ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK | NOTE 4 - ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK The ACL consists of the ALLL and the reserve for unfunded commitments. It is increased through a provision for credit losses that is charged to earnings, based on the Company’s quarterly evaluation of the loan and lease portfolio and related commitments, and is reduced by net charge-offs and the ALLL associated with sold loans. See Note 5 “Allowance for Credit Losses, Nonperforming Assets, and Concentrations of Credit Risk” to the Company’s audited Consolidated Financial Statements in the Annual Report on Form 10-K for the year ended December 31, 2018 , for a detailed discussion of the ALLL reserve methodology and estimation techniques. On a quarterly basis, the Company reviews and refines its estimate of the ACL, taking into consideration changes in portfolio size and composition, historical loss experience, internal risk ratings, current economic conditions, industry performance trends and other pertinent information. As of March 31, 2019 , there were no material changes in assumptions or estimation techniques compared with prior periods that impacted the determination of the current period’s ALLL and the reserve for unfunded lending commitments. A summary of changes in the ACL is presented below: Three Months Ended March 31, 2019 (in millions) Commercial Retail Total Allowance for loan and lease losses, beginning of period $690 $552 $1,242 Charge-offs (26 ) (112 ) (138 ) Recoveries 2 47 49 Net charge-offs (24 ) (65 ) (89 ) Provision charged to income 25 67 92 Allowance for loan and lease losses, end of period 691 554 1,245 Reserve for unfunded lending commitments, beginning of period 91 — 91 Provision for unfunded lending commitments (7 ) — (7 ) Reserve for unfunded lending commitments, end of period 84 — 84 Total allowance for credit losses, end of period $775 $554 $1,329 Three Months Ended March 31, 2018 (in millions) Commercial Retail Total Allowance for loan and lease losses, beginning of period $685 $551 $1,236 Charge-offs (3 ) (113 ) (116 ) Recoveries 6 40 46 Net charge-offs 3 (73 ) (70 ) Provision charged to income 23 57 80 Allowance for loan and lease losses, end of period 711 535 1,246 Reserve for unfunded lending commitments, beginning of period 88 — 88 Provision for unfunded lending commitments (2 ) — (2 ) Reserve for unfunded lending commitments, end of period 86 — 86 Total allowance for credit losses, end of period $797 $535 $1,332 The recorded investment in loans and leases based on the Company’s evaluation methodology is presented below: March 31, 2019 December 31, 2018 (in millions) Commercial Retail Total Commercial Retail Total Individually evaluated $386 $696 $1,082 $391 $723 $1,114 Formula-based evaluation 57,303 59,230 116,533 56,392 59,154 115,546 Total loans and leases $57,689 $59,926 $117,615 $56,783 $59,877 $116,660 A summary of the ACL by evaluation method is presented below: March 31, 2019 December 31, 2018 (in millions) Commercial Retail Total Commercial Retail Total Individually evaluated $42 $25 $67 $38 $26 $64 Formula-based evaluation 733 529 1,262 743 526 1,269 Allowance for credit losses $775 $554 $1,329 $781 $552 $1,333 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: March 31, 2019 Criticized (in millions) Pass Special Mention Substandard Doubtful Total Commercial $39,296 $1,096 $892 $213 $41,497 Commercial real estate 12,953 381 36 2 13,372 Leases 2,670 111 39 — 2,820 Total commercial loans and leases $54,919 $1,588 $967 $215 $57,689 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 The recorded investment in classes of retail loans, categorized by delinquency status is presented below: March 31, 2019 Days Past Due (in millions) Current 1-29 30-59 60-89 90 or More Total Residential mortgages $18,876 $119 $38 $10 $131 $19,174 Home equity loans 883 80 12 4 27 1,006 Home equity lines of credit 11,769 366 76 28 155 12,394 Home equity loans serviced by others 332 22 8 2 11 375 Home equity lines of credit serviced by others 67 14 2 1 11 95 Automobile 10,654 1,067 196 58 17 11,992 Education 9,084 142 22 12 14 9,274 Credit cards 1,879 59 14 9 21 1,982 Other retail 3,502 75 27 17 13 3,634 Total retail loans $57,046 $1,944 $395 $141 $400 $59,926 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 Nonperforming Assets The following table presents nonperforming loans and leases and loans accruing and 90 days or more past due: Nonperforming Accruing and 90 days or more past due (in millions) March 31, 2019 December 31, 2018 March 31, 2019 December 31, 2018 Commercial $208 $194 $1 $1 Commercial real estate 4 7 — — Leases — — — — Total commercial loans and leases 