Citizens Financial (CFG) 10-Q 4 Nov 20 2020 Q3 Quarterly report Financial data

Cover Page

Cover Page - shares	9 Months Ended
	Sep. 30, 2020	Oct. 30, 2020
Entity Information [Line Items]
Document Type	10-Q
Document Quarterly Report	true
Document Period End Date	Sep. 30, 2020
Document Transition Report	false
Entity File Number	001-36636
Entity Registrant Name	CITIZENS FINANCIAL GROUP INC/RI
Entity Incorporation, State or Country Code	DE
Entity Tax Identification Number	05-0412693
Entity Address, Address Line One	One Citizens Plaza
Entity Address, City or Town	Providence
Entity Address, State or Province	RI
Entity Address, Postal Zip Code	02903
City Area Code	401
Local Phone Number	456-7000
Entity Current Reporting Status	Yes
Entity Interactive Data Current	Yes
Entity Filer Category	Large Accelerated Filer
Entity Small Business	false
Entity Emerging Growth Company	false
Entity Shell Company	false
Entity Common Stock, Shares Outstanding		427,073,084
Entity Central Index Key	0000759944
Amendment Flag	false
Document Fiscal Year Focus	2020
Document Fiscal Period Focus	Q3
Current Fiscal Year End Date	--12-31
Common Stock
Entity Information [Line Items]
Title of 12(b) Security	Common stock, $0.01 par value per share
Trading Symbol	CFG
Security Exchange Name	NYSE
Series D Preferred Stock
Entity Information [Line Items]
Title of 12(b) Security	Depositary Shares, each representing a 1/40th interest in a share of 6.350% Fixed-to-Floating Rate Non-Cumulative Perpetual Preferred Stock, Series D
Trading Symbol	CFG PrD
Security Exchange Name	NYSE
Series E Preferred Stock
Entity Information [Line Items]
Title of 12(b) Security	Depositary Shares, each representing a 1/40th interest in a share of 5.000% Fixed-Rate Non-Cumulative Perpetual Preferred Stock, Series E
Trading Symbol	CFG PrE
Security Exchange Name	NYSE

CONSOLIDATED BALANCE SHEETS (UN

CONSOLIDATED BALANCE SHEETS (UNAUDITED) - USD ($) $ in Millions		Sep. 30, 2020	Dec. 31, 2019
ASSETS:
Cash and due from banks		$ 904	$ 1,175
Interest-bearing cash and due from banks		8,312	2,211
Interest-bearing deposits in banks		328	297
Debt securities available for sale, at fair value (including $577 and $359 pledged to creditors, respectively)	[1]	22,884	20,613
Debt securities held to maturity (fair value of $2,709 and $3,242 respectively, and including $159 and $249 pledged to creditors, respectively)	[1]	2,578	3,202
Equity investment securities, at fair value		57	47
Equity investment securities, at cost		605	807
Loans held for sale, at fair value		3,587	1,946
Other loans held for sale		127	1,384
Loans and leases		124,071	119,088
Less: Allowance for loan and lease losses		(2,542)	(1,252)
Net loans and leases		121,529	117,836
Derivative assets		2,030	807
Premises and equipment, net		747	761
Bank-owned life insurance		1,751	1,725
Goodwill		7,050	7,044
Other assets		6,739	5,878
TOTAL ASSETS		179,228	165,733
Deposits:
Noninterest-bearing		41,249	29,233
Interest-bearing		101,672	96,080
Total deposits		142,921	125,313
Short-term borrowed funds		252	274
Derivative liabilities		100	120
Deferred taxes, net		638	866
Long-term borrowed funds		9,109	14,047
Other liabilities		3,739	2,912
TOTAL LIABILITIES		156,759	143,532
Contingencies (refer to Note 12)
Preferred stock:
$25.00 par value,100,000,000 shares authorized; 2,000,000 and 1,600,000 shares issued and outstanding at September 30, 2020 and December 31, 2019, respectively		1,965	1,570
Common stock:
$0.01 par value, 1,000,000,000 shares authorized; 569,739,386 shares issued and 427,073,084 shares outstanding at September 30, 2020 and 568,238,730 shares issued and 433,121,083 shares outstanding at December 31, 2019		6	6
Additional paid-in capital		18,922	18,891
Retained earnings		6,189	6,498
Treasury stock, at cost, 142,666,302 and 135,117,647 shares at September 30, 2020 and December 31, 2019, respectively		(4,623)	(4,353)
Accumulated other comprehensive income (loss)		10	(411)
TOTAL STOCKHOLDERS’ EQUITY		22,469	22,201
TOTAL LIABILITIES AND STOCKHOLDERS’ EQUITY		$ 179,228	$ 165,733
[1]	Includes only collateral pledged by the Company where counterparties have the right to sell or pledge the collateral.

CONSOLIDATED BALANCE SHEETS (_2

CONSOLIDATED BALANCE SHEETS (UNAUDITED) (Parenthetical) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
ASSETS:
Securities held-to-maturity, fair value	$ 2,709	$ 3,242
STOCKHOLDERS’ EQUITY:
Preferred stock, par value (in dollars per share)	$ 25	$ 25
Preferred stock, authorized (in shares)	100,000,000	100,000,000
Preferred stock, issued (in shares)	2,000,000	1,600,000
Preferred stock, outstanding (in shares)	2,000,000	1,600,000
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)	569,739,386	568,238,730
Common stock, outstanding (in shares)	427,073,084	433,121,083
Treasury stock (in shares)	142,666,302	135,117,647
Available-for-sale Securities
ASSETS:
Securities, pledged to creditors	$ 577	$ 359
Held-to-maturity Securities
ASSETS:
Securities, pledged to creditors	159	249
Securities held-to-maturity, fair value	$ 2,709	$ 3,242

CONSOLIDATED STATEMENTS OF OPER

CONSOLIDATED STATEMENTS OF OPERATIONS (UNAUDITED) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
INTEREST INCOME:
Interest and fees on loans and leases	$ 1,120	$ 1,356	$ 3,614	$ 4,129
Interest and fees on loans held for sale, at fair value	21	19	56	45
Interest and fees on other loans held for sale	16	2	32	8
Investment securities	121	153	398	483
Interest-bearing deposits in banks	2	8	8	23
Total interest income	1,280	1,538	4,108	4,688
INTEREST EXPENSE:
Deposits	89	297	440	892
Short-term borrowed funds	0	2	1	8
Long-term borrowed funds	54	94	210	317
Total interest expense	143	393	651	1,217
Net interest income	1,137	1,145	3,457	3,471
Provision for credit losses	428	101	1,492	283
Net interest income after provision for credit losses	709	1,044	1,965	3,188
NONINTEREST INCOME:
Service charges and fees	97	128	299	377
Mortgage banking fees	287	117	722	222
Card fees	57	67	161	190
Capital markets fees	58	39	162	150
Trust and investment services fees	53	50	151	150
Foreign exchange and interest rate products	27	35	85	106
Letter of credit and loan fees	37	34	102	100
Securities gains, net	1	3	4	15
Net impairment losses recognized in earnings on debt securities	0	(1)	0	(2)
Other income	37	21	55	75
Total noninterest income	654	493	1,741	1,383
NONINTEREST EXPENSE:
Salaries and employee benefits	524	508	1,586	1,524
Equipment and software expense	149	130	424	381
Outside services	139	128	405	356
Occupancy	81	80	247	245
Other operating expense	95	127	317	355
Total noninterest expense	988	973	2,979	2,861
Income before income tax expense	375	564	727	1,710
Income tax expense	61	115	126	369
NET INCOME	314	449	601	1,341
Net income available to common stockholders	$ 289	$ 432	$ 526	$ 1,291
Weighted-average common shares outstanding:
Basic (in Shares)	426,846,096	445,703,987	427,058,412	454,802,186
Diluted (in Shares)	427,992,349	447,134,595	428,142,358	456,218,755
Per common share information:
Basic earnings (in dollars per share)	$ 0.68	$ 0.97	$ 1.23	$ 2.84
Diluted earnings (in Dollars per Share)	$ 0.68	$ 0.97	$ 1.23	$ 2.83

CONSOLIDATED STATEMENTS OF COMP

CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME (UNAUDITED) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Statement of Comprehensive Income [Abstract]
Net income	$ 314	$ 449	$ 601	$ 1,341
Other comprehensive income (loss):
Net unrealized derivative instruments (losses) gains arising during the periods, net of income taxes of $0, ($1), $30 and $35, respectively	0	(4)	88	103
Reclassification adjustment for net derivative (gains) losses included in net income, net of income taxes of ($15), $4, ($27) and $13, respectively	(42)	10	(79)	40
Net unrealized debt securities (losses) gains arising during the periods, net of income taxes of ($14), $13, $131 and $165, respectively	(44)	42	405	509
Other-than-temporary impairment not recognized in earnings on debt securities, net of income taxes of $0, $0, $0 and $0, respectively	0	(1)	0	0
Reclassification of net debt securities gains to net income, net of income taxes of $0, $0, ($1) and ($3), respectively	(1)	(2)	(3)	(10)
Amortization of actuarial loss, net of income taxes of $1, $2, $2 and $5, respectively	3	3	10	9
Net other comprehensive income	(84)	48	421	651
Total comprehensive income	$ 230	$ 497	$ 1,022	$ 1,992

CONSOLIDATED STATEMENTS OF CO_2

CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME (UNAUDITED) (Parenthetical) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Statement of Comprehensive Income [Abstract]
Net unrealized derivative instrument gains arising during the periods, tax	$ 0	$ (1)	$ 30	$ 35
Reclassification adjustment for net derivative (gains) losses included in net income, tax	(15)	4	(27)	13
Net unrealized debt securities gains arising during the periods, tax	(14)	13	131	165
Other-than-temporary impairment not recognized in earnings on debt securities, tax	0	0	0	0
Reclassification of net debt securities gains to net income, tax	0	0	(1)	(3)
Amortization of actuarial loss, tax	$ 1	$ 2	$ 2	$ 5

CONSOLIDATED STATEMENTS OF CHAN

CONSOLIDATED STATEMENTS OF CHANGES IN STOCKHOLDERS' EQUITY (UNAUDITED) - USD ($) $ in Millions	Total	Preferred Stock	Common Stock	Additional Paid-in Capital	Retained Earnings	Treasury Stock, at Cost	Accumulated Other Comprehensive Income (Loss)	Cumulative Effect, Period Of Adoption, Adjustment	Cumulative Effect, Period Of Adoption, AdjustmentRetained Earnings	Cumulative Effect, Period Of Adoption, AdjustmentAccumulated Other Comprehensive Income (Loss)
Beginning balance (in shares) at Dec. 31, 2018		1,000,000	466,000,000
Beginning balance at Dec. 31, 2018	$ 20,817	$ 840	$ 6	$ 18,815	$ 5,385	$ (3,133)	$ (1,096)			$ 5
Increase (Decrease) in Stockholders' Equity [Roll Forward]
Dividends to common stockholders	(459)				(459)
Dividends to preferred stockholders	(50)				(50)
Preferred stock issued (in shares)		0
Preferred stock issued	293	$ 293
Treasury stock purchased (in shares)			(23,000,000)
Treasury stock purchased	(820)					(820)
Share-based compensation plans (in shares)			1,000,000
Share-based compensation plans	48			48		0
Employee stock purchase plan shares purchased	13			13
Total comprehensive income:
Net income	1,341				1,341
Other comprehensive income	651						651
Total comprehensive income	1,992				1,341		651
Ending balance (in shares) at Sep. 30, 2019		1,000,000	444,000,000
Ending balance at Sep. 30, 2019	21,851	$ 1,133	$ 6	18,876	6,229	(3,953)	(440)	$ 17	$ 12	5
Beginning balance (in shares) at Jun. 30, 2019		1,000,000	458,000,000
Beginning balance at Jun. 30, 2019	22,017	$ 1,133	$ 6	18,860	5,959	(3,453)	(488)
Increase (Decrease) in Stockholders' Equity [Roll Forward]
Dividends to common stockholders	(162)				(162)
Dividends to preferred stockholders	(17)				(17)
Treasury stock purchased (in shares)			(14,000,000)
Treasury stock purchased	(500)					(500)
Share-based compensation plans (in shares)			0
Share-based compensation plans	11			11		0
Employee stock purchase plan shares purchased	5			5
Total comprehensive income:
Net income	449				449
Other comprehensive income	48						48
Total comprehensive income	497				449		48
Ending balance (in shares) at Sep. 30, 2019		1,000,000	444,000,000
Ending balance at Sep. 30, 2019	21,851	$ 1,133	$ 6	18,876	6,229	(3,953)	(440)	17	12	5
Beginning balance (in shares) at Dec. 31, 2019		2,000,000	433,000,000
Beginning balance at Dec. 31, 2019	22,201	$ 1,570	$ 6	18,891	6,498	(4,353)	(411)
Increase (Decrease) in Stockholders' Equity [Roll Forward]
Dividends to common stockholders	(504)				(504)
Dividends to preferred stockholders	(75)				(75)
Preferred stock issued (in shares)		0
Preferred stock issued	$ 395	$ 395
Treasury stock purchased (in shares)	(7,548,655)		(7,000,000)
Treasury stock purchased	$ (270)			0		(270)
Share-based compensation plans (in shares)			1,000,000
Share-based compensation plans	17			17		0
Employee stock purchase plan shares purchased	14			14
Total comprehensive income:
Net income	601				601
Other comprehensive income	421						421
Total comprehensive income	1,022				601		421
Ending balance (in shares) at Sep. 30, 2020		2,000,000	427,000,000
Ending balance at Sep. 30, 2020	22,469	$ 1,965	$ 6	18,922	6,189	(4,623)	10	(331)	(331)	0
Beginning balance (in shares) at Jun. 30, 2020		2,000,000	427,000,000
Beginning balance at Jun. 30, 2020	22,418	$ 1,965	$ 6	18,908	6,068	(4,623)	94
Increase (Decrease) in Stockholders' Equity [Roll Forward]
Dividends to common stockholders	(168)				(168)
Dividends to preferred stockholders	(25)				(25)
Preferred stock issued (in shares)		0
Preferred stock issued	0	$ 0
Treasury stock purchased (in shares)			0
Treasury stock purchased	0					0
Share-based compensation plans (in shares)			0
Share-based compensation plans	10			10		0
Employee stock purchase plan shares purchased	4			4
Total comprehensive income:
Net income	314				314
Other comprehensive income	(84)						(84)
Total comprehensive income	230				314		(84)
Ending balance (in shares) at Sep. 30, 2020		2,000,000	427,000,000
Ending balance at Sep. 30, 2020	$ 22,469	$ 1,965	$ 6	$ 18,922	$ 6,189	$ (4,623)	$ 10	$ (331)	$ (331)	$ 0

CONSOLIDATED STATEMENTS OF CASH

CONSOLIDATED STATEMENTS OF CASH FLOWS (UNAUDITED) - USD ($) $ in Millions		9 Months Ended
		Sep. 30, 2020	Sep. 30, 2019
OPERATING ACTIVITIES
Net income		$ 601	$ 1,341
Adjustments to reconcile net income to net cash provided by operating activities:
Provision for credit losses		1,492	283
Net change in loans held for sale		(655)	(697)
Depreciation, amortization and accretion		413	432
Amortization of intangibles		6	8
Deferred income taxes		(251)	(41)
Share-based compensation		34	44
Net gain on sales of:
Debt securities		(4)	(21)
Premises and equipment		0	(6)
Increase in other assets		(2,960)	(506)
Increase in other liabilities		569	133
Net cash (used in) provided by operating activities		(755)	970
Investment securities:
Purchases of debt securities available for sale		(5,547)	(4,633)
Proceeds from maturities and paydowns of debt securities available for sale		4,583	2,728
Proceeds from sales of debt securities available for sale		48	1,495
Proceeds from maturities and paydowns of debt securities held to maturity		629	280
Net decrease in equity securities, at fair value		0	136
Net decrease in equity securities, at cost		202	100
Net increase in interest-bearing deposits in banks		(31)	(10)
Acquisitions, net of cash acquired		(3)	(129)
Net increase in loans and leases		(5,303)	(1,534)
Capital expenditures, net		1	(47)
Other		(78)	(172)
Net cash used in investing activities		(5,499)	(1,786)
FINANCING ACTIVITIES
Net increase in deposits		17,608	5,139
Net decrease in short-term borrowed funds		(43)	(244)
Proceeds from issuance of long-term borrowed funds		8,323	7,300
Repayments of long-term borrowed funds		(13,258)	(10,556)
Treasury stock purchased		(270)	(820)
Net proceeds from issuance of preferred stock		395	293
Dividends declared and paid to common stockholders		(504)	(459)
Dividends declared and paid to preferred stockholders		(73)	(48)
Premium paid to exchange subordinated debt		(80)	0
Payments of employee tax withholding for share-based compensation		(14)	(21)
Net cash provided by financing activities		12,084	584
(Decrease) increase in cash and cash equivalents	[1]	5,830	(232)
Cash and cash equivalents at beginning of period	[1]	3,386	4,074
Cash and cash equivalents at end of period	[1]	$ 9,216	$ 3,842
[1]	Cash and cash equivalents includes cash and due from banks and interest-bearing cash and due from banks as reflected on the Consolidated Balance Sheets.

BASIS OF PRESENTATION

BASIS OF PRESENTATION	9 Months Ended
	Sep. 30, 2020
Organization, Consolidation and Presentation of Financial Statements [Abstract]
BASIS OF PRESENTATION	NOTE 1 - BASIS OF PRESENTATION Basis of Presentation The unaudited interim Consolidated Financial Statements, including the Notes presented in this document of Citizens Financial Group, Inc., have been prepared in accordance with GAAP interim reporting requirements, and therefore do not include all information and Notes included in the audited Consolidated Financial Statements in conformity with GAAP. These unaudited interim Consolidated Financial Statements and Notes presented in this document should be read in conjunction with the Company’s audited Consolidated Financial Statements and accompanying Notes included in the Company’s 2019 Form 10-K. The Company’s principal business activity is banking, conducted through its banking subsidiary, CBNA. The unaudited interim Consolidated Financial Statements include the accounts of the Company and subsidiaries in which the Company has a controlling financial interest. All intercompany transactions and balances have been eliminated. The Company has evaluated its unconsolidated entities and does not believe that any entity in which it has an interest, but does not currently consolidate, meets the requirements to be consolidated as a variable interest entity. The unaudited interim Consolidated Financial Statements include all adjustments, consisting of normal recurring adjustments, necessary for a fair presentation of the results for the interim periods. The results for interim periods are not necessarily indicative of results for a full year. The preparation of financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. Material estimates that are particularly susceptible to significant change in the near-term relate to the determination of the ACL, the fair value of MSRs, and the evaluation and measurement of impairment of goodwill. Significant Accounting Policies For further information regarding the Company’s significant accounting policies, see Note 1 in the Company’s 2019 Form 10-K. Accounting Pronouncements Adopted in 2020 Pronouncement Summary of Guidance Effects on Financial Statements Financial Instruments - Credit Losses Issued June 2016 • Required effective date: January 1, 2020. • Establishes a single allowance framework for financial assets carried at amortized cost (including securities HTM), which reflects management’s estimate of credit losses over the full remaining expected life of the financial assets. • Amends impairment guidance for securities AFS to incorporate an allowance, which allows for reversals of impairment losses in the event that the credit of an issuer improves. • Requires a cumulative-effect adjustment to retained earnings, net of taxes, as of the beginning of the reporting period of adoption. • Requires enhanced credit quality disclosures including disaggregation of credit quality indicators by vintage. • The Company adopted the new standard on January 1, 2020, retrospectively for loans and leases and HTM securities and prospectively for AFS securities. Refer to Note 4 for discussion of the significant accounting policy for the allowance for credit losses following adoption. • Adoption resulted in a cumulative-effect reduction of $337 million, net of taxes of $114 million, to retained earnings and a corresponding increase to the ACL of $451 million. Refer to Note 4 for the impact of the adoption to the ALLL and reserve for unfunded commitments. • Adoption of the new standard could produce higher volatility in the quarterly provision for credit losses than the prior incurred loss reserve process and could adversely impact the Company’s ongoing earnings. • Based on the credit quality of the Company’s existing debt securities portfolio, the Company did not recognize an allowance for HTM and AFS debt securities upon adoption. Goodwill Issued January 2017 • Requires an impairment loss to be recognized when the estimated fair value of a reporting unit falls below its carrying value. • Eliminates the second condition in the current guidance that requires an impairment loss to be recognized only if the estimated implied fair value of the goodwill is below its carrying value. • Applied prospectively to all goodwill impairment tests performed after the adoption date. • The Company adopted the new standard on January 1, 2020. Refer to Note 6 for discussion of the significant accounting policy for goodwill impairment following adoption. • Adoption did not 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. • 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 disclosures. • Retrospective application is required for all other amendments for all periods presented. • The Company adopted the new standard on January 1, 2020. • Adoption did not have a material impact on the Company’s Consolidated Financial Statements. Required fair value measurement disclosures are included in Note 13. Simplifying the Accounting for Income Taxes Issued December 2019 • Simplifies the accounting for income taxes by eliminating certain exceptions related to the approach for intraperiod tax allocation, the methodology for calculating income taxes in an interim period and the recognition of deferred tax liabilities for outside basis differences. • Simplifies aspects of the accounting for franchise taxes and enacted changes in tax laws or rates. • Clarifies the accounting for transactions that result in a step-up in the tax basis of goodwill. • The Company adopted the new standard on January 1, 2020. • Adoption did not have an impact on the Company’s Consolidated Financial Statements. Pronouncement Summary of Guidance Effects on Financial Statements Facilitation of the Effects of Reference Rate Reform on Financial Reporting Issued March 2020 • Provides the option to apply a number of practical expedients when evaluating if a contract modification as the result of reference rate reform is considered a new contract or a continuation of an existing contract. • Provides optional expedients to the evaluation of, and accounting for, fair value and cash flow hedges affected by reference rate reform. • Provides an optional one-time election to sell or transfer debt securities classified as HTM that reference a rate affected by reference rate reform • The Company adopted the new standard in the first quarter of 2020 upon issuance and is effective through December 31, 2022. • Adoption did not have a material impact on the Company’s Consolidated Financial Statements.

