciliation	The effective income tax rate differed from the U.S. federal income tax rate of 21% for the year ended December 31, 2018 , and 35% for the years ended December 31, 2017 and 2016 , as presented below: Year Ended December 31, 2018 2017 2016 (in millions, except ratio data) Amount Rate Amount Rate Amount Rate U.S. Federal income tax expense and tax rate $459 21.0 % $669 35.0 % $537 35.0 % Increase (decrease) resulting from: Federal rate change (34 ) (1.6 ) (331 ) (17.3 ) — — State and local income taxes (net of federal benefit) 89 4.1 46 2.4 38 2.5 Bank-owned life insurance (12 ) (0.5 ) (19 ) (1.0 ) (19 ) (1.2 ) Tax-exempt interest (15 ) (0.7 ) (21 ) (1.1 ) (19 ) (1.3 ) Tax advantaged investments (including related credits) (44 ) (2.0 ) (51 ) (2.7 ) (31 ) (2.0 ) Other tax credits (8 ) (0.4 ) (3 ) (0.1 ) (14 ) (0.9 ) Adjustments for uncertain tax positions 1 0.1 (23 ) (1.2 ) — — Non-deductible FDIC premiums 21 1.0 — — — — Other 5 0.2 (7 ) (0.4 ) (3 ) (0.2 ) Total income tax expense and tax rate $462 21.2 % $260 13.6 % $489 31.9 %
Schedule of Deferred Tax Assets and Liabilities	The tax effects of temporary differences that give rise to significant portions of the deferred tax assets and liabilities are presented below: December 31, (in millions) 2018 2017 Deferred tax assets: Other comprehensive income $366 $271 Allowance for credit losses 308 310 State net operating loss carryforwards 90 88 Accrued expenses not currently deductible 36 40 Investment and other tax credit carryforwards 74 65 Fair value adjustments 28 27 Total deferred tax assets 902 801 Valuation allowance (110 ) (105 ) Deferred tax assets, net of valuation allowance 792 696 Deferred tax liabilities: Leasing transactions 527 525 Amortization of intangibles 364 352 Depreciation 195 182 Pension and other employee compensation plans 127 110 Partnerships 51 37 Deferred Income 50 27 MSRs 51 34 Total deferred tax liabilities 1,365 1,267 Net deferred tax liability $573 $571
Schedule of Unrecognized Tax Benefits Roll Forward	A reconciliation of the beginning and ending amount of unrecognized tax benefits is presented below: December 31, (in millions) 2018 2017 2016 Balance at the beginning of the year $5 $42 $62 Gross increase for tax positions related to current year 3 — — Gross decrease for tax positions related to prior years — (27 ) (19 ) Gross increase for tax positions related to prior years — — 1 Decreases for tax positions as a result of the lapse of the statutes of limitations — (1 ) (2 ) Decreases for tax positions related to settlements with taxing authorities — (9 ) — Balance at end of year $8 $5 $42

EARNINGS PER SHARE (Tables)

EARNINGS PER SHARE (Tables)	12 Months Ended
	Dec. 31, 2018
Earnings Per Share [Abstract]
Schedule of earnings per share	Year Ended December 31, (in millions, except share and per-share data) 2018 2017 2016 Numerator (basic and diluted): Net income $1,721 $1,652 $1,045 Less: Preferred stock dividends 29 14 14 Net income available to common stockholders $1,692 $1,638 $1,031 Denominator: Weighted-average common shares outstanding - basic 478,822,072 502,157,440 522,093,545 Dilutive common shares: share-based awards 1,608,669 1,527,651 1,837,173 Weighted-average common shares outstanding - diluted 480,430,741 503,685,091 523,930,718 Earnings per common share: Basic $3.54 $3.26 $1.97 Diluted 3.52 3.25 1.97

REGULATORY MATTERS (Tables)

REGULATORY MATTERS (Tables)	12 Months Ended
	Dec. 31, 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) As of December 31, 2018 Common equity tier 1 capital (1) $14,485 10.6 $8,683 6.375 % Tier 1 capital (2) 15,325 11.3 10,726 7.875 Total capital (3) 18,157 13.3 13,450 9.875 Tier 1 leverage (4) 15,325 10.0 6,121 4.000 As of 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 1.25% for 2017; N/A to Tier 1 leverage.

BUSINESS OPERATING SEGMENTS (Ta

BUSINESS OPERATING SEGMENTS (Tables)	12 Months Ended
	Dec. 31, 2018
Segment Reporting [Abstract]
Schedule of segment reporting information	As of and for the Year Ended December 31, 2018 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $3,064 $1,497 ($29 ) $4,532 Noninterest income 973 545 78 1,596 Total revenue 4,037 2,042 49 6,128 Noninterest expense 2,723 813 83 3,619 Profit before provision for credit losses 1,314 1,229 (34 ) 2,509 Provision for credit losses 289 26 11 326 Income (loss) before income tax expense (benefit) 1,025 1,203 (45 ) 2,183 Income tax expense (benefit) 258 276 (72 ) 462 Net income $767 $927 $27 $1,721 Total average assets $62,444 $52,362 $39,747 $154,553 As of and for the Year Ended December 31, 2017 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $2,651 $1,411 $111 $4,173 Noninterest income 905 538 91 1,534 Total revenue 3,556 1,949 202 5,707 Noninterest expense 2,593 772 109 3,474 Profit before provision for credit losses 963 1,177 93 2,233 Provision for credit losses 265 19 37 321 Income before income tax expense (benefit) 698 1,158 56 1,912 Income tax expense (benefit) 246 384 (370 ) 260 Net income $452 $774 $426 $1,652 Total average assets $59,714 $49,747 $40,492 $149,953 As of and for the Year Ended December 31, 2016 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $2,443 $1,288 $27 $3,758 Noninterest income 883 466 148 1,497 Total revenue 3,326 1,754 175 5,255 Noninterest expense 2,547 741 64 3,352 Profit before provision for credit losses 779 1,013 111 1,903 Provision for credit losses 243 47 79 369 Income before income tax expense (benefit) 536 966 32 1,534 Income tax expense (benefit) 191 335 (37 ) 489 Net income $345 $631 $69 $1,045 Total average assets $56,388 $47,159 $39,636 $143,183

PARENT COMPANY FINANCIALS (Tabl

PARENT COMPANY FINANCIALS (Tables)	12 Months Ended
	Dec. 31, 2018
Condensed Financial Information Disclosure [Abstract]
Condensed Statements of Operations	Condensed Statements of Operations Year Ended December 31, (in millions) 2018 2017 2016 OPERATING INCOME: Income from consolidated subsidiaries and excluding equity in undistributed earnings: Dividends from banking subsidiaries $1,650 $1,055 $555 Interest 46 43 53 Management and service fees 22 31 26 Income from nonbank subsidiaries and excluding equity in undistributed earnings: Dividends from nonbank subsidiaries 5 4 — Interest 2 1 — Equity securities gains — 1 3 All other operating income 1 1 7 Total operating income 1,726 1,136 644 OPERATING EXPENSE: Salaries and employee benefits 25 40 37 Interest expense 89 97 99 All other expenses 23 22 15 Total operating expense 137 159 151 Income before taxes and undistributed income 1,589 977 493 Income taxes (13 ) (10 ) (26 ) Income before undistributed earnings of subsidiaries 1,602 987 519 Equity in undistributed earnings of subsidiaries: Bank 109 655 522 Nonbank 10 10 4 Net income $1,721 $1,652 $1,045 Other comprehensive income (loss), net of income taxes: Net pension plan activity arising during the period $5 ($1 ) ($2 ) Net unrealized derivative instrument gains (losses) arising during the period 2 1 (8 ) Other comprehensive income (loss) activity of the Parent Company, net of income taxes 7 — (10 ) Other comprehensive loss activity of Bank subsidiaries, net of income taxes (283 ) (7 ) (271 ) Total other comprehensive loss, net of income taxes (276 ) (7 ) (281 ) Total comprehensive income $1,445 $1,645 $764
Condensed Balance Sheets	Condensed Balance Sheets (in millions) December 31, 2018 December 31, 2017 ASSETS: Cash and due from banks $961 $563 Loans and advances to: Bank subsidiaries 1,158 1,160 Nonbank subsidiaries 70 70 Investments in subsidiaries: Bank subsidiaries 20,590 20,765 Nonbank subsidiaries 83 73 Other assets 117 125 TOTAL ASSETS $22,979 $22,756 LIABILITIES: Long-term borrowed funds due to: Unaffiliated companies $1,987 $2,320 Other liabilities 175 166 TOTAL LIABILITIES 2,162 2,486 TOTAL STOCKHOLDERS’ EQUITY 20,817 20,270 TOTAL LIABILITIES AND STOCKHOLDERS’ EQUITY $22,979 $22,756
Condensed Cash Flow Statements	Condensed Cash Flow Statements Year Ended December 31, (in millions) 2018 2017 2016 OPERATING ACTIVITIES Net income $1,721 $1,652 $1,045 Adjustments to reconcile net income to net cash provided by operating activities: Deferred income taxes 17 (11 ) 5 Gain on sales of assets — (1 ) (3 ) Equity in undistributed earnings of subsidiaries (120 ) (665 ) (526 ) Increase (decrease) in other liabilities 11 99 (19 ) (Increase) decrease in other assets (7 ) 5 35 Other operating, net 40 (1 ) (4 ) Total adjustments (59 ) (574 ) (512 ) Net cash provided by operating activities 1,662 1,078 533 INVESTING ACTIVITIES Investments in and advances to subsidiaries — (230 ) (40 ) Repayment of investments in and advances to subsidiaries — 167 588 Other investing, net (1 ) (1 ) (2 ) Net cash (used) provided by investing activities (1 ) (64 ) 546 FINANCING ACTIVITIES Proceeds from issuance of long-term borrowed funds — — 349 Repayments of long-term borrowed funds (333 ) — (625 ) Proceeds from issuance of common stock — 34 22 Treasury stock purchased (1,025 ) (820 ) (430 ) Net proceeds from issuance of preferred stock 593 — — Dividends declared and paid to common stockholders (471 ) (322 ) (241 ) Dividends declared and paid to preferred stockholders (14 ) (14 ) (14 ) Other financing, net (13 ) — — Net cash used by financing activities (1,263 ) (1,122 ) (939 ) Increase (decrease) in cash and due from banks 398 (108 ) 140 Cash and due from banks at beginning of year 563 671 531 Cash and due from banks at end of year $961 $563 $671

BASIS OF PRESENTATION Narrative

BASIS OF PRESENTATION Narrative (Details) - USD ($) $ in Millions		Jan. 01, 2019	Aug. 01, 2018	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Business Acquisition [Line Items]
Goodwill				$ 6,923	$ 6,887	$ 6,876
Purchase price allocation adjustment	[1]			23
Franklin American Mortgage Company
Business Acquisition [Line Items]
Consideration transferred			$ 582
Goodwill			59	36
Intangible assets acquired			32	30
Purchase price allocation adjustment				23
Amortization expense				$ 2
Residential mortgages | Franklin American Mortgage Company
Business Acquisition [Line Items]
MSR portfolio fair value			$ 590
Subsequent Event | Accounting Standards Update 2016-02
Business Acquisition [Line Items]
Right-of-use asset		$ 750
Lease liability		750
Subsequent Event | Accounting Standards Update 2017-12
Business Acquisition [Line Items]
Transfer of securities		755
Unrealized loss on transfer of securities		$ 15
[1]	Adjustments to goodwill are the result of an update to the purchase price allocation for the FAMC acquisition, given higher value attributed to purchased net assets.

CASH AND DUE FROM BANKS (Detail

CASH AND DUE FROM BANKS (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Cash and Cash Equivalents [Abstract]
Interest-bearing cash and due from banks	$ 2,993	$ 2,045
Interest rate on FRB balances	2.40%
Interest earned on FRB balances	$ 28	$ 16	$ 7

SECURITIES - Narrative (Details

SECURITIES - Narrative (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016	Dec. 31, 2015
Debt Securities, Available-for-sale [Line Items]
Taxable interest income from investment securities	$ 672	$ 625	$ 584
Impaired debt securities sold	0	0	0
Pretax non-credit related losses were deferred in OCI	4	0	27
Mortgage-backed securities
Debt Securities, Available-for-sale [Line Items]
Securitizations of mortgage loans	142	134	68
Available-for-sale Securities
Debt Securities, Available-for-sale [Line Items]
Cumulative credit losses recognized in earnings	81	80	75	$ 66
Credit impairments recognized in earnings on securities that have been previously impaired	3	7	12
Held-to-maturity Securities
Debt Securities, Available-for-sale [Line Items]
Cumulative credit losses recognized in earnings	$ 0	$ 0	$ 0

SECURITIES - Schedule of Invest

SECURITIES - Schedule of Investments (Details) - USD ($) $ in Millions		Dec. 31, 2018	Dec. 31, 2017
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-Sale, Amortized Cost		$ 20,476	$ 20,394
Debt Securities Available-for-Sale, Gross Unrealized Gains		31	47
Debt Securities Available-for-Sale, Gross Unrealized Losses		(612)	(284)
Debt securities available for sale:	[1]	19,895	20,157
Debt Securities Held-to-Maturity, Amortized Cost		4,165	4,685
Debt Securities Held-to-Maturity, Gross Unrealized Gain		8	29
Debt Securities Held-to-Maturity, Gross Unrealized Losses		(132)	(46)
Debt Securities Held-to-Maturity, Fair Value		4,041	4,668
Equity Securities, at Fair Value, Amortized Cost		181	169
Equity Securities, at Fair Value, Fair Value		181	169
Other equity securities, Amortized Cost		7	7
Other equity securities, Fair Value		7	7
Total equity securities, at cost, Amortized Cost		834	722
Total equity securities, at cost, Fair Value		834	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		24	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:		24	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:		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		20,211	20,065
Debt Securities Available-for-Sale, Gross Unrealized Gains		28	40
Debt Securities Available-for-Sale, Gross Unrealized Losses		(605)	(277)
Debt securities available for sale:		19,634	19,828
Debt Securities Held-to-Maturity, Amortized Cost		3,425	3,853
Debt Securities Held-to-Maturity, Gross Unrealized Gain		0	7
Debt Securities Held-to-Maturity, Gross Unrealized Losses		(132)	(46)
Debt Securities Held-to-Maturity, Fair Value		3,293	3,814
Other/non-agency
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-Sale, Amortized Cost		236	311
Debt Securities Available-for-Sale, Gross Unrealized Gains		3	7
Debt Securities Available-for-Sale, Gross Unrealized Losses		(7)	(7)
Debt securities available for sale:		232	311
Debt Securities Held-to-Maturity, Amortized Cost		740	832
Debt Securities Held-to-Maturity, Gross Unrealized Gain		8	22
Debt Securities Held-to-Maturity, Gross Unrealized Losses		0	0
Debt Securities Held-to-Maturity, Fair Value		748	854
Total mortgage-backed securities
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-Sale, Amortized Cost		20,447	20,376
Debt Securities Available-for-Sale, Gross Unrealized Gains		31	47
Debt Securities Available-for-Sale, Gross Unrealized Losses		(612)	(284)
Debt securities available for sale:		19,866	20,139
Debt Securities Held-to-Maturity, Amortized Cost		4,165	4,685
Debt Securities Held-to-Maturity, Gross Unrealized Gain		8	29
Debt Securities Held-to-Maturity, Gross Unrealized Losses		(132)	(46)
Debt Securities Held-to-Maturity, Fair Value		4,041	4,668
Money market mutual fund investments
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Equity Securities, at Fair Value, Amortized Cost		181	165
Equity Securities, at Fair Value, Fair Value		181	165
Other investments
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Equity Securities, at Fair Value, Amortized Cost		0	4
Equity Securities, at Fair Value, 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, 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		364	252
Federal Home Loan Bank stock, Fair Value		$ 364	$ 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	Dec. 31, 2018USD ($)
Amortized Cost:
Amortized Cost, Debt securities available for sale, Maturity of 1 Year or Less	$ 25
Amortized Cost, Debt securities available for sale, Maturity of 1-5 Years	291
Amortized Cost, Debt securities available for sale, Maturity of 5-10 Years	1,540
Amortized Cost, Debt securities available for sale, Maturity After 10 Years	18,620
Amortized Cost, Debt securities available for sale, Total	20,476
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	4,165
Amortized Cost, Debt securities held to maturity, Total	4,165
Total amortized cost of debt securities, Maturity of 1 Year or Less	25
Total amortized cost of debt securities, Maturity of 1-5 Years	291
Total amortized cost of debt securities, Maturity of 5-10 Years	1,540
Total amortized cost of debt securities, Maturity After 10 Years	22,785
Total amortized cost of debt securities, Total	24,641
Fair Value:
Fair Value, Debt securities available for sale, Maturity of 1 Year or Less	25
Fair Value, Debt securities available for sale, Maturity of 1-5 Years	284
Fair Value, Debt securities available for sale, Maturity of 5-10 Years	1,505
Fair Value, Debt securities available for sale, Maturity After 10 Years	18,081
Fair Value, Debt securities available for sale, Total	19,895
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	4,041
Fair Value, Debt securities held to maturity, Total	4,041
Total fair value of debt securities, Maturity of 1 Year or Less	25
Total fair value of debt securities, Maturity of 1-5 Years	284
Total fair value of debt securities, Maturity of 5-10 Years	1,505
Total fair value of debt securities, Maturity After 10 Years	22,122
Total fair value of debt securities, Total	23,936
U.S. Treasury and other
Amortized Cost:
Amortized Cost, Debt securities available for sale, Maturity of 1 Year or Less	24
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	24
Fair Value:
Fair Value, Debt securities available for sale, Maturity of 1 Year or Less	24
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	24
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	281
Amortized Cost, Debt securities available for sale, Maturity of 5-10 Years	1,540
Amortized Cost, Debt securities available for sale, Maturity After 10 Years	18,390
Amortized Cost, Debt securities available for sale, Total	20,211
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	3,425
Amortized Cost, Debt securities held to maturity, Total	3,425
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	274
Fair Value, Debt securities available for sale, Maturity of 5-10 Years	1,505
Fair Value, Debt securities available for sale, Maturity After 10 Years	17,855
Fair Value, Debt securities available for sale, Total	19,634
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	3,293
Fair Value, Debt securities held to maturity, Total	3,293
Other/non-agency
Amortized Cost:
Amortized Cost, Debt securities available for sale, Maturity of 1 Year or Less	1
Amortized Cost, Debt securities available for sale, Maturity of 1-5 Years	10
Amortized Cost, Debt securities available for sale, Maturity of 5-10 Years	0
Amortized Cost, Debt securities available for sale, Maturity After 10 Years	225
Amortized Cost, Debt securities available for sale, Total	236
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	740
Amortized Cost, Debt securities held to maturity, Total	740
Fair Value:
Fair Value, Debt securities available for sale, Maturity of 1 Year or Less	1
Fair Value, Debt securities available for sale, Maturity of 1-5 Years	10
Fair Value, Debt securities available for sale, Maturity of 5-10 Years	0
Fair Value, Debt securities available for sale, Maturity After 10 Years	221
Fair Value, Debt securities available for sale, Total	232
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	748
Fair Value, Debt securities held to maturity, Total	$ 748