212 201 1 1 Residential mortgages (1) 138 136 20 15 Home equity loans 42 50 — — Home equity lines of credit 217 231 — — Home equity loans serviced by others 15 17 — — Home equity lines of credit serviced by others 14 15 — — Automobile 70 81 — — Education 43 38 2 2 Credit card 22 20 — — Other retail 7 8 9 7 Total retail loans 568 596 31 24 Total $780 $797 $32 $25 (1) Nonperforming balances exclude first lien residential mortgage loans that are 100% guaranteed by the Federal Housing Administration. These loans, which are accruing and 90 days or more past due, totaled $13 million and $12 million as of March 31, 2019 and December 31, 2018 , 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 $144 million and $133 million as of March 31, 2019 and December 31, 2018 , 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 as of both March 31, 2019 and December 31, 2018 . A summary of nonperforming loan and lease key performance indicators is presented below: March 31, 2019 December 31, 2018 Nonperforming commercial loans and leases as a percentage of total loans and leases 0.18 % 0.17 % Nonperforming retail loans as a percentage of total loans and leases 0.48 0.51 Nonperforming loans and leases as a percentage of total loans and leases 0.66 % 0.68 % Nonperforming commercial assets as a percentage of total assets 0.13 % 0.13 % Nonperforming retail assets as a percentage of total assets 0.37 0.39 Nonperforming assets as a percentage of total assets 0.50 % 0.52 % The recorded investment in mortgage loans collateralized by residential real estate property for which formal foreclosure proceedings are in process was $170 million and $172 million as of March 31, 2019 and December 31, 2018 , respectively. An analysis of the age of both accruing and nonaccruing loan and lease past due amounts is presented below: March 31, 2019 December 31, 2018 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 $70 $9 $71 $150 $85 $3 $78 $166 Commercial real estate 56 65 2 123 8 32 5 45 Leases 8 — — 8 7 — — 7 Total commercial loans and leases 134 74 73 281 100 35 83 218 Residential mortgages 38 10 131 179 37 13 133 183 Home equity loans 12 4 27 43 12 3 38 53 Home equity lines of credit 76 28 155 259 65 22 195 282 Home equity loans serviced by others 8 2 11 21 7 3 13 23 Home equity lines of credit serviced by others 2 1 11 14 2 1 7 10 Automobile 196 58 17 271 207 59 72 338 Education 22 12 14 48 23 13 11 47 Credit cards 14 9 21 44 14 10 20 44 Other retail 27 17 13 57 26 18 15 59 Total retail loans 395 141 400 936 393 142 504 1,039 Total $529 $215 $473 $1,217 $493 $177 $587 $1,257 Impaired Loans Impaired loans include nonaccruing larger balance (greater than $3 million carrying value), non-homogeneous commercial and commercial real estate loans, and restructured loans that are deemed TDRs. A summary of impaired loans by class is presented below: March 31, 2019 (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 $195 $42 $165 $415 $360 Commercial real estate — — 26 46 26 Leases — — — — — Total commercial loans and leases 195 42 191 461 386 Residential mortgages 28 2 118 188 146 Home equity loans 30 2 70 135 100 Home equity lines of credit 23 1 179 243 202 Home equity loans serviced by others 20 1 19 51 39 Home equity lines of credit serviced by others 1 — 6 10 7 Automobile 1 — 21 30 22 Education 126 10 23 149 149 Credit cards 25 8 — 25 25 Other retail 3 1 3 7 6 Total retail loans 257 25 439 838 696 Total $452 $67 $630 $1,299 $1,082 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 Additional information on impaired loans is presented below: Three Months Ended March 31, 2019 2018 (in millions) Interest Income Recognized Average Recorded Investment Interest Income Recognized Average Recorded Investment Commercial $3 $301 $2 $293 Commercial real estate — 26 — 27 Leases — — — — Total commercial loans and leases 3 327 2 320 Residential mortgages 1 143 1 149 Home equity loans 2 101 2 118 Home equity lines of credit 2 196 2 194 Home equity loans serviced by others 1 39 1 50 Home equity lines of credit serviced by others — 7 — 9 Automobile — 21 — 22 Education 2 150 2 171 Credit cards — 24 — 24 Other retail — 6 — 8 Total retail loans 8 687 8 745 Total $11 $1,014 $10 $1,065 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. 