SECURITIES

SECURITIES	9 Months Ended
	Sep. 30, 2020
Investments, Debt and Equity Securities [Abstract]
SECURITIES	NOTE 2 - SECURITIES The following table presents the major components of securities at amortized cost and fair value: September 30, 2020 December 31, 2019 (in millions) Amortized Cost Gross Unrealized Gains Gross Unrealized Losses Fair Value Amortized Cost Gross Unrealized Gains Gross Unrealized Losses Fair Value U.S. Treasury and other $11 $— $— $11 $71 $— $— $71 State and political subdivisions 4 — — 4 5 — — 5 Mortgage-backed securities, at fair value: Federal agencies and U.S. government sponsored entities 20,962 617 (38 ) 21,541 19,803 143 (71 ) 19,875 Other/non-agency 482 33 — 515 638 24 — 662 Total mortgage-backed securities, at fair value 21,444 650 (38 ) 22,056 20,441 167 (71 ) 20,537 Asset-backed securities, at fair value (1) 813 — — 813 — — — — Total debt securities available for sale, at fair value $22,272 $650 ($38 ) $22,884 $20,517 $167 ($71 ) $20,613 Mortgage-backed securities, at cost: Federal agencies and U.S. government sponsored entities $2,578 $131 $— $2,709 $3,202 $45 ($5 ) $3,242 Total debt securities held to maturity, at cost $2,578 $131 $— $2,709 $3,202 $45 ($5 ) $3,242 Money market mutual fund investments $57 $— $— $57 $47 $— $— $47 Total equity securities, at fair value $57 $— $— $57 $47 $— $— $47 Federal Reserve Bank stock $577 $— $— $577 $577 $— $— $577 Federal Home Loan Bank stock 20 — — 20 222 — — 222 Other equity securities 8 — — 8 8 — — 8 Total equity securities, at cost $605 $— $— $605 $807 $— $— $807 (1) In September 2020, Citizens sold $973 million of private in-school education loans, inclusive of accrued interest, capitalized interest and fees. Additionally, the Company provided financing to the purchaser for a portion of the sale price in the form of $813 million of asset-backed securities, collateralized by the sold assets, which are classified as AFS. Refer to Note 7 for additional information. Accrued interest receivable on debt securities totaled $57 million and $58 million as of September 30, 2020 and December 31, 2019 , respectively, and is included in other assets on the Consolidated Balance Sheets. The following table presents the amortized cost and fair value of debt securities by contractual maturity as of September 30, 2020 . Expected maturities may differ from contractual maturities because issuers may have the right to call or prepay obligations with or without incurring penalties. September 30, 2020 Distribution of Maturities (in millions) 1 Year or Less After 1 Year through 5 Years After 5 Years through 10 Years After 10 Years Total Amortized cost: U.S. Treasury and other $11 $— $— $— $11 State and political subdivisions — — — 4 4 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities 4 147 1,591 19,220 20,962 Other/non-agency — — — 482 482 Asset-backed securities — — 813 — 813 Total debt securities available for sale 15 147 2,404 19,706 22,272 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — — — 2,578 2,578 Total debt securities held to maturity — — — 2,578 2,578 Total amortized cost of debt securities $15 $147 $2,404 $22,284 $24,850 Fair value: U.S. Treasury and other $11 $— $— $— $11 State and political subdivisions — — — 4 4 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities 4 153 1,647 19,737 21,541 Other/non-agency — — — 515 515 Asset-backed securities — — 813 — 813 Total debt securities available for sale 15 153 2,460 20,256 22,884 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — — — 2,709 2,709 Total debt securities held to maturity — — — 2,709 2,709 Total fair value of debt securities $15 $153 $2,460 $22,965 $25,593 Taxable interest income from investment securities as presented on the Consolidated Statements of Operations was $121 million and $153 million for the three months ended September 30, 2020 and 2019 , respectively and $398 million and $483 million for the nine months ended September 30, 2020 and 2019 , respectively. The following table presents realized gains and losses on securities: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Gains on sale of debt securities (1) $1 $5 $4 $21 Losses on sale of debt securities — — — — Debt securities gains, net $1 $5 $4 $21 (1) For the three and nine months ended September 30, 2019 , $2 million and $6 million , respectively, of gains on sale of debt securities were recognized in mortgage banking fees in the Consolidated Statement of Operations as they related to AFS securities held as economic hedges of the value of the MSR portfolio recognized using the amortization method. The following table presents the amortized cost and fair value of debt securities pledged: September 30, 2020 December 31, 2019 (in millions) Amortized Cost Fair Value Amortized Cost Fair Value Pledged against repurchase agreements $227 $234 $265 $266 Pledged against FHLB borrowed funds 478 515 638 662 Pledged against derivatives, to qualify for fiduciary powers, and to secure public and other deposits as required by law 3,506 3,620 3,670 3,672 Citizens regularly enters into security repurchase agreements with unrelated counterparties, which 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 in nature and are accounted for as secured borrowed funds on the Company’s Consolidated Balance Sheets. Citizens recognized no offsetting of short-term receivables or payables as of September 30, 2020 or December 31, 2019 . Citizens offsets certain derivative assets and derivative liabilities on the Consolidated Balance Sheets. For further information, see Note 9 . Securitizations of mortgage loans retained in the investment portfolio were $34 million for the three and nine months ended September 30, 2020 . Securitizations of mortgage loans retained in the investment portfolio were $28 million and $72 million for the three and nine months ended September 30, 2019 , respectively. These securitizations include a substantive guarantee by a third party. In 2020, the guarantors were FNMA and FHLMC. In 2019 , the guarantors were FNMA, FHLMC, and GNMA. The debt securities received from the guarantors are classified as AFS. Impairment Upon purchase of HTM investment securities and at each subsequent measurement date, Citizens is required to evaluate the securities for risk of loss over their life and, if necessary, establish an associated reserve. Recognition of a reserve for expected credit losses is not required if the amount the Company expects to realize is zero (commonly referred to as “zero expected credit losses”). The Company evaluated its existing HTM portfolio and concluded that all of the securities met the zero expected credit loss criteria, and therefore no CECL reserve was booked for HTM securities as of the balance sheet date. Citizens reviews its AFS debt securities for impairment at the individual security level on a quarterly basis, or more frequently if a potential loss triggering event occurs. The initial indicator of impairment for debt securities classified as AFS is a decline in fair value below its amortized cost basis. For any security that has declined in fair value below the amortized cost basis, the Company recognizes an impairment loss in current period earnings if management has the intent to sell the security or if it is more likely than not it will be required to sell the security before recovery of its amortized cost basis. 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 the amortized cost basis, impairment equal to the shortfall in cash flows has occurred. Citizens evaluates whether any portion of the impairment is attributable to credit-related factors or various other market factors affecting the fair value of the security (e.g., interest rates, spread levels, liquidity in the sector, etc.), and the public credit rating of the security. If credit-related factors exist, credit-related impairment has occurred regardless of the Company’s intent to hold the security until it recovers. The credit-related portion of impairment is recognized in current period earnings as provision expense through the establishment of an allowance for AFS securities, to the extent the allowance does not reduce the value of the AFS security below its current fair value. The remaining non-credit related portion of impairment is recognized in OCI. Improvement in credit losses in subsequent periods results in a reversal of the allowance for AFS securities and a corresponding decrease to provision expense, to the extent the allowance does not become negative. Accrued interest receivable on AFS debt securities is excluded from the balances used to calculate the allowance for AFS securities. All accrued and uncollected interest is immediately reversed against interest income when it is deemed uncollectible. The Company has evaluated any AFS securities in an unrealized loss position at September 30, 2020 and concluded that all unrealized losses are due to non-credit related factors. As such, the Company does not have an allowance for AFS securities as of September 30, 2020 . The following table presents AFS mortgage-backed debt securities with fair values below their respective carrying values, separated by the duration the securities have been in a continuous unrealized loss position: September 30, 2020 Less than 12 Months 12 Months or Longer Total (dollars in millions) Fair Value Gross Unrealized Losses Fair Value Gross Unrealized Losses Fair Value Gross Unrealized Losses Federal agencies and U.S. government sponsored entities $2,524 ($38 ) $— $— $2,524 ($38 ) The following table present AFS and HTM mortgage-backed debt securities with fair values below their respective carrying values, separated by the duration the securities have been in a continuous unrealized loss position: December 31, 2019 Less than 12 Months 12 Months or Longer Total (dollars in millions) Fair Value Gross Unrealized Losses Fair Value Gross Unrealized Losses Fair Value Gross Unrealized Losses Federal agencies and U.S. government sponsored entities $5,135 ($24 ) $3,748 ($52 ) $8,883 ($76 ) 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 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 September 30, 2020

LOANS AND LEASES

LOANS AND LEASES	9 Months Ended
	Sep. 30, 2020
Receivables [Abstract]
LOANS AND LEASES	NOTE 3 - 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. 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, automobile, education and other retail. The following table presents the Company’s loans and leases, excluding LHFS, disclosed in portfolio segments and classes: (in millions) September 30, 2020 December 31, 2019 Commercial (1) $45,185 $41,479 Commercial real estate 14,889 13,522 Leases 2,288 2,537 Total commercial loans and leases 62,362 57,538 Residential mortgages 19,633 19,083 Home equity 12,322 13,154 Automobile 12,035 12,120 Education 11,631 10,347 Other retail 6,088 6,846 Total retail loans 61,709 61,550 Total loans and leases $124,071 $119,088 (1) Includes PPP loans fully guaranteed by the SBA of $4.7 billion as of September 30, 2020 . Accrued interest receivable on loans and leases held for investment totaled $470 million and $495 million as of September 30, 2020 and December 31, 2019 , respectively, and is included in other assets in the Consolidated Balance Sheets. The following table presents the composition of LHFS. September 30, 2020 December 31, 2019 (in millions) Residential Mortgages (1) Commercial (2) Total Residential Mortgages (1) Commercial (2) Total Loans held for sale at fair value $3,425 $162 $3,587 $1,778 $168 $1,946 Other loans held for sale — 127 127 1,101 283 1,384 (1) Residential mortgage LHFS are originated for sale. (2) Commercial LHFS at fair value consist of loans managed by the Company’s commercial secondary loan desk. Other commercial LHFS generally consist 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 $25.2 billion and $25.3 billion at September 30, 2020 and December 31, 2019 , respectively. Loans pledged as collateral to support the contingent ability to borrow at the FRB discount window were primarily comprised of auto, commercial, commercial real estate, and education loans, and totaled $39.2 billion and $17.4 billion at September 30, 2020 and December 31, 2019 , respectively. During the three months ended September 30, 2020 , the Company purchased $801 million of education loans and $101 million of other retail loans. During the three months ended September 30, 2019 , the Company purchased $164 million of education loans and $66 million of other retail loans. During the nine months ended September 30, 2020 , the Company purchased $1.7 billion of education loans and $628 million of other retail loans. During the nine months ended September 30, 2019 , the Company purchased $464 million of education loans and $66 million of other retail loans. During the three months ended September 30, 2020 , the Company sold $94 million of commercial loans and $879 million of education loans. For further information, see Note 2 and Note 7 . During the three months ended September 30, 2019 , the Company sold $109 million of commercial loans. During the nine months ended September 30, 2020 , the Company sold $356 million of commercial loans, $879 million of education loans and $1.5 billion of residential mortgage loans. During the nine months ended September 30, 2019 , the Company sold $291 million of commercial loans and $628 million of retail loans, including $22 million of retail TDRs. Interest income on direct financing and sales-type leases was $17 million and $18 million for the three months ended September 30, 2020 and 2019 , respectively, and was $54 million and $58 million for the nine months ended September 30, 2020 and 2019