SECURITIES - Income Recognized

SECURITIES - Income Recognized from Investment Securities (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Gain (Loss) on Sale of Investments [Abstract]
Gains on sale of debt securities	$ 19	$ 11	$ 18
Losses on sale of debt securities	0	0	(2)
Debt securities gains, net	19	11	16
Equity securities gains	$ 0	$ 1	$ 3

SECURITIES - Schedule of Securi

SECURITIES - Schedule of Securities Pledged (Details) - USD ($) $ in Millions	Dec. 31, 2018	Dec. 31, 2017
Investments, Debt and Equity Securities [Abstract]
Pledged against repurchase agreements, Amortized Cost	$ 344	$ 358
Pledged against FHLB borrowed funds, Amortized Cost	745	839
Pledged against derivatives, to qualify for fiduciary powers, and to secure public and other deposits as required by law, Amortized Cost	3,592	3,113
Pledged against repurchase agreements, Fair Value	338	357
Pledged against FHLB borrowed funds, Fair Value	752	861
Pledged against derivatives, to qualify for fiduciary powers, and to secure public and other deposits as required by law, Fair Value	$ 3,460	$ 3,082

SECURITIES - Other than tempora

SECURITIES - Other than temporary impairment recognized in earnings (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Investments, Debt and Equity Securities [Abstract]
Total other-than-temporary impairment losses	$ (7)	$ (7)	$ (39)
Portions of loss recognized in other comprehensive income (before taxes)	4	0	27
Net securities impairment losses recognized in earnings	$ (3)	$ (7)	$ (12)

SECURITIES - Schedule of Inve_2

SECURITIES - Schedule of Investments in Continuous Loss Positions (Details) $ in Millions	Dec. 31, 2018USD ($)Securities	Dec. 31, 2017USD ($)Securities
Number of Issues
Less than 12 Months | Securities	176	300
12 Months or Longer | Securities	440	162
Total | Securities	616	462
Fair Value
Less than 12 Months	$ 5,020	$ 10,218
12 Months or Longer	15,196	8,145
Total	20,216	18,363
Gross Unrealized Losses
Less than 12 Months	(90)	(98)
12 Months or Longer	(654)	(232)
Total	$ (744)	$ (330)
Federal agencies and U.S. government sponsored entities
Number of Issues
Less than 12 Months | Securities	166	294
12 Months or Longer | Securities	429	152
Total | Securities	595	446
Fair Value
Less than 12 Months	$ 4,881	$ 10,163
12 Months or Longer	15,124	8,061
Total	20,005	18,224
Gross Unrealized Losses
Less than 12 Months	(89)	(97)
12 Months or Longer	(648)	(226)
Total	$ (737)	$ (323)
Other/non-agency
Number of Issues
Less than 12 Months | Securities	10	6
12 Months or Longer | Securities	11	10
Total | Securities	21	16
Fair Value
Less than 12 Months	$ 139	$ 55
12 Months or Longer	72	84
Total	211	139
Gross Unrealized Losses
Less than 12 Months	(1)	(1)
12 Months or Longer	(6)	(6)
Total	$ (7)	$ (7)

SECURITIES - Schedule of Cumula

SECURITIES - Schedule of Cumulative Credit Losses Recognized in Earnings (Details) - Available-for-sale Securities - USD ($) $ in Millions		12 Months Ended
		Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Other than Temporary Impairment, Credit Losses Recognized in Earnings [Roll Forward]
Cumulative balance at beginning of period		$ 80	$ 75	$ 66
Credit impairments recognized in earnings on debt securities that have been previously impaired		3	7	12
Reductions due to increases in cash flow expectations on impaired debt securities (1)	[1]	(2)	(2)	(3)
Cumulative balance at end of period		$ 81	$ 80	$ 75
[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	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans held for sale, at fair value:	$ 1,219	$ 497
Other loans held for sale	101	221
Level 2
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans held for sale, at fair value:	1,219	497
Other loans held for sale	0	0
Level 2 | Residential loans held for sale
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans held for sale, at fair value:	967	326
Level 2 | Commercial loans held for sale
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans held for sale, at fair value:	252	171
TDR Loans
Accounts, Notes, Loans and Financing Receivable [Line Items]
Sales		78
Gain (loss) on sales of loans		17
Residential mortgages | TDR Loans
Accounts, Notes, Loans and Financing Receivable [Line Items]
Sales		49
Retail | Residential mortgages
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans pledged as collateral for FHLB borrowed funds	25,600	24,900
Loans pledged as collateral to support the contingent ability to borrow at the FRB discount window	16,800	18,100
Retail | Education loans
Accounts, Notes, Loans and Financing Receivable [Line Items]
Purchases	457	862
Retail | Automobile loans
Accounts, Notes, Loans and Financing Receivable [Line Items]
Purchases		153
Retail | Residential mortgages
Accounts, Notes, Loans and Financing Receivable [Line Items]
Sales		254
Retail | Home equity loans
Accounts, Notes, Loans and Financing Receivable [Line Items]
Sales		29
Commercial Portfolio Segment | Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
Sales	$ 553	$ 603

LOANS AND LEASES - Summary of L

LOANS AND LEASES - Summary of Loans and Leases Portfolio (Details) - USD ($) $ in Millions		Dec. 31, 2018	Dec. 31, 2017
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	[1],[2]	$ 116,660	$ 110,617
Loans held for sale		1,300	718
Mortgage loans serviced for others | Banking Subsidiaries
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		69,600	20,300
Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		56,783	52,031
Commercial | Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		40,857	37,562
Commercial | Commercial real estate
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		13,023	11,308
Commercial | Leases
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		2,903	3,161
Retail
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		59,877	58,586
Retail | Residential mortgages
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		18,978	17,045
Retail | Home equity loans
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		1,073	1,392
Retail | Home equity lines of credit
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		12,710	13,483
Retail | Home equity loans serviced by others
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		399	542
Retail | Home equity lines of credit serviced by others
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		104	149
Retail | Automobile
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		12,106	13,204
Retail | Education
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		8,900	8,134
Retail | Credit cards
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		1,991	1,848
Retail | Other retail
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases		$ 3,616	$ 2,789
[1]	Excluded from the table above are loans held for sale totaling $1.3 billion and $718 million as of December 31, 2018 and 2017, respectively.
[2]	Mortgage loans serviced for others by the Company’s subsidiaries are not included above, and amounted to $69.6 billion and $20.3 billion at December 31, 2018 and 2017, respectively.

LOANS AND LEASES - Summary of I

LOANS AND LEASES - Summary of Investments in Leases (Details) - Leases - USD ($) $ in Millions	Dec. 31, 2018	Dec. 31, 2017
Accounts, Notes, Loans and Financing Receivable [Line Items]
Direct financing leases	$ 2,863	$ 3,122
Leveraged leases	40	39
Total leases	$ 2,903	$ 3,161

LOANS AND LEASES - Components o

LOANS AND LEASES - Components of Investments in Leases (Details) - USD ($) $ in Millions	Dec. 31, 2018	Dec. 31, 2017
Accounts, Notes, Loans and Financing Receivable [Line Items]
Total future minimum lease rentals	$ 2,075
Leases
Accounts, Notes, Loans and Financing Receivable [Line Items]
Total future minimum lease rentals	2,075	$ 2,347
Estimated residual value of leased equipment (non-guaranteed)	1,091	1,072
Initial direct costs	13	15
Unearned income on minimum lease rentals and estimated residual value of leased equipment	(276)	(273)
Total leases	$ 2,903	$ 3,161

LOANS AND LEASES - Future Minim

LOANS AND LEASES - Future Minimum Payments Receivable (Details) $ in Millions	Dec. 31, 2018USD ($)
Receivables [Abstract]
2,019	$ 589
2,020	461
2,021	340
2,022	258
2,023	180
Thereafter	247
Total	$ 2,075

ALLOWANCE FOR CREDIT LOSSES, _3

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Narrative (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017		Dec. 31, 2016
Accounts, Notes, Loans and Financing Receivable [Line Items]
Provision for credit losses	$ 326	$ 321		$ 369
Minimum qualifying balance	3
Nonperforming assets, net of valuation allowance	34	36
Mortgage loans collateralized by OREO	$ 172	181
High loan to value criteria (exceeds)	90.00%
Allowance for loan and lease losses
Accounts, Notes, Loans and Financing Receivable [Line Items]
Provision for credit losses	$ 323	$ 305	[1]	$ 355
[1]	Includes an increase of approximately $50 million to commercial and corresponding decrease to retail for the impact of the enhancement to the assessment of qualitative risks, factors and events that may not be measured in the modeled results.

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	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017		Dec. 31, 2016
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	326	$ 321		$ 369
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	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	1,236	1,236		1,216
Charge-offs	(494)	(512)		(536)
Recoveries	177	207		201
Net charge-offs	(317)	(305)		(335)
Provision charged to income	323	305	[1]	355
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	1,242	1,236		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	72		58
Provision for unfunded lending commitments	3	16		14
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	91	88		72
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, Beginning balance	1,324	1,308
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	1,333	1,324		1,308
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	685	663		596
Charge-offs	(52)	(75)		(79)
Recoveries	19	40		33
Net charge-offs	(33)	(35)		(46)
Provision charged to income	38	57	[1]	113
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	690	685		663
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	72		58
Provision for unfunded lending commitments	3	16		14
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	91	88		72
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, Beginning balance	773	735
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	781	773		735
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	551	573		620
Charge-offs	(442)	(437)		(457)
Recoveries	158	167		168
Net charge-offs	(284)	(270)		(289)
Provision charged to income	285	248	[1]	242
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	552	551		573
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
Provision for unfunded lending commitments	0	0		0
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	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, Beginning balance	551	573
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	$ 552	551		$ 573
Scenario, Adjustment | Commercial | Allowance for loan and lease losses
Allowance for Loan and Lease Losses [Roll Forward]
Provision charged to income		$ 50
[1]	Includes an increase of approximately $50 million to commercial and corresponding decrease to retail for the impact of the enhancement to the assessment of qualitative risks, factors and events that may not be measured in the modeled results.

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	Dec. 31, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment [Line Items]
Individually evaluated	$ 1,114	$ 1,131
Formula-based evaluation	115,546	109,486
Total loans and leases	116,660	110,617
Commercial
Financing Receivable, Recorded Investment [Line Items]
Individually evaluated	391	370
Formula-based evaluation	56,392	51,661
Total loans and leases	56,783	52,031
Retail
Financing Receivable, Recorded Investment [Line Items]
Individually evaluated	723	761
Formula-based evaluation	59,154	57,825
Total loans and leases	$ 59,877	$ 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	Dec. 31, 2018	Dec. 31, 2017
Financing Receivable, Allowance for Credit Losses [Line Items]
Individually evaluated	$ 64	$ 81
Formula-based evaluation	1,269	1,243
Allowance for credit losses	1,333	1,324
Commercial
Financing Receivable, Allowance for Credit Losses [Line Items]
Individually evaluated	38	47
Formula-based evaluation	743	726
Allowance for credit losses	781	773
Retail
Financing Receivable, Allowance for Credit Losses [Line Items]
Individually evaluated	26	34
Formula-based evaluation	526	517
Allowance for credit losses	$ 552	$ 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	Dec. 31, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment [Line Items]
Total	$ 116,660	$ 110,617
Commercial
Financing Receivable, Recorded Investment [Line Items]
Total	56,783	52,031
Commercial | Commercial Banking
Financing Receivable, Recorded Investment [Line Items]
Total	56,783	52,031
Commercial | Commercial
Financing Receivable, Recorded Investment [Line Items]
Total	40,857	37,562
Commercial | Commercial real estate
Financing Receivable, Recorded Investment [Line Items]
Total	13,023	11,308
Commercial | Leases
Financing Receivable, Recorded Investment [Line Items]
Total	2,903	3,161
Commercial | Pass | Commercial Banking
Financing Receivable, Recorded Investment [Line Items]
Total	53,946	49,205
Commercial | Pass | Commercial
Financing Receivable, Recorded Investment [Line Items]
Total	38,600	35,430
Commercial | Pass | Commercial real estate
Financing Receivable, Recorded Investment [Line Items]
Total	12,523	10,706
Commercial | Pass | Leases
Financing Receivable, Recorded Investment [Line Items]
Total	2,823	3,069
Commercial | Special Mention | Commercial Banking
Financing Receivable, Recorded Investment [Line Items]
Total	1,682	1,716
Commercial | Special Mention | Commercial
Financing Receivable, Recorded Investment [Line Items]
Total	1,231	1,143
Commercial | Special Mention | Commercial real estate
Financing Receivable, Recorded Investment [Line Items]
Total	412	500
Commercial | Special Mention | Leases
Financing Receivable, Recorded Investment [Line Items]
Total	39	73
Commercial | Substandard | Commercial Banking
Financing Receivable, Recorded Investment [Line Items]
Total	951	878
Commercial | Substandard | Commercial
Financing Receivable, Recorded Investment [Line Items]
Total	828	785
Commercial | Substandard | Commercial real estate
Financing Receivable, Recorded Investment [Line Items]
Total	82	74
Commercial | Substandard | Leases
Financing Receivable, Recorded Investment [Line Items]
Total	41	19
Commercial | Doubtful | Commercial Banking
Financing Receivable, Recorded Investment [Line Items]
Total	204	232
Commercial | Doubtful | Commercial
Financing Receivable, Recorded Investment [Line Items]
Total	198	204
Commercial | Doubtful | Commercial real estate
Financing Receivable, Recorded Investment [Line Items]
Total	6	28
Commercial | Doubtful | Leases
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	Dec. 31, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	$ 1,257	$ 1,456
Total loans and leases	116,660	110,617
Financing Receivables, 30 to 59 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	493	501
Financing Receivables, 60 to 89 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	177	163
Financing Receivables, 90 Days or More Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	587	792
Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Total loans and leases	59,877	58,586
Retail | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	18,664	16,714
Past Due	183	184
Total loans and leases	18,978	17,045
Retail | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	945	1,212
Past Due	53	78
Total loans and leases	1,073	1,392
Retail | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	12,042	12,756
Past Due	282	289
Total loans and leases	12,710	13,483
Retail | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	355	477
Past Due	23	36
Total loans and leases	399	542
Retail | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	79	116
Past Due	10	12
Total loans and leases	104	149
Retail | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	10,729	11,596
Past Due	338	335
Total loans and leases	12,106	13,204
Retail | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	8,694	7,898
Past Due	47	76
Total loans and leases	8,900	8,134
Retail | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	1,894	1,747
Past Due	44	38
Total loans and leases	1,991	1,848
Retail | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	3,481	2,679
Past Due	59	42
Total loans and leases	3,616	2,789
Retail | Total retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Current	56,883	55,195
Total loans and leases	59,877	58,586
Retail | Financing Receivables, 1 to 29 Days Past Due | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	131	147
Retail | Financing Receivables, 1 to 29 Days Past Due | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	75	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	386	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	21	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	15	21
Retail | Financing Receivables, 1 to 29 Days Past Due | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	1,039	1,273
Retail | Financing Receivables, 1 to 29 Days Past Due | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	159	160
Retail | Financing Receivables, 1 to 29 Days Past Due | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	53	63
Retail | Financing Receivables, 1 to 29 Days Past Due | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	76	68
Retail | Financing Receivables, 1 to 29 Days Past Due | Total retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	1,955	2,301
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	12	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	65	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	7	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	207	220
Retail | Financing Receivables, 30 to 59 Days Past Due | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	23	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	26	20
Retail | Financing Receivables, 30 to 59 Days Past Due | Total retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	393	433
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	22	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	3	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	59	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	10	9
Retail | Financing Receivables, 60 to 89 Days Past Due | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	18	12
Retail | Financing Receivables, 60 to 89 Days Past Due | Total retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	142	138
Retail | Financing Receivables, 90 Days or More Past Due | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	133	120
Retail | Financing Receivables, 90 Days or More Past Due | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	38	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	195	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	13	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	72	60
Retail | Financing Receivables, 90 Days or More Past Due | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	11	41
Retail | Financing Receivables, 90 Days or More Past Due | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	20	17
Retail | Financing Receivables, 90 Days or More Past Due | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	15	10
Retail | Financing Receivables, 90 Days or More Past Due | Total retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	$ 504	$ 519

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		Dec. 31, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans		$ 797	$ 871
Loans accruing and 90 days or more past due		25	32
GNMA loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans sold with right to repurchase		133	30
Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Loans accruing and 90 days or more past due		12	15
Commercial | Commercial Banking
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans		201	265
Loans accruing and 90 days or more past due		1	8
Commercial | Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans		194	238
Loans accruing and 90 days or more past due		1	5
Commercial | Commercial real estate
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans		7	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
Retail | Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans		596	606
Loans accruing and 90 days or more past due		24	24
Retail | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans	[1]	136	128
Loans accruing and 90 days or more past due	[1]	15	16
Retail | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans		50	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		231	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		17	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		15	18
Loans accruing and 90 days or more past due		0	0
Retail | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans		81	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		2	3
Retail | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans		20	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		8	5
Loans accruing and 90 days or more past due		$ 7	$ 5
[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 $12 million and $15 million as of December 31, 2018 and 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 $133 million and $30 million as of December 31, 2018 and 2017, respectively. These loans are included in the Company’s Consolidated Balance Sheets.