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: (in millions) March 31, 2019 December 31, 2018 Commercial $296 $304 Retail 696 723 Unfunded commitments related to TDRs 25 30 The table below summarizes how loans were modified during the three months ended March 31, 2019 and 2018 . The reported balances represent the post-modification outstanding recorded investment and can include loans that became TDRs during the period and were paid off in full, charged off, or sold prior to period end. Pre-modification balances for modified loans approximate the post-modification balances shown. Three Months Ended March 31, 2019 Primary Modification Types Interest Rate Reduction 1 Maturity Extension 2 Other 3 (dollars in millions) Number of Contracts Recorded Investment Number of Contracts Recorded Investment Number of Contracts Recorded Investment Commercial — $— 5 $1 12 $40 Commercial real estate — — — — — — Total commercial loans — — 5 1 12 40 Residential mortgages 4 2 11 2 30 4 Home equity loans 7 — — — 27 1 Home equity lines of credit 29 4 35 6 105 8 Home equity loans serviced by others — — — — 4 — Home equity lines of credit serviced by others — — — — 2 — Automobile 25 — 5 — 289 4 Education — — — — 67 2 Credit cards 616 4 — — — — Other retail — — — — 1 — Total retail loans 681 10 51 8 525 19 Total 681 $10 56 $9 537 $59 Three Months Ended March 31, 2018 Primary Modification Types Interest Rate Reduction 1 Maturity Extension 2 Other 3 (dollars in millions) Number of Contracts Recorded Investment Number of Contracts Recorded Investment Number of Contracts Recorded Investment Commercial 1 $— 6 $1 18 $75 Commercial real estate — — 1 — — — Total commercial loans 1 — 7 1 18 75 Residential mortgages 7 1 7 1 53 6 Home equity loans 11 1 — — 32 2 Home equity lines of credit 15 1 42 5 93 7 Home equity loans serviced by others 1 — — — 7 — Home equity lines of credit serviced by others 2 — — — 3 — Automobile 36 1 17 1 269 4 Education — — — — 112 1 Credit cards 594 3 — — — — Other retail 1 — — — 4 — Total retail loans 667 7 66 7 573 20 Total 668 $7 73 $8 591 $95 (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 net change to ALLL resulting from modification for the three months ended March 31, 2019 and 2018 was $2 million and $1 million , respectively. Charge-offs may also be recorded on TDRs. Citizens recorded $1 million of charge-offs resulting from the modification of loans in the three months ended March 31, 2019 and 2018 . A payment default refers to a loan that becomes 90 days or more past due under the modified terms. Loan data includes loans meeting the criteria that were paid off in full, charged off, or sold prior to March 31, 2019 and 2018 . 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. For commercial loans, recorded investment in TDRs that defaulted within 12 months of their modification date for the three months ended March 31, 2018 were $3 million . There were none for the three months ended March 31, 2019 . For retail loans, there were $9 million and $10 million of loans which defaulted within 12 months of their restructuring date for the three months ended March 31, 2019 and 2018 , respectively. Concentrations of Credit Risk Most of the Company’s lending activity is with customers located in the New England, Mid-Atlantic and Midwest regions. Generally, loans are collateralized by assets including real estate, inventory, accounts receivable, other personal property and investment securities. As of March 31, 2019 and December 31, 2018 , Citizens had a significant amount of loans collateralized by residential and commercial real estate. There were no significant concentration risks within the commercial loan or retail loan portfolios. Exposure to credit losses arising from lending transactions may fluctuate with fair values of collateral supporting loans, which may not perform according to contractual agreements. The Company’s policy is to collateralize loans to the extent necessary; however, unsecured loans are also granted on the basis of the financial strength of the applicant and the facts surrounding the transaction. Certain loan products, including residential mortgages, home equity loans and lines of credit, and credit cards, have contractual features that may increase credit exposure to the Company in the event of an increase in interest rates or a decline in housing values. These products include loans that exceed 90% of the value of the underlying collateral (high LTV loans), interest-only and negative amortization residential mortgages, and loans with low introductory rates. Certain loans have more than one of these characteristics. The following tables present balances of loans with these characteristics: March 31, 2019 (in millions) Residential Mortgages Home Equity Loans and Lines of Credit Home Equity Products Serviced by Others Credit Cards Total High loan-to-value $342 $79 $134 $— $555 Interest-only/negative amortization 1,724 — — — 1,724 Low introductory rate — — — 219 219 Multiple characteristics and other 2 — — — 2 Total $2,068 $79 $134 $219 $2,500 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 |