ALLOWANCE FOR CREDIT LOSSES, NO

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK	9 Months Ended
	Sep. 30, 2020
Receivables [Abstract]
ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK	NOTE 4 - ALLOWANCE FOR CREDIT LOSSES, NONACCRUING LOANS AND LEASES, AND CONCENTRATIONS OF CREDIT RISK Allowance for Credit Losses Management’s estimate of expected credit losses in the Company’s loan and lease portfolios is recorded in the ALLL and the reserve for unfunded lending commitments (collectively the ACL). See Note 5 in the Company’s 2019 Form 10-K for a detailed discussion of the ACL reserve methodology and estimation techniques as of December 31, 2019. Upon adoption of CECL effective January 1, 2020, the Company’s ACL reserve methodology changed to estimate expected credit losses over the contractual life of loans and leases. The ACL is maintained at a level the Company believes to be appropriate to absorb expected lifetime credit losses over the contractual life of the loan and lease portfolios and on the unfunded lending commitments. The determination of the ACL is based on periodic evaluation of the loan and lease portfolios and unfunded lending commitments that are not unconditionally cancelable considering a number of relevant underlying factors, including key assumptions and evaluation of quantitative and qualitative information. Key assumptions used in the ACL measurement process include the use of a two-year reasonable and supportable economic forecast period followed by a one-year period during which the expected credit losses revert to long-term historical macroeconomic inputs. The evaluation of quantitative and qualitative information is performed through assessments of groups of assets that share similar risk characteristics and certain individual loans and leases that do not share similar risk characteristics with the collective group. Loans are grouped generally by product type (e.g., commercial, commercial real estate, residential mortgage, etc.), and significant loan portfolios are assessed for credit losses using econometric models. The quantitative evaluation of the adequacy of the ACL utilizes a single economic forecast as its foundation, and is primarily based on econometric models that use known or estimated data as of the balance sheet date and forecasted data over the reasonable and supportable period. Known and estimated data include current PD, LGD and EAD (for commercial loans and leases), timing and amount of expected draws (for unfunded lending commitments), FICO, LTV, term and time on books (for retail loans), mix and level of loan balances, delinquency levels, assigned risk ratings, previous loss experience, current business conditions, amounts and timing of expected future cash flows, and factors particular to a specific commercial credit such as competition, business and management performance. Forward-looking economic assumptions include real gross domestic product, unemployment rate, interest rate curve, and changes in collateral values. This data is aggregated to estimate expected credit losses over the contractual life of the loans and leases, adjusted for expected prepayments. In highly volatile economic environments historical information, such as commercial customer financial statements or consumer credit ratings, may not be as important to estimating future expected losses as forecasted inputs to the models. The ACL may also be affected materially by a variety of qualitative factors that the Company considers to reflect current judgment of various events and risks that are not measured in the statistical procedures including uncertainty related to the economic forecasts used in the modeled credit loss estimates, loan growth, back testing results, credit underwriting policy exceptions, regulatory and audit findings, and peer comparisons. The qualitative allowance is further informed by multiple alternative scenarios to support the period-end ACL balance. The measurement process results in specific or pooled allowances for loans, leases and unfunded lending commitments, and qualitative allowances that are judgmentally determined and applied across the portfolio. There are certain loan portfolios that may not need an econometric model to enable the Company to calculate management’s best estimate of the expected credit losses. Less data intensive, non-modeled approaches to estimating losses are considered more efficient and practical for portfolios that have lower levels of outstanding balances (e.g., runoff or closed portfolios, new products or products that are not significant to the Company’s overall credit risk exposure). Loans and leases that do not share similar risk characteristics are individually assessed for expected credit losses. Nonaccruing commercial and commercial real estate loans with an outstanding balance of $5 million or greater and all commercial and commercial real estate TDRs (regardless of size) are assessed on an individual loan level basis. Generally, the measurement of ACL on individual loans and leases is the present value of its future cash flows or the fair value of its underlying collateral, if the loan or lease is collateral dependent. Loans that are deemed to be collateral dependent are written down to the fair value, less costs to sell, if sale of the collateral is expected as of the evaluation date and are reassessed each subsequent period to determine if a change to the ACL is required. Subsequent evaluations may result in an increase or decrease to the ACL, based on a corresponding change in the fair value of the collateral during the period. Any subsequent decrease to the ACL (because of an increase to the collateral-dependent loan’s fair value) is limited to the total amount previously written off for that loan. For retail TDRs that are not collateral dependent, the ACL is developed using the present value of expected future cash flows compared to the amortized cost basis 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. Expected recoveries are considered in management’s estimate of the ACL and may result in a negative adjustment (i.e., reduction) to the ACL balance. A loan is collateral dependent if repayment is expected to be provided substantially through the operation or sale of the collateral when the borrower is experiencing financial difficulty as of the evaluation date. Generally, repayment would be expected to be provided substantially by the sale or continued operation of the underlying collateral if cash flows to repay the loan from all other available sources (including guarantors) are expected to be no more than nominal. If repayment is dependent only on the operation of the collateral, the fair value of the collateral would not be adjusted for estimated costs to sell. If a loan is considered collateral dependent, the ACL is calculated as the difference between the fair value of collateral (adjusted for the costs to sell if the sale of the collateral is expected) and the amortized cost basis as of the evaluation date. It is possible to have a negative ACL for a collateral dependent loan if the fair value of the collateral increases in a subsequent reporting period. The negative ACL cannot exceed the total amount previously charged off. Accrued interest receivable on loans and leases is excluded from asset balances used to calculate the ACL. All accrued and uncollected interest is immediately reversed against interest income when a loan or lease is placed on nonaccrual status. Uncollectible interest is written off timely in accordance with regulatory guidelines. Generally, loans and leases are 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. Residential mortgages are placed on nonaccrual status when contractually past due 120 days or more, or sooner if deemed collateral dependent, unless guaranteed by the Federal Housing Administration. Loans in COVID-19 pandemic-related forbearance programs continue to accrue interest during the forbearance period; a reserve is established for interest income expected to be uncollectible following forbearance. The amount of accrued interest receivable reversed against interest income for the three months ended September 30, 2020 was $4 million for total commercial and retail, respectively. Accrued interest reversed against interest income for the nine months ended September 30, 2020 was $7 million and $13 million for total commercial and retail, respectively. The Company estimates expected credit losses associated with off-balance sheet financial instruments such as standby letters of credit, financial guarantees and unfunded loan commitments that are not unconditionally cancelable. 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, current and future economic conditions, timing and amount of expected draws, and performance trends within specific portfolio segments, result in the estimate of the reserve for unfunded lending commitments. The Company does not recognize a reserve for future draws from credit lines that are unconditionally cancelable (e.g., credit cards). 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 loan and lease portfolios and the unfunded lending commitments are reported in the Consolidated Statements of Operations as provision for credit losses. The following table presents a summary of changes in the ALLL and the reserve for unfunded lending commitments for the three and nine months ended September 30, 2020 : Three Months Ended September 30, 2020 Nine Months Ended September 30, 2020 (in millions) Commercial Retail Total Commercial Retail Total Allowance for loan and lease losses, beginning of period $1,235 $1,213 $2,448 $674 $578 $1,252 Cumulative effect of change in accounting principle — — — (176 ) 629 453 Allowance for loan and lease losses, beginning of period, adjusted 1,235 1,213 2,448 498 1,207 1,705 Charge-offs (171 ) (86 ) (257 ) (292 ) (319 ) (611 ) Recoveries 1 37 38 7 101 108 Net charge-offs (170 ) (49 ) (219 ) (285 ) (218 ) (503 ) Provision charged to income 224 89 313 1,076 264 1,340 Allowance for loan and lease losses, end of period $1,289 $1,253 $2,542 $1,289 $1,253 $2,542 Reserve for unfunded lending commitments, beginning of period $69 $10 $79 $44 $— $44 Cumulative effective of change in accounting principle — — — (3 ) 1 (2 ) Reserve for unfunded lending commitments, beginning of period, adjusted 69 10 79 41 1 42 Provision for unfunded lending commitments 83 32 115 111 41 152 Reserve for unfunded lending commitments, end of period $152 $42 $194 $152 $42 $194 The following table provides additional detail on the cumulative effect of change in accounting principle on the ACL and related coverage ratios: December 31, 2019 January 1, 2020 September 30, 2020 (in millions) Amortized Cost Basis ACL Balance Coverage Impact of Adoption of CECL ACL Balance Coverage Amortized Cost Basis ACL Balance Coverage Commercial (1) $41,479 $575 1.4 % ($199 ) $376 0.9 % $45,185 $826 1.8 % Commercial real estate 13,522 124 0.9 (57 ) 67 0.5 14,889 548 3.7 Leases 2,537 19 0.7 77 96 3.8 2,288 67 2.9 Total commercial loans and leases 57,538 718 1.2 (179 ) 539 0.9 62,362 1,441 2.3 Residential 19,083 35 0.2 95 130 0.7 19,633 133 0.7 Home equity 13,154 83 0.6 73 156 1.2 12,322 156 1.3 Automobile 12,120 123 1.0 83 206 1.7 12,035 221 1.8 Education 10,347 116 1.1 298 414 4.0 11,631 386 3.3 Other retail 6,846 221 3.2 81 302 4.4 6,088 399 6.6 Total retail loans 61,550 578 0.9 630 1,208 2.0 61,709 1,295 2.1 Total loans and leases $119,088 $1,296 1.1 % $451 $1,747 1.5 % $124,071 $2,736 2.2 % (1) The commercial coverage ratio includes a 21 basis point reduction associated with PPP loans as of September 30, 2020 . The difference in ACL as of September 30, 2020 as compared to December 31, 2019 continues to be driven by the COVID-19 pandemic and associated lockdowns and the resulting economic impacts from March to September 2020, as well as the Company’s adoption of CECL on January 1, 2020. Citizens added $451 million in ACL upon adoption of CECL, and has since added an additional $989 million in the nine months ended September 30, 2020, resulting in an ending ACL balance of $2.7 billion . The increase in commercial net charge-offs in the nine months ended September 30, 2020 as compared to the nine months ended September 30, 2019 was driven by charge-offs in CRE, metals and mining, oil and gas, and casual dining industry sectors. Retail net charge-offs were flat in the nine months ended September 20, 2020 as compared to the nine months ended September 30, 2019. To determine the ACL as of September 30, 2020, Citizens utilized an economic scenario that generally reflects real GDP growth of 4.5% over 2021, returning to fourth quarter 2019 real GDP levels by the first quarter of 2022. The scenario also projects the fourth quarter 2020 unemployment rate to be in the range of 9% to 9.5%, and falling to 7% to 7.5% by the fourth quarter of 2021. While the macroeconomic forecast was slightly improved relative to the second quarter 2020 forecast, Citizens continued to apply management judgment to adjust the modeled reserves in the commercial industry sectors most impacted by the COVID-19-related lockdowns, including in retail and hospitality, casual dining, retail trade, price-sensitive energy and related, and educational services, as well as in certain retail products. The following table presents a summary of changes in the ALLL and the reserve for unfunded lending commitments for the three and nine months ended September 30, 2019 : Three Months Ended September 30, 2019 Nine Months Ended September 30, 2019 (in millions) Commercial Retail Total Commercial Retail Total Allowance for loan and lease losses, beginning of period $680 $547 $1,227 $690 $552 $1,242 Charge-offs (35 ) (124 ) (159 ) (106 ) (347 ) (453 ) Recoveries 3 43 46 17 128 145 Net charge-offs (32 ) (81 ) (113 ) (89 ) (219 ) (308 ) Provision charged to income 64 85 149 111 218 329 Allowance for loan and lease losses, end of period $712 $551 $1,263 $712 $551 $1,263 Reserve for unfunded lending commitments, beginning of period $93 $— $93 $91 $— $91 Provision for unfunded lending commitments (48 ) — (48 ) (46 ) — (46 ) Reserve for unfunded lending commitments, end of period $45 $— $45 $45 $— $45 Credit Quality Indicators Loan and lease portfolio segments and classes, excluding LHFS, are presented by credit quality indicator and vintage year. Citizens defines the vintage date for the purpose of this disclosure as the date of the most recent credit decision. In general, renewals are categorized as new credit decisions and reflect the renewal date as the vintage date. Loans modified in a TDR are considered to be a continuation of the original loan and vintage date corresponds with the initial loan origination date. For commercial loans and leases, Citizens utilizes regulatory classification ratings to monitor credit quality. Regulatory classification ratings are assigned at loan origination and are periodically re-evaluated by Citizens utilizing a risk-based approach, or at any time management becomes aware of information affecting the borrowers' ability to fulfill their obligations. Both quantitative and qualitative factors are considered in this review process. 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. The following table presents the amortized cost basis of commercial loans and leases, by vintage date and regulatory classification rating, as of September 30, 2020 : Term Loans by Origination Year Revolving Loans (in millions) 2020 2019 2018 2017 2016 Prior to 2016 Within the Revolving Period Converted to Term Total Commercial Pass (1) $7,478 $6,823 $4,838 $2,747 $1,515 $2,453 $15,115 $182 $41,151 Special Mention 58 275 237 149 92 222 892 125 2,050 Substandard 60 220 326 100 85 140 630 19 1,580 Doubtful 52 22 35 43 20 42 186 4 404 Total commercial 7,648 7,340 5,436 3,039 1,712 2,857 16,823 330 45,185 Commercial real estate Pass 1,774 3,406 3,608 1,553 825 1,112 1,073 — 13,351 Special Mention 11 216 128 237 171 9 77 — 849 Substandard 68 1 170 50 53 66 60 — 468 Doubtful 20 38 53 — 36 3 24 47 221 Total commercial real estate 1,873 3,661 3,959 1,840 1,085 1,190 1,234 47 14,889 Leases Pass 332 327 265 169 200 917 — — 2,210 Special Mention — 2 3 6 5 25 — — 41 Substandard — 2 2 5 4 — — — 13 Doubtful — — 9 1 3 11 — — 24 Total leases 332 331 279 181 212 953 — — 2,288 Total commercial loans and leases Pass (1) 9,584 10,556 8,711 4,469 2,540 4,482 16,188 182 56,712 Special Mention 69 493 368 392 268 256 969 125 2,940 Substandard 128 223 498 155 142 206 690 19 2,061 Doubtful 72 60 97 44 59 56 210 51 649 Total commercial loans and leases $9,853 $11,332 $9,674 $5,060 $3,009 $5,000 $18,057 $377 $62,362 (1) Includes $4.7 billion of PPP loans designated as pass that are fully guaranteed by the SBA originating in 2020. For retail loans, Citizens utilizes credit scores provided by FICO which are generally refreshed on a quarterly basis and the loan’s payment and delinquency status to monitor credit quality. Management believes FICO credit scores are considered the strongest indicator of credit losses over the contractual life of the loan as the scores are based on current and historical national industry-wide consumer level credit performance data, and assist management in predicting the borrower’s future payment performance. The following table presents the amortized cost basis of retail loans, by vintage date and FICO scores, as of September 30, 2020 : Term Loans by Origination Year Revolving Loans (in millions) 2020 2019 2018 2017 2016 Prior to 2016 Within the Revolving Period Converted to Term Total Residential mortgages 800+ $1,971 $1,983 $751 $1,297 $1,833 $2,061 $— $— $9,896 740-799 2,351 1,341 463 612 776 977 — — 6,520 680-739 596 408 193 207 317 500 — — 2,221 620-679 101 97 44 51 69 235 — — 597 <620 17 23 34 56 54 197 — — 381 No FICO available (1) 4 1 — 1 — 12 — — 18 Total residential mortgages 5,040 3,853 1,485 2,224 3,049 3,982 — — 19,633 Home equity 800+ 3 9 11 7 5 245 4,319 360 4,959 740-799 1 7 7 7 4 204 3,224 340 3,794 680-739 — 4 9 14 8 197 1,671 293 2,196 620-679 — 8 16 19 12 146 420 201 822 <620 1 15 27 30 18 129 117 213 550 No FICO available (1) — — — — — — 1 — 1 Total home equity 5 43 70 77 47 921 9,752 1,407 12,322 Automobile 800+ 780 862 472 358 209 91 — — 2,772 740-799 1,130 1,127 606 406 214 87 — — 3,570 680-739 1,028 1,012 527 327 170 69 — — 3,133 620-679 523 557 300 185 102 46 — — 1,713 <620 90 245 202 157 96 48 — — 838 No FICO available (1) 1 1 — — — 7 — — 9 Total automobile 3,552 3,804 2,107 1,433 791 348 — — 12,035 Education 800+ 1,191 1,276 810 772 586 776 — — 5,411 740-799 1,307 1,151 621 449 292 443 — — 4,263 680-739 385 378 217 160 110 239 — — 1,489 620-679 27 52 42 36 31 108 — — 296 <620 2 7 13 14 12 56 — — 104 No FICO available (1) 6 — — — — 62 — — 68 Total education 2,918 2,864 1,703 1,431 1,031 1,684 — — 11,631 Other retail 800+ 286 474 174 79 17 49 313 — 1,392 740-799 419 611 217 97 23 33 621 2 2,023 680-739 356 409 141 60 13 17 555 6 1,557 620-679 195 156 51 19 3 6 181 7 618 <620 18 45 24 9 2 4 81 9 192 No FICO available (1) 36 1 — — — — 267 2 306 Total other retail 1,310 1,696 607 264 58 109 2,018 26 6,088 Retail 800+ 4,231 4,604 2,218 2,513 2,650 3,222 4,632 360 24,430 740-799 5,208 4,237 1,914 1,571 1,309 1,744 3,845 342 20,170 680-739 2,365 2,211 1,087 768 618 1,022 2,226 299 10,596 620-679 846 870 453 310 217 541 601 208 4,046 <620 128 335 300 266 182 434 198 222 2,065 No FICO available (1) 47 3 — 1 — 81 268 2 402 Total retail $12,825 $12,260 $5,972 $5,429 $4,976 $7,044 $11,770 $1,433 $61,709 (1) Represents loans for which an updated FICO score was unavailable (e.g., due to recent profile changes). Nonaccrual and Past Due Assets The following table presents nonaccrual loans and leases and loans accruing and 90 days or more past due: As of September 30, 2020 As of December 31, 2019 (in millions) Nonaccrual loans and leases 90+ days past due and accruing Nonaccrual with no related ACL Nonaccrual loans and leases Commercial $435 $3 $33 $240 Commercial real estate 323 — 3 2 Leases 2 — — 3 Total commercial loans and leases 760 3 36 245 Residential mortgages 131 17 101 93 Home equity 265 — 192 246 Automobile 80 — 18 67 Education 16 2 5 18 Other retail 25 6 1 34 Total retail 517 25 317 458 Total loans and leases $1,277 $28 $353 $703 Interest income is generally not recognized for loans and leases that are on nonaccrual status. The Company reverses accrued interest receivable with a charge to interest income upon classifying the loan or lease as nonaccrual. The following table presents an analysis of the age of both accruing and nonaccruing loan and lease past due amounts: September 30, 2020 December 31, 2019 Days Past Due Days Past Due (in millions) Current-29 30-59 60-89 90 or More Total Current-29 30-59 60-89 90 or More Total Commercial $44,845 $105 $129 $106 $45,185 $41,340 $45 $27 $67 $41,479 Commercial real estate 14,743 90 — 56 14,889 13,520 1 1 — 13,522 Leases 2,284 1 1 2 2,288 2,498 37 — 2 2,537 Total commercial loans and leases 61,872 196 130 164 62,362 57,358 83 28 69 57,538 Residential mortgages 19,430 64 16 123 19,633 18,947 35 17 84 19,083 Home equity 12,007 51 29 235 12,322 12,834 91 40 189 13,154 Automobile 11,825 147 52 11 12,035 11,788 227 81 24 12,120 Education 11,585 28 12 6 11,631 10,290 30 15 12 10,347 Other retail 6,005 33 22 28 6,088 6,729 45 31 41 6,846 Total retail loans 60,852 323 131 403 61,709 60,588 428 184 350 61,550 Total $122,724 $519 $261 $567 $124,071 $117,946 $511 $212 $419 $119,088 The Company estimates expected credit losses based on the fair value of collateral for collateralized loans that management believes will not be paid under the terms of the original loan contract. These loans are considered to be collateral dependent, and the estimated credit loss is calculated as the difference between the loan’s amortized cost basis and the fair value of the collateral as of each evaluation date. Collateral values for residential mortgage and home equity loans are based on refreshed valuations which are updated at least every 90 days less estimated costs to sell. At September 30, 2020 and December 31, 2019 , the Company had collateral-dependent residential mortgage and home equity loans totaling $489 million and $227 million , respectively. For collateral-dependent commercial loans, the ACL is individually assessed based on the fair value of the collateral. Various types of collateral are used, including real estate, inventory, equipment, accounts receivable, securities and cash, among others. For commercial real estate loans, collateral values are generally based on appraisals which are updated based on management judgment under the specific circumstances on a case-by-case basis. At September 30, 2020 and December 31, 2019 , the Company had collateral-dependent commercial loans totaling $144 million and $85 million , respectively. The amortized cost basis of mortgage loans collateralized by residential real estate property for which formal foreclosure proceedings were in process was $129 million and $152 million as of September 30, 2020 and December 31, 2019 , respectively. Troubled Debt Restructurings TDR is the classification given to a loan that has been restructured in a manner that grants a concession to a borrower experiencing financial hardship that the Company would not otherwise make. Citizens implemented various retail and commercial loan modification programs to provide borrowers relief from the economic impacts of COVID-19. The CARES Act and bank regulatory agencies provided guidance stating certain loan modifications to borrowers experiencing financial distress as a result of COVID-19 may not be accounted for as TDRs under U.S. GAAP. In accordance with the CARES Act, Citizens has elected to not apply TDR classification to any COVID-19 related loan modifications performed after March 1, 2020 for borrowers who were current as of December 31, 2019. In addition, for loans modified in response to the COVID-19 pandemic that are not eligible for relief from TDR classification under the CARES Act, the Company elected to apply the guidance issued by the bank regulatory agencies. Under this guidance, deferral of principal and interest for up to six months to borrowers who were current as of March 1, 2020 and impacted by COVID-19 are not classified as TDRs. For loan modifications that include a payment deferral and are not TDRs, the borrower’s past due and nonaccrual status will not be impacted during the deferral period. Interest income will continue to be recognized over the contractual life of the loan. The following table summarizes TDRs by class and total unfunded commitments: (in millions) September 30, 2020 December 31, 2019 Commercial $294 $297 Retail 715 667 Unfunded commitments related to TDRs 49 42 The following tables below summarize how loans were modified during the three and nine months ended September 30, 2020 and 2019 . The reported balances represent the post-modification outstanding amortized cost basis 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 September 30, 2020 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 — $— 12 $103 2 $1 Commercial real estate — — — — — — Total commercial loans — — 12 103 2 1 Residential mortgages 47 9 41 6 19 4 Home equity 23 2 52 4 104 6 Automobile 25 1 47 — 1,119 18 Education — — — — 140 3 Other retail 410 1 — — 74 — Total retail loans 505 13 140 10 1,456 31 Total 505 $13 152 $113 1,458 $32 Three Months Ended September 30, 2019 Primary Modification Types Interest Rate Reduction (1) Maturity Extension (2) Other (3) (dollars in millions) Number of Contracts Amortized Cost Number of Contracts Amortized Cost Number of Contracts Amortized Cost Commercial 2 $— 6 $1 6 $15 Commercial real estate — — — — — — Total commercial loans 2 — 6 1 6 15 Residential mortgages 12 2 8 2 25 4 Home equity 63 6 16 1 120 6 Automobile 46 1 4 — 309 4 Education — — — — 131 2 Other retail 805 5 — — 218 — Total retail loans 926 14 28 3 803 16 Total 928 $14 34 $4 809 $31 Nine Months Ended September 30, 2020 Primary Modification Types Interest Rate Reduction (1) Maturity Extension (2) Other (3) (dollars in millions) Number of Contracts Amortized Cost Number of Contracts Amortized Cost Number of Contracts Amortized Cost Commercial — $— 18 $106 34 $95 Commercial real estate — — — — — — Total commercial loans — — 18 106 34 95 Residential mortgages 139 26 149 27 60 11 Home equity 96 8 107 8 365 21 Automobile 108 2 48 — 2,212 35 Education — — — — 373 9 Other retail 1,916 8 — — 251 2 Total retail loans 2,259 44 304 35 3,261 78 Total 2,259 $44 322 $141 3,295 $173 Nine Months Ended September 30, 2019 Primary Modification Types Interest Rate Reduction (1) Maturity Extension (2) Other (3) (dollars in millions) Number of Contracts Amortized Cost Number of Contracts Amortized Cost Number of Contracts Amortized Cost Commercial 3 $— 18 $2 24 $102 Commercial real estate — — 1 — — — Total commercial loans 3 — 19 2 24 102 Residential mortgages 25 6 29 5 87 13 Home equity 148 15 66 10 358 21 Automobile 111 2 16 — 933 13 Education — — — — 211 5 Other retail 2,362 14 — — 362 — Total retail loans 2,646 37 111 15 1,951 52 Total 2,649 $37 130 $17 1,975 $154 (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 of loans for the three months ended September 30, 2020 and 2019 was ($30) million and $3 million , respectively. The net change to ALLL resulting from modifications of loans for the nine months ended September 30, 2020 and 2019 was ($21) million and $7 million , respectively. Charge-offs may also be recorded on TDRs. Citizens recorded $43 million and $1 million of charge-offs resulting from modification of loans in the three months ended September 30, 2020 and 2019 , respectively. Citizens recorded $49 million and $3 million for the nine months ended September 30, 2020 and 2019 , respectively. 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 September 30, 2020 and 2019 . For commercial loans, recorded investment in TDRs that defaulted within 12 months of their modification date for the three months ended September 30, 2020 were $14 million and there were none for the three months ended September 30, 2019. There were $53 million and $1 million in the nine months ended September 30, 2020 and 2019 . For retail loans, there were $22 million and $9 million of loans which defaulted within their restructuring date for the three months ended September 30, 2020 and 2019 , respectively, and $47 million and $28 million of loans which defaulted within 12 months of their restructuring date for the nine months ended September 30, 2020 and 2019 , respectively. Concentrations of Credit Risk As of September 30, 2020 , under the Company’s COVID-19-related forbearance and other customer accommodation programs that are guided by the CARES Act as well as banking regulator interagency guidance, Citizens deferred payments on approximately $2.4 billion , or 3.8% , of the retail portfolio, approximately $795 million , or 1.4% , of the commercial portfolio, and approximately $464 million , or 8.1% , of the Business Banking portfolio. The vast majority of these deferrals are not classified as TDRs. Most of the Company’s lending activity is with customers located in the New England, Mid-Atlantic and Midwest regions. Generally, loans are collateralized by assets including real estate, inventory, accounts receivable, other personal property and investment securities. As of September 30, 2020 and December 31, 2019 , 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 c

MORTGAGE BANKING

MORTGAGE BANKING	9 Months Ended
	Sep. 30, 2020
Mortgage Banking [Abstract]
MORTGAGE BANKING	NOTE 5 - MORTGAGE BANKING AND OTHER The Company sells residential mortgages to GSEs and other parties, who may issue securities backed by pools of such loans. The Company retains no beneficial interests in these sales, but may retain the servicing rights for the loans sold. The Company is obligated to subsequently repurchase a loan if the purchaser discovers a representation or warranty violation such as noncompliance with eligibility or servicing requirements, or customer fraud that should have been identified in a loan file review. The 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. The following table summarizes activity related to residential mortgage loans sold with servicing rights retained: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Cash proceeds from residential mortgage loans sold with servicing retained $9,504 $6,117 $23,668 $13,265 Gain on sales (1) 273 88 699 180 Contractually specified servicing, late and other ancillary fees (1) 56 53 169 152 (1) Reported in mortgage banking fees on the Consolidated Statements of Operations. Effective January 1, 2020, the Company elected to account for all MSRs previously accounted for under the amortization method under the fair value method. Under the fair value method, MSRs are recorded at fair value at each reporting date with any changes in fair value during the period recorded in mortgage banking fees in the Consolidated Statements of Operations. The unpaid principal balance of the related residential mortgage loans was $80.7 billion and $77.5 billion as of September 30, 2020 and December 31, 2019 , respectively. The Company manages an active hedging strategy to manage the risk associated with changes in the value of the MSR portfolio, which includes the purchase of freestanding derivatives. The following table summarizes changes in MSRs recorded using the fair value method: As of and for the Three Months Ended September 30, As of and for the Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Fair value as of beginning of the period $568 $531 $642 $600 Transfers upon election of fair value method — — 190 — Fair value as of beginning of the period, adjusted 568 531 832 600 Amounts capitalized 85 78 238 170 Changes in unpaid principal balance during the period (1) (55 ) (31 ) (141 ) (88 ) Changes in fair value during the period (2) 8 (68 ) (323 ) (172 ) Fair value at end of the period $606 $510 $606 $510 (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 key economic assumptions and the decline in fair value if the respective adverse change was realized. These sensitivities are hypothetical, with the effect of a variation in a particular assumption on the fair value of the MSRs 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 largely dependent upon movements in market interest rates. September 30, 2020 December 31, 2019 Actual Decline in fair value due to Actual Decline in fair value due to (dollars in millions) Fair value $606 50 bps adverse change 100 bps adverse change $642 50 bps adverse change 100 bps adverse change Weighted average life (in years) 3.8 5.5 Weighted average constant prepayment rate 19.4% $116 $169 13.9% $116 $222 Weighted average option adjusted spread 608 bps 10 21 440 bps 12 25 Citizens accounts for derivatives in its mortgage banking operations at fair value on the Consolidated Balance Sheets 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 9 for additional information. Other Serviced Loans From time to time, Citizens engages in other servicing relationships. The following table presents the unpaid principal balance of other serviced loans: (in millions) September 30, 2020 December 31, 2019 Education (1) $866 $— Commercial (2) 44 33 (1) Represents the servicing associated with education loans sold. See Note 7 for further information. (2) Represents the government guaranteed portion of SBA loans sold to outside investors.