ALLOWANCE FOR CREDIT LOSSES,_10

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Performance Indicators for Nonperforming Assets (Details)	Dec. 31, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans and leases as a percentage of total loans and leases	0.68%	0.79%
Nonperforming assets as a percentage of total assets	0.52%	0.60%
Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans and leases as a percentage of total loans and leases	0.17%	0.24%
Nonperforming assets as a percentage of total assets	0.13%	0.17%
Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Nonperforming loans and leases as a percentage of total loans and leases	0.51%	0.55%
Nonperforming assets as a percentage of total assets	0.39%	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	Dec. 31, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	$ 1,257	$ 1,456
Financing Receivables, 30 to 59 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	493	501
Financing Receivables, 60 to 89 Days Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	177	163
Financing Receivables, 90 Days or More Past Due
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	587	792
Commercial | Commercial Banking
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	218	366
Commercial | Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	166	273
Commercial | Commercial real estate
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	45	88
Commercial | Leases
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	7	5
Commercial | Financing Receivables, 30 to 59 Days Past Due | Commercial Banking
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	100	68
Commercial | Financing Receivables, 30 to 59 Days Past Due | Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	85	26
Commercial | Financing Receivables, 30 to 59 Days Past Due | Commercial real estate
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	8	38
Commercial | Financing Receivables, 30 to 59 Days Past Due | Leases
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	7	4
Commercial | Financing Receivables, 60 to 89 Days Past Due | Commercial Banking
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	35	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	32	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 | Commercial Banking
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	83	273
Commercial | Financing Receivables, 90 Days or More Past Due | Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	78	243
Commercial | Financing Receivables, 90 Days or More Past Due | Commercial real estate
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	5	30
Commercial | Financing Receivables, 90 Days or More Past Due | Leases
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	0	0
Retail | Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	1,039	1,090
Retail | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	183	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	282	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	338	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	44	38
Retail | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	59	42
Retail | Financing Receivables, 30 to 59 Days Past Due | Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	393	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	12	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	65	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	7	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	207	220
Retail | Financing Receivables, 30 to 59 Days Past Due | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	23	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	26	20
Retail | Financing Receivables, 60 to 89 Days Past Due | Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	142	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	22	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	3	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	59	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	10	9
Retail | Financing Receivables, 60 to 89 Days Past Due | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	18	12
Retail | Financing Receivables, 90 Days or More Past Due | Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	504	519
Retail | Financing Receivables, 90 Days or More Past Due | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	133	120
Retail | Financing Receivables, 90 Days or More Past Due | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	38	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	195	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	13	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	72	60
Retail | Financing Receivables, 90 Days or More Past Due | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	11	41
Retail | Financing Receivables, 90 Days or More Past Due | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	20	17
Retail | Financing Receivables, 90 Days or More Past Due | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Past Due	$ 15	$ 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	Dec. 31, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	$ 483	$ 506
Allowance on Impaired Loans	64	81
Impaired Loans Without a Related Allowance	631	625
Unpaid Contractual Balance	1,363	1,364
Total Recorded Investment in Impaired Loans	1,114	1,131
Commercial | Commercial Banking
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	218	208
Allowance on Impaired Loans	38	47
Impaired Loans Without a Related Allowance	173	162
Unpaid Contractual Balance	488	443
Total Recorded Investment in Impaired Loans	391	370
Commercial | Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	186	183
Allowance on Impaired Loans	31	42
Impaired Loans Without a Related Allowance	167	159
Unpaid Contractual Balance	450	403
Total Recorded Investment in Impaired Loans	353	342
Commercial | Commercial real estate
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	32	25
Allowance on Impaired Loans	7	5
Impaired Loans Without a Related Allowance	6	3
Unpaid Contractual Balance	38	40
Total Recorded Investment in Impaired Loans	38	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 | Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	265	298
Allowance on Impaired Loans	26	34
Impaired Loans Without a Related Allowance	458	463
Unpaid Contractual Balance	875	921
Total Recorded Investment in Impaired Loans	723	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	127	126
Unpaid Contractual Balance	201	197
Total Recorded Investment in Impaired Loans	155	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	76	80
Unpaid Contractual Balance	148	162
Total Recorded Investment in Impaired Loans	110	121
Retail | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	21	16
Allowance on Impaired Loans	1	1
Impaired Loans Without a Related Allowance	181	181
Unpaid Contractual Balance	244	241
Total Recorded Investment in Impaired Loans	202	197
Retail | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	22	29
Allowance on Impaired Loans	1	2
Impaired Loans Without a Related Allowance	19	22
Unpaid Contractual Balance	54	67
Total Recorded Investment in Impaired Loans	41	51
Retail | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	1	2
Allowance on Impaired Loans	0	0
Impaired Loans Without a Related Allowance	7	7
Unpaid Contractual Balance	11	14
Total Recorded Investment in Impaired Loans	8	9
Retail | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	1	2
Allowance on Impaired Loans	0	0
Impaired Loans Without a Related Allowance	22	21
Unpaid Contractual Balance	31	30
Total Recorded Investment in Impaired Loans	23	23
Retail | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Impaired Loans With a Related Allowance	130	154
Allowance on Impaired Loans	11	17
Impaired Loans Without a Related Allowance	23	21
Unpaid Contractual Balance	153	175
Total Recorded Investment in Impaired Loans	153	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	1	1
Unpaid Contractual Balance	25	25
Total Recorded Investment in Impaired Loans	25	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	2	4
Unpaid Contractual Balance	8	10
Total Recorded Investment in Impaired Loans	$ 6	$ 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	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	$ 41	$ 35	$ 35
Average Recorded Investment	1,031	1,130	1,102
Commercial | Commercial Banking
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	10	4	5
Average Recorded Investment	344	417	351
Commercial | Commercial
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	9	4	5
Average Recorded Investment	312	380	295
Commercial | Commercial real estate
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	1	0	0
Average Recorded Investment	32	37	53
Commercial | Leases
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	0	0	0
Average Recorded Investment	0	0	3
Retail | Retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	31	31	30
Average Recorded Investment	687	713	751
Retail | Residential mortgages
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	5	4	4
Average Recorded Investment	146	136	161
Retail | Home equity loans
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	6	6	7
Average Recorded Investment	107	121	144
Retail | Home equity lines of credit
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	7	6	6
Average Recorded Investment	181	176	178
Retail | Home equity loans serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	3	3	3
Average Recorded Investment	42	49	60
Retail | Home equity lines of credit serviced by others
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	0	0	0
Average Recorded Investment	9	9	9
Retail | Automobile
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	1	1	0
Average Recorded Investment	20	18	14
Retail | Education
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	8	9	7
Average Recorded Investment	154	173	150
Retail | Credit cards
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	1	2	2
Average Recorded Investment	21	22	23
Retail | Other retail
Financing Receivable, Recorded Investment, Past Due [Line Items]
Interest Income Recognized	0	0	1
Average Recorded Investment	$ 7	$ 9	$ 12

ALLOWANCE FOR CREDIT LOSSES,_14

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - TDRs and Unfunded Commitments (Details) - USD ($) $ in Millions	Dec. 31, 2018	Dec. 31, 2017
Accounts, Notes, Loans and Financing Receivable [Line Items]
Unfunded commitments related to TDRs	$ 30	$ 39
Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
TDR balance	304	129
Retail
Accounts, Notes, Loans and Financing Receivable [Line Items]
TDR balance	$ 723	$ 761

ALLOWANCE FOR CREDIT LOSSES,_15

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Troubled Debt Restructuring (Details) $ in Millions		12 Months Ended
		Dec. 31, 2018USD ($)contract	Dec. 31, 2017USD ($)contract	Dec. 31, 2016USD ($)contract
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		$ 3	$ 1	$ 8
Charge-offs Resulting from Modification		$ 5	$ 5	$ 4
Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	2,641	2,724	2,585
Pre-Modification Outstanding Recorded Investment	[1]	$ 31	$ 34	$ 37
Post-Modification Outstanding Recorded Investment	[1]	$ 32	$ 36	$ 37
Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	339	386	348
Pre-Modification Outstanding Recorded Investment	[2]	$ 88	$ 65	$ 54
Post-Modification Outstanding Recorded Investment	[2]	$ 88	$ 66	$ 55
Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	2,334	2,562	2,501
Pre-Modification Outstanding Recorded Investment	[3]	$ 314	$ 164	$ 150
Post-Modification Outstanding Recorded Investment	[3]	308	161	146
Commercial
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	(1)	3
Charge-offs Resulting from Modification		0	0	0
Commercial | Commercial
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	(1)	3
Charge-offs Resulting from Modification		0	0	0
Commercial | Commercial real estate
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	0
Charge-offs Resulting from Modification		$ 0	$ 0	$ 0
Commercial | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	7	7	13
Pre-Modification Outstanding Recorded Investment	[1]	$ 1	$ 1	$ 1
Post-Modification Outstanding Recorded Investment	[1]	$ 1	$ 1	$ 1
Commercial | Interest Rate Reduction | Commercial
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	7	7	12
Pre-Modification Outstanding Recorded Investment	[1]	$ 1	$ 1	$ 1
Post-Modification Outstanding Recorded Investment	[1]	$ 1	$ 1	$ 1
Commercial | Interest Rate Reduction | Commercial real estate
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	0	0	1
Pre-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0
Commercial | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	52	46	82
Pre-Modification Outstanding Recorded Investment	[2]	$ 54	$ 22	$ 25
Post-Modification Outstanding Recorded Investment	[2]	$ 53	$ 22	$ 26
Commercial | Maturity Extension | Commercial
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	49	45	81
Pre-Modification Outstanding Recorded Investment	[2]	$ 23	$ 22	$ 20
Post-Modification Outstanding Recorded Investment	[2]	$ 22	$ 22	$ 21
Commercial | Maturity Extension | Commercial real estate
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	3	1	1
Pre-Modification Outstanding Recorded Investment	[2]	$ 31	$ 0	$ 5
Post-Modification Outstanding Recorded Investment	[2]	$ 31	$ 0	$ 5
Commercial | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	55	16	14
Pre-Modification Outstanding Recorded Investment	[3]	$ 233	$ 70	$ 48
Post-Modification Outstanding Recorded Investment	[3]	$ 231	$ 71	$ 48
Commercial | Other | Commercial
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	53	15	14
Pre-Modification Outstanding Recorded Investment	[3]	$ 202	$ 70	$ 48
Post-Modification Outstanding Recorded Investment	[3]	$ 200	$ 71	$ 48
Commercial | Other | Commercial real estate
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	2	1	0
Pre-Modification Outstanding Recorded Investment	[3]	$ 31	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[3]	31	0	0
Retail
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		3	2	5
Charge-offs Resulting from Modification		5	5	4
Retail | Residential mortgages
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		(1)	(1)	(1)
Charge-offs Resulting from Modification		0	0	0
Retail | Home equity loans
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	(1)
Charge-offs Resulting from Modification		0	0	0
Retail | Home equity lines of credit
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	0
Charge-offs Resulting from Modification		1	1	1
Retail | Home equity loans serviced by others
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	0
Charge-offs Resulting from Modification		0	0	0
Retail | Home equity lines of credit serviced by others
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	0
Charge-offs Resulting from Modification		0	0	0
Retail | Automobile
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		0	0	0
Charge-offs Resulting from Modification		4	4	3
Retail | Education
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		1	2	4
Charge-offs Resulting from Modification		0	0	0
Retail | Credit cards
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		4	3	3
Charge-offs Resulting from Modification		0	0	0
Retail | Other retail
Financing Receivable, Modifications [Line Items]
Net Change to ALLL Resulting from Modification		(1)	(2)	0
Charge-offs Resulting from Modification		$ 0	$ 0	$ 0
Retail | Interest Rate Reduction
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	2,634	2,717	2,572
Pre-Modification Outstanding Recorded Investment	[1]	$ 30	$ 33	$ 36
Post-Modification Outstanding Recorded Investment	[1]	$ 31	$ 35	$ 36
Retail | Interest Rate Reduction | Residential mortgages
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	35	71	71
Pre-Modification Outstanding Recorded Investment	[1]	$ 4	$ 9	$ 10
Post-Modification Outstanding Recorded Investment	[1]	$ 4	$ 10	$ 10
Retail | Interest Rate Reduction | Home equity loans
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	43	82	97
Pre-Modification Outstanding Recorded Investment	[1]	$ 3	$ 5	$ 6
Post-Modification Outstanding Recorded Investment	[1]	$ 4	$ 6	$ 6
Retail | Interest Rate Reduction | Home equity lines of credit
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	76	50	49
Pre-Modification Outstanding Recorded Investment	[1]	$ 6	$ 3	$ 4
Post-Modification Outstanding Recorded Investment	[1]	$ 7	$ 3	$ 4
Retail | Interest Rate Reduction | Home equity loans serviced by others
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	4	15	18
Pre-Modification Outstanding Recorded Investment	[1]	$ 0	$ 1	$ 1
Post-Modification Outstanding Recorded Investment	[1]	$ 0	$ 1	$ 1
Retail | Interest Rate Reduction | Home equity lines of credit serviced by others
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	5	5	8
Pre-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0
Retail | Interest Rate Reduction | Automobile
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	158	130	138
Pre-Modification Outstanding Recorded Investment	[1]	$ 4	$ 2	$ 3
Post-Modification Outstanding Recorded Investment	[1]	$ 3	$ 2	$ 3
Retail | Interest Rate Reduction | Education
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	0	0	0
Pre-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0
Retail | Interest Rate Reduction | Credit cards
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	2,312	2,363	2,187
Pre-Modification Outstanding Recorded Investment	[1]	$ 13	$ 13	$ 12
Post-Modification Outstanding Recorded Investment	[1]	$ 13	$ 13	$ 12
Retail | Interest Rate Reduction | Other retail
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[1]	1	1	4
Pre-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[1]	$ 0	$ 0	$ 0
Retail | Maturity Extension
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	287	340	266
Pre-Modification Outstanding Recorded Investment	[2]	$ 34	$ 43	$ 29
Post-Modification Outstanding Recorded Investment	[2]	$ 35	$ 44	$ 29
Retail | Maturity Extension | Residential mortgages
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	61	73	60
Pre-Modification Outstanding Recorded Investment	[2]	$ 8	$ 12	$ 10
Post-Modification Outstanding Recorded Investment	[2]	$ 8	$ 13	$ 10
Retail | Maturity Extension | Home equity loans
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	1	1	39
Pre-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 4
Post-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 5
Retail | Maturity Extension | Home equity lines of credit
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	178	235	121
Pre-Modification Outstanding Recorded Investment	[2]	$ 25	$ 30	$ 13
Post-Modification Outstanding Recorded Investment	[2]	$ 26	$ 30	$ 12
Retail | Maturity Extension | Home equity loans serviced by others
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	0	0	0
Pre-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0
Retail | Maturity Extension | Home equity lines of credit serviced by others
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	1	2	5
Pre-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 1
Post-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 1
Retail | Maturity Extension | Automobile
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	46	29	41
Pre-Modification Outstanding Recorded Investment	[2]	$ 1	$ 1	$ 1
Post-Modification Outstanding Recorded Investment	[2]	$ 1	$ 1	$ 1
Retail | Maturity Extension | Education
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	0	0	0
Pre-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0
Retail | Maturity Extension | Credit cards
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	0	0	0
Pre-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0
Retail | Maturity Extension | Other retail
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[2]	0	0	0
Pre-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[2]	$ 0	$ 0	$ 0
Retail | Other
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	2,279	2,546	2,487
Pre-Modification Outstanding Recorded Investment	[3]	$ 81	$ 94	$ 102
Post-Modification Outstanding Recorded Investment	[3]	$ 77	$ 90	$ 98
Retail | Other | Residential mortgages
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	142	171	247
Pre-Modification Outstanding Recorded Investment	[3]	$ 17	$ 19	$ 26
Post-Modification Outstanding Recorded Investment	[3]	$ 17	$ 19	$ 26
Retail | Other | Home equity loans
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	134	232	279
Pre-Modification Outstanding Recorded Investment	[3]	$ 5	$ 13	$ 18
Post-Modification Outstanding Recorded Investment	[3]	$ 5	$ 13	$ 17
Retail | Other | Home equity lines of credit
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	413	395	304
Pre-Modification Outstanding Recorded Investment	[3]	$ 29	$ 27	$ 23
Post-Modification Outstanding Recorded Investment	[3]	$ 29	$ 27	$ 22
Retail | Other | Home equity loans serviced by others
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	23	52	60
Pre-Modification Outstanding Recorded Investment	[3]	$ 1	$ 2	$ 2
Post-Modification Outstanding Recorded Investment	[3]	$ 1	$ 2	$ 2
Retail | Other | Home equity lines of credit serviced by others
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	14	26	24
Pre-Modification Outstanding Recorded Investment	[3]	$ 1	$ 2	$ 1
Post-Modification Outstanding Recorded Investment	[3]	$ 1	$ 2	$ 1
Retail | Other | Automobile
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	1,189	1,336	1,081
Pre-Modification Outstanding Recorded Investment	[3]	$ 21	$ 24	$ 20
Post-Modification Outstanding Recorded Investment	[3]	$ 17	$ 20	$ 18
Retail | Other | Education
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	355	329	479
Pre-Modification Outstanding Recorded Investment	[3]	$ 7	$ 7	$ 12
Post-Modification Outstanding Recorded Investment	[3]	$ 7	$ 7	$ 12
Retail | Other | Credit cards
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	0	0	0
Pre-Modification Outstanding Recorded Investment	[3]	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[3]	$ 0	$ 0	$ 0
Retail | Other | Other retail
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	[3]	9	5	13
Pre-Modification Outstanding Recorded Investment	[3]	$ 0	$ 0	$ 0
Post-Modification Outstanding Recorded Investment	[3]	$ 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	12 Months Ended
	Dec. 31, 2018USD ($)contract	Dec. 31, 2017USD ($)contract	Dec. 31, 2016USD ($)contract
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	1,103	1,116	1,074
Balance Defaulted | $	$ 103	$ 50	$ 60
Commercial | Commercial Banking
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	29	9	23
Balance Defaulted | $	$ 63	$ 9	$ 13
Commercial | Commercial
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	28	8	22
Balance Defaulted | $	$ 63	$ 5	$ 13
Commercial | Commercial real estate
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	1	1	1
Balance Defaulted | $	$ 0	$ 4	$ 0
Retail | Retail
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	1,074	1,107	1,051
Balance Defaulted | $	$ 40	$ 41	$ 47
Retail | Residential mortgages
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	128	152	187
Balance Defaulted | $	$ 15	$ 19	$ 24
Retail | Home equity loans
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	31	43	50
Balance Defaulted | $	$ 2	$ 2	$ 3
Retail | Home equity lines of credit
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	238	200	155
Balance Defaulted | $	$ 18	$ 14	$ 13
Retail | Home equity loans serviced by others
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	15	23	37
Balance Defaulted | $	$ 0	$ 0	$ 1
Retail | Home equity lines of credit serviced by others
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	6	10	17
Balance Defaulted | $	$ 0	$ 1	$ 0
Retail | Automobile
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	167	140	110
Balance Defaulted | $	$ 2	$ 1	$ 2
Retail | Education
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	23	44	59
Balance Defaulted | $	$ 1	$ 1	$ 1
Retail | Credit cards
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	465	491	433
Balance Defaulted | $	$ 2	$ 3	$ 3
Retail | Other retail
Financing Receivable, Modifications [Line Items]
Number of Contracts | contract	1	4	3
Balance Defaulted | $	$ 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	Dec. 31, 2018	Dec. 31, 2017
Financing Receivable, Recorded Investment [Line Items]
Total	$ 116,660	$ 110,617
High loan-to-value
Financing Receivable, Recorded Investment [Line Items]
Total	553	796
High loan-to-value | Residential Mortgages
Financing Receivable, Recorded Investment [Line Items]
Total	318	366
High loan-to-value | Home Equity Loans and Lines of Credit
Financing Receivable, Recorded Investment [Line Items]
Total	87	166
High loan-to-value | Home Equity Products Serviced by Others
Financing Receivable, Recorded Investment [Line Items]
Total	148	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	0
Interest only/negative amortization
Financing Receivable, Recorded Investment [Line Items]
Total	1,795	1,764
Interest only/negative amortization | Residential Mortgages
Financing Receivable, Recorded Investment [Line Items]
Total	1,794	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	1
Low introductory rate
Financing Receivable, Recorded Investment [Line Items]
Total	217	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	217	197
Low introductory rate | Education
Financing Receivable, Recorded Investment [Line Items]
Total	0	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	0
Credit risk, loans with increased credit exposure
Financing Receivable, Recorded Investment [Line Items]
Total	2,566	2,758
Credit risk, loans with increased credit exposure | Residential Mortgages
Financing Receivable, Recorded Investment [Line Items]
Total	2,113	2,130
Credit risk, loans with increased credit exposure | Home Equity Loans and Lines of Credit
Financing Receivable, Recorded Investment [Line Items]
Total	87	166
Credit risk, loans with increased credit exposure | Home Equity Products Serviced by Others
Financing Receivable, Recorded Investment [Line Items]
Total	148	264
Credit risk, loans with increased credit exposure | Credit Cards
Financing Receivable, Recorded Investment [Line Items]
Total	217	197
Credit risk, loans with increased credit exposure | Education
Financing Receivable, Recorded Investment [Line Items]
Total	$ 1	$ 1

PREMISES, EQUIPMENT, AND SOFT_3

PREMISES, EQUIPMENT, AND SOFTWARE - Narrative (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Capital Leases of Lessee [Abstract]
Depreciation expense	$ 117	$ 124	$ 130
Capitalized Software
Capitalized software, gross	1,800	1,700
Capitalized software, accumulated amortization	948	869
Amortization of software	189	180	$ 170
Assets subject to operating leases	$ 92	$ 112

PREMISES, EQUIPMENT, AND SOFT_4

PREMISES, EQUIPMENT, AND SOFTWARE - Schedule of Premises and Equipment (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017
Property, Plant and Equipment [Line Items]
Total premises and equipment, gross	$ 2,275	$ 2,590
Less: accumulated depreciation	(1,484)	(1,905)
Total premises and equipment, net	791	685
Land and land improvements
Property, Plant and Equipment [Line Items]
Total premises and equipment, gross	$ 112	47
Land and land improvements | Minimum
Property, Plant and Equipment [Line Items]
Useful life	10 years
Land and land improvements | Maximum
Property, Plant and Equipment [Line Items]
Useful life	75 years
Buildings and leasehold improvements
Property, Plant and Equipment [Line Items]
Total premises and equipment, gross	$ 852	719
Buildings and leasehold improvements | Minimum
Property, Plant and Equipment [Line Items]
Useful life	5 years
Buildings and leasehold improvements | Maximum
Property, Plant and Equipment [Line Items]
Useful life	60 years
Furniture, fixtures and equipment
Property, Plant and Equipment [Line Items]
Total premises and equipment, gross	$ 1,019	1,465
Furniture, fixtures and equipment | Minimum
Property, Plant and Equipment [Line Items]
Useful life	5 years
Furniture, fixtures and equipment | Maximum
Property, Plant and Equipment [Line Items]
Useful life	20 years
Construction in progress
Property, Plant and Equipment [Line Items]
Total premises and equipment, gross	$ 292	$ 359

PREMISES, EQUIPMENT, AND SOFT_5

PREMISES, EQUIPMENT, AND SOFTWARE - Schedule of Amortization (Details) $ in Millions	Dec. 31, 2018USD ($)
Capitalized Software, Expected Future Amortization Expense [Abstract]
2,019	$ 186
2,020	155
2,021	116
2,022	80
2,023	48
Thereafter	72
Total	657	[1]
In-process software	$ 188
[1]	Excluded from this balance is $188 million of in-process software at December 31, 2018.

LEASE COMMITMENTS - Narrative (

LEASE COMMITMENTS - Narrative (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Leases [Abstract]
Rent expense for operating leases and capital leases	$ 212	$ 211	$ 208

LEASE COMMITMENTS - Aggregate M

LEASE COMMITMENTS - Aggregate Minimum Rental Commitments (Details) $ in Millions	Dec. 31, 2018USD ($)
Operating Leases
2,019	$ 165
2,020	153
2,021	136
2,022	109
2,023	85
Thereafter	247
Total minimum lease payments	895
Capital Leases
2,019	3
2,020	2
2,021	2
2,022	1
2,023	0
Thereafter	8
Total minimum lease payments	16
Amounts representing interest	(8)
Present value of net minimum lease payments	$ 8

MORTGAGE BANKING - Residential

MORTGAGE BANKING - Residential Mortgage Loans (Details) - USD ($) $ in Millions		12 Months Ended
		Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Accounts, Notes, Loans and Financing Receivable [Line Items]
Residential mortgage loan sale proceeds		$ 8,149	$ 3,161	$ 2,652
Residential Mortgages
Accounts, Notes, Loans and Financing Receivable [Line Items]
Residential mortgage loan sale proceeds		8,149	3,161	2,652
Mortgage Banking Fees
Accounts, Notes, Loans and Financing Receivable [Line Items]
Gain on sales	[1]	89	35	69
Contractually specified servicing, late and other ancillary fees	[1]	$ 118	$ 53	$ 51
[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	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017
MSRs:
Balance as of beginning of period	$ 201	$ 167
Amount capitalized	36	37
Purchases	16	28
Amortization	(32)	(31)
Carrying amount before valuation allowance	221	201
Valuation allowance for servicing assets
Balance as of beginning of period	3	5
Valuation recoveries	(3)	(2)
Balance at end of period	0	3
Net carrying value of MSRs	$ 221	$ 198

MORTGAGE BANKING - Changes Re_2

MORTGAGE BANKING - Changes Related to MSR's - Fair Value Method (Details) $ in Millions	12 Months Ended
	Dec. 31, 2018USD ($)
MSRs:
Fair value at end of the period	$ 600
Residential mortgages
MSRs:
Fair value as of beginning of the period	0
Acquired MSRs	590
Amounts capitalized	73
Changes in unpaid principal balance during the period	(32)	[1]
Changes in fair value during the period	(31)	[2]
Fair value at end of the period	$ 600
[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	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017
Servicing Assets And Servicing Liabilities At Amortized Cost, Assumptions Used To Estimate Fair Value [Abstract]
MSR portfolio fair value	$ 243	$ 218
Weighted average life (in years)	6 years 6 months	5 years 10 months 24 days
Weighted average constant prepayment rate	8.50%	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]
Fair value	$ 600
Weighted-average life (in years)	8 years
Weighted-average constant prepayment rate	8.20%
Weighted average option adjusted spread	6.09%
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	$ 24	$ 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	68
Decline in fair value due to 50 bps decrease in option adjusted spread	$ 13
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	$ 56	$ 46
Decline in fair value due to 100 bps decrease in discount rate	9	$ 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	148
Decline in fair value due to 100 bps decrease in option adjusted spread	$ 26

GOODWILL AND INTANGIBLE ASSET_2

GOODWILL AND INTANGIBLE ASSETS - Narrative (Details) $ in Millions	12 Months Ended			372 Months Ended
	Dec. 31, 2018USD ($)reporting_unit	Dec. 31, 2017USD ($)	Dec. 31, 2016USD ($)	Dec. 31, 2018USD ($)business	Aug. 01, 2018USD ($)
Goodwill [Line Items]
Number of reporting units | reporting_unit	2
Number of acquisitions of banks or assets of banks | business				25
Goodwill acquired during period	$ 36
Goodwill impairment	0	$ 0	$ 0
Amortization of intangible assets	3	0	$ 0
Consumer Banking
Goodwill [Line Items]
Goodwill accumulated impairment loss	5,900	5,900		$ 5,900
Commercial Banking
Goodwill [Line Items]
Goodwill accumulated impairment loss	50	$ 50		50
Franklin American Mortgage Company
Goodwill [Line Items]
Intangible assets acquired	30			30	$ 32
Amortization expense	$ 2			$ 2

GOODWILL AND INTANGIBLE ASSET_3

GOODWILL AND INTANGIBLE ASSETS - Goodwill Rollforward (Details) - USD ($) $ in Millions		12 Months Ended
		Dec. 31, 2018	Dec. 31, 2017
Goodwill [Roll Forward]
Beginning balance		$ 6,887	$ 6,876
Business acquisition		59	11
Adjustments	[1]	(23)
Ending balance		6,923	6,887
Consumer Banking
Goodwill [Roll Forward]
Beginning balance		2,136	2,136
Business acquisition		59	0
Adjustments	[1]	(23)
Ending balance		2,172	2,136
Commercial Banking
Goodwill [Roll Forward]
Beginning balance		4,751	4,740
Business acquisition		0	11
Adjustments	[1]	0
Ending balance		$ 4,751	$ 4,751
[1]	Adjustments to goodwill are the result of an update to the purchase price allocation for the FAMC acquisition, given higher value attributed to purchased net assets.

GOODWILL AND INTANGIBLE ASSET_4

GOODWILL AND INTANGIBLE ASSETS - Other Intangibles (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017
Finite-Lived Intangible Assets [Line Items]
Gross	$ 34	$ 2
Accumulated Amortization	3	0
Net	$ 31	2
Acquired technology
Finite-Lived Intangible Assets [Line Items]
Useful life	7 years
Gross	$ 20	0
Accumulated Amortization	1	0
Net	19	0
Acquired relationships
Finite-Lived Intangible Assets [Line Items]
Gross	11	2
Accumulated Amortization	1	0
Net	10	2
Other
Finite-Lived Intangible Assets [Line Items]
Gross	3	0
Accumulated Amortization	1	0
Net	$ 2	$ 0
Minimum | Acquired relationships
Finite-Lived Intangible Assets [Line Items]
Useful life	5 years
Minimum | Other
Finite-Lived Intangible Assets [Line Items]
Useful life	2 years
Maximum | Acquired relationships
Finite-Lived Intangible Assets [Line Items]
Useful life	15 years
Maximum | Other
Finite-Lived Intangible Assets [Line Items]
Useful life	3 years

GOODWILL AND INTANGIBLE ASSET_5

GOODWILL AND INTANGIBLE ASSETS - Intangible Asset Amortization (Details) $ in Millions	Dec. 31, 2018USD ($)
Finite-Lived Intangible Assets, Amortization Expense, Maturity Schedule [Abstract]
2,019	$ 5
2,020	5
2,021	4
2,022	3
2,023	$ 3

VARIABLE INTEREST ENTITIES - Na

VARIABLE INTEREST ENTITIES - Narrative (Details) - USD ($)		12 Months Ended
		Dec. 31, 2018	Dec. 31, 2017
Variable Interest Entity [Line Items]
Loans and leases	[1],[2]	$ 116,660,000,000	$ 110,617,000,000
LIHTC Investments
Variable Interest Entity [Line Items]
Net impairment losses recognized in earnings		0	0
Commercial | Special Purpose Entities
Variable Interest Entity [Line Items]
Loans and leases		613,000,000	$ 0
Undrawn commitments to extend credit | Special Purpose Entities
Variable Interest Entity [Line Items]
Undrawn commitments to extend credit		$ 584,000,000
[1]	Excluded from the table above are loans held for sale totaling $1.3 billion and $718 million as of December 31, 2018 and 2017, respectively.
[2]	Mortgage loans serviced for others by the Company’s subsidiaries are not included above, and amounted to $69.6 billion and $20.3 billion at December 31, 2018 and 2017, respectively.

VARIABLE INTEREST ENTITIES - Sc

VARIABLE INTEREST ENTITIES - Schedule of Variable Interest Entities (Details) - USD ($) $ in Millions		Dec. 31, 2018	Dec. 31, 2017
Variable Interest Entity [Line Items]
Lending to special purpose entities included in loans and leases	[1],[2]	$ 116,660	$ 110,617
LIHTC Investments
Variable Interest Entity [Line Items]
LIHTC investment included in other assets		1,236	951
LIHTC unfunded commitments included in other liabilities		673	491
Renewable Energy
Variable Interest Entity [Line Items]
Renewable energy investments included in other assets		319	335
Commercial | Special Purpose Entities
Variable Interest Entity [Line Items]
Lending to special purpose entities included in loans and leases		$ 613	$ 0
[1]	Excluded from the table above are loans held for sale totaling $1.3 billion and $718 million as of December 31, 2018 and 2017, respectively.
[2]	Mortgage loans serviced for others by the Company’s subsidiaries are not included above, and amounted to $69.6 billion and $20.3 billion at December 31, 2018 and 2017, respectively.