GOODWILL

GOODWILL	9 Months Ended
	Sep. 30, 2020
Goodwill and Intangible Assets Disclosure [Abstract]
GOODWILL	NOTE 6 - GOODWILL Goodwill is the purchase premium associated with the acquisition of a business and is assigned to the Company’s reporting units at the acquisition date. A reporting unit is a business operating segment or a component of a business operating segment. Citizens has identified and assigned 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. 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. Goodwill is not amortized, but is subject to annual impairment tests. Citizens reviews goodwill for impairment annually as of October 31 st and in interim periods when events or changes indicate the carrying value of one or more reporting units may not be recoverable. The Company has the option of performing a qualitative assessment of goodwill to determine whether it is more likely than not that the fair value of each reporting unit is less than the carrying value. If it is more likely than not that the fair value exceeds the carrying value, then no further testing is necessary; otherwise, Citizens must perform a quantitative assessment of goodwill. Citizens may elect to bypass the qualitative assessment and perform a quantitative assessment. The quantitative assessment, 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 inclusive of goodwill, applicable goodwill is deemed to be not impaired. If the carrying value of the reporting unit inclusive of goodwill exceeds its fair value, an impairment charge is recorded for the excess. The impairment loss recognized cannot exceed the amount of goodwill assigned to the reporting unit, and the loss establishes a new basis in the goodwill. Subsequent reversal of goodwill impairment losses is not permitted. Under the quantitative impairment assessment, 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. In the first quarter of 2020, U.S. economic conditions deteriorated significantly with the spread of the COVID-19 pandemic and associated lockdowns. In response to the crises and the ongoing impacts to the banking industry and markets in which Citizens operates, the Company performed a quantitative goodwill impairment assessment in the third quarter 2020. When calculating the fair value of the Company’s reporting units under the income approach, short and medium-term forecasts incorporated current economic conditions and ongoing impacts of the COVID-19 pandemic, including a federal funds target near zero and near-term elevated ACL, offset by significant monetary and fiscal stimulus. Long-term cash flow projections reflected normalized rate and credit environments, as well as a long-term rate of return for each reporting unit. At the conclusion of the quantitative assessment it was determined that the estimated fair value of the Commercial Banking reporting unit exceeded its carrying amount by approximately 5%, and that of the Consumer Banking reporting unit substantially exceeded its carrying value. The change in the carrying value of goodwill for the nine months ended September 30, 2020 is presented below: (in millions) Consumer Banking Commercial Banking Total Balance at December 31, 2019 $2,258 $4,786 $7,044 Business acquisitions — 6 6 Balance at September 30, 2020 $2,258 $4,792 $7,050 Accumulated impairment losses related to the Consumer Banking reporting unit totaled $5.9 billion at September 30, 2020 and December 31, 2019 . The accumulated impairment losses related to the Commercial Banking reporting unit totaled $50 million at September 30, 2020 and December 31, 2019 . No impairment was recorded for the three and nine months ended September 30, 2020 or 2019 .

VARIABLE INTEREST ENTITIES

VARIABLE INTEREST ENTITIES	9 Months Ended
	Sep. 30, 2020
Equity Method Investments and Joint Ventures [Abstract]
VARIABLE INTEREST ENTITIES	NOTE 7 - VARIABLE INTEREST ENTITIES Citizens 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 or asset-backed securities, and lending to special purpose entities. Citizens’ maximum exposure to loss as a result of its involvement with these entities is limited to the balance sheet carrying amount of its investment in equity and asset-backed securities, unfunded commitments, and outstanding principal balance of loans to special purpose entities. A summary of these investments is presented below: (in millions) September 30, 2020 December 31, 2019 Lending to special purpose entities included in loans and leases $1,173 $1,101 LIHTC investment included in other assets 1,543 1,401 LIHTC unfunded commitments included in other liabilities 810 716 Investment in asset-backed securities included in AFS securities 813 — Renewable energy investments included in other assets 410 355 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 September 30, 2020 and December 31, 2019 , the lending facilities had aggregate unpaid principal balances of $1.2 billion and $1.1 billion , respectively, and undrawn commitments to extend credit of $1.3 billion and $1.2 billion , respectively. 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, Citizens 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: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Tax credits included in income tax expense $40 $30 $120 $99 Amortization expense included in income tax expense 42 33 127 105 Other tax benefits included in income tax expense 10 8 30 24 No LIHTC investment impairment losses were recognized three and nine months ended September 30, 2020 and 2019 , respectively. Asset-backed securities In September 2020, Citizens sold $973 million of education loans, inclusive of accrued interest, capitalized interest and fees, to a third-party sponsored VIE. As part of this sale, the Company recognized a gain on sale of $32 million in other income. The Company provided financing to the purchaser for a portion of the sale price in the form of $813 million of asset-backed securities collateralized by the sold assets. Citizens will continue to act as primary servicer for the sold educational loans, and will receive a servicing fee. A third-party special servicer will be responsible for servicing for all loans that become significantly delinquent, as discussed below. At the time of the sale, and at each subsequent reporting period, Citizens is required to evaluate its involvement with the VIE to determine if it holds a variable interest in the VIE and, if so, if the Company is the primary beneficiary of the VIE. If Citizens is both a variable interest holder and the primary beneficiary of the VIE it would be required to consolidate the VIE. As of September 30, 2020, the Company concluded that both their investment in asset-backed securities as well as the primary servicing fee are considered variable interests in the VIE as there is a possibility, even if remote, that would result in either the Company’s interest in the asset-backed securities or the primary servicing fee absorbing some of the losses of the VIE. After concluding that the Company has one or more variable interests in the VIE, the Company must determine if the Company is the primary beneficiary of the VIE. GAAP defines the primary beneficiary as the entity that has both an economic exposure to the VIE as well as the power to direct the activities that are determined to be most significant to the economic performance of the VIE. In order to make this determination, the Company needed to first establish which activities are the most significant to the economic performance of the VIE. Based on a review of the historical performance of the types of education loans sold to the VIE, as well as consideration of which activities performed by the owner or servicer of the loans contribute most significantly to the ultimate performance of the loans, the Company concluded that the determination of the assets to be purchased by the VIE and the servicing activities that are performed for significantly delinquent loans are the activities that most significantly impact the performance of the loans, and thus the performance of the VIE holding these assets. As a result, the Company concluded that the entity that controls the determination of the assets to be purchased by the VIE and the servicing activities on significantly delinquent loans controls the activities that most significantly impact the economic performance of the VIE. As part of the sale process, the equity holder in the VIE had the ability to remove loans from the proposed sale pool, demonstrating control over the determination of the assets to be purchased. In addition, as a holder of asset-backed securities and the primary servicer of the loans, Citizens does not have the power to direct servicing of significantly delinquent loans. These rights are reserved for the third-party special servicer of the loans, who is controlled through a contractual relationship with the equity investor in the VIE. As the activities which most significantly affect the performance of the VIE are controlled by the equity holder in the VIE, and not by Citizens, the Company has concluded that Citizens is therefore not the primary beneficiary. Accordingly, Citizens does not consolidate the VIE and accounts for its investment in AFS asset-backed securities on the Consolidated Balance Sheets. 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.

BORROWED FUNDS

BORROWED FUNDS	9 Months Ended
	Sep. 30, 2020
Debt Disclosure [Abstract]
BORROWED FUNDS	NOTE 8 - BORROWED FUNDS Short-term borrowed funds Short-term borrowed funds were $252 million and $274 million as of September 30, 2020 and December 31, 2019 , respectively. Long-term borrowed funds The following table presents a summary of the Company’s long-term borrowed funds: (in millions) September 30, 2020 December 31, 2019 Parent Company: 2.375% fixed-rate senior unsecured debt, due July 2021 $350 $349 4.150% fixed-rate subordinated debt, due September 2022 (1) 181 348 3.750% fixed-rate subordinated debt, due July 2024 (1) 159 250 4.023% fixed-rate subordinated debt, due October 2024 (1) 25 42 4.350% fixed-rate subordinated debt, due August 2025 (1) 193 249 4.300% fixed-rate subordinated debt, due December 2025 (1) 450 750 2.850% fixed-rate senior unsecured notes, due July 2026 497 496 2.500% fixed-rate senior unsecured notes, due February 2030 297 — 3.250% fixed-rate senior unsecured notes, due April 2030 745 — 2.638% fixed-rate subordinated debt, due September 2032 (1) 542 — CBNA’s Global Note Program: 2.250% senior unsecured notes, due March 2020 — 700 2.678% floating-rate senior unsecured notes, due March 2020 (2) — 300 2.217% floating-rate senior unsecured notes, due May 2020 (2) — 250 2.200% senior unsecured notes, due May 2020 — 500 2.250% senior unsecured notes, due October 2020 750 750 2.550% senior unsecured notes, due May 2021 1,005 991 3.250% senior unsecured notes, due February 2022 720 711 0.985% floating-rate senior unsecured notes, due February 2022 (2) 299 299 1.044% floating-rate senior unsecured notes, due May 2022 (2) 250 250 2.650% senior unsecured notes, due May 2022 512 501 3.700% senior unsecured notes, due March 2023 530 515 1.168% floating-rate senior unsecured notes, due March 2023 (2) 249 249 2.250% senior unsecured notes, due April 2025 745 — 3.750% senior unsecured notes, due February 2026 555 521 Additional Borrowings by CBNA and Other Subsidiaries: Federal Home Loan Bank advances, 0.943% weighted average rate, due through 2038 19 5,008 Other 36 18 Total long-term borrowed funds $9,109 $14,047 (1) September 30, 2020 balances reflect the September 2020 completion of (i) $621 million in private exchange offers for five series of outstanding subordinated notes whereby participants received a combination of the Company’s newly issued 2.638% fixed-rate subordinated notes due 2032 and an additional cash payment and (ii) $11 million in related cash tender offers whereby validly tendered and accepted subordinated notes were purchased by Citizens and subsequently cancelled. (2) Rate disclosed reflects the floating rate as of September 30, 2020 or final rate, as applicable. The Parent Company’s long-term borrowed funds as of September 30, 2020 and December 31, 2019 included principal balances of $3.5 billion and $2.5 billion , respectively, and unamortized deferred issuance costs and/or discounts of ($92) million and ($8) million , respectively. CBNA and other subsidiaries’ long-term borrowed funds as of September 30, 2020 and December 31, 2019 included principal balances of $5.6 billion and $11.5 billion , respectively, with unamortized deferred issuance costs and/or discounts of ($13) million and ($13) million , respectively, and hedging basis adjustments of $128 million and $50 million , respectively. See Note 9 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 $3.7 billion and $9.8 billion at September 30, 2020 and December 31, 2019 , respectively. The Company’s available FHLB borrowing capacity was $13.2 billion and $7.2 billion at September 30, 2020 and December 31, 2019 , 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 September 30, 2020 , the Company’s unused secured borrowing capacity was approximately $61.7 billion , which includes unencumbered securities, FHLB borrowing capacity, and FRB discount window capacity. The following table presents a summary of maturities for the Company’s long-term borrowed funds at September 30, 2020 : (in millions) Parent Company CBNA and Other Subsidiaries Consolidated Year 2020 $— $752 $752 2021 350 1,014 1,364 2022 181 1,790 1,971 2023 — 780 780 2024 184 — 184 2025 and thereafter 2,724 1,334 4,058 Total $3,439 $5,670 $9,109

DERIVATIVES

DERIVATIVES	9 Months Ended
	Sep. 30, 2020
Derivative Instruments and Hedging Activities Disclosure [Abstract]
DERIVATIVES	NOTE 9 - DERIVATIVES In the normal course of business, Citizens enters into a variety of derivative transactions 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 TBAs, forward sale contracts and purchase options. The Company does not use derivatives for speculative purposes. The Company’s derivative instruments are recognized on the Consolidated Balance Sheets in derivative assets and derivative liabilities 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 in the Company’s 2019 Form 10-K. Derivative assets and derivative liabilities are netted by counterparty on the Consolidated Balance Sheets 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 master netting agreement. The following table presents derivative instruments included on the Consolidated Balance Sheets: September 30, 2020 December 31, 2019 (in millions) Notional Amount (1) Derivative Assets Derivative Liabilities Notional Amount (1) Derivative Assets Derivative Liabilities Derivatives designated as hedging instruments: Interest rate contracts $26,800 $4 $1 $29,846 $1 $— Derivatives not designated as hedging instruments: Interest rate contracts 148,161 1,761 216 142,386 772 133 Foreign exchange contracts 16,448 239 189 15,101 174 166 TBA contracts 13,161 7 34 — — — Other contracts 8,011 275 66 6,868 37 23 Total derivatives not designated as hedging instruments 2,282 505 983 322 Gross derivative fair values 2,286 506 984 322 Less: Gross amounts offset in the Consolidated Balance Sheets (2) (187 ) (187 ) (107 ) (107 ) Less: Cash collateral applied (2) (69 ) (219 ) (70 ) (95 ) Total net derivative fair values presented in the Consolidated Balance Sheets $2,030 $100 $807 $120 (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. (2) Amounts represent the impact of enforceable master netting agreements that allow the Company to net settle positive and negative positions. The Company’s derivative transactions are internally divided into three sub-groups: institutional, customer and residential loan. Certain derivative transactions within these sub-groups are designated as fair value or cash flow hedges, as described below: Derivatives Designated As Hedging Instruments The Company’s institutional derivatives qualify for hedge accounting treatment. The net interest accruals on interest rate swaps designated in a fair value or cash flow hedge relationship are treated as an adjustment to interest income or interest expense of the item being hedged. The Company formally documents at inception all hedging relationships, as well as risk management objectives and strategies for undertaking various accounting hedges. Additionally, the Company monitors the effectiveness of its hedge relationships during the duration of the hedge period. The methods utilized to assess hedge effectiveness vary based on hedge relationship and the Company monitors each relationship to ensure that management’s initial intent continues to be satisfied. 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 subsequently reflects changes in the fair value of the derivative in earnings after termination of the hedge relationship. Fair Value Hedges In a fair value hedge, changes in the fair value of both the derivative instrument and the hedged asset or liability attributable to the risk being hedged are recognized in the same income statement line item in the Consolidated Statements of Operations when the changes in fair value occur. Citizens has outstanding interest rate swap agreements utilized to manage the interest rate exposure on its long-term borrowings and AFS debt securities. In March 2020 the fair value hedge of certain fixed rate residential mortgages was terminated due to a portion of the hedged item being sold. Certain fair value hedges have been designated as a last-of-layer hedge, which affords the Company the ability to execute a fair value hedge of the interest rate risk associated with a portfolio of similar pre-payable assets whereby the last dollar amount estimated to remain in the portfolio of assets is identified as the hedged item. The following table presents the change in fair value of interest rate contracts, designated as fair value hedges, as well as the change in fair value of the related hedged items attributable to the risk being hedged, included in the Consolidated Statements of Operations: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Affected Line Item in the Consolidated Statements of Operations Interest rate swaps hedging borrowed funds ($16 ) $18 $82 $122 Interest expense - borrowed funds Hedged long-term debt attributable to the risk being hedged 17 (18 ) (78 ) (121 ) Interest expense - borrowed funds Interest rate swaps hedging fixed rate loans — (10 ) 17 (26 ) Interest and fees on loans and leases Hedged fixed rate loans attributable to the risk being hedged — 10 (17 ) 26 Interest and fees on loans and leases Interest rate swaps hedging debt securities available for sale 7 (13 ) (114 ) (13 ) Interest income - investment securities Hedged debt securities available for sale attributable to risk being hedged (7 ) 13 114 13 Interest income - investment securities The following table reflects amounts recorded on the Consolidated Balance Sheets related to cumulative basis adjustments for fair value hedges: September 30, 2020 December 31, 2019 (in millions) Debt securities available for sale (1) Long-term borrowed funds Debt securities available for sale (1) Residential mortgages Long-term borrowed funds Carrying amount of hedged assets $12,314 $— $15,798 $976 $— Carrying amount of hedged liabilities — 4,072 — — 4,689 Cumulative amount of fair value hedging adjustments included in the carrying amount of the hedged items 107 128 (8 ) 17 50 (1) The Company designated $2.0 billion as the hedged amount (from a closed portfolio of prepayable financial assets with a carrying value of $12.3 billion and $15.8 billion at September 30, 2020 and December 31, 2019, respectively) in a last-of-layer hedging relationship, which commenced in the third quarter of 2019. Cash Flow Hedges In a cash flow hedge, the entire change in the fair value of the interest rate swap included in the assessment of hedge effectiveness is initially recorded in OCI and is subsequently reclassified from OCI to current period earnings (interest income or interest expense) in the same period that the hedged item affects earnings. Citizens has outstanding interest rate swap agreements designed to hedge a portion of the Company’s floating rate assets and liabilities. All of these swaps have been deemed highly effective cash flow hedges. During the next 12 months, there are $2 million in pre-tax net gains on derivative instruments included in OCI expected to be reclassified to net interest income in the Consolidated Statements of Operations. This amount could differ from amounts actually recognized due to changes in interest rates, hedge de-designations, and the addition of other hedges subsequent to September 30, 2020 . The following table presents the pre-tax net gains (losses) recorded in the Consolidated Statements of Operations and in the Consolidated Statements of Comprehensive Income relating to derivative instruments designated as cash flow hedges: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Amount of pre-tax net (losses) gains recognized in OCI $— ($5 ) $118 $138 Amount of pre-tax net gains (losses) reclassified from OCI into interest income 68 (22 ) 128 (62 ) Amount of pre-tax net (losses) gains reclassified from OCI into interest expense (11 ) 8 (22 ) 9 Derivatives Not Designated As Hedging Instruments Economic Hedges The Company’s economic hedges include those related to offsetting customer derivatives, residential mortgage loan derivatives (including interest rate lock commitments and forward sales commitments) and derivatives to hedge its residential MSR portfolio. Customer derivatives include interest rate and foreign exchange derivative contracts designed to meet the hedging and financing needs of the Company’s customers, and are economically hedged by the Company to offset its market exposure. Interest rate lock commitments on residential mortgage loans that will be held for sale are considered derivative instruments, and are economically hedged by entering into forward sale commitments to manage changes in fair value due to interest rate risk. Residential MSR portfolio derivatives are entered to hedge the risk of changes in the fair value of the Company’s MSR asset. The following table presents the effect of economic hedges on noninterest income: Amounts Recognized in Noninterest Income for the Three Months Ended September 30, Nine Months Ended September 30, Affected Line Item in the Consolidated Statements of Operations (in millions) 2020 2019 2020 2019 Economic hedge type: Customer interest rate contracts $7 $196 $1,276 $850 Foreign exchange and interest rate products Customer foreign exchange contracts 80 (81 ) 73 (162 ) Foreign exchange and interest rate products Derivative transactions to hedge interest rate risk 1 (182 ) (1,245 ) (809 ) Foreign exchange and interest rate products Derivative transactions to hedge foreign exchange risk (126 ) 130 (77 ) 224 Foreign exchange and interest rate products Residential loan commitments 36 6 190 22 Mortgage banking fees Derivative contracts used to hedge residential loan commitments 6 29 (13 ) 24 Mortgage banking fees Derivative contracts used to hedge residential MSRs 2 92 335 208 Mortgage banking fees Other derivative contracts 26 — (30 ) — Foreign exchange and interest rate products Derivative transactions to hedge other derivative risk (25 ) — 32 — Foreign exchange and interest rate products Total $7 $190 $541 $357