VARIABLE INTEREST ENTITIES - _2

VARIABLE INTEREST ENTITIES - Schedule of Affordable Housing Tax Credit Investments (Details) - LIHTC Investments - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Schedule of Equity Method Investments [Line Items]
Tax credits included in income tax expense	$ 101	$ 83	$ 59
Amortization expense included in income tax expense	110	94	59
Other tax benefits included in income tax expense	$ 25	$ 31	$ 21

DEPOSITS - Narrative (Details)

DEPOSITS - Narrative (Details) $ in Millions	Dec. 31, 2018USD ($)
Banking and Thrift [Abstract]
Time deposits of $100,000 or more	$ 13,844

DEPOSITS - Major Components of

DEPOSITS - Major Components of Deposits (Details) - USD ($) $ in Millions	Dec. 31, 2018	Dec. 31, 2017
Deposits, by Type [Abstract]
Demand	$ 29,458	$ 29,279
Checking with interest	23,067	22,229
Regular savings	12,007	9,518
Money market accounts	35,701	37,454
Term deposits	19,342	16,609
Total deposits	$ 119,575	$ 115,089

DEPOSITS - Maturities of Term D

DEPOSITS - Maturities of Term Deposits (Details) - USD ($) $ in Millions	Dec. 31, 2018	Dec. 31, 2017
Time Deposits, Fiscal Year Maturity [Abstract]
2,019	$ 15,889
2,020	2,519
2,021	649
2,022	174
2,023	106
2024 and thereafter	5
Total	$ 19,342	$ 16,609

DEPOSITS - Maturities of Term_2

DEPOSITS - Maturities of Term Deposits Greater than $100,000 (Details) $ in Millions	Dec. 31, 2018USD ($)
Contractual Maturities, Time Deposits, $100,000 or More [Abstract]
Three months or less	$ 5,388
After three months through six months	2,676
After six months through twelve months	3,844
After twelve months	1,936
Total term deposits	$ 13,844

BORROWED FUNDS - Narrative (Det

BORROWED FUNDS - Narrative (Details) - USD ($) $ in Millions	Dec. 31, 2018	Dec. 31, 2017
Debt Instrument [Line Items]
Hedging basis adjustments	$ 449	$ 693
Short-term borrowed funds	2,809	2,671
Available borrowing capacity	36,200
FHLB advances and letters of credit | Secured Debt
Debt Instrument [Line Items]
Short-term borrowed funds	13,000	9,400
FHLB advances
Debt Instrument [Line Items]
Available borrowing capacity	4,800	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	12,500	9,500
Unamortized deferred issuance costs and or discounts	(14)	(19)
Hedging basis adjustments	$ (58)	$ (63)

BORROWED FUNDS - Short Term Deb

BORROWED FUNDS - Short Term Debt (Details) - USD ($) $ in Millions		Dec. 31, 2018	Dec. 31, 2017
Short-term Debt [Line Items]
Total short-term borrowed funds		$ 2,809	$ 2,671
Federal funds purchased
Short-term Debt [Line Items]
Total short-term borrowed funds		820	460
Securities sold under agreements to repurchase
Short-term Debt [Line Items]
Total short-term borrowed funds		336	355
Other short-term borrowed funds
Short-term Debt [Line Items]
Total short-term borrowed funds	[1]	1,653	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 discounts		(1)	(1)
Other basis adjustments		$ (8)	$ (4)
[1]	December 31, 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 ($8) 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		12 Months Ended
		Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Federal funds purchased and securities sold under agreements to repurchase
Short-term Debt [Line Items]
Weighted-average interest rate at period end	[1]	1.72%	0.74%	0.26%
Maximum amount outstanding at month-end during the period	[2]	$ 1,282	$ 1,174	$ 1,522
Average amount outstanding during the period	[2]	$ 654	$ 776	$ 947
Weighted-average interest rate during the period	[1]	0.92%	0.36%	0.09%
Other short-term borrowed funds
Short-term Debt [Line Items]
Weighted-average interest rate at period end	[1]	2.50%	1.72%	0.94%
Maximum amount outstanding at month-end during the period		$ 2,509	$ 3,508	$ 5,461
Average amount outstanding during the period		$ 1,808	$ 2,321	$ 3,207
Weighted-average interest rate during the period	[1]	2.42%	1.32%	0.64%
[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		Dec. 31, 2018	Dec. 31, 2017
Debt Instrument [Line Items]
Long-term borrowed funds		$ 14,433	$ 11,765
5.158% fixed-to-floating rate subordinated debt, callable, due 2023
Debt Instrument [Line Items]
Interest rate		5.158%
Parent company
Debt Instrument [Line Items]
Long-term borrowed funds		$ 1,987
Banking Subsidiaries
Debt Instrument [Line Items]
Long-term borrowed funds		$ 12,446
Senior Unsecured Notes | Parent company | 2.375% fixed rate senior unsecured debt, due 2021
Debt Instrument [Line Items]
Interest rate		2.375%
Long-term borrowed funds		$ 349	349
Senior Unsecured Notes | Banking Subsidiaries | 2.450% senior unsecured notes, due 2019
Debt Instrument [Line Items]
Interest rate		2.45%
Long-term borrowed funds	[1],[2]	$ 0	743
Senior Unsecured Notes | Banking Subsidiaries | 2.500% senior unsecured notes, due 2019
Debt Instrument [Line Items]
Interest rate		2.50%
Long-term borrowed funds	[1],[2]	$ 0	741
Senior Unsecured Notes | Banking Subsidiaries | 2.250% senior unsecured notes, due 2020 (1)
Debt Instrument [Line Items]
Interest rate		2.25%
Long-term borrowed funds	[1]	$ 691	692
Senior Unsecured Notes | Banking Subsidiaries | 3.278% floating rate senior unsecured notes, due 2020
Debt Instrument [Line Items]
Interest rate		3.278%
Long-term borrowed funds	[1],[3]	$ 300	299
Senior Unsecured Notes | Banking Subsidiaries | 3.247% floating rate senior unsecured notes, due 2020
Debt Instrument [Line Items]
Interest rate		3.247%
Long-term borrowed funds	[1],[3]	$ 250	249
Senior Unsecured Notes | Banking Subsidiaries | 2.200% senior unsecured notes, due 2020
Debt Instrument [Line Items]
Interest rate		2.20%
Long-term borrowed funds	[1]	$ 499	498
Senior Unsecured Notes | Banking Subsidiaries | 2.250% senior unsecured notes, due 2020
Debt Instrument [Line Items]
Interest rate		2.25%
Long-term borrowed funds	[1]	$ 738	742
Senior Unsecured Notes | Banking Subsidiaries | 2.550% senior unsecured notes, due 2021
Debt Instrument [Line Items]
Interest rate		2.55%
Long-term borrowed funds	[1]	$ 964	964
Senior Unsecured Notes | Banking Subsidiaries | 3.487% floating-rate senior unsecured notes, due 2022
Debt Instrument [Line Items]
Interest rate		3.487%
Long-term borrowed funds	[1],[3]	$ 249	249
Senior Unsecured Notes | Banking Subsidiaries | 2.650% senior unsecured notes, due 2022
Debt Instrument [Line Items]
Interest rate		2.65%
Long-term borrowed funds	[1]	$ 487	491
Senior Unsecured Notes | Banking Subsidiaries | 3.700% senior unsecured notes, due 2023
Debt Instrument [Line Items]
Interest rate		3.70%
Long-term borrowed funds	[1]	$ 502	0
Senior Unsecured Notes | Banking Subsidiaries | 3.753% floating-rate senior unsecured notes, due 2023
Debt Instrument [Line Items]
Interest rate		3.753%
Long-term borrowed funds	[1],[3]	$ 249	0
Subordinated Debt | Parent company | 4.150% fixed rate subordinated debt, due 2022
Debt Instrument [Line Items]
Interest rate		4.15%
Long-term borrowed funds		$ 348	348
Subordinated Debt | Parent company | 5.158% fixed-to-floating rate subordinated debt, callable, due 2023
Debt Instrument [Line Items]
Interest rate		5.158%
Long-term borrowed funds	[4]	$ 0	333
Subordinated Debt | Parent company | 3.750% fixed rate subordinated debt due 2024
Debt Instrument [Line Items]
Interest rate		3.75%
Long-term borrowed funds		$ 250	250
Subordinated Debt | Parent company | 4.023% fixed rate subordinated debt, due 2024
Debt Instrument [Line Items]
Interest rate		4.023%
Long-term borrowed funds		$ 42	42
Subordinated Debt | Parent company | 4.350% fixed rate subordinated debt, due 2025
Debt Instrument [Line Items]
Interest rate		4.35%
Long-term borrowed funds		$ 249	249
Subordinated Debt | Parent company | 4.300% fixed rate subordinated debt, due 2025
Debt Instrument [Line Items]
Interest rate		4.30%
Long-term borrowed funds		$ 749	749
Federal Home Loan advances | Banking Subsidiaries
Debt Instrument [Line Items]
Weighted average interest rate		2.725%
Long-term borrowed funds		$ 7,508	3,761
Other | Banking Subsidiaries
Debt Instrument [Line Items]
Long-term borrowed funds		$ 9	$ 16
[1]	Issued under CBNA’s Global Bank Note Program.
[2]	Reclassified to short-term borrowed funds.
[3]	Rate disclosed reflects the floating rate as of December 31, 2018.
[4]	Redeemed on June 29, 2018.

BORROWED FUNDS - Maturities of

BORROWED FUNDS - Maturities of Long-term Borrowed Funds (Details) - USD ($) $ in Millions	Dec. 31, 2018	Dec. 31, 2017
Debt Instrument [Line Items]
2,019	$ 0
2,020	9,982
2,021	1,316
2,022	1,087
2,023	751
2024 and thereafter	1,297
Total	14,433	$ 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	0
2,020	9,982
2,021	967
2,022	739
2,023	751
2024 and thereafter	7
Total	$ 12,446

DERIVATIVES - Narrative (Detail

DERIVATIVES - Narrative (Details) $ in Millions	Dec. 31, 2018USD ($)
Derivative Instruments and Hedging Activities Disclosure [Abstract]
Net gain (pre-tax) on derivatives expected to be reclassified in next 12 months	$ 15

DERIVATIVES - Schedule of Deriv

DERIVATIVES - Schedule of Derivative Instruments (Details) - USD ($) $ in Millions		Dec. 31, 2018	Dec. 31, 2017
Derivative Assets
Derivative assets		$ 449	$ 693
Less: Gross amounts offset in the Consolidated Balance Sheets	[1]	(87)	(72)
Less: Cash collateral applied	[1]	(45)	(4)
Total net derivative fair values presented in the Consolidated Balance Sheets		317	617
Derivative Liabilities
Derivative Liabilities		415	533
Less: Gross amounts offset in the Consolidated Balance Sheets	[1]	(87)	(72)
Less: Cash collateral applied	[1]	(36)	(151)
Total net derivative fair values presented in the Consolidated Balance Sheets		292	310
Derivatives not designated as hedging instruments:
Derivative Assets
Derivative assets		444	693
Derivative Liabilities
Derivative Liabilities		415	533
Interest rate swaps
Derivative Assets
Derivative assets		306	538
Derivative Liabilities
Derivative Liabilities		277	379
Interest rate swaps | Derivatives designated as hedging instruments:
Derivatives, Fair Value [Line Items]
Notional amount	[2]	12,050	13,300
Derivative Assets
Derivative assets		5	0
Derivative Liabilities
Derivative Liabilities		0	0
Interest rate swaps | Derivatives not designated as hedging instruments:
Derivatives, Fair Value [Line Items]
Notional amount	[2]	117,076	80,180
Derivative Assets
Derivative assets		301	538
Derivative Liabilities
Derivative Liabilities		277	379
Foreign exchange contracts
Derivative Assets
Derivative assets		129	148
Derivative Liabilities
Derivative Liabilities		113	149
Foreign exchange contracts | Derivatives not designated as hedging instruments:
Derivatives, Fair Value [Line Items]
Notional amount	[2]	9,866	9,882
Derivative Assets
Derivative assets		129	148
Derivative Liabilities
Derivative Liabilities		113	149
Other contracts
Derivative Assets
Derivative assets		14	7
Derivative Liabilities
Derivative Liabilities		25	5
Other contracts | Derivatives not designated as hedging instruments:
Derivatives, Fair Value [Line Items]
Notional amount	[2]	3,555	1,039
Derivative Assets
Derivative assets		14	7
Derivative Liabilities
Derivative Liabilities		$ 25	$ 5
[1]	Amounts represent the impact of enforceable master netting agreements that allow the Company to net settle positive and negative positions as well as collateral paid and received.
[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	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Derivative Instruments, Gain (Loss) [Line Items]
Derivative	$ 205	$ 66	$ 65
Hedge of interest rate risk | Other Income
Derivative Instruments, Gain (Loss) [Line Items]
Derivative	8	(26)	(6)
Hedged Item	(9)	27	5
Hedge Ineffectiveness	$ (1)	$ 1	$ (1)

DERIVATIVES - Effect of Derivat

DERIVATIVES - Effect of Derivative Instruments on Net Income (Details) - USD ($) $ in Millions		12 Months Ended
		Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Derivative Instruments, Gain (Loss) [Line Items]
Amounts reclassified from OCI to interest expense		$ (1,226)	$ (747)	$ (508)
Amount Reclassified from AOCI | Net Unrealized (Losses) Gains on Derivatives
Derivative Instruments, Gain (Loss) [Line Items]
Effective portion of loss recognized in OCI	[1]	(44)	(23)	(100)
Amounts reclassified from OCI to interest income	[2]	(55)	25	90
Amounts reclassified from OCI to interest expense	[2]	12	0	(27)
Amounts reclassified from OCI to other income	[3]	$ 0	$ 0	$ (5)
[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.
[3]	This includes gains and losses attributable to previously hedged cash flows where the likelihood occurrence of those cash flows is no longer probable.

DERIVATIVES - Effect of Custome

DERIVATIVES - Effect of Customer Derivatives and Economic Hedges on Net Income (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	$ 205	$ 66	$ 65
Economic Hedge Type | Foreign exchange and interest rate products | Customer interest rate contracts
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	5	5	(23)
Economic Hedge Type | Foreign exchange and interest rate products | Customer foreign exchange contracts
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	(54)	172	(81)
Economic Hedge Type | Foreign exchange and interest rate products | Derivatives transactions to hedge interest rate risk
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	43	46	70
Economic Hedge Type | Foreign exchange and interest rate products | Derivatives transactions to hedge foreign exchange risk
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	158	(151)	95
Economic Hedge Type | Mortgage banking fees | Residential loan commitments
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	(3)	2	(2)
Economic Hedge Type | Mortgage banking fees | Forward sale contracts
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	21	(8)	6
Economic Hedge Type | Mortgage banking fees | Interest rate derivative contracts used to hedge residential MSRs
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	$ 35	$ 0	$ 0

EMPLOYEE BENEFITS - Narrative (

EMPLOYEE BENEFITS - Narrative (Details) - USD ($)	Sep. 12, 2018	Jan. 01, 2015	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Defined Benefit Plans and Other Postretirement Benefit Plans Table Text Block [Line Items]
Years of service used in determining benefits			5 years
Net actuarial losses			$ 618,000,000	$ 585,000,000
401(k) Plan
Employer matching contribution percentage		100.00%
Employer matching contribution, Percent of employees' pay		4.00%
Employer matching contribution, addition			2.00%
Employer contribution amount			$ 68,000,000	$ 61,000,000	$ 55,000,000
Qualified Plan
Defined Benefit Plans and Other Postretirement Benefit Plans Table Text Block [Line Items]
Discount rate			4.33%	3.67%	4.19%
Employer contributions	$ 50,000,000		$ 50,000,000	$ 0
Expected contribution			$ 0
Non-Qualified Plan
Defined Benefit Plans and Other Postretirement Benefit Plans Table Text Block [Line Items]
Discount rate			4.24%	3.53%	4.05%
Employer contributions			$ 8,000,000	$ 8,000,000
Expected contribution			$ 9,000,000
Postretirement Benefit Plan
Defined Benefit Plans and Other Postretirement Benefit Plans Table Text Block [Line Items]
Discount rate			3.98%	3.20%
Expected contribution			$ 1,000,000
Defined Benefit Plan, Assumed Health Care Cost Trend Rates [Abstract]
Assumed annual rate of increase in the per capita cost of covered health care benefits			6.50%	7.00%
Ultimate health care cost trend rate			5.00%	5.00%

EMPLOYEE BENEFITS - Allocation

EMPLOYEE BENEFITS - Allocation of Plan Assets (Details)	Dec. 31, 2018	Dec. 31, 2017
Defined Benefit Plan Disclosure [Line Items]
Actual asset allocations	100.00%	100.00%
Equity securities
Defined Benefit Plan Disclosure [Line Items]
Minimum target asset allocation	53.00%
Actual asset allocations	51.30%	54.00%
Debt securities
Defined Benefit Plan Disclosure [Line Items]
Minimum target asset allocation	46.00%
Actual asset allocations	47.60%	45.00%
Other
Defined Benefit Plan Disclosure [Line Items]
Minimum target asset allocation	1.00%
Actual asset allocations	1.10%	1.00%

EMPLOYEE BENEFITS - Changes in

EMPLOYEE BENEFITS - Changes in the Fair Value of Pension Plan Assets, Projected Benefit Obligation, Funded Status, and Accumulated Benefit Obligation (Details) - USD ($) $ in Millions	Sep. 12, 2018	Dec. 31, 2018	Dec. 31, 2017
Qualified Plan
Defined Benefit Plan, Change in Fair Value of Plan Assets [Roll Forward]
Fair value of plan assets as of January 1		$ 1,139	$ 1,015
Actual return on plan assets		(81)	185
Employer contributions	$ 50	50	0
Benefits and administrative expenses paid		(58)	(61)
Fair value of plan assets as of December 31		1,050	1,139
Projected benefit obligation		972	1,089
Pension asset (obligation)		78	50
Accumulated benefit obligation		972	1,089
Non-Qualified Plan
Defined Benefit Plan, Change in Fair Value of Plan Assets [Roll Forward]
Fair value of plan assets as of January 1		0	0
Actual return on plan assets		0	0
Employer contributions		8	8
Benefits and administrative expenses paid		(8)	(8)
Fair value of plan assets as of December 31		0	0
Projected benefit obligation		95	106
Pension asset (obligation)		(95)	(106)
Accumulated benefit obligation		$ 95	$ 106

EMPLOYEE BENEFITS - Plan Amount

EMPLOYEE BENEFITS - Plan Amounts Recognized in OCI (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Retirement Benefits [Abstract]
Net periodic pension income	$ (16)	$ (2)	$ (1)
Net actuarial loss (gain)	49	(31)	54
Amortization of prior service credit	1	1	1
Amortization of net actuarial loss	(17)	(18)	(16)
Total recognized in other comprehensive income (loss)	33	(48)	39
Total recognized in net periodic pension cost and other comprehensive income (loss)	$ 17	$ (50)	$ 38

EMPLOYEE BENEFITS - Schedule of

EMPLOYEE BENEFITS - Schedule of Net Periodic (Income) Cost (Details) - USD ($) $ in Millions		12 Months Ended
		Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Defined Benefit Plan Disclosure [Line Items]
Service cost		$ 3	$ 3	$ 3
Interest cost		43	46	48
Expected return on plan assets		(79)	(69)	(68)
Amortization of actuarial loss		17	18	16
Net periodic pension (income) cost	[1]	(16)	(2)	(1)
Qualified Plan
Defined Benefit Plan Disclosure [Line Items]
Service cost		3	3	3
Interest cost		39	42	44
Expected return on plan assets		(79)	(69)	(68)
Amortization of actuarial loss		15	16	14
Net periodic pension (income) cost	[1]	(22)	(8)	(7)
Non-Qualified Plan
Defined Benefit Plan Disclosure [Line Items]
Service cost		0	0	0
Interest cost		4	4	4
Expected return on plan assets		0	0	0
Amortization of actuarial loss		2	2	2
Net periodic pension (income) cost	[1]	$ 6	$ 6	$ 6
[1]	In the Consolidated Statements of Operations, service cost is presented in salaries and employee benefits, and all other components of net periodic pension (income) costs are presented in other operating expense.