ACCUMULATED OTHER COMPREHENSIVE

ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS)	9 Months Ended
	Sep. 30, 2020
Equity [Abstract]
ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS)	NOTE 10 - ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS) The following table presents the changes in the balances, net of income taxes, of each component of AOCI: As of and for the Three Months Ended September 30, (in millions) Net Unrealized (Losses) Gains on Derivatives Net Unrealized (Losses) Gains on Debt Securities Employee Benefit Plans Total AOCI Balance at July 1, 2019 ($6 ) ($25 ) ($457 ) ($488 ) Other comprehensive income before reclassifications (4 ) 42 — 38 Other-than-temporary impairment not recognized in earnings on debt securities — (1 ) — (1 ) Amounts reclassified to the Consolidated Statements of Operations 10 (2 ) 3 11 Net other comprehensive income 6 39 3 48 Balance at September 30, 2019 $— $14 ($454 ) ($440 ) Balance at July 1, 2020 $54 $448 ($408 ) $94 Other comprehensive (loss) income before reclassifications — (44 ) — (44 ) Amounts reclassified to the Consolidated Statements of Operations (42 ) (1 ) 3 (40 ) Net other comprehensive (loss) income (42 ) (45 ) 3 (84 ) Balance at September 30, 2020 $12 $403 ($405 ) $10 Primary location of amounts reclassified to the Consolidated Statements of Operations Net interest income Securities gains, net Other operating expense As of and for the Nine Months Ended September 30, (in millions) Net Unrealized (Losses) Gains on Derivatives Net Unrealized (Losses) Gains on Debt Securities Employee Benefit Plans Total AOCI Balance at January 1, 2019 ($143 ) ($490 ) ($463 ) ($1,096 ) Other comprehensive income before reclassifications 103 509 — 612 Amounts reclassified to the Consolidated Statements of Operations 40 (10 ) 9 39 Net other comprehensive income 143 499 9 651 Cumulative effect of change in accounting principle — 5 — 5 Balance at September 30, 2019 $— $14 ($454 ) ($440 ) Balance at January 1, 2020 $3 $1 ($415 ) ($411 ) Other comprehensive income before reclassifications 88 405 — 493 Amounts reclassified to the Consolidated Statements of Operations (79 ) (3 ) 10 (72 ) Net other comprehensive income 9 402 10 421 Balance at September 30, 2020 $12 $403 ($405 ) $10 Primary location of amounts reclassified to the Consolidated Statements of Operations Net interest income Securities gains, net Other operating expense

STOCKHOLDERS' EQUITY

STOCKHOLDERS' EQUITY	9 Months Ended
	Sep. 30, 2020
Equity [Abstract]
STOCKHOLDERS' EQUITY	NOTE 11 - STOCKHOLDERS’ EQUITY Preferred Stock The following table summarizes the Company’s preferred stock: September 30, 2020 December 31, 2019 (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 1,000 300,000 296 300,000 296 Series C 1,000 300,000 297 300,000 297 Series D 1,000 (1) 300,000 (2) 293 300,000 293 Series E 1,000 (1) 450,000 (3) 437 450,000 437 Series F 1,000 400,000 395 — — Total 2,000,000 $1,965 1,600,000 $1,570 (1) Equivalent to $25 per depositary share. (2) Represented by 12,000,000 depositary shares each representing a 1/40th interest in the Series D Preferred Stock. (3) Represented by 18,000,000 depositary shares each representing a 1/40th interest in the Series E Preferred Stock. For further detail regarding the terms and conditions of the Company’s preferred stock, see Note 16 to the Company’s Consolidated Financial Statements in the 2019 Form 10-K and Note 11 to the Company’s Quarterly Report on Form 10-Q for the period ended June 30, 2020. 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: Three Months Ended September 30, 2020 Three Months Ended September 30, 2019 (in millions, except per share data) Dividends Declared per Share Dividends Declared Dividends Paid Dividends Declared per Share Dividends Declared Dividends Paid Common stock $0.39 $168 $168 $0.36 $162 $162 Preferred stock Series A $10.90 $3 $3 $27.50 $7 $— Series B — — 9 — — 9 Series C 15.94 4 5 15.94 5 4 Series D 15.88 4 5 15.88 5 5 Series E 12.50 6 6 — — — Series F 19.15 8 — — — — Total preferred stock $25 $28 $17 $18 Nine Months Ended September 30, 2020 Nine Months Ended September 30, 2019 (in millions, except per share and share data) Dividends Declared per Share Dividends Declared Dividends Paid Dividends Declared per Share Dividends Declared Dividends Paid Common stock $1.17 $504 $504 $1.00 $459 $459 Preferred stock Series A $51.88 $13 $10 $55.00 $14 $7 Series B 30.00 9 18 30.00 9 20 Series C 47.81 14 15 47.81 14 13 Series D 47.63 14 15 43.57 13 8 Series E 37.50 17 15 — — — Series F 19.15 8 — — — — Total preferred stock $75 $73 $50 $48 Treasury Stock During the nine months ended September 30, 2020 , the Company repurchased $270 million , or 7,548,655 shares, of its outstanding common stock, which are held in treasury stock. On March 16, 2020, the Company announced it would suspend all share repurchase activity through June 30, 2020. On April 17, 2020, the Company extended this suspension through December 31, 2020.

COMMITMENTS AND CONTINGENCIES

COMMITMENTS AND CONTINGENCIES	9 Months Ended
	Sep. 30, 2020
Commitments and Contingencies Disclosure [Abstract]
COMMITMENTS AND CONTINGENCIES	NOTE 12 - COMMITMENTS AND CONTINGENCIES A summary of outstanding off-balance sheet arrangements is presented below. For more information on these arrangements, see Note 18 in the Company’s 2019 Form 10-K. (in millions) September 30, 2020 December 31, 2019 Commitments to extend credit $73,173 $72,743 Letters of credit 2,132 2,190 Risk participation agreements 103 37 Loans sold with recourse 48 37 Marketing rights 29 33 Total $75,485 $75,040 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. The Company’s commercial loan trading desk provides ongoing secondary market support and liquidity to its clients. Unsettled loan trades (e.g., loan purchase contracts) represent firm commitments to purchase or sell loans from / to 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. The principal balances of unsettled commercial loan trade purchases and sales were $69 million and $143 million , respectively, at September 30, 2020 and $ 183 million and $236 million , respectively, at December 31, 2019 . 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). 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. 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. Standby letters of credit and commercial letters of credit are issued for terms of up to ten years and one year , respectively. Other Commitments Citizens has additional off-balance sheet arrangements that are summarized below: • Marketing Rights - During 2003, Citizens entered into a 25 -year agreement to acquire the naming and marketing rights of a baseball stadium in Pennsylvania. • 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 GSEs. 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. The Company also sells the government guaranteed portion of certain SBA loans to outside investors, for which it retains the servicing rights. • 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. The current amount of credit exposure is spread out over 84 counterparties. RPAs generally have terms ranging from one year to five years ; however, certain outstanding agreements have terms as long as nine years . Contingencies The Company operates in a legal and regulatory environment that exposes it to potentially significant risks. A certain amount of litigation ordinarily results from the nature of the Company’s banking and other businesses. The Company is a party to legal proceedings, including class actions. The Company is also the subject of investigations, reviews, subpoenas, and regulatory matters arising out of its normal business operations, which, in some instances, relate to concerns about fair lending, unfair and/or deceptive practices, mortgage-related issues, and mis-selling of certain products. In addition, the Company engages in discussions with relevant governmental and regulatory authorities on a regular and ongoing basis regarding various issues, and any issues discussed or identified may result in investigatory or other action being taken. Litigation and regulatory matters may result in settlements, damages, fines, penalties, public or private censure, increased costs, required remediation, restrictions on business activities, or other impacts on the Company. In these disputes and proceedings, the Company contests liability and the amount of damages as appropriate. Given their complex nature, and based on the Company's experience, it may be years before some of these matters are finally resolved. Moreover, before liability can be reasonably estimated for a claim, numerous legal and factual issues may need to be examined, including through potentially lengthy discovery and determination of important factual matters, and by addressing novel or unsettled legal issues relevant to the proceedings in question. The Company cannot predict with certainty if, how, or when such claims will be resolved or what the eventual settlement, fine, penalty or other relief, if any, may be, particularly for claims that are at an early stage in their development or where claimants seek substantial or indeterminate damages. The Company recognizes a provision for a claim when, in the opinion of management after seeking legal advice, it is probable that a liability exists and the amount of loss can be reasonably estimated. In many proceedings, however, it is not possible to determine whether any loss is probable or to estimate the amount of any loss. Based on information currently available, the advice of legal counsel and other advisers, and established reserves, management believes that the aggregate liabilities, if any, potentially arising from these proceedings will not have a materially adverse effect on the Company’s unaudited interim Consolidated Financial Statements.

FAIR VALUE MEASUREMENTS

FAIR VALUE MEASUREMENTS	9 Months Ended
	Sep. 30, 2020
Fair Value Disclosures [Abstract]
FAIR VALUE MEASUREMENTS	NOTE 13 - 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 LHFS and certain commercial and commercial real estate LHFS at fair value. September 30, 2020 December 31, 2019 (in millions) Aggregate Fair Value Aggregate Unpaid Principal Aggregate Fair Value Greater (Less) Aggregate Unpaid Principal Aggregate Fair Value Aggregate Unpaid Principal Aggregate Fair Value Greater (Less) Aggregate Unpaid Principal Residential mortgage loans held for sale, at fair value $3,425 $3,256 $169 $1,778 $1,727 $51 Commercial and commercial real estate loans held for sale, at fair value 162 172 (10 ) 168 175 (7 ) For more information on the election of the fair value option for these assets see Note 19 in the Company’s 2019 Form 10-K. The following table presents the changes in fair value for assets where the Company has elected the fair value option: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Affected Line Item in the Consolidated Statements of Operations Residential mortgage loans held for sale, at fair value $46 ($4 ) $149 $5 Mortgage banking fees Commercial and commercial real estate loans held for sale, at fair value 6 — (2 ) 4 Capital market fees Recurring Fair Value Measurements Citizens utilizes a variety of valuation techniques to measure its assets and liabilities at fair value on a recurring basis. For more information on the valuation techniques utilized to measure recurring fair value see Note 19 in the Company’s 2019 Form 10-K. Asset-backed securities The fair value of securities backed by education loans is estimated using observable inputs, including prices of similar securities that transact in the marketplace and current market assumptions related to yield, as well as unobservable inputs, including expected conditional default rates and prepayment speed estimates. Therefore, the Company classifies these asset-backed securities in Level 3 of the fair value hierarchy given the use of unobservable inputs. Forward commitments to sell to-be-announced mortgage securities The fair value of TBAs is estimated using observable prices of similar loan pools that transact in the marketplace, as well as sector curves and benchmarking techniques. Therefore, the Company classifies TBAs in Level 2 of the fair value hierarchy given the observable market inputs. The following table presents assets and liabilities measured at fair value, including gross derivative assets and liabilities on a recurring basis at September 30, 2020 : (in millions) Total Level 1 Level 2 Level 3 Debt securities available for sale: Mortgage-backed securities $22,056 $— $22,056 $— Asset-backed securities 813 — — 813 State and political subdivisions 4 — 4 — U.S. Treasury and other 11 11 — — Total debt securities available for sale 22,884 11 22,060 813 Loans held for sale, at fair value: Residential loans held for sale 3,425 — 3,425 — Commercial loans held for sale 162 — 162 — Total loans held for sale, at fair value 3,587 — 3,587 — Mortgage servicing rights 606 — — 606 Derivative assets: Interest rate contracts 1,765 — 1,765 — Foreign exchange contracts 239 — 239 — TBA contracts 7 — 7 — Other contracts 275 — 66 209 Total derivative assets 2,286 — 2,077 209 Equity securities, at fair value: Money market mutual fund investments 57 57 — — Total equity securities, at fair value 57 57 — — Total assets $29,420 $68 $27,724 $1,628 Derivative liabilities: Interest rate contracts $217 $— $217 $— Foreign exchange contracts 189 — 189 — TBA contracts 34 — 34 — Other contracts 66 — 66 — Total derivative liabilities 506 — 506 — Total liabilities $506 $— $506 $— The following table presents assets and liabilities measured at fair value, including gross derivative assets and liabilities on a recurring basis at December 31, 2019 : (in millions) Total Level 1 Level 2 Level 3 Debt securities available for sale: Mortgage-backed securities $20,537 $— $20,537 $— State and political subdivisions 5 — 5 — U.S. Treasury and other 71 71 — — Total debt securities available for sale 20,613 71 20,542 — Loans held for sale, at fair value: Residential loans held for sale 1,778 — 1,778 — Commercial loans held for sale 168 — 168 — Total loans held for sale, at fair value 1,946 — 1,946 — Mortgage servicing rights 642 — — 642 Derivative assets: Interest rate contracts 773 — 773 — Foreign exchange contracts 174 — 174 — Other contracts 37 — 18 19 Total derivative assets 984 — 965 19 Equity securities, at fair value: Money market mutual fund investments 47 47 — — Total equity securities, at fair value 47 47 — — Total assets $24,232 $118 $23,453 $661 Derivative liabilities: Interest rate contracts $133 $— $133 $— Foreign exchange contracts 166 — 166 — Other contracts 23 — 23 — Total derivative liabilities 322 — 322 — Total liabilities $322 $— $322 $— The following tables present a roll forward of the balance sheet amounts for assets measured at fair value on a recurring basis and classified as Level 3: Three Months Ended September 30, 2020 Nine Months Ended September 30, 2020 (in millions) Mortgage Servicing Rights Asset-Backed Securities Other Derivative Contracts Mortgage Servicing Rights Asset-Backed Securities Other Derivative Contracts Beginning balance $568 $— $173 $642 $— $19 Transfers upon election of fair value method — — — 190 — — Beginning balance, adjusted 568 — 173 832 — 19 Purchases — 813 — — 813 — Issuances 85 — 283 238 — 688 Settlements (1) (55 ) — (372 ) (141 ) — (792 ) Changes in fair value during the period recognized in earnings (2) 8 — 125 (323 ) — 294 Ending balance $606 $813 $209 $606 $813 $209 Three Months Ended September 30, 2019 Nine Months Ended September 30, 2019 (in millions) Mortgage Servicing Rights Other Derivative Contracts Mortgage Servicing Rights Other Derivative Contracts Beginning balance $531 $25 $600 $— Issuances 78 61 170 104 Settlements (1) (31 ) (64 ) (88 ) (107 ) Changes in fair value during the period recognized in earnings (2) (68 ) 4 (172 ) 11 Transfers from Level 2 to Level 3 (3) — — — 18 Ending balance $510 $26 $510 $26 (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 driven by market conditions. These changes are recorded in mortgage banking fees in the Consolidated Statements of Operations. (3) Reflects changes in the significance of unobservable inputs on derivative contracts associated with mortgage origination activities. The following table presents quantitative information about the Company’s Level 3 assets, including the range and weighted-average of the significant unobservable inputs used to fair value these assets, as well as valuation techniques used. As of September 30, 2020 Valuation Technique Unobservable Input Range (Weighted Average) Mortgage servicing rights Discounted Cash Flow Constant prepayment rate 10.87-37.32% CPR (19.4% CPR) Option adjusted spread 350-1,060 bps (608 bps) Asset-Backed Securities Discounted Cash Flow Conditional prepayment rate 8.00% Constant default rate 1.85% Other derivative contracts Internal Model Pull through rate 11.72-100.00% (82.45%) MSR value (26.73)-124.27 bps (81.38 bps) Nonrecurring Fair Value Measurements Fair value is also used on a nonrecurring basis to evaluate collateral-dependent loans for impairment or for disclosure purposes. For more information on the valuation techniques utilized to measure nonrecurring fair value see Note 19 in the Company’s 2019 Form 10-K. The following table presents losses on assets measured at fair value on a nonrecurring basis and recorded in earnings: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Collateral-dependent loans ($21 ) ($8 ) ($65 ) ($36 ) The following table presents assets measured at fair value on a nonrecurring basis: September 30, 2020 December 31, 2019 (in millions) Total Level 1 Level 2 Level 3 Total Level 1 Level 2 Level 3 Collateral-dependent loans $633 $— $633 $— $312 $— $312 $— The following table presents the estimated fair value for financial instruments not recorded at fair value in the unaudited interim Consolidated Financial Statements. The carrying amounts are recorded in the Consolidated Balance Sheets under the indicated captions: September 30, 2020 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 $2,578 $2,709 $— $— $2,578 $2,709 $— $— Equity securities, at cost 605 605 — — 597 597 8 8 Other loans held for sale 127 127 — — — — 127 127 Loans and leases 124,071 125,498 — — 633 633 123,438 124,865 Financial liabilities: Deposits 142,921 143,004 — — 142,921 143,004 — — Short-term borrowed funds 252 252 — — 252 252 — — Long-term borrowed funds 9,109 9,568 — — 9,109 9,568 — — December 31, 2019 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 $3,202 $3,242 $— $— $3,202 $3,242 $— $— Equity securities, at cost 807 807 — — 807 807 — — Other loans held for sale 1,384 1,384 — — — — 1,384 1,384 Loans and leases 119,088 119,792 — — 312 312 118,776 119,480 Financial liabilities: Deposits 125,313 125,340 — — 125,313 125,340 — — Short-term borrowed funds 274 274 — — 274 274 — — Long-term borrowed funds 14,047 14,228 — — 14,047 14,228 — —

NONINTEREST INCOME

NONINTEREST INCOME	9 Months Ended
	Sep. 30, 2020
Other Income and Expenses [Abstract]
NONINTEREST INCOME	NOTE 14 - NONINTEREST INCOME Revenues from Contracts with Customers The following table presents the components of revenue from contracts with customers disaggregated by revenue stream and business operating segment: Three Months Ended September 30, 2020 Three Months Ended September 30, 2019 (in millions) Consumer Banking Commercial Banking Consolidated (1) Consumer Banking Commercial Banking Consolidated (1) Service charges and fees $71 $25 $96 $102 $25 $127 Card fees 49 7 56 57 10 67 Capital markets fees — 50 50 — 38 38 Trust and investment services fees 53 — 53 50 — 50 Other banking fees — 3 3 1 2 3 Total revenue from contracts with customers $173 $85 $258 $210 $75 $285 Nine Months Ended September 30, 2020 Nine Months Ended September 30, 2019 (in millions) Consumer Banking Commercial Banking Consolidated (1) Consumer Banking Commercial Banking Consolidated (1) Service charges and fees $222 $76 $298 $298 $77 $375 Card fees 136 24 160 162 28 190 Capital markets fees — 163 163 — 140 140 Trust and investment services fees 151 — 151 150 — 150 Other banking fees — 7 7 1 7 8 Total revenue from contracts with customers $509 $270 $779 $611 $252 $863 (1) There is no revenue from contracts with customers included in Other non-segment operations. The Company recognized trailing commissions of $3 million and $4 million for the three months ended September 30, 2020 and 2019 , respectively, and $10 million and $11 million for the nine months ended September 30, 2020 and 2019 , respectively, related to services provided in previous reporting periods. Fees from other investment services are recognized at a point in time upon completion of the service. Revenue from Other Sources Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Bank-owned life insurance $13 $14 $41 $41

OTHER OPERATING EXPENSE

OTHER OPERATING EXPENSE	9 Months Ended
	Sep. 30, 2020
Other Income and Expenses [Abstract]
OTHER OPERATING EXPENSE	NOTE 15 - OTHER OPERATING EXPENSE The following table presents the details of other operating expense: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Promotional expense $24 $31 $75 $86 Other 71 96 242 269 Other operating expense $95 $127 $317 $355

EARNINGS PER SHARE

EARNINGS PER SHARE	9 Months Ended
	Sep. 30, 2020
Earnings Per Share [Abstract]
EARNINGS PER SHARE	NOTE 16 - EARNINGS PER SHARE Three Months Ended September 30, Nine Months Ended September 30, (in millions, except share and per share data) 2020 2019 2020 2019 Numerator (basic and diluted): Net income $314 $449 $601 $1,341 Less: Preferred stock dividends 25 17 75 50 Net income available to common stockholders $289 $432 $526 $1,291 Denominator: Weighted-average common shares outstanding - basic 426,846,096 445,703,987 427,058,412 454,802,186 Dilutive common shares: share-based awards 1,146,253 1,430,608 1,083,946 1,416,569 Weighted-average common shares outstanding - diluted 427,992,349 447,134,595 428,142,358 456,218,755 Earnings per common share: Basic $0.68 $0.97 $1.23 $2.84 Diluted (1) 0.68 0.97 1.23 2.83 (1) Potential dilutive common shares are excluded from the computation of diluted EPS in the periods where the effect would be antidilutive. Excluded from the computation of diluted EPS were weighted average antidilutive shares totaling 1,193,668 and 772 for the three months ended September 30, 2020 and 2019 , respectively, and 1,249,785 and 359,952 for the nine months ended September 30, 2020 and 2019 , respectively.

BUSINESS OPERATING SEGMENTS

BUSINESS OPERATING SEGMENTS	9 Months Ended
	Sep. 30, 2020
Segment Reporting [Abstract]
BUSINESS OPERATING SEGMENTS	NOTE 17 - 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 a segment head who reports 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. For more information on the Company’s business operating segments, as well as Other non-segment operations, see Note 25 in the Company’s 2019 Form 10-K. As of and for the Three Months Ended September 30, 2020 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $845 $421 ($129 ) $1,137 Noninterest income 495 144 15 654 Total revenue 1,340 565 (114 ) 1,791 Noninterest expense 742 210 36 988 Profit (loss) before provision for credit losses 598 355 (150 ) 803 Provision for credit losses 55 161 212 428 Income (loss) before income tax expense (benefit) 543 194 (362 ) 375 Income tax expense (benefit) 136 41 (116 ) 61 Net income (loss) $407 $153 ($246 ) $314 Total average assets $73,605 $60,889 $43,181 $177,675 As of and for the Three Months Ended September 30, 2019 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $799 $360 ($14 ) $1,145 Noninterest income 336 133 24 493 Total revenue 1,135 493 10 1,638 Noninterest expense 718 213 42 973 Profit (loss) before provision for credit losses 417 280 (32 ) 665 Provision for credit losses 83 27 (9 ) 101 Income (loss) before income tax expense (benefit) 334 253 (23 ) 564 Income tax expense (benefit) 83 57 (25 ) 115 Net income $251 $196 $2 $449 Total average assets $66,365 $55,614 $40,131 $162,110 As of and for the Nine Months Ended September 30, 2020 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $2,452 $1,205 ($200 ) $3,457 Noninterest income 1,280 413 48 1,741 Total revenue 3,732 1,618 (152 ) 5,198 Noninterest expense 2,215 644 120 2,979 Profit (loss) before provision for credit losses 1,517 974 (272 ) 2,219 Provision for credit losses 232 274 986 1,492 Income (loss) before income tax expense (benefit) 1,285 700 (1,258 ) 727 Income tax expense (benefit) 322 147 (343 ) 126 Net income (loss) $963 $553 ($915 ) $601 Total average assets $71,227 $61,722 $41,943 $174,892 As of and for the Nine Months Ended September 30, 2019 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $2,386 $1,103 ($18 ) $3,471 Noninterest income 860 432 91 1,383 Total revenue 3,246 1,535 73 4,854 Noninterest expense 2,133 639 89 2,861 Profit (loss) before provision for credit losses 1,113 896 (16 ) 1,993 Provision for credit losses 228 73 (18 ) 283 Income before income tax expense (benefit) 885 823 2 1,710 Income tax expense (benefit) 219 184 (34 ) 369 Net income $666 $639 $36 $1,341 Total average assets $65,624 $55,793 $39,927 $161,344 There have been no significant changes in the management accounting practices utilized by the Company regarding the basis of presentation for segment results as discussed in Note 25 in the Company’s 2019 Form 10-K.

BASIS OF PRESENTATION (Policies

BASIS OF PRESENTATION (Policies)	9 Months Ended
	Sep. 30, 2020
Organization, Consolidation and Presentation of Financial Statements [Abstract]
Basis of Presentation	The unaudited interim Consolidated Financial Statements, including the Notes presented in this document of Citizens Financial Group, Inc., have been prepared in accordance with GAAP interim reporting requirements, and therefore do not include all information and Notes included in the audited Consolidated Financial Statements in conformity with GAAP. These unaudited interim Consolidated Financial Statements and Notes presented in this document should be read in conjunction with the Company’s audited Consolidated Financial Statements and accompanying Notes included in the Company’s 2019 Form 10-K. The Company’s principal business activity is banking, conducted through its banking subsidiary, CBNA.
Consolidation	The unaudited interim Consolidated Financial Statements include the accounts of the Company and subsidiaries in which the Company has a controlling financial interest. All intercompany transactions and balances have been eliminated. The Company has evaluated its unconsolidated entities and does not believe that any entity in which it has an interest, but does not currently consolidate, meets the requirements to be consolidated as a variable interest entity. The unaudited interim Consolidated Financial Statements include all adjustments, consisting of normal recurring adjustments, necessary for a fair presentation of the results for the interim periods. The results for interim periods are not necessarily indicative of results for a full year.
Use of Estimates	The preparation of financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. Material estimates that are particularly susceptible to significant change in the near-term relate to the determination of the ACL, the fair value of MSRs, and the evaluation and measurement of impairment of goodwill.
Adopted and Pending Accounting Pronouncements	Accounting Pronouncements Adopted in 2020 Pronouncement Summary of Guidance Effects on Financial Statements Financial Instruments - Credit Losses Issued June 2016 • Required effective date: January 1, 2020. • Establishes a single allowance framework for financial assets carried at amortized cost (including securities HTM), which reflects management’s estimate of credit losses over the full remaining expected life of the financial assets. • Amends impairment guidance for securities AFS to incorporate an allowance, which allows for reversals of impairment losses in the event that the credit of an issuer improves. • Requires a cumulative-effect adjustment to retained earnings, net of taxes, as of the beginning of the reporting period of adoption. • Requires enhanced credit quality disclosures including disaggregation of credit quality indicators by vintage. • The Company adopted the new standard on January 1, 2020, retrospectively for loans and leases and HTM securities and prospectively for AFS securities. Refer to Note 4 for discussion of the significant accounting policy for the allowance for credit losses following adoption. • Adoption resulted in a cumulative-effect reduction of $337 million, net of taxes of $114 million, to retained earnings and a corresponding increase to the ACL of $451 million. Refer to Note 4 for the impact of the adoption to the ALLL and reserve for unfunded commitments. • Adoption of the new standard could produce higher volatility in the quarterly provision for credit losses than the prior incurred loss reserve process and could adversely impact the Company’s ongoing earnings. • Based on the credit quality of the Company’s existing debt securities portfolio, the Company did not recognize an allowance for HTM and AFS debt securities upon adoption. Goodwill Issued January 2017 • Requires an impairment loss to be recognized when the estimated fair value of a reporting unit falls below its carrying value. • Eliminates the second condition in the current guidance that requires an impairment loss to be recognized only if the estimated implied fair value of the goodwill is below its carrying value. • Applied prospectively to all goodwill impairment tests performed after the adoption date. • The Company adopted the new standard on January 1, 2020. Refer to Note 6 for discussion of the significant accounting policy for goodwill impairment following adoption. • Adoption did not 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. • 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 disclosures. • Retrospective application is required for all other amendments for all periods presented. • The Company adopted the new standard on January 1, 2020. • Adoption did not have a material impact on the Company’s Consolidated Financial Statements. Required fair value measurement disclosures are included in Note 13. Simplifying the Accounting for Income Taxes Issued December 2019 • Simplifies the accounting for income taxes by eliminating certain exceptions related to the approach for intraperiod tax allocation, the methodology for calculating income taxes in an interim period and the recognition of deferred tax liabilities for outside basis differences. • Simplifies aspects of the accounting for franchise taxes and enacted changes in tax laws or rates. • Clarifies the accounting for transactions that result in a step-up in the tax basis of goodwill. • The Company adopted the new standard on January 1, 2020. • Adoption did not have an impact on the Company’s Consolidated Financial Statements. Pronouncement Summary of Guidance Effects on Financial Statements Facilitation of the Effects of Reference Rate Reform on Financial Reporting Issued March 2020 • Provides the option to apply a number of practical expedients when evaluating if a contract modification as the result of reference rate reform is considered a new contract or a continuation of an existing contract. • Provides optional expedients to the evaluation of, and accounting for, fair value and cash flow hedges affected by reference rate reform. • Provides an optional one-time election to sell or transfer debt securities classified as HTM that reference a rate affected by reference rate reform • The Company adopted the new standard in the first quarter of 2020 upon issuance and is effective through December 31, 2022. • Adoption did not have a material impact on the Company’s Consolidated Financial Statements.

BASIS OF PRESENTATION (Tables)

BASIS OF PRESENTATION (Tables)	9 Months Ended
	Sep. 30, 2020
Organization, Consolidation and Presentation of Financial Statements [Abstract]
Schedule of new accounting pronouncements and changes in accounting principles	Accounting Pronouncements Adopted in 2020 Pronouncement Summary of Guidance Effects on Financial Statements Financial Instruments - Credit Losses Issued June 2016 • Required effective date: January 1, 2020. • Establishes a single allowance framework for financial assets carried at amortized cost (including securities HTM), which reflects management’s estimate of credit losses over the full remaining expected life of the financial assets. • Amends impairment guidance for securities AFS to incorporate an allowance, which allows for reversals of impairment losses in the event that the credit of an issuer improves. • Requires a cumulative-effect adjustment to retained earnings, net of taxes, as of the beginning of the reporting period of adoption. • Requires enhanced credit quality disclosures including disaggregation of credit quality indicators by vintage. • The Company adopted the new standard on January 1, 2020, retrospectively for loans and leases and HTM securities and prospectively for AFS securities. Refer to Note 4 for discussion of the significant accounting policy for the allowance for credit losses following adoption. • Adoption resulted in a cumulative-effect reduction of $337 million, net of taxes of $114 million, to retained earnings and a corresponding increase to the ACL of $451 million. Refer to Note 4 for the impact of the adoption to the ALLL and reserve for unfunded commitments. • Adoption of the new standard could produce higher volatility in the quarterly provision for credit losses than the prior incurred loss reserve process and could adversely impact the Company’s ongoing earnings. • Based on the credit quality of the Company’s existing debt securities portfolio, the Company did not recognize an allowance for HTM and AFS debt securities upon adoption. Goodwill Issued January 2017 • Requires an impairment loss to be recognized when the estimated fair value of a reporting unit falls below its carrying value. • Eliminates the second condition in the current guidance that requires an impairment loss to be recognized only if the estimated implied fair value of the goodwill is below its carrying value. • Applied prospectively to all goodwill impairment tests performed after the adoption date. • The Company adopted the new standard on January 1, 2020. Refer to Note 6 for discussion of the significant accounting policy for goodwill impairment following adoption. • Adoption did not 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. • 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 disclosures. • Retrospective application is required for all other amendments for all periods presented. • The Company adopted the new standard on January 1, 2020. • Adoption did not have a material impact on the Company’s Consolidated Financial Statements. Required fair value measurement disclosures are included in Note 13. Simplifying the Accounting for Income Taxes Issued December 2019 • Simplifies the accounting for income taxes by eliminating certain exceptions related to the approach for intraperiod tax allocation, the methodology for calculating income taxes in an interim period and the recognition of deferred tax liabilities for outside basis differences. • Simplifies aspects of the accounting for franchise taxes and enacted changes in tax laws or rates. • Clarifies the accounting for transactions that result in a step-up in the tax basis of goodwill. • The Company adopted the new standard on January 1, 2020. • Adoption did not have an impact on the Company’s Consolidated Financial Statements. Pronouncement Summary of Guidance Effects on Financial Statements Facilitation of the Effects of Reference Rate Reform on Financial Reporting Issued March 2020 • Provides the option to apply a number of practical expedients when evaluating if a contract modification as the result of reference rate reform is considered a new contract or a continuation of an existing contract. • Provides optional expedients to the evaluation of, and accounting for, fair value and cash flow hedges affected by reference rate reform. • Provides an optional one-time election to sell or transfer debt securities classified as HTM that reference a rate affected by reference rate reform • The Company adopted the new standard in the first quarter of 2020 upon issuance and is effective through December 31, 2022. • Adoption did not have a material impact on the Company’s Consolidated Financial Statements.

SECURITIES (Tables)

SECURITIES (Tables)	9 Months Ended
	Sep. 30, 2020
Investments, Debt and Equity Securities [Abstract]
Schedule of securities held	The following table presents the major components of securities at amortized cost and fair value: September 30, 2020 December 31, 2019 (in millions) Amortized Cost Gross Unrealized Gains Gross Unrealized Losses Fair Value Amortized Cost Gross Unrealized Gains Gross Unrealized Losses Fair Value U.S. Treasury and other $11 $— $— $11 $71 $— $— $71 State and political subdivisions 4 — — 4 5 — — 5 Mortgage-backed securities, at fair value: Federal agencies and U.S. government sponsored entities 20,962 617 (38 ) 21,541 19,803 143 (71 ) 19,875 Other/non-agency 482 33 — 515 638 24 — 662 Total mortgage-backed securities, at fair value 21,444 650 (38 ) 22,056 20,441 167 (71 ) 20,537 Asset-backed securities, at fair value (1) 813 — — 813 — — — — Total debt securities available for sale, at fair value $22,272 $650 ($38 ) $22,884 $20,517 $167 ($71 ) $20,613 Mortgage-backed securities, at cost: Federal agencies and U.S. government sponsored entities $2,578 $131 $— $2,709 $3,202 $45 ($5 ) $3,242 Total debt securities held to maturity, at cost $2,578 $131 $— $2,709 $3,202 $45 ($5 ) $3,242 Money market mutual fund investments $57 $— $— $57 $47 $— $— $47 Total equity securities, at fair value $57 $— $— $57 $47 $— $— $47 Federal Reserve Bank stock $577 $— $— $577 $577 $— $— $577 Federal Home Loan Bank stock 20 — — 20 222 — — 222 Other equity securities 8 — — 8 8 — — 8 Total equity securities, at cost $605 $— $— $605 $807 $— $— $807 (1) In September 2020, Citizens sold $973 million of private in-school education loans, inclusive of accrued interest, capitalized interest and fees. Additionally, the Company provided financing to the purchaser for a portion of the sale price in the form of $813 million of asset-backed securities, collateralized by the sold assets, which are classified as AFS. Refer to Note 7 for additional information.
Schedule of investments classified by maturity date	The following table presents the amortized cost and fair value of debt securities by contractual maturity as of September 30, 2020 . Expected maturities may differ from contractual maturities because issuers may have the right to call or prepay obligations with or without incurring penalties. September 30, 2020 Distribution of Maturities (in millions) 1 Year or Less After 1 Year through 5 Years After 5 Years through 10 Years After 10 Years Total Amortized cost: U.S. Treasury and other $11 $— $— $— $11 State and political subdivisions — — — 4 4 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities 4 147 1,591 19,220 20,962 Other/non-agency — — — 482 482 Asset-backed securities — — 813 — 813 Total debt securities available for sale 15 147 2,404 19,706 22,272 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — — — 2,578 2,578 Total debt securities held to maturity — — — 2,578 2,578 Total amortized cost of debt securities $15 $147 $2,404 $22,284 $24,850 Fair value: U.S. Treasury and other $11 $— $— $— $11 State and political subdivisions — — — 4 4 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities 4 153 1,647 19,737 21,541 Other/non-agency — — — 515 515 Asset-backed securities — — 813 — 813 Total debt securities available for sale 15 153 2,460 20,256 22,884 Mortgage-backed securities: Federal agencies and U.S. government sponsored entities — — — 2,709 2,709 Total debt securities held to maturity — — — 2,709 2,709 Total fair value of debt securities $15 $153 $2,460 $22,965 $25,593
Schedule of income recognized on investment securities	The following table presents realized gains and losses on securities: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Gains on sale of debt securities (1) $1 $5 $4 $21 Losses on sale of debt securities — — — — Debt securities gains, net $1 $5 $4 $21 (1) For the three and nine months ended September 30, 2019 , $2 million and $6 million
Schedule of financial instruments owned and pledged as collateral	The following table presents the amortized cost and fair value of debt securities pledged: September 30, 2020 December 31, 2019 (in millions) Amortized Cost Fair Value Amortized Cost Fair Value Pledged against repurchase agreements $227 $234 $265 $266 Pledged against FHLB borrowed funds 478 515 638 662 Pledged against derivatives, to qualify for fiduciary powers, and to secure public and other deposits as required by law 3,506 3,620 3,670 3,672
Schedule of unrealized loss on investments	The following table presents AFS mortgage-backed debt securities with fair values below their respective carrying values, separated by the duration the securities have been in a continuous unrealized loss position: September 30, 2020 Less than 12 Months 12 Months or Longer Total (dollars in millions) Fair Value Gross Unrealized Losses Fair Value Gross Unrealized Losses Fair Value Gross Unrealized Losses Federal agencies and U.S. government sponsored entities $2,524 ($38 ) $— $— $2,524 ($38 ) The following table present AFS and HTM mortgage-backed debt securities with fair values below their respective carrying values, separated by the duration the securities have been in a continuous unrealized loss position: December 31, 2019 Less than 12 Months 12 Months or Longer Total (dollars in millions) Fair Value Gross Unrealized Losses Fair Value Gross Unrealized Losses Fair Value Gross Unrealized Losses Federal agencies and U.S. government sponsored entities $5,135 ($24 ) $3,748 ($52 ) $8,883 ($76 )

LOANS AND LEASES (Tables)

LOANS AND LEASES (Tables)	9 Months Ended
	Sep. 30, 2020
Receivables [Abstract]
Schedule of loans and leases	The following table presents the Company’s loans and leases, excluding LHFS, disclosed in portfolio segments and classes: (in millions) September 30, 2020 December 31, 2019 Commercial (1) $45,185 $41,479 Commercial real estate 14,889 13,522 Leases 2,288 2,537 Total commercial loans and leases 62,362 57,538 Residential mortgages 19,633 19,083 Home equity 12,322 13,154 Automobile 12,035 12,120 Education 11,631 10,347 Other retail 6,088 6,846 Total retail loans 61,709 61,550 Total loans and leases $124,071 $119,088 (1) Includes PPP loans fully guaranteed by the SBA of $4.7 billion as of September 30, 2020 . Accrued interest receivable on loans and leases held for investment totaled $470 million and $495 million as of September 30, 2020 and December 31, 2019 , respectively, and is included in other assets in the Consolidated Balance Sheets. The following table presents the composition of LHFS. September 30, 2020 December 31, 2019 (in millions) Residential Mortgages (1) Commercial (2) Total Residential Mortgages (1) Commercial (2) Total Loans held for sale at fair value $3,425 $162 $3,587 $1,778 $168 $1,946 Other loans held for sale — 127 127 1,101 283 1,384 (1) Residential mortgage LHFS are originated for sale. (2) Commercial LHFS at fair value consist of loans managed by the Company’s commercial secondary loan desk. Other commercial LHFS generally consist of loans associated with the Company’s syndication business.