EMPLOYEE BENEFITS - Assumptions

EMPLOYEE BENEFITS - Assumptions Used in Determining Actuarial Present Value of Benefit Obligations and Net Periodic Benefit Cost (Details)	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Assumptions for benefit obligations
Expected long-term rate of return on plan assets	7.00%	7.00%	7.50%
Assumptions for net periodic pension cost
Expected long-term rate of return on plan assets	7.00%	7.00%	7.50%
Qualified Plan
Assumptions for benefit obligations
Discount rate	4.33%	3.67%	4.19%
Assumptions for net periodic pension cost
Discount rate	3.67%	4.19%	4.64%
Non-Qualified Plan
Assumptions for benefit obligations
Discount rate	4.24%	3.53%	4.05%
Assumptions for net periodic pension cost
Discount rate	3.53%	4.05%	4.54%

EMPLOYEE BENEFITS - Expected Fu

EMPLOYEE BENEFITS - Expected Future Benefit Payments (Details) $ in Millions	Dec. 31, 2018USD ($)
Qualified and Non-Qualified Plans
Expected benefit payments by fiscal year ended
December 31, 2019	$ 64
December 31, 2020	64
December 31, 2021	65
December 31, 2022	66
December 31, 2023	67
December 31, 2024 - 2028	340
Postretirement Benefit Plan
Expected benefit payments by fiscal year ended
December 31, 2019	1
December 31, 2020	1
December 31, 2021	1
December 31, 2022	1
December 31, 2023	1
December 31, 2024 - 2028	$ 5

EMPLOYEE BENEFITS - Fair Value

EMPLOYEE BENEFITS - Fair Value of Plan Assets (Details) - USD ($) $ in Millions		Dec. 31, 2018	Dec. 31, 2017
Cash and money market funds
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		$ 12
U.S. government obligations
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		5	$ 8
Non-U.S. government obligations
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		1	2
Municipal obligations
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		1	1
Corporate bonds
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		99	102
Asset-backed securities
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value			1
Bank loans
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		1
Level 1
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		17	0
Level 1 | Cash and money market funds
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		12
Level 1 | U.S. government obligations
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		5	0
Level 1 | Non-U.S. government obligations
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		0	0
Level 1 | Municipal obligations
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		0	0
Level 1 | Corporate bonds
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		0	0
Level 1 | Asset-backed securities
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value			0
Level 1 | Bank loans
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		0
Level 2
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		102	114
Level 2 | Cash and money market funds
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		0
Level 2 | U.S. government obligations
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		0	8
Level 2 | Non-U.S. government obligations
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		1	2
Level 2 | Municipal obligations
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		1	1
Level 2 | Corporate bonds
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		99	102
Level 2 | Asset-backed securities
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value			1
Level 2 | Bank loans
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		1
Level 3
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		0	0
Level 3 | Cash and money market funds
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		0
Level 3 | U.S. government obligations
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		0	0
Level 3 | Non-U.S. government obligations
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		0	0
Level 3 | Municipal obligations
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		0	0
Level 3 | Corporate bonds
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		0	0
Level 3 | Asset-backed securities
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value			0
Level 3 | Bank loans
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		0
Total
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		119	114
Investments Measured at Net Asset Value
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value	[1]	931	1,024
Investment
Defined Benefit Plan Disclosure [Line Items]
Assets at fair value		$ 1,050	$ 1,138
[1]	Certain investments that were measured at net asset value per share (or its equivalent) have not been classified in the fair value hierarchy.

EMPLOYEE BENEFITS - Fair Valu_2

EMPLOYEE BENEFITS - Fair Value Estimated Using Net Asset Value per Share (Details) - USD ($) $ in Millions		12 Months Ended
		Dec. 31, 2018	Dec. 31, 2017
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share [Line Items]
Unfunded commitments		$ 0
Mutual funds | Liquid Cash Fund
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share [Line Items]
Unfunded commitments		0
Common and collective funds | Global equities funds
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share [Line Items]
Unfunded commitments		$ 0
Redemption notice period		3 days
Common and collective funds | Balanced funds
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share [Line Items]
Unfunded commitments		$ 0
Redemption notice period		2 days
Common and collective funds | Fixed income fund
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share [Line Items]
Unfunded commitments		$ 0
Redemption notice period		3 days
Managed portfolio, fixed income mutual fund | Managed Portfolio, Fixed Income Mutual Fund
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share [Line Items]
Unfunded commitments	[1]	$ 0
Redemption notice period		1 day
Limited partnerships | Global equity fund
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share [Line Items]
Unfunded commitments		$ 0
Redemption notice period		3 days
Investments Measured at Net Asset Value
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share [Line Items]
Investments measured at net asset value	[2]	$ 931	$ 1,024
Investments Measured at Net Asset Value | Mutual funds | Liquid Cash Fund
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share [Line Items]
Investments measured at net asset value		0	11
Investments Measured at Net Asset Value | Common and collective funds | Global equities funds
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share [Line Items]
Investments measured at net asset value		399	472
Investments Measured at Net Asset Value | Common and collective funds | Balanced funds
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share [Line Items]
Investments measured at net asset value		221	214
Investments Measured at Net Asset Value | Common and collective funds | Fixed income fund
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share [Line Items]
Investments measured at net asset value		139	150
Investments Measured at Net Asset Value | Managed portfolio, fixed income mutual fund | Managed Portfolio, Fixed Income Mutual Fund
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share [Line Items]
Investments measured at net asset value	[1]	32	35
Investments Measured at Net Asset Value | Limited partnerships | Global equity fund
Fair Value, Investments, Entities that Calculate Net Asset Value Per Share [Line Items]
Investments measured at net asset value		$ 140	$ 142
[1]	The managed portfolio fixed income mutual fund seeks to outperform the Barclay’s U.S. Long Credit Index or similar benchmark.
[2]	Certain investments that were measured at net asset value per share (or its equivalent) have not been classified in the fair value hierarchy.

EMPLOYEE BENEFITS - Assumptio_2

EMPLOYEE BENEFITS - Assumptions Used in Determining the Net Periodic Benefit Cost of the Postretirement Benefits Plan (Details)	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017
Postretirement Benefit Plan
Defined Benefit Plans and Other Postretirement Benefit Plans Table Text Block [Line Items]
Discount rate	3.20%	3.53%

RECLASSIFICATIONS OUT OF ACCU_3

RECLASSIFICATIONS OUT OF ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS) - Schedule of Accumulated Other Comprehensive (Loss) (Details) - USD ($) $ in Millions		12 Months Ended
		Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance		$ 20,270	$ 19,747	$ 19,646
Other comprehensive loss before reclassifications		(272)	(20)	(201)
Other-than-temporary impairment not recognized in earnings on debt securities		(3)	0	(17)
Amounts reclassified to the Consolidated Statements of Operations		(1)	13	(63)
Reclassification of tax effects resulting from the 2017 Tax Legislation			0
Net other comprehensive loss		(276)	(7)	(281)
Ending balance		20,817	20,270	19,747
Net Unrealized (Losses) Gains on Derivatives
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance		(143)	(88)	10
Other comprehensive loss before reclassifications		(33)	(14)	(62)
Other-than-temporary impairment not recognized in earnings on debt securities		0		0
Amounts reclassified to the Consolidated Statements of Operations		33	(16)	(36)
Reclassification of tax effects resulting from the 2017 Tax Legislation	[1]		(25)
Net other comprehensive loss		0	(30)	(98)
Ending balance		(143)	(143)	(88)
Net Unrealized (Losses) Gains on Securities
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance		(236)	(186)	(28)
Other comprehensive loss before reclassifications		(239)	(6)	(139)
Other-than-temporary impairment not recognized in earnings on debt securities		(3)		(17)
Amounts reclassified to the Consolidated Statements of Operations		(12)	(2)	(2)
Reclassification of tax effects resulting from the 2017 Tax Legislation	[1]		(42)
Net other comprehensive loss		(254)	(8)	(158)
Ending balance		(490)	(236)	(186)
Employee Benefit Plans
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance		(441)	(394)	(369)
Other comprehensive loss before reclassifications		0	0	0
Other-than-temporary impairment not recognized in earnings on debt securities		0		0
Amounts reclassified to the Consolidated Statements of Operations		(22)	31	(25)
Reclassification of tax effects resulting from the 2017 Tax Legislation	[1]		(78)
Net other comprehensive loss		(22)	31	(25)
Ending balance		(463)	(441)	(394)
Total AOCI
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance		(820)	(668)	(387)
Reclassification of tax effects resulting from the 2017 Tax Legislation	[1]		(145)
Ending balance		$ (1,096)	$ (820)	$ (668)
[1]	As of December 31, 2017, the balance of AOCI reflects the retrospective adoption of FASB ASU 2018-02, Income Statement-Reporting Comprehensive Income (Topic 220): Reclassification of Certain Tax Effects from Accumulated Other Comprehensive Income. For further discussion, see Note 22 “Income Taxes.”

RECLASSIFICATIONS OUT OF ACCU_4

RECLASSIFICATIONS OUT OF ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS) - Reclassifications out of Accumulated Other Comprehensive Loss (Details) - USD ($) $ in Millions		12 Months Ended
		Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Reclassification Adjustment out of Accumulated Other Comprehensive Income [Line Items]
Interest income		$ 5,758	$ 4,920	$ 4,266
Interest expense		(1,226)	(747)	(508)
Securities gains, net		19	11	16
Net debt securities impairment losses recognized in earnings		(3)	(7)	(12)
Salaries and employee benefits		(495)	(542)	(521)
Income before income tax expense		2,183	1,912	1,534
Income tax expense		462	260	489
NET INCOME		1,721	1,652	1,045
Amount Reclassified from AOCI
Reclassification Adjustment out of Accumulated Other Comprehensive Income [Line Items]
Income tax expense		5	(6)	38
NET INCOME		1	(13)	63
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		(55)	25	90
Interest expense	[1]	12	0	(27)
Other income		0	0	(5)
Income before income tax expense		(43)	25	58
Income tax expense		(10)	9	22
NET INCOME		(33)	16	36
Reclassification of net securities gains (losses) to net income: | Amount Reclassified from AOCI
Reclassification Adjustment out of Accumulated Other Comprehensive Income [Line Items]
Securities gains, net		19	11	16
Net debt securities impairment losses recognized in earnings		(3)	(7)	(12)
Income before income tax expense		16	4	4
Income tax expense		4	2	2
NET INCOME		12	2	2
Reclassification of changes related to the employee benefit plan: | Amount Reclassified from AOCI
Reclassification Adjustment out of Accumulated Other Comprehensive Income [Line Items]
Salaries and employee benefits		33	(48)	39
Income before income tax expense		33	(48)	39
Income tax expense		11	(17)	14
NET INCOME		$ 22	$ (31)	$ 25
[1]	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.

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	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Reclassification Adjustment out of Accumulated Other Comprehensive Income [Line Items]
Net interest income	$ 4,532	$ 4,173	$ 3,758
Provision for credit losses	326	321	369
Noninterest income	1,596	1,534	1,497
Noninterest expense	3,619	3,474	3,352
Income before income tax expense	2,183	1,912	1,534
Income tax expense	462	260	489
NET INCOME	1,721	1,652	1,045
Amount Reclassified from AOCI
Reclassification Adjustment out of Accumulated Other Comprehensive Income [Line Items]
Net interest income	(43)	25	63
Noninterest income	16	4	(1)
Noninterest expense	(33)	48	(39)
Income tax expense	5	(6)	38
NET INCOME	$ 1	$ (13)	$ 63

STOCKHOLDERS' EQUITY - Narrativ

STOCKHOLDERS' EQUITY - Narrative (Details) - USD ($)	Jan. 29, 2019	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Class of Stock [Line Items]
Number of shares issued (in shares)		850,000	250,000
Redemption period		90 days
Redemption price per share (in dollars per share)		$ 1,000
Cost of stock repurchase		$ 1,025,000,000	$ 820,000,000	$ 430,000,000
Treasury stock purchased (in shares)		25,773,807	22,362,401
Treasury stock purchased, price per share (in dollars per share)		$ 39.77	$ 36.67
Treasury stock purchased		$ 1,025,000,000	$ 820,000,000	430,000,000
Treasury Stock, at Cost
Class of Stock [Line Items]
Treasury stock purchased		1,025,000,000	845,000,000	405,000,000
Additional Paid-in Capital
Class of Stock [Line Items]
Treasury stock purchased		$ 0	$ (25,000,000)	$ 25,000,000
Deferred compensation, share-based payments
Class of Stock [Line Items]
Shares repurchased (in shares)		0	0
Subsequent Event
Class of Stock [Line Items]
Redemption period	90 days
Series D Preferred Stock | Subsequent Event
Class of Stock [Line Items]
Preferred stock issued	$ 300,000,000
Number of shares issued (in shares)	12,000,000
Percentage interest in shares	2.50%
Preferred stock, dividend rate	6.35%
Preferred stock, liquidation preference (in dollars per share)	$ 1,000
Shares issued (in dollars per share)	$ 25
Proceeds from issuance of stock	$ 293,000,000
Redemption price per share (in dollars per share)	$ 1,000
LIBOR | Series D Preferred Stock | Subsequent Event
Class of Stock [Line Items]
Basis spread on variable rate	3.642%

STOCKHOLDERS' EQUITY - Preferre

STOCKHOLDERS' EQUITY - Preferred Stock (Details) - USD ($) $ / shares in Units, $ in Millions	Dec. 31, 2018	Dec. 31, 2017
Preferred Stock
Preferred stock, authorized (in shares)	100,000,000	100,000,000
Preferred stock, par value (in dollars per share)	$ 25	$ 25
Preferred stock, issued (in shares)	850,000	250,000
Preferred stock, issued	$ 840	$ 247
Preferred stock, outstanding (in shares)	850,000	250,000
Preferred stock, outstanding	$ 840	$ 247
Series A
Preferred Stock
Preferred stock, liquidation preference (in dollars per share)	$ 1,000
Preferred stock, issued (in shares)	250,000	250,000
Preferred stock, issued	$ 247	$ 247
Preferred stock, outstanding (in shares)	250,000	250,000
Series B
Preferred Stock
Preferred stock, liquidation preference (in dollars per share)	$ 1,000
Preferred stock, issued (in shares)	300,000
Preferred stock, issued	$ 296
Preferred stock, outstanding (in shares)	300,000
Series C
Preferred Stock
Preferred stock, liquidation preference (in dollars per share)	$ 1,000
Preferred stock, issued (in shares)	300,000
Preferred stock, issued	$ 297
Preferred stock, outstanding (in shares)	300,000

STOCKHOLDERS' EQUITY - Prefer_2

STOCKHOLDERS' EQUITY - Preferred Stock Outstanding (Details) - $ / shares	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017
Class of Stock [Line Items]
Number of shares issued (in shares)	850,000	250,000
Redemption period	90 days
Redemption price per share (in dollars per share)	$ 1,000
Series A
Class of Stock [Line Items]
Number of shares issued (in shares)	250,000	250,000
Preferred stock, dividend rate	5.50%
Series B
Class of Stock [Line Items]
Number of shares issued (in shares)	300,000
Preferred stock, dividend rate	6.00%
Series C
Class of Stock [Line Items]
Number of shares issued (in shares)	300,000
Preferred stock, dividend rate	6.375%
LIBOR | Series A
Class of Stock [Line Items]
Preferred stock, dividend payment rate	3.96%
LIBOR | Series B
Class of Stock [Line Items]
Preferred stock, dividend payment rate	3.003%
LIBOR | Series C
Class of Stock [Line Items]
Preferred stock, dividend payment rate	3.157%

STOCKHOLDERS' EQUITY - Dividend

STOCKHOLDERS' EQUITY - Dividends (Details) - USD ($)	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Class of Stock [Line Items]
Common stock, dividends per share (in dollars per share)	$ 0.98	$ 0.64	$ 0.46
Common stock dividends	471,000,000	322,000,000	241,000,000
Preferred stock dividends	29,000,000	14,000,000	14,000,000
Dividends Declared
Class of Stock [Line Items]
Common stock dividends	471,000,000	322,000,000	241,000,000
Preferred stock dividends	29,000,000	14,000,000	14,000,000
Dividends Paid
Class of Stock [Line Items]
Common stock dividends	471,000,000	322,000,000	241,000,000
Preferred stock dividends	14,000,000	14,000,000	14,000,000
Series A
Class of Stock [Line Items]
Preferred stock, dividends per share (in dollars per share)	55	55	55
Preferred stock dividends	14,000,000	14,000,000
Series A | Dividends Declared
Class of Stock [Line Items]
Preferred stock dividends	14,000,000	14,000,000	14,000,000
Series A | Dividends Paid
Class of Stock [Line Items]
Preferred stock dividends	14,000,000	14,000,000	14,000,000
Series B
Class of Stock [Line Items]
Preferred stock, dividends per share (in dollars per share)	37	0	0
Preferred stock dividends	11,000,000
Series B | Dividends Declared
Class of Stock [Line Items]
Preferred stock dividends	11,000,000	0	0
Series B | Dividends Paid
Class of Stock [Line Items]
Preferred stock dividends	0	0	0
Series C
Class of Stock [Line Items]
Preferred stock, dividends per share (in dollars per share)	12.57	0	0
Preferred stock dividends	4,000,000
Series C | Dividends Declared
Class of Stock [Line Items]
Preferred stock dividends	4,000,000	0	0
Series C | Dividends Paid
Class of Stock [Line Items]
Preferred stock dividends	$ 0	$ 0	$ 0

SHARE-BASED COMPENSATION - Narr

SHARE-BASED COMPENSATION - Narrative (Details) - USD ($)	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Share-based Compensation Arrangement by Share-based Payment Award [Line Items]
Employee discount on company stock	10.00%
Maximum employee salary contribution percentage - ESPP	10.00%
Maximum employee contribution amount - ESPP	$ 25,000
Compensation expense related to share-based plans	41,000,000	$ 39,000,000	$ 23,000,000
Share-based compensation not yet recognized	$ 41,000,000
Unrecognized compensation expense, weighted-average period of recognition	2 years
Tax benefit recognized in earnings for share-based compensation arrangements	$ 3,000,000	$ 9,000,000	$ 8,000,000
2014 Omnibus Incentive Plan | Time-based restricted stock units
Share-based Compensation Arrangement by Share-based Payment Award [Line Items]
Vesting period	3 years
2014 Omnibus Incentive Plan | Performance-based restricted stock units
Share-based Compensation Arrangement by Share-based Payment Award [Line Items]
Vesting period	3 years
Citizens Share Awards
Share-based Compensation Arrangement by Share-based Payment Award [Line Items]
Awards granted (in shares)	1,174,501	1,256,816	1,552,416
Weighted average grant price (in dollars per share)	$ 39.54	$ 39.09	$ 24.53
Awards vested (in shares)	877,111	1,426,850	1,762,655
Weighted average grant price of awards vested (in dollars per share)	$ 30.50	$ 21.91	$ 22.14
Omnibus Incentive Plan And Directors Plan
Share-based Compensation Arrangement by Share-based Payment Award [Line Items]
Number of shares available for grant (in shares)	49,742,766
2014 Employee Stock Purchase Plan
Share-based Compensation Arrangement by Share-based Payment Award [Line Items]
Number of shares available for grant (in shares)	6,255,128

SHARE-BASED COMPENSATION - Shar

SHARE-BASED COMPENSATION - Share-based Compensation Activity (Details) - Citizens Share Awards - $ / shares	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Shares Underlying Awards
Nonvested, Beginning of period (in shares)	2,621,514
Granted (in shares)	1,174,501	1,256,816	1,552,416
Vested (in shares)	(877,111)	(1,426,850)	(1,762,655)
Forfeited (in shares)	(25,623)
Nonvested, End of period (in shares)	2,893,281	2,621,514
Weighted Average Grant Price
Nonvested, Beginning of period (in dollars per share)	$ 33.30
Granted (in dollars per share)	39.54	$ 39.09	$ 24.53
Vested (in dollars per share)	30.50	21.91	$ 22.14
Forfeited (in dollars per share)	35.88
Nonvested, End of period (in dollars per share)	$ 34.04	$ 33.30

COMMITMENTS AND CONTINGENCIES -

COMMITMENTS AND CONTINGENCIES - Narrative (Details) $ in Millions	12 Months Ended
	Dec. 31, 2018USD ($)counterparty	Dec. 31, 2017USD ($)	Dec. 31, 2003
Letters of Credit [Abstract]
Letters of credit outstanding	$ 3	$ 3
Risk Participation Agreements [Abstract]
Risk participation agreements	$ 19	16
Risk participation agreements number of counterparties | counterparty	84
Risk participation agreements, Maximum term	10 years
Commercial loans held for sale | Purchase commitment
Commitments [Abstract]
Unsettled commercial loan trade purchases	$ 68	65
Unsettled commercial loan trade sales	$ 161	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 terms	10 years
Commercial letters of credit
Letters of Credit [Abstract]
Letters of credit terms	1 year

COMMITMENTS AND CONTINGENCIES_2

COMMITMENTS AND CONTINGENCIES - Schedule of Outstanding Off-balance sheet Arrangements (Details) - USD ($) $ in Millions	Dec. 31, 2018	Dec. 31, 2017
Other Commitments [Line Items]
Commitment amount	$ 71,739	$ 65,159
Undrawn commitments to extend credit
Other Commitments [Line Items]
Commitment amount	69,553	62,959
Letters of credit
Other Commitments [Line Items]
Commitment amount	2,125	2,136
Marketing rights
Other Commitments [Line Items]
Commitment amount	37	41
Risk participation agreements
Other Commitments [Line Items]
Commitment amount	19	16
Residential mortgage loans sold with recourse
Other Commitments [Line Items]
Commitment amount	$ 5	$ 7

FAIR VALUE MEASUREMENTS - Narra

FAIR VALUE MEASUREMENTS - Narrative (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Other income	$ 67	$ 91	$ 159
Commercial loans held for sale
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Other income	(2)	4	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 for loans accounted for under fair value option	$ 6	$ 6	$ (5)

FAIR VALUE MEASUREMENTS - Resid

FAIR VALUE MEASUREMENTS - Residential and Commercial Mortgage Loans Held For Sale (Details) - USD ($) $ in Millions	Dec. 31, 2018	Dec. 31, 2017
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Aggregate Fair Value	$ 1,219	$ 497
Level 2
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Aggregate Fair Value	1,219	497
Level 2 | Residential loans held for sale
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Aggregate Fair Value	967	326
Aggregate Unpaid Principal	967	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	252	171
Aggregate Unpaid Principal	252	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		Dec. 31, 2018	Dec. 31, 2017
Assets
Debt securities available for sale:	[1]	$ 19,895	$ 20,157
Loans held for sale, at fair value:		1,219	497
Mortgage servicing rights		600
Derivative assets		449	693
Equity securities, at fair value:
Money market mutual fund investments		181	165
Other investments		0	4
Total equity securities, at fair value		181	169
Total assets		22,344	21,516
Liabilities
Total derivative liabilities		415	533
Total liabilities		415	533
Interest rate swaps
Assets
Derivative assets		306	538
Liabilities
Total derivative liabilities		277	379
Foreign exchange contracts
Assets
Derivative assets		129	148
Liabilities
Total derivative liabilities		113	149
Other contracts
Assets
Derivative assets		14	7
Liabilities
Total derivative liabilities		25	5
Level 1
Assets
Debt securities available for sale:		24	12
Loans held for sale, at fair value:		0	0
Derivative assets		0	0
Equity securities, at fair value:
Money market mutual fund investments		181	165
Other investments		0	0
Total equity securities, at fair value		181	165
Total assets		205	177
Liabilities
Total derivative liabilities		0	0
Total liabilities		0	0
Level 1 | Interest rate swaps
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
Debt securities available for sale:		19,871	20,145
Loans held for sale, at fair value:		1,219	497
Derivative assets		449	693
Equity securities, at fair value:
Money market mutual fund investments		0	0
Other investments		0	4
Total equity securities, at fair value		0	4
Total assets		21,539	21,339
Liabilities
Total derivative liabilities		415	533
Total liabilities		415	533
Level 2 | Interest rate swaps
Assets
Derivative assets		306	538
Liabilities
Total derivative liabilities		277	379
Level 2 | Foreign exchange contracts
Assets
Derivative assets		129	148
Liabilities
Total derivative liabilities		113	149
Level 2 | Other contracts
Assets
Derivative assets		14	7
Liabilities
Total derivative liabilities		25	5
Level 3
Assets
Debt securities available for sale:		0	0
Loans held for sale, at fair value:		0	0
Derivative assets		0	0
Equity securities, at fair value:
Money market mutual fund investments		0	0
Other investments		0	0
Total equity securities, at fair value		0	0
Total assets		600	0
Liabilities
Total derivative liabilities		0	0
Total liabilities		0	0
Level 3 | Interest rate swaps
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
Debt securities available for sale:		19,866	20,139
Mortgage-backed securities | Level 1
Assets
Debt securities available for sale:		0	0
Mortgage-backed securities | Level 2
Assets
Debt securities available for sale:		19,866	20,139
Mortgage-backed securities | Level 3
Assets
Debt securities available for sale:		0	0
State and political subdivisions
Assets
Debt securities available for sale:		5	6
State and political subdivisions | Level 1
Assets
Debt securities available for sale:		0	0
State and political subdivisions | Level 2
Assets
Debt securities available for sale:		5	6
State and political subdivisions | Level 3
Assets
Debt securities available for sale:		0	0
U.S. Treasury and other
Assets
Debt securities available for sale:		24	12
U.S. Treasury and other | Level 1
Assets
Debt securities available for sale:		24	12
U.S. Treasury and other | Level 2
Assets
Debt securities available for sale:		0	0
U.S. Treasury and other | Level 3
Assets
Debt securities available for sale:		0	0
Residential loans held for sale
Assets
Loans held for sale, at fair value:		967	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:		967	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:		252	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:		252	171
Commercial loans held for sale | Level 3
Assets
Loans held for sale, at fair value:		0	$ 0
Residential mortgages
Assets
Mortgage servicing rights		600
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		$ 600
[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 at Fair Value on Recurring Basis (Details) - Residential mortgages $ in Millions	12 Months Ended
	Dec. 31, 2018USD ($)
Fair Value, Assets Measured on Recurring Basis, Unobservable Input Reconciliation, Calculation [Roll Forward]
Beginning balance	$ 0
Acquired MSRs	590
Amount capitalized	73
Change in unpaid principal balance during the period	(32)	[1]
Change in fair value during the period	(31)	[2]
Ending balance	$ 600
[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.

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	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
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	$ (13)	$ (35)	$ (33)
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	3	(2)	(4)
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	(2)	(3)	(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	$ (7)	$ (15)	$ 11

FAIR VALUE MEASUREMENTS - Sch_4

FAIR VALUE MEASUREMENTS - Schedule of Fair Value Measurements on a Nonrecurring Basis (Details) - Nonrecurring measurement basis - USD ($) $ in Millions	Dec. 31, 2018	Dec. 31, 2017
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Impaired collateral-dependent loans	$ 338	$ 393
MSRs	243	218
Foreclosed assets	29	31
Leased assets	92	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	338	393
MSRs	0	0
Foreclosed assets	29	31
Leased assets	92	112
Level 3
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Impaired collateral-dependent loans	0	0
MSRs	243	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		Dec. 31, 2018	Dec. 31, 2017
Financial Assets:
Securities held to maturity, carrying value		$ 4,165	$ 4,685
Securities held-to-maturity, fair value		4,041	4,668
Other investment securities, at cost, carrying value		834	722
Other investment securities, at cost, estimated fair value		834	722
Other loans held for sale, carrying value		101	221
Other loans held for sale, fair value		101	221
Loans and leases, carrying value	[1],[2]	116,660	110,617
Loans and leases, fair value		116,627	111,168
Financial Liabilities:
Deposits, carrying value		119,575	115,089
Deposits, fair value		119,503	115,039
Federal funds purchased and securities sold under agreements to repurchase, carrying value		1,156	815
Federal funds purchased and securities sold under agreements to repurchase, fair value		1,156	815
Other short-term borrowed funds, carrying value		1,653	1,856
Other short-term borrowed funds, fair value		1,653	1,856
Long-term borrowed funds, carrying value		14,433	11,765
Long-term borrowed funds, fair value		14,390	11,891
Level 1
Financial Assets:
Securities held to maturity, carrying value		0	0
Securities held-to-maturity, fair value		0	0
Other investment securities, at cost, carrying value		0	0
Other investment securities, at cost, estimated 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
Financial Liabilities:
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
Financial Assets:
Securities held to maturity, carrying value		4,165	4,685
Securities held-to-maturity, fair value		4,041	4,668
Other investment securities, at cost, carrying value		834	722
Other investment securities, at cost, estimated fair value		834	722
Other loans held for sale, carrying value		0	0
Other loans held for sale, fair value		0	0
Loans and leases, carrying value		338	393
Loans and leases, fair value		338	393
Financial Liabilities:
Deposits, carrying value		119,575	115,089
Deposits, fair value		119,503	115,039
Federal funds purchased and securities sold under agreements to repurchase, carrying value		1,156	815
Federal funds purchased and securities sold under agreements to repurchase, fair value		1,156	815
Other short-term borrowed funds, carrying value		1,653	1,856
Other short-term borrowed funds, fair value		1,653	1,856
Long-term borrowed funds, carrying value		14,433	11,765
Long-term borrowed funds, fair value		14,390	11,891
Level 3
Financial Assets:
Securities held to maturity, carrying value		0	0
Securities held-to-maturity, fair value		0	0
Other investment securities, at cost, carrying value		0	0
Other investment securities, at cost, estimated fair value		0	0
Other loans held for sale, carrying value		101	221
Other loans held for sale, fair value		101	221
Loans and leases, carrying value		116,322	110,224
Loans and leases, fair value		116,289	110,775
Financial Liabilities:
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 December 31, 2018 and 2017, respectively.
[2]	Mortgage loans serviced for others by the Company’s subsidiaries are not included above, and amounted to $69.6 billion and $20.3 billion at December 31, 2018 and 2017, respectively.

NONINTEREST INCOME - Narrative

NONINTEREST INCOME - Narrative (Details) $ in Millions	12 Months Ended
	Dec. 31, 2018USD ($)
Trust and investment services fees
Disaggregation of Revenue [Line Items]
Trailing commission income	$ 16

NONINTEREST INCOME - Noninteres

NONINTEREST INCOME - Noninterest Income (Details) - USD ($) $ in Millions		12 Months Ended
		Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Other Income and Expenses [Abstract]
Revenue from contracts with customers	[1]	$ 1,119
Revenue from other sources		477
Total noninterest income		$ 1,596	$ 1,534	$ 1,497
[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) $ in Millions	12 Months Ended
	Dec. 31, 2018USD ($)
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	$ 1,119	[1]
Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	786
Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	333
Service charges and fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	513	[1]
Service charges and fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	408
Service charges and fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	105
Card fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	244	[1]
Card fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	207
Card fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	37
Capital markets fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	181	[1]
Capital markets fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	0
Capital markets fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	181
Trust and investment services fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	171	[1]
Trust and investment services fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	171
Trust and investment services fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	0
Other banking fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	10	[1]
Other banking fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	0
Other banking fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	$ 10
[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	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Other Income and Expenses [Abstract]
Bank-owned life insurance	$ 56	$ 54	$ 54

OTHER OPERATING EXPENSE (Detail

OTHER OPERATING EXPENSE (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Other Income and Expenses [Abstract]
Deposit insurance	$ 104	$ 137	$ 120
Promotional expense	129	105	98
Settlements and operating losses	47	54	62
Other	215	246	241
Other operating expense	$ 495	$ 542	$ 521

INCOME TAXES - Narrative (Detai

INCOME TAXES - Narrative (Details) - USD ($)	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Significant Change in Unrecognized Tax Benefits is Reasonably Possible [Line Items]
U.S. Federal income tax rate	21.00%	35.00%	35.00%
State operating loss carryforwards	$ 1,400,000,000
Deferred tax asset valuation allowance	110,000,000	$ 105,000,000
Decrease in deferred tax asset valuation allowance	5,000,000
Unrecognized tax benefits that would impact effective tax rate	6,000,000
Interest on unrecognized tax benefits accrued (released) during period	0	8,000,000	$ 8,000,000
Accrued interest on unrecognized tax benefits	2,000,000	1,000,000	22,000,000
Penalties accrued income tax examination	0	0	0
Penalties expense income tax examination	0	$ 0	$ 0
Tax Years Ended Prior to 1988
Significant Change in Unrecognized Tax Benefits is Reasonably Possible [Line Items]
Base year loan loss reserves attributable to prior years	$ 557,000,000

INCOME TAXES - Income Tax Expen

INCOME TAXES - Income Tax Expense (Benefit) (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Income Tax Disclosure [Abstract]
Income tax expense	$ 462	$ 260	$ 489
Tax effect of changes in OCI	(96)	(7)	(168)
Total comprehensive income tax expense	$ 366	$ 253	$ 321