ALLOWANCE FOR CREDIT LOSSES, _2

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK (Tables)	9 Months Ended
	Sep. 30, 2020
Receivables [Abstract]
Schedule of changes in the allowance for credit losses	The following table presents a summary of changes in the ALLL and the reserve for unfunded lending commitments for the three and nine months ended September 30, 2020 : Three Months Ended September 30, 2020 Nine Months Ended September 30, 2020 (in millions) Commercial Retail Total Commercial Retail Total Allowance for loan and lease losses, beginning of period $1,235 $1,213 $2,448 $674 $578 $1,252 Cumulative effect of change in accounting principle — — — (176 ) 629 453 Allowance for loan and lease losses, beginning of period, adjusted 1,235 1,213 2,448 498 1,207 1,705 Charge-offs (171 ) (86 ) (257 ) (292 ) (319 ) (611 ) Recoveries 1 37 38 7 101 108 Net charge-offs (170 ) (49 ) (219 ) (285 ) (218 ) (503 ) Provision charged to income 224 89 313 1,076 264 1,340 Allowance for loan and lease losses, end of period $1,289 $1,253 $2,542 $1,289 $1,253 $2,542 Reserve for unfunded lending commitments, beginning of period $69 $10 $79 $44 $— $44 Cumulative effective of change in accounting principle — — — (3 ) 1 (2 ) Reserve for unfunded lending commitments, beginning of period, adjusted 69 10 79 41 1 42 Provision for unfunded lending commitments 83 32 115 111 41 152 Reserve for unfunded lending commitments, end of period $152 $42 $194 $152 $42 $194 The following table provides additional detail on the cumulative effect of change in accounting principle on the ACL and related coverage ratios: December 31, 2019 January 1, 2020 September 30, 2020 (in millions) Amortized Cost Basis ACL Balance Coverage Impact of Adoption of CECL ACL Balance Coverage Amortized Cost Basis ACL Balance Coverage Commercial (1) $41,479 $575 1.4 % ($199 ) $376 0.9 % $45,185 $826 1.8 % Commercial real estate 13,522 124 0.9 (57 ) 67 0.5 14,889 548 3.7 Leases 2,537 19 0.7 77 96 3.8 2,288 67 2.9 Total commercial loans and leases 57,538 718 1.2 (179 ) 539 0.9 62,362 1,441 2.3 Residential 19,083 35 0.2 95 130 0.7 19,633 133 0.7 Home equity 13,154 83 0.6 73 156 1.2 12,322 156 1.3 Automobile 12,120 123 1.0 83 206 1.7 12,035 221 1.8 Education 10,347 116 1.1 298 414 4.0 11,631 386 3.3 Other retail 6,846 221 3.2 81 302 4.4 6,088 399 6.6 Total retail loans 61,550 578 0.9 630 1,208 2.0 61,709 1,295 2.1 Total loans and leases $119,088 $1,296 1.1 % $451 $1,747 1.5 % $124,071 $2,736 2.2 % (1) The commercial coverage ratio includes a 21 basis point reduction associated with PPP loans as of September 30, 2020 . The difference in ACL as of September 30, 2020 as compared to December 31, 2019 continues to be driven by the COVID-19 pandemic and associated lockdowns and the resulting economic impacts from March to September 2020, as well as the Company’s adoption of CECL on January 1, 2020. Citizens added $451 million in ACL upon adoption of CECL, and has since added an additional $989 million in the nine months ended September 30, 2020, resulting in an ending ACL balance of $2.7 billion . The increase in commercial net charge-offs in the nine months ended September 30, 2020 as compared to the nine months ended September 30, 2019 was driven by charge-offs in CRE, metals and mining, oil and gas, and casual dining industry sectors. Retail net charge-offs were flat in the nine months ended September 20, 2020 as compared to the nine months ended September 30, 2019. To determine the ACL as of September 30, 2020, Citizens utilized an economic scenario that generally reflects real GDP growth of 4.5% over 2021, returning to fourth quarter 2019 real GDP levels by the first quarter of 2022. The scenario also projects the fourth quarter 2020 unemployment rate to be in the range of 9% to 9.5%, and falling to 7% to 7.5% by the fourth quarter of 2021. While the macroeconomic forecast was slightly improved relative to the second quarter 2020 forecast, Citizens continued to apply management judgment to adjust the modeled reserves in the commercial industry sectors most impacted by the COVID-19-related lockdowns, including in retail and hospitality, casual dining, retail trade, price-sensitive energy and related, and educational services, as well as in certain retail products. The following table presents a summary of changes in the ALLL and the reserve for unfunded lending commitments for the three and nine months ended September 30, 2019 : Three Months Ended September 30, 2019 Nine Months Ended September 30, 2019 (in millions) Commercial Retail Total Commercial Retail Total Allowance for loan and lease losses, beginning of period $680 $547 $1,227 $690 $552 $1,242 Charge-offs (35 ) (124 ) (159 ) (106 ) (347 ) (453 ) Recoveries 3 43 46 17 128 145 Net charge-offs (32 ) (81 ) (113 ) (89 ) (219 ) (308 ) Provision charged to income 64 85 149 111 218 329 Allowance for loan and lease losses, end of period $712 $551 $1,263 $712 $551 $1,263 Reserve for unfunded lending commitments, beginning of period $93 $— $93 $91 $— $91 Provision for unfunded lending commitments (48 ) — (48 ) (46 ) — (46 ) Reserve for unfunded lending commitments, end of period $45 $— $45 $45 $— $45
Schedule of classes of loans and leases, amortized cost basis by credit quality indicator	The following table presents the amortized cost basis of commercial loans and leases, by vintage date and regulatory classification rating, as of September 30, 2020 : Term Loans by Origination Year Revolving Loans (in millions) 2020 2019 2018 2017 2016 Prior to 2016 Within the Revolving Period Converted to Term Total Commercial Pass (1) $7,478 $6,823 $4,838 $2,747 $1,515 $2,453 $15,115 $182 $41,151 Special Mention 58 275 237 149 92 222 892 125 2,050 Substandard 60 220 326 100 85 140 630 19 1,580 Doubtful 52 22 35 43 20 42 186 4 404 Total commercial 7,648 7,340 5,436 3,039 1,712 2,857 16,823 330 45,185 Commercial real estate Pass 1,774 3,406 3,608 1,553 825 1,112 1,073 — 13,351 Special Mention 11 216 128 237 171 9 77 — 849 Substandard 68 1 170 50 53 66 60 — 468 Doubtful 20 38 53 — 36 3 24 47 221 Total commercial real estate 1,873 3,661 3,959 1,840 1,085 1,190 1,234 47 14,889 Leases Pass 332 327 265 169 200 917 — — 2,210 Special Mention — 2 3 6 5 25 — — 41 Substandard — 2 2 5 4 — — — 13 Doubtful — — 9 1 3 11 — — 24 Total leases 332 331 279 181 212 953 — — 2,288 Total commercial loans and leases Pass (1) 9,584 10,556 8,711 4,469 2,540 4,482 16,188 182 56,712 Special Mention 69 493 368 392 268 256 969 125 2,940 Substandard 128 223 498 155 142 206 690 19 2,061 Doubtful 72 60 97 44 59 56 210 51 649 Total commercial loans and leases $9,853 $11,332 $9,674 $5,060 $3,009 $5,000 $18,057 $377 $62,362 (1) Includes $4.7 billion of PPP loans designated as pass that are fully guaranteed by the SBA originating in 2020. For retail loans, Citizens utilizes credit scores provided by FICO which are generally refreshed on a quarterly basis and the loan’s payment and delinquency status to monitor credit quality. Management believes FICO credit scores are considered the strongest indicator of credit losses over the contractual life of the loan as the scores are based on current and historical national industry-wide consumer level credit performance data, and assist management in predicting the borrower’s future payment performance. The following table presents the amortized cost basis of retail loans, by vintage date and FICO scores, as of September 30, 2020 : Term Loans by Origination Year Revolving Loans (in millions) 2020 2019 2018 2017 2016 Prior to 2016 Within the Revolving Period Converted to Term Total Residential mortgages 800+ $1,971 $1,983 $751 $1,297 $1,833 $2,061 $— $— $9,896 740-799 2,351 1,341 463 612 776 977 — — 6,520 680-739 596 408 193 207 317 500 — — 2,221 620-679 101 97 44 51 69 235 — — 597 <620 17 23 34 56 54 197 — — 381 No FICO available (1) 4 1 — 1 — 12 — — 18 Total residential mortgages 5,040 3,853 1,485 2,224 3,049 3,982 — — 19,633 Home equity 800+ 3 9 11 7 5 245 4,319 360 4,959 740-799 1 7 7 7 4 204 3,224 340 3,794 680-739 — 4 9 14 8 197 1,671 293 2,196 620-679 — 8 16 19 12 146 420 201 822 <620 1 15 27 30 18 129 117 213 550 No FICO available (1) — — — — — — 1 — 1 Total home equity 5 43 70 77 47 921 9,752 1,407 12,322 Automobile 800+ 780 862 472 358 209 91 — — 2,772 740-799 1,130 1,127 606 406 214 87 — — 3,570 680-739 1,028 1,012 527 327 170 69 — — 3,133 620-679 523 557 300 185 102 46 — — 1,713 <620 90 245 202 157 96 48 — — 838 No FICO available (1) 1 1 — — — 7 — — 9 Total automobile 3,552 3,804 2,107 1,433 791 348 — — 12,035 Education 800+ 1,191 1,276 810 772 586 776 — — 5,411 740-799 1,307 1,151 621 449 292 443 — — 4,263 680-739 385 378 217 160 110 239 — — 1,489 620-679 27 52 42 36 31 108 — — 296 <620 2 7 13 14 12 56 — — 104 No FICO available (1) 6 — — — — 62 — — 68 Total education 2,918 2,864 1,703 1,431 1,031 1,684 — — 11,631 Other retail 800+ 286 474 174 79 17 49 313 — 1,392 740-799 419 611 217 97 23 33 621 2 2,023 680-739 356 409 141 60 13 17 555 6 1,557 620-679 195 156 51 19 3 6 181 7 618 <620 18 45 24 9 2 4 81 9 192 No FICO available (1) 36 1 — — — — 267 2 306 Total other retail 1,310 1,696 607 264 58 109 2,018 26 6,088 Retail 800+ 4,231 4,604 2,218 2,513 2,650 3,222 4,632 360 24,430 740-799 5,208 4,237 1,914 1,571 1,309 1,744 3,845 342 20,170 680-739 2,365 2,211 1,087 768 618 1,022 2,226 299 10,596 620-679 846 870 453 310 217 541 601 208 4,046 <620 128 335 300 266 182 434 198 222 2,065 No FICO available (1) 47 3 — 1 — 81 268 2 402 Total retail $12,825 $12,260 $5,972 $5,429 $4,976 $7,044 $11,770 $1,433 $61,709 (1) Represents loans for which an updated FICO score was unavailable (e.g., due to recent profile changes).
Schedule of nonaccrual loans and leases and loans accruing and 90 days or more past due	The following table presents nonaccrual loans and leases and loans accruing and 90 days or more past due: As of September 30, 2020 As of December 31, 2019 (in millions) Nonaccrual loans and leases 90+ days past due and accruing Nonaccrual with no related ACL Nonaccrual loans and leases Commercial $435 $3 $33 $240 Commercial real estate 323 — 3 2 Leases 2 — — 3 Total commercial loans and leases 760 3 36 245 Residential mortgages 131 17 101 93 Home equity 265 — 192 246 Automobile 80 — 18 67 Education 16 2 5 18 Other retail 25 6 1 34 Total retail 517 25 317 458 Total loans and leases $1,277 $28 $353 $703
Schedule of accruing and nonaccruing past due amounts	The following table presents an analysis of the age of both accruing and nonaccruing loan and lease past due amounts: September 30, 2020 December 31, 2019 Days Past Due Days Past Due (in millions) Current-29 30-59 60-89 90 or More Total Current-29 30-59 60-89 90 or More Total Commercial $44,845 $105 $129 $106 $45,185 $41,340 $45 $27 $67 $41,479 Commercial real estate 14,743 90 — 56 14,889 13,520 1 1 — 13,522 Leases 2,284 1 1 2 2,288 2,498 37 — 2 2,537 Total commercial loans and leases 61,872 196 130 164 62,362 57,358 83 28 69 57,538 Residential mortgages 19,430 64 16 123 19,633 18,947 35 17 84 19,083 Home equity 12,007 51 29 235 12,322 12,834 91 40 189 13,154 Automobile 11,825 147 52 11 12,035 11,788 227 81 24 12,120 Education 11,585 28 12 6 11,631 10,290 30 15 12 10,347 Other retail 6,005 33 22 28 6,088 6,729 45 31 41 6,846 Total retail loans 60,852 323 131 403 61,709 60,588 428 184 350 61,550 Total $122,724 $519 $261 $567 $124,071 $117,946 $511 $212 $419 $119,088
Troubled debt restructurings on financing receivables	The following table summarizes TDRs by class and total unfunded commitments: (in millions) September 30, 2020 December 31, 2019 Commercial $294 $297 Retail 715 667 Unfunded commitments related to TDRs 49 42 The following tables below summarize how loans were modified during the three and nine months ended September 30, 2020 and 2019 . The reported balances represent the post-modification outstanding amortized cost basis 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 September 30, 2020 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 — $— 12 $103 2 $1 Commercial real estate — — — — — — Total commercial loans — — 12 103 2 1 Residential mortgages 47 9 41 6 19 4 Home equity 23 2 52 4 104 6 Automobile 25 1 47 — 1,119 18 Education — — — — 140 3 Other retail 410 1 — — 74 — Total retail loans 505 13 140 10 1,456 31 Total 505 $13 152 $113 1,458 $32 Three Months Ended September 30, 2019 Primary Modification Types Interest Rate Reduction (1) Maturity Extension (2) Other (3) (dollars in millions) Number of Contracts Amortized Cost Number of Contracts Amortized Cost Number of Contracts Amortized Cost Commercial 2 $— 6 $1 6 $15 Commercial real estate — — — — — — Total commercial loans 2 — 6 1 6 15 Residential mortgages 12 2 8 2 25 4 Home equity 63 6 16 1 120 6 Automobile 46 1 4 — 309 4 Education — — — — 131 2 Other retail 805 5 — — 218 — Total retail loans 926 14 28 3 803 16 Total 928 $14 34 $4 809 $31 Nine Months Ended September 30, 2020 Primary Modification Types Interest Rate Reduction (1) Maturity Extension (2) Other (3) (dollars in millions) Number of Contracts Amortized Cost Number of Contracts Amortized Cost Number of Contracts Amortized Cost Commercial — $— 18 $106 34 $95 Commercial real estate — — — — — — Total commercial loans — — 18 106 34 95 Residential mortgages 139 26 149 27 60 11 Home equity 96 8 107 8 365 21 Automobile 108 2 48 — 2,212 35 Education — — — — 373 9 Other retail 1,916 8 — — 251 2 Total retail loans 2,259 44 304 35 3,261 78 Total 2,259 $44 322 $141 3,295 $173 Nine Months Ended September 30, 2019 Primary Modification Types Interest Rate Reduction (1) Maturity Extension (2) Other (3) (dollars in millions) Number of Contracts Amortized Cost Number of Contracts Amortized Cost Number of Contracts Amortized Cost Commercial 3 $— 18 $2 24 $102 Commercial real estate — — 1 — — — Total commercial loans 3 — 19 2 24 102 Residential mortgages 25 6 29 5 87 13 Home equity 148 15 66 10 358 21 Automobile 111 2 16 — 933 13 Education — — — — 211 5 Other retail 2,362 14 — — 362 — Total retail loans 2,646 37 111 15 1,951 52 Total 2,649 $37 130 $17 1,975 $154 (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 loans that may increase credit exposure	The following tables present balances of loans with these characteristics: September 30, 2020 (in millions) Residential Mortgages Home Equity Other Retail Total High loan-to-value $408 $95 $— $503 Interest-only/negative amortization 2,594 — — 2,594 Low introductory rate — — 183 183 Multiple characteristics and other 4 — — 4 Total $3,006 $95 $183 $3,284 December 31, 2019 (in millions) Residential Mortgages Home Equity Other Retail Total High loan-to-value $402 $151 $— $553 Interest-only/negative amortization 2,043 — — 2,043 Low introductory rate — — 235 235 Total $2,445 $151 $235 $2,831

MORTGAGE BANKING (Tables)

MORTGAGE BANKING (Tables)	9 Months Ended
	Sep. 30, 2020
Mortgage Banking [Abstract]
Schedule of mortgage banking activities	The following table summarizes activity related to residential mortgage loans sold with servicing rights retained: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Cash proceeds from residential mortgage loans sold with servicing retained $9,504 $6,117 $23,668 $13,265 Gain on sales (1) 273 88 699 180 Contractually specified servicing, late and other ancillary fees (1) 56 53 169 152 (1) Reported in mortgage banking fees on the Consolidated Statements of Operations.
Servicing asset at fair value	The following table summarizes changes in MSRs recorded using the fair value method: As of and for the Three Months Ended September 30, As of and for the Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Fair value as of beginning of the period $568 $531 $642 $600 Transfers upon election of fair value method — — 190 — Fair value as of beginning of the period, adjusted 568 531 832 600 Amounts capitalized 85 78 238 170 Changes in unpaid principal balance during the period (1) (55 ) (31 ) (141 ) (88 ) Changes in fair value during the period (2) 8 (68 ) (323 ) (172 ) Fair value at end of the period $606 $510 $606 $510 (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	September 30, 2020 December 31, 2019 Actual Decline in fair value due to Actual Decline in fair value due to (dollars in millions) Fair value $606 50 bps adverse change 100 bps adverse change $642 50 bps adverse change 100 bps adverse change Weighted average life (in years) 3.8 5.5 Weighted average constant prepayment rate 19.4% $116 $169 13.9% $116 $222 Weighted average option adjusted spread 608 bps 10 21 440 bps 12 25
Schedule of Other Serviced Loans	The following table presents the unpaid principal balance of other serviced loans: (in millions) September 30, 2020 December 31, 2019 Education (1) $866 $— Commercial (2) 44 33 (1) Represents the servicing associated with education loans sold. See Note 7 for further information. (2) Represents the government guaranteed portion of SBA loans sold to outside investors.

GOODWILL (Tables)

GOODWILL (Tables)	9 Months Ended
	Sep. 30, 2020
Goodwill and Intangible Assets Disclosure [Abstract]
Change in carrying value of goodwill	The change in the carrying value of goodwill for the nine months ended September 30, 2020 is presented below: (in millions) Consumer Banking Commercial Banking Total Balance at December 31, 2019 $2,258 $4,786 $7,044 Business acquisitions — 6 6 Balance at September 30, 2020 $2,258 $4,792 $7,050

VARIABLE INTEREST ENTITIES (Tab

VARIABLE INTEREST ENTITIES (Tables)	9 Months Ended
	Sep. 30, 2020
Equity Method Investments and Joint Ventures [Abstract]
Schedule of variable interest entities	A summary of these investments is presented below: (in millions) September 30, 2020 December 31, 2019 Lending to special purpose entities included in loans and leases $1,173 $1,101 LIHTC investment included in other assets 1,543 1,401 LIHTC unfunded commitments included in other liabilities 810 716 Investment in asset-backed securities included in AFS securities 813 — Renewable energy investments included in other assets 410 355
Schedule of Affordable Housing Tax Credit investments	The following table presents other information related to the Company’s affordable housing tax credit investments: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Tax credits included in income tax expense $40 $30 $120 $99 Amortization expense included in income tax expense 42 33 127 105 Other tax benefits included in income tax expense 10 8 30 24

BORROWED FUNDS (Tables)

BORROWED FUNDS (Tables)	9 Months Ended
	Sep. 30, 2020
Debt Disclosure [Abstract]
Schedule of long-term borrowed funds	The following table presents a summary of the Company’s long-term borrowed funds: (in millions) September 30, 2020 December 31, 2019 Parent Company: 2.375% fixed-rate senior unsecured debt, due July 2021 $350 $349 4.150% fixed-rate subordinated debt, due September 2022 (1) 181 348 3.750% fixed-rate subordinated debt, due July 2024 (1) 159 250 4.023% fixed-rate subordinated debt, due October 2024 (1) 25 42 4.350% fixed-rate subordinated debt, due August 2025 (1) 193 249 4.300% fixed-rate subordinated debt, due December 2025 (1) 450 750 2.850% fixed-rate senior unsecured notes, due July 2026 497 496 2.500% fixed-rate senior unsecured notes, due February 2030 297 — 3.250% fixed-rate senior unsecured notes, due April 2030 745 — 2.638% fixed-rate subordinated debt, due September 2032 (1) 542 — CBNA’s Global Note Program: 2.250% senior unsecured notes, due March 2020 — 700 2.678% floating-rate senior unsecured notes, due March 2020 (2) — 300 2.217% floating-rate senior unsecured notes, due May 2020 (2) — 250 2.200% senior unsecured notes, due May 2020 — 500 2.250% senior unsecured notes, due October 2020 750 750 2.550% senior unsecured notes, due May 2021 1,005 991 3.250% senior unsecured notes, due February 2022 720 711 0.985% floating-rate senior unsecured notes, due February 2022 (2) 299 299 1.044% floating-rate senior unsecured notes, due May 2022 (2) 250 250 2.650% senior unsecured notes, due May 2022 512 501 3.700% senior unsecured notes, due March 2023 530 515 1.168% floating-rate senior unsecured notes, due March 2023 (2) 249 249 2.250% senior unsecured notes, due April 2025 745 — 3.750% senior unsecured notes, due February 2026 555 521 Additional Borrowings by CBNA and Other Subsidiaries: Federal Home Loan Bank advances, 0.943% weighted average rate, due through 2038 19 5,008 Other 36 18 Total long-term borrowed funds $9,109 $14,047 (1) September 30, 2020 balances reflect the September 2020 completion of (i) $621 million in private exchange offers for five series of outstanding subordinated notes whereby participants received a combination of the Company’s newly issued 2.638% fixed-rate subordinated notes due 2032 and an additional cash payment and (ii) $11 million in related cash tender offers whereby validly tendered and accepted subordinated notes were purchased by Citizens and subsequently cancelled. (2) Rate disclosed reflects the floating rate as of September 30, 2020 or final rate, as applicable.
Schedule of maturities of long-term borrowed funds	The following table presents a summary of maturities for the Company’s long-term borrowed funds at September 30, 2020 : (in millions) Parent Company CBNA and Other Subsidiaries Consolidated Year 2020 $— $752 $752 2021 350 1,014 1,364 2022 181 1,790 1,971 2023 — 780 780 2024 184 — 184 2025 and thereafter 2,724 1,334 4,058 Total $3,439 $5,670 $9,109

DERIVATIVES (Tables)