INCOME TAXES - Components of In

INCOME TAXES - Components of Income Tax Expense (Benefit) (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Current
U.S. federal	$ 271	$ 376	$ 292
State and local	94	20	44
Total	365	396	336
Deferred
U.S. federal	90	(142)	159
State and local	7	6	(6)
Total	97	(136)	153
U.S. federal	361	234	451
State and local	101	26	38
Income tax expense	$ 462	$ 260	$ 489

INCOME TAXES - Effective Income

INCOME TAXES - Effective Income Tax Reconciliation (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Amount
U.S. Federal income tax expense	$ 459	$ 669	$ 537
Increase (decrease) resulting from:
Federal rate change	(34)	(331)	0
State and local income taxes (net of federal benefit)	89	46	38
Bank-owned life insurance	(12)	(19)	(19)
Tax-exempt interest	(15)	(21)	(19)
Tax advantaged investments (including related credits)	(44)	(51)	(31)
Other tax credits	(8)	(3)	(14)
Adjustments for uncertain tax positions	1	(23)	0
Non-deductible FDIC premiums	21	0	0
Other	5	(7)	(3)
Income tax expense	$ 462	$ 260	$ 489
Rate
U.S. Federal income tax rate	21.00%	35.00%	35.00%
Increase (decrease) resulting from:
Federal rate change	(1.60%)	(17.30%)	0.00%
State and local income taxes (net of federal benefit)	4.10%	2.40%	2.50%
Bank-owned life insurance	(0.50%)	(1.00%)	(1.20%)
Tax-exempt interest	(0.70%)	(1.10%)	(1.30%)
Tax advantaged investments (including related credits)	(2.00%)	(2.70%)	(2.00%)
Other tax credits	(0.40%)	(0.10%)	(0.90%)
Adjustments for uncertain tax positions	0.10%	(1.20%)	0.00%
Non-deductible FDIC premiums	1.00%	0.00%	0.00%
Other	0.20%	(0.40%)	(0.20%)
Total income tax expense and tax rate	21.20%	13.60%	31.90%

INCOME TAXES - Deferred Income

INCOME TAXES - Deferred Income Tax Assets and Liabilities (Details) - USD ($) $ in Millions	Dec. 31, 2018	Dec. 31, 2017
Deferred tax assets:
Other comprehensive income	$ 366	$ 271
Allowance for credit losses	308	310
State net operating loss carryforwards	90	88
Accrued expenses not currently deductible	36	40
Investment and other tax credit carryforwards	74	65
Fair value adjustments	28	27
Total deferred tax assets	902	801
Valuation allowance	(110)	(105)
Deferred tax assets, net of valuation allowance	792	696
Deferred tax liabilities:
Leasing transactions	527	525
Amortization of intangibles	364	352
Depreciation	195	182
Pension and other employee compensation plans	127	110
Partnerships	51	37
Deferred Income	50	27
MSRs	51	34
Total deferred tax liabilities	1,365	1,267
Net deferred tax liability	$ 573	$ 571

INCOME TAXES - Unrecognized Tax

INCOME TAXES - Unrecognized Tax Benefits (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Reconciliation of Unrecognized Tax Benefits, Excluding Amounts Pertaining to Examined Tax Returns [Roll Forward]
Balance at the beginning of the year	$ 5	$ 42	$ 62
Gross increase for tax positions related to current year	3	0	0
Gross decrease for tax positions related to prior years	0	(27)	(19)
Gross increase for tax positions related to prior years	0	0	1
Decreases for tax positions as a result of the lapse of the statutes of limitations	0	(1)	(2)
Decreases for tax positions related to settlements with taxing authorities	0	(9)	0
Balance at end of year	$ 8	$ 5	$ 42

EARNINGS PER SHARE (Details)

EARNINGS PER SHARE (Details) - USD ($) $ / shares in Units, $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Numerator (basic and diluted):
Net income	$ 1,721	$ 1,652	$ 1,045
Less: Preferred stock dividends	29	14	14
Net income available to common stockholders	$ 1,692	$ 1,638	$ 1,031
Denominator:
Weighted-average common shares outstanding - basic (in shares)	478,822,072	502,157,440	522,093,545
Dilutive common shares: share-based awards (in shares)	1,608,669	1,527,651	1,837,173
Weighted-average common shares outstanding - diluted (in shares)	480,430,741	503,685,091	523,930,718
Earnings per common share:
Basic (in dollars per share)	$ 3.54	$ 3.26	$ 1.97
Diluted (in dollars per share)	$ 3.52	$ 3.25	$ 1.97
Antidilutive securities (in shares)	0	533	0

REGULATORY MATTERS - Narrative

REGULATORY MATTERS - Narrative (Details) - USD ($)	3 Months Ended				12 Months Ended
	Jun. 30, 2019	Mar. 31, 2019	Dec. 31, 2018	Sep. 30, 2018	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Compliance with Regulatory Capital Requirements under Banking Regulations [Line Items]
Common stock, dividends per share (in dollars per share)			$ 0.27	$ 0.27
Preferred stock, issued			$ 840,000,000		$ 840,000,000	$ 247,000,000
Treasury stock purchased					1,025,000,000	820,000,000	$ 430,000,000
Common stock dividends					471,000,000	322,000,000	241,000,000
Dividends to preferred stockholders					29,000,000	14,000,000	$ 14,000,000
Forecast
Compliance with Regulatory Capital Requirements under Banking Regulations [Line Items]
Common stock, dividends per share (in dollars per share)	$ 0.32	$ 0.32
Repurchases of stock	$ 1,020,000,000
Series B
Compliance with Regulatory Capital Requirements under Banking Regulations [Line Items]
Preferred stock, issued			296,000,000		296,000,000
Dividends to preferred stockholders					11,000,000
Series C
Compliance with Regulatory Capital Requirements under Banking Regulations [Line Items]
Preferred stock, issued			297,000,000		297,000,000
Dividends to preferred stockholders					4,000,000
Series A
Compliance with Regulatory Capital Requirements under Banking Regulations [Line Items]
Preferred stock, issued			247,000,000		247,000,000	247,000,000
Dividends to preferred stockholders					14,000,000	$ 14,000,000
5.158% fixed-to-floating rate subordinated debt, callable, due 2023
Compliance with Regulatory Capital Requirements under Banking Regulations [Line Items]
Debt redeemed			$ 333,000,000		$ 333,000,000
Interest rate			5.158%		5.158%

REGULATORY MATTERS - Capital an

REGULATORY MATTERS - Capital and Capital Ratio Information (Details) - USD ($) $ in Millions		Dec. 31, 2018	Dec. 31, 2017
Common Equity Tier 1 to Risk-Weighted Assets (Amount)
Actual	[1]	$ 14,485	$ 14,309
Minimum Capital Adequacy	[1]	$ 8,683	$ 7,342
Common Equity Tier 1 to Risk-Weighted Assets (Ratio)
Actual	[1]	10.60%	11.20%
Minimum Capital Adequacy	[1],[2]	6.375%	5.75%
Tier 1 Capital to Risk-Weighted Assets (Amount)
Actual	[3]	$ 15,325	$ 14,556
Minimum Capital Adequacy	[3]	$ 10,726	$ 9,258
Tier 1 Capital to Risk-Weighted Assets (Ratio)
Actual	[3]	11.30%	11.40%
Minimum Capital Adequacy	[2],[3]	7.875%	7.25%
Total Capital to Risk-Weighted Assets (Amount)
Actual	[4]	$ 18,157	$ 17,781
Minimum Capital Adequacy	[4]	$ 13,450	$ 11,812
Total Capital to Risk-Weighted Assets (Ratio)
Actual	[4]	13.30%	13.90%
Minimum Capital Adequacy	[2],[4]	9.875%	9.25%
Tier 1 Capital to Average Assets (Leverage) (Amount)
Actual	[5]	$ 15,325	$ 14,556
Minimum Capital Adequacy	[5]	$ 6,121	$ 5,824
Tier 1 Capital to Average Assets (Leverage) (Ratio)
Actual	[5]	10.00%	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 1.25% 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	12 Months Ended
	Dec. 31, 2018USD ($)segment
Segment Reporting Information [Line Items]
Business operating segments | segment	2
Consumer Banking | Maximum
Segment Reporting Information [Line Items]
Revenues	$ 25
Commercial Banking | Minimum
Segment Reporting Information [Line Items]
Revenues	25
Commercial Banking | Maximum
Segment Reporting Information [Line Items]
Revenues	$ 2,500

BUSINESS OPERATING SEGMENTS (De

BUSINESS OPERATING SEGMENTS (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Segment Reporting Information [Line Items]
Net interest income	$ 4,532	$ 4,173	$ 3,758
Noninterest income	1,596	1,534	1,497
Total revenue	6,128	5,707	5,255
Noninterest expense	3,619	3,474	3,352
Profit (loss) before provision for credit losses	2,509	2,233	1,903
Provision for credit losses	326	321	369
Income before income tax expense	2,183	1,912	1,534
Income tax expense	462	260	489
NET INCOME	1,721	1,652	1,045
Total average assets	154,553	149,953	143,183
Operating Segments | Consumer Banking
Segment Reporting Information [Line Items]
Net interest income	3,064	2,651	2,443
Noninterest income	973	905	883
Total revenue	4,037	3,556	3,326
Noninterest expense	2,723	2,593	2,547
Profit (loss) before provision for credit losses	1,314	963	779
Provision for credit losses	289	265	243
Income before income tax expense	1,025	698	536
Income tax expense	258	246	191
NET INCOME	767	452	345
Total average assets	62,444	59,714	56,388
Operating Segments | Commercial Banking
Segment Reporting Information [Line Items]
Net interest income	1,497	1,411	1,288
Noninterest income	545	538	466
Total revenue	2,042	1,949	1,754
Noninterest expense	813	772	741
Profit (loss) before provision for credit losses	1,229	1,177	1,013
Provision for credit losses	26	19	47
Income before income tax expense	1,203	1,158	966
Income tax expense	276	384	335
NET INCOME	927	774	631
Total average assets	52,362	49,747	47,159
Other
Segment Reporting Information [Line Items]
Net interest income	(29)	111	27
Noninterest income	78	91	148
Total revenue	49	202	175
Noninterest expense	83	109	64
Profit (loss) before provision for credit losses	(34)	93	111
Provision for credit losses	11	37	79
Income before income tax expense	(45)	56	32
Income tax expense	(72)	(370)	(37)
NET INCOME	27	426	69
Total average assets	$ 39,747	$ 40,492	$ 39,636

PARENT COMPANY FINANCIALS - Con

PARENT COMPANY FINANCIALS - Condensed Statements of Operations (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Operating Income
Equity securities gains	$ 0	$ 1	$ 3
Total interest income	5,758	4,920	4,266
Operating expense
Salaries and employee benefits	1,880	1,766	1,714
Interest expense	1,226	747	508
All other expenses	495	542	521
Income taxes	462	260	489
NET INCOME	1,721	1,652	1,045
Other comprehensive income (loss), net of income taxes:
Net unrealized derivative instrument gains (losses) arising during the period	(33)	(14)	(62)
Net other comprehensive loss	(276)	(7)	(281)
Total other comprehensive loss, net of income taxes	(276)	(7)	(281)
Total comprehensive income	1,445	1,645	764
Parent company
Operating Income
Dividends from banking subsidiaries	1,650	1,055	555
Interest income	46	43	53
Management and service fees	22	31	26
Equity securities gains	0	1	3
All other operating income	1	1	7
Total interest income	1,726	1,136	644
Operating expense
Salaries and employee benefits	25	40	37
Interest expense	89	97	99
All other expenses	23	22	15
Total operating expense	137	159	151
Income before taxes and undistributed income	1,589	977	493
Income taxes	(13)	(10)	(26)
Income before undistributed income of subsidiaries and associated companies	1,602	987	519
Equity in undistributed income (losses) of subsidiaries and associated companies	120	665	526
NET INCOME	1,721	1,652	1,045
Other comprehensive income (loss), net of income taxes:
Net pension plan activity arising during the period	5	(1)	(2)
Net unrealized derivative instrument gains (losses) arising during the period	2	1	(8)
Net other comprehensive loss	7	0	(10)
Other comprehensive income (loss) activity of Bank subsidiaries, net of income taxes	(283)	(7)	(271)
Total other comprehensive loss, net of income taxes	(276)	(7)	(281)
Total comprehensive income	1,445	1,645	764
Nonbank subsidiaries | Parent company
Operating Income
Interest income	2	1	0
Dividends from nonbank subsidiaries	5	4	0
Operating expense
Equity in undistributed income (losses) of subsidiaries and associated companies	10	10	4
Bank subsidiaries | Parent company
Operating expense
Equity in undistributed income (losses) of subsidiaries and associated companies	$ 109	$ 655	$ 522

PARENT COMPANY FINANCIALS - C_2

PARENT COMPANY FINANCIALS - Condensed Balance Sheets (Details) - USD ($) $ in Millions	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016	Dec. 31, 2015
ASSETS:
Cash and due from banks	$ 1,081	$ 987
Other assets	4,754	3,429
TOTAL ASSETS	160,518	152,336
LIABILITIES:
Long-term borrowed funds	14,433	11,765
Other liabilities	2,019	1,660
TOTAL LIABILITIES	139,701	132,066
TOTAL STOCKHOLDERS’ EQUITY	20,817	20,270	$ 19,747	$ 19,646
TOTAL LIABILITIES AND STOCKHOLDERS’ EQUITY	160,518	152,336
Parent company
ASSETS:
Cash and due from banks	961	563
Other assets	117	125
TOTAL ASSETS	22,979	22,756
LIABILITIES:
Long-term borrowed funds	1,987
Other liabilities	175	166
TOTAL LIABILITIES	2,162	2,486
TOTAL STOCKHOLDERS’ EQUITY	20,817	20,270
TOTAL LIABILITIES AND STOCKHOLDERS’ EQUITY	22,979	22,756
Bank subsidiaries | Parent company
ASSETS:
Loans and advances	1,158	1,160
Investments in subsidiaries	20,590	20,765
Nonbank subsidiaries | Parent company
ASSETS:
Loans and advances	70	70
Investments in subsidiaries	83	73
Unaffiliated companies | Parent company
LIABILITIES:
Long-term borrowed funds	$ 1,987	$ 2,320

PARENT COMPANY FINANCIALS - C_3

PARENT COMPANY FINANCIALS - Condensed Cash Flow Statements (Details) - USD ($) $ in Millions		12 Months Ended
		Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
OPERATING ACTIVITIES
Net income		$ 1,721	$ 1,652	$ 1,045
Deferred income taxes		97	(136)	153
Increase (decrease) in other liabilities		303	(119)	(59)
(Increase) decrease in other assets		(1,217)	(502)	(274)
Net cash provided by operating activities		1,767	1,883	1,490
INVESTING ACTIVITIES
Net cash used in investing activities		(7,077)	(3,984)	(11,326)
FINANCING ACTIVITIES
Proceeds from issuance of long-term borrowed funds		22,503	15,363	15,144
Repayments of long-term borrowed funds		(14,837)	(12,751)	(8,429)
Treasury stock purchased		(1,025)	(820)	(430)
Net proceeds from issuance of preferred stock		593	0	0
Dividends declared and paid to common stockholders		(471)	(322)	(241)
Dividends declared and paid to preferred stockholders		(14)	(14)	(14)
Net cash provided by financing activities		6,352	1,429	10,455
Increase (Decrease) in cash and cash equivalents	[1]	1,042	(672)	619
Cash and cash equivalents at beginning of period	[1]	3,032	3,704	3,085
Cash and cash equivalents at end of period	[1]	4,074	3,032	3,704
Parent company
OPERATING ACTIVITIES
Net income		1,721	1,652	1,045
Deferred income taxes		17	(11)	5
Gain on sales of assets		0	(1)	(3)
Equity in undistributed earnings of subsidiaries		(120)	(665)	(526)
Increase (decrease) in other liabilities		11	99	(19)
(Increase) decrease in other assets		(7)	5	35
Other operating, net		40	(1)	(4)
Total adjustments		(59)	(574)	(512)
Net cash provided by operating activities		1,662	1,078	533
INVESTING ACTIVITIES
Investments in and advances to subsidiaries		0	(230)	(40)
Repayment of investments in and advances to subsidiaries		0	167	588
Other investing, net		(1)	(1)	(2)
Net cash used in investing activities		(1)	(64)	546
FINANCING ACTIVITIES
Proceeds from issuance of long-term borrowed funds		0	0	349
Repayments of long-term borrowed funds		(333)	0	(625)
Proceeds from issuance of common stock		0	34	22
Treasury stock purchased		(1,025)	(820)	(430)
Net proceeds from issuance of preferred stock		593	0	0
Dividends declared and paid to common stockholders		(471)	(322)	(241)
Dividends declared and paid to preferred stockholders		(14)	(14)	(14)
Other financing, net		(13)	0	0
Net cash provided by financing activities		(1,263)	(1,122)	(939)
Increase (Decrease) in cash and cash equivalents		398	(108)	140
Cash and cash equivalents at beginning of period		563	671	531
Cash and cash equivalents at end of period		$ 961	$ 563	$ 671
[1]	Cash and cash equivalents include cash and due from banks and interest-bearing cash and due from banks as reflected on the Consolidated Balance Sheets.

PARENT COMPANY FINANCIALS - Nar

PARENT COMPANY FINANCIALS - Narrative (Details) - USD ($) $ in Millions	12 Months Ended
	Dec. 31, 2018	Dec. 31, 2017	Dec. 31, 2016
Condensed Financial Information Disclosure [Abstract]
Payments of ordinary common stock dividends	$ 471	$ 322	$ 241
Dividends to preferred stockholders	$ 14	$ 14	$ 14