DERIVATIVES (Tables)	9 Months Ended
	Sep. 30, 2020
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: September 30, 2020 December 31, 2019 (in millions) Notional Amount (1) Derivative Assets Derivative Liabilities Notional Amount (1) Derivative Assets Derivative Liabilities Derivatives designated as hedging instruments: Interest rate contracts $26,800 $4 $1 $29,846 $1 $— Derivatives not designated as hedging instruments: Interest rate contracts 148,161 1,761 216 142,386 772 133 Foreign exchange contracts 16,448 239 189 15,101 174 166 TBA contracts 13,161 7 34 — — — Other contracts 8,011 275 66 6,868 37 23 Total derivatives not designated as hedging instruments 2,282 505 983 322 Gross derivative fair values 2,286 506 984 322 Less: Gross amounts offset in the Consolidated Balance Sheets (2) (187 ) (187 ) (107 ) (107 ) Less: Cash collateral applied (2) (69 ) (219 ) (70 ) (95 ) Total net derivative fair values presented in the Consolidated Balance Sheets $2,030 $100 $807 $120 (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. (2) Amounts represent the impact of enforceable master netting agreements that allow the Company to net settle positive and negative positions.
Schedule of fair value hedges	The following table presents the change in fair value of interest rate contracts, designated as fair value hedges, as well as the change in fair value of the related hedged items attributable to the risk being hedged, included in the Consolidated Statements of Operations: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Affected Line Item in the Consolidated Statements of Operations Interest rate swaps hedging borrowed funds ($16 ) $18 $82 $122 Interest expense - borrowed funds Hedged long-term debt attributable to the risk being hedged 17 (18 ) (78 ) (121 ) Interest expense - borrowed funds Interest rate swaps hedging fixed rate loans — (10 ) 17 (26 ) Interest and fees on loans and leases Hedged fixed rate loans attributable to the risk being hedged — 10 (17 ) 26 Interest and fees on loans and leases Interest rate swaps hedging debt securities available for sale 7 (13 ) (114 ) (13 ) Interest income - investment securities Hedged debt securities available for sale attributable to risk being hedged (7 ) 13 114 13 Interest income - investment securities The following table reflects amounts recorded on the Consolidated Balance Sheets related to cumulative basis adjustments for fair value hedges: September 30, 2020 December 31, 2019 (in millions) Debt securities available for sale (1) Long-term borrowed funds Debt securities available for sale (1) Residential mortgages Long-term borrowed funds Carrying amount of hedged assets $12,314 $— $15,798 $976 $— Carrying amount of hedged liabilities — 4,072 — — 4,689 Cumulative amount of fair value hedging adjustments included in the carrying amount of the hedged items 107 128 (8 ) 17 50 (1) The Company designated $2.0 billion as the hedged amount (from a closed portfolio of prepayable financial assets with a carrying value of $12.3 billion and $15.8 billion at September 30, 2020 and December 31, 2019, respectively) in a last-of-layer hedging relationship, which commenced in the third quarter of 2019.
Schedule of effect of cash flow hedges on net income and stockholders' equity	The following table presents the pre-tax net gains (losses) recorded in the Consolidated Statements of Operations and in the Consolidated Statements of Comprehensive Income relating to derivative instruments designated as cash flow hedges: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Amount of pre-tax net (losses) gains recognized in OCI $— ($5 ) $118 $138 Amount of pre-tax net gains (losses) reclassified from OCI into interest income 68 (22 ) 128 (62 ) Amount of pre-tax net (losses) gains reclassified from OCI into interest expense (11 ) 8 (22 ) 9
Schedule of effect of derivative Instruments on net income	The following table presents the effect of economic hedges on noninterest income: Amounts Recognized in Noninterest Income for the Three Months Ended September 30, Nine Months Ended September 30, Affected Line Item in the Consolidated Statements of Operations (in millions) 2020 2019 2020 2019 Economic hedge type: Customer interest rate contracts $7 $196 $1,276 $850 Foreign exchange and interest rate products Customer foreign exchange contracts 80 (81 ) 73 (162 ) Foreign exchange and interest rate products Derivative transactions to hedge interest rate risk 1 (182 ) (1,245 ) (809 ) Foreign exchange and interest rate products Derivative transactions to hedge foreign exchange risk (126 ) 130 (77 ) 224 Foreign exchange and interest rate products Residential loan commitments 36 6 190 22 Mortgage banking fees Derivative contracts used to hedge residential loan commitments 6 29 (13 ) 24 Mortgage banking fees Derivative contracts used to hedge residential MSRs 2 92 335 208 Mortgage banking fees Other derivative contracts 26 — (30 ) — Foreign exchange and interest rate products Derivative transactions to hedge other derivative risk (25 ) — 32 — Foreign exchange and interest rate products Total $7 $190 $541 $357

ACCUMULATED OTHER COMPREHENSI_2

ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS) (Tables)	9 Months Ended
	Sep. 30, 2020
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: As of and for the Three Months Ended September 30, (in millions) Net Unrealized (Losses) Gains on Derivatives Net Unrealized (Losses) Gains on Debt Securities Employee Benefit Plans Total AOCI Balance at July 1, 2019 ($6 ) ($25 ) ($457 ) ($488 ) Other comprehensive income before reclassifications (4 ) 42 — 38 Other-than-temporary impairment not recognized in earnings on debt securities — (1 ) — (1 ) Amounts reclassified to the Consolidated Statements of Operations 10 (2 ) 3 11 Net other comprehensive income 6 39 3 48 Balance at September 30, 2019 $— $14 ($454 ) ($440 ) Balance at July 1, 2020 $54 $448 ($408 ) $94 Other comprehensive (loss) income before reclassifications — (44 ) — (44 ) Amounts reclassified to the Consolidated Statements of Operations (42 ) (1 ) 3 (40 ) Net other comprehensive (loss) income (42 ) (45 ) 3 (84 ) Balance at September 30, 2020 $12 $403 ($405 ) $10 Primary location of amounts reclassified to the Consolidated Statements of Operations Net interest income Securities gains, net Other operating expense As of and for the Nine Months Ended September 30, (in millions) Net Unrealized (Losses) Gains on Derivatives Net Unrealized (Losses) Gains on Debt Securities Employee Benefit Plans Total AOCI Balance at January 1, 2019 ($143 ) ($490 ) ($463 ) ($1,096 ) Other comprehensive income before reclassifications 103 509 — 612 Amounts reclassified to the Consolidated Statements of Operations 40 (10 ) 9 39 Net other comprehensive income 143 499 9 651 Cumulative effect of change in accounting principle — 5 — 5 Balance at September 30, 2019 $— $14 ($454 ) ($440 ) Balance at January 1, 2020 $3 $1 ($415 ) ($411 ) Other comprehensive income before reclassifications 88 405 — 493 Amounts reclassified to the Consolidated Statements of Operations (79 ) (3 ) 10 (72 ) Net other comprehensive income 9 402 10 421 Balance at September 30, 2020 $12 $403 ($405 ) $10 Primary location of amounts reclassified to the Consolidated Statements of Operations Net interest income Securities gains, net Other operating expense

STOCKHOLDERS' EQUITY (Tables)

STOCKHOLDERS' EQUITY (Tables)	9 Months Ended
	Sep. 30, 2020
Equity [Abstract]
Schedule of preferred stock	The following table summarizes the Company’s preferred stock: September 30, 2020 December 31, 2019 (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 1,000 300,000 296 300,000 296 Series C 1,000 300,000 297 300,000 297 Series D 1,000 (1) 300,000 (2) 293 300,000 293 Series E 1,000 (1) 450,000 (3) 437 450,000 437 Series F 1,000 400,000 395 — — Total 2,000,000 $1,965 1,600,000 $1,570 (1) Equivalent to $25 per depositary share. (2) Represented by 12,000,000 depositary shares each representing a 1/40th interest in the Series D Preferred Stock. (3) Represented by 18,000,000 depositary shares each representing a 1/40th interest in the Series E Preferred Stock.
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: Three Months Ended September 30, 2020 Three Months Ended September 30, 2019 (in millions, except per share data) Dividends Declared per Share Dividends Declared Dividends Paid Dividends Declared per Share Dividends Declared Dividends Paid Common stock $0.39 $168 $168 $0.36 $162 $162 Preferred stock Series A $10.90 $3 $3 $27.50 $7 $— Series B — — 9 — — 9 Series C 15.94 4 5 15.94 5 4 Series D 15.88 4 5 15.88 5 5 Series E 12.50 6 6 — — — Series F 19.15 8 — — — — Total preferred stock $25 $28 $17 $18 Nine Months Ended September 30, 2020 Nine Months Ended September 30, 2019 (in millions, except per share and share data) Dividends Declared per Share Dividends Declared Dividends Paid Dividends Declared per Share Dividends Declared Dividends Paid Common stock $1.17 $504 $504 $1.00 $459 $459 Preferred stock Series A $51.88 $13 $10 $55.00 $14 $7 Series B 30.00 9 18 30.00 9 20 Series C 47.81 14 15 47.81 14 13 Series D 47.63 14 15 43.57 13 8 Series E 37.50 17 15 — — — Series F 19.15 8 — — — — Total preferred stock $75 $73 $50 $48

COMMITMENTS AND CONTINGENCIES (

COMMITMENTS AND CONTINGENCIES (Tables)	9 Months Ended
	Sep. 30, 2020
Commitments and Contingencies Disclosure [Abstract]
Schedule of outstanding off balance sheet arrangements	A summary of outstanding off-balance sheet arrangements is presented below. For more information on these arrangements, see Note 18 in the Company’s 2019 Form 10-K. (in millions) September 30, 2020 December 31, 2019 Commitments to extend credit $73,173 $72,743 Letters of credit 2,132 2,190 Risk participation agreements 103 37 Loans sold with recourse 48 37 Marketing rights 29 33 Total $75,485 $75,040

FAIR VALUE MEASUREMENTS (Tables

FAIR VALUE MEASUREMENTS (Tables)	9 Months Ended
	Sep. 30, 2020
Fair Value Disclosures [Abstract]
Fair value option	The following table presents the changes in fair value for assets where the Company has elected the fair value option: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Affected Line Item in the Consolidated Statements of Operations Residential mortgage loans held for sale, at fair value $46 ($4 ) $149 $5 Mortgage banking fees Commercial and commercial real estate loans held for sale, at fair value 6 — (2 ) 4 Capital market fees Citizens elected to account for residential mortgage LHFS and certain commercial and commercial real estate LHFS at fair value. September 30, 2020 December 31, 2019 (in millions) Aggregate Fair Value Aggregate Unpaid Principal Aggregate Fair Value Greater (Less) Aggregate Unpaid Principal Aggregate Fair Value Aggregate Unpaid Principal Aggregate Fair Value Greater (Less) Aggregate Unpaid Principal Residential mortgage loans held for sale, at fair value $3,425 $3,256 $169 $1,778 $1,727 $51 Commercial and commercial real estate loans held for sale, at fair value 162 172 (10 ) 168 175 (7 )
Assets and liabilities measured on recurring basis	The following table presents assets and liabilities measured at fair value, including gross derivative assets and liabilities on a recurring basis at September 30, 2020 : (in millions) Total Level 1 Level 2 Level 3 Debt securities available for sale: Mortgage-backed securities $22,056 $— $22,056 $— Asset-backed securities 813 — — 813 State and political subdivisions 4 — 4 — U.S. Treasury and other 11 11 — — Total debt securities available for sale 22,884 11 22,060 813 Loans held for sale, at fair value: Residential loans held for sale 3,425 — 3,425 — Commercial loans held for sale 162 — 162 — Total loans held for sale, at fair value 3,587 — 3,587 — Mortgage servicing rights 606 — — 606 Derivative assets: Interest rate contracts 1,765 — 1,765 — Foreign exchange contracts 239 — 239 — TBA contracts 7 — 7 — Other contracts 275 — 66 209 Total derivative assets 2,286 — 2,077 209 Equity securities, at fair value: Money market mutual fund investments 57 57 — — Total equity securities, at fair value 57 57 — — Total assets $29,420 $68 $27,724 $1,628 Derivative liabilities: Interest rate contracts $217 $— $217 $— Foreign exchange contracts 189 — 189 — TBA contracts 34 — 34 — Other contracts 66 — 66 — Total derivative liabilities 506 — 506 — Total liabilities $506 $— $506 $— The following table presents assets and liabilities measured at fair value, including gross derivative assets and liabilities on a recurring basis at December 31, 2019 : (in millions) Total Level 1 Level 2 Level 3 Debt securities available for sale: Mortgage-backed securities $20,537 $— $20,537 $— State and political subdivisions 5 — 5 — U.S. Treasury and other 71 71 — — Total debt securities available for sale 20,613 71 20,542 — Loans held for sale, at fair value: Residential loans held for sale 1,778 — 1,778 — Commercial loans held for sale 168 — 168 — Total loans held for sale, at fair value 1,946 — 1,946 — Mortgage servicing rights 642 — — 642 Derivative assets: Interest rate contracts 773 — 773 — Foreign exchange contracts 174 — 174 — Other contracts 37 — 18 19 Total derivative assets 984 — 965 19 Equity securities, at fair value: Money market mutual fund investments 47 47 — — Total equity securities, at fair value 47 47 — — Total assets $24,232 $118 $23,453 $661 Derivative liabilities: Interest rate contracts $133 $— $133 $— Foreign exchange contracts 166 — 166 — Other contracts 23 — 23 — Total derivative liabilities 322 — 322 — Total liabilities $322 $— $322 $—
Assets measured at fair value on recurring basis and classified as Level 3	The following tables present a roll forward of the balance sheet amounts for assets measured at fair value on a recurring basis and classified as Level 3: Three Months Ended September 30, 2020 Nine Months Ended September 30, 2020 (in millions) Mortgage Servicing Rights Asset-Backed Securities Other Derivative Contracts Mortgage Servicing Rights Asset-Backed Securities Other Derivative Contracts Beginning balance $568 $— $173 $642 $— $19 Transfers upon election of fair value method — — — 190 — — Beginning balance, adjusted 568 — 173 832 — 19 Purchases — 813 — — 813 — Issuances 85 — 283 238 — 688 Settlements (1) (55 ) — (372 ) (141 ) — (792 ) Changes in fair value during the period recognized in earnings (2) 8 — 125 (323 ) — 294 Ending balance $606 $813 $209 $606 $813 $209 Three Months Ended September 30, 2019 Nine Months Ended September 30, 2019 (in millions) Mortgage Servicing Rights Other Derivative Contracts Mortgage Servicing Rights Other Derivative Contracts Beginning balance $531 $25 $600 $— Issuances 78 61 170 104 Settlements (1) (31 ) (64 ) (88 ) (107 ) Changes in fair value during the period recognized in earnings (2) (68 ) 4 (172 ) 11 Transfers from Level 2 to Level 3 (3) — — — 18 Ending balance $510 $26 $510 $26 (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 driven by market conditions. These changes are recorded in mortgage banking fees in the Consolidated Statements of Operations. (3) Reflects changes in the significance of unobservable inputs on derivative contracts associated with mortgage origination activities.
Fair value measurement inputs and valuation techniques	The following table presents quantitative information about the Company’s Level 3 assets, including the range and weighted-average of the significant unobservable inputs used to fair value these assets, as well as valuation techniques used. As of September 30, 2020 Valuation Technique Unobservable Input Range (Weighted Average) Mortgage servicing rights Discounted Cash Flow Constant prepayment rate 10.87-37.32% CPR (19.4% CPR) Option adjusted spread 350-1,060 bps (608 bps) Asset-Backed Securities Discounted Cash Flow Conditional prepayment rate 8.00% Constant default rate 1.85% Other derivative contracts Internal Model Pull through rate 11.72-100.00% (82.45%) MSR value (26.73)-124.27 bps (81.38 bps)
Gains (losses) on assets and liabilities measured on a nonrecurring basis included in earnings	The following table presents losses on assets measured at fair value on a nonrecurring basis and recorded in earnings: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Collateral-dependent loans ($21 ) ($8 ) ($65 ) ($36 )
Fair value of assets and liabilities measured on a nonrecurring basis	The following table presents assets measured at fair value on a nonrecurring basis: September 30, 2020 December 31, 2019 (in millions) Total Level 1 Level 2 Level 3 Total Level 1 Level 2 Level 3 Collateral-dependent loans $633 $— $633 $— $312 $— $312 $—
Assets and liabilities measured at fair value	The following table presents the estimated fair value for financial instruments not recorded at fair value in the unaudited interim Consolidated Financial Statements. The carrying amounts are recorded in the Consolidated Balance Sheets under the indicated captions: September 30, 2020 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 $2,578 $2,709 $— $— $2,578 $2,709 $— $— Equity securities, at cost 605 605 — — 597 597 8 8 Other loans held for sale 127 127 — — — — 127 127 Loans and leases 124,071 125,498 — — 633 633 123,438 124,865 Financial liabilities: Deposits 142,921 143,004 — — 142,921 143,004 — — Short-term borrowed funds 252 252 — — 252 252 — — Long-term borrowed funds 9,109 9,568 — — 9,109 9,568 — — December 31, 2019 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 $3,202 $3,242 $— $— $3,202 $3,242 $— $— Equity securities, at cost 807 807 — — 807 807 — — Other loans held for sale 1,384 1,384 — — — — 1,384 1,384 Loans and leases 119,088 119,792 — — 312 312 118,776 119,480 Financial liabilities: Deposits 125,313 125,340 — — 125,313 125,340 — — Short-term borrowed funds 274 274 — — 274 274 — — Long-term borrowed funds 14,047 14,228 — — 14,047 14,228 — —

NONINTEREST INCOME (Tables)

NONINTEREST INCOME (Tables)	9 Months Ended
	Sep. 30, 2020
Other Income and Expenses [Abstract]
Components of revenue from contracts with customers	The following table presents the components of revenue from contracts with customers disaggregated by revenue stream and business operating segment: Three Months Ended September 30, 2020 Three Months Ended September 30, 2019 (in millions) Consumer Banking Commercial Banking Consolidated (1) Consumer Banking Commercial Banking Consolidated (1) Service charges and fees $71 $25 $96 $102 $25 $127 Card fees 49 7 56 57 10 67 Capital markets fees — 50 50 — 38 38 Trust and investment services fees 53 — 53 50 — 50 Other banking fees — 3 3 1 2 3 Total revenue from contracts with customers $173 $85 $258 $210 $75 $285 Nine Months Ended September 30, 2020 Nine Months Ended September 30, 2019 (in millions) Consumer Banking Commercial Banking Consolidated (1) Consumer Banking Commercial Banking Consolidated (1) Service charges and fees $222 $76 $298 $298 $77 $375 Card fees 136 24 160 162 28 190 Capital markets fees — 163 163 — 140 140 Trust and investment services fees 151 — 151 150 — 150 Other banking fees — 7 7 1 7 8 Total revenue from contracts with customers $509 $270 $779 $611 $252 $863 (1) There is no revenue from contracts with customers included in Other non-segment operations.
Details of other income	Revenue from Other Sources Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Bank-owned life insurance $13 $14 $41 $41

OTHER OPERATING EXPENSE (Tables

OTHER OPERATING EXPENSE (Tables)	9 Months Ended
	Sep. 30, 2020
Other Income and Expenses [Abstract]
Schedule of other operating expense	The following table presents the details of other operating expense: Three Months Ended September 30, Nine Months Ended September 30, (in millions) 2020 2019 2020 2019 Promotional expense $24 $31 $75 $86 Other 71 96 242 269 Other operating expense $95 $127 $317 $355

EARNINGS PER SHARE (Tables)

EARNINGS PER SHARE (Tables)	9 Months Ended
	Sep. 30, 2020
Earnings Per Share [Abstract]
Schedule of earnings per share	Three Months Ended September 30, Nine Months Ended September 30, (in millions, except share and per share data) 2020 2019 2020 2019 Numerator (basic and diluted): Net income $314 $449 $601 $1,341 Less: Preferred stock dividends 25 17 75 50 Net income available to common stockholders $289 $432 $526 $1,291 Denominator: Weighted-average common shares outstanding - basic 426,846,096 445,703,987 427,058,412 454,802,186 Dilutive common shares: share-based awards 1,146,253 1,430,608 1,083,946 1,416,569 Weighted-average common shares outstanding - diluted 427,992,349 447,134,595 428,142,358 456,218,755 Earnings per common share: Basic $0.68 $0.97 $1.23 $2.84 Diluted (1) 0.68 0.97 1.23 2.83 (1) Potential dilutive common shares are excluded from the computation of diluted EPS in the periods where the effect would be antidilutive. Excluded from the computation of diluted EPS were weighted average antidilutive shares totaling 1,193,668 and 772 for the three months ended September 30, 2020 and 2019 , respectively, and 1,249,785 and 359,952 for the nine months ended September 30, 2020 and 2019 , respectively.

BUSINESS OPERATING SEGMENTS (Ta

BUSINESS OPERATING SEGMENTS (Tables)	9 Months Ended
	Sep. 30, 2020
Segment Reporting [Abstract]
Schedule of segment reporting information	As of and for the Three Months Ended September 30, 2020 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $845 $421 ($129 ) $1,137 Noninterest income 495 144 15 654 Total revenue 1,340 565 (114 ) 1,791 Noninterest expense 742 210 36 988 Profit (loss) before provision for credit losses 598 355 (150 ) 803 Provision for credit losses 55 161 212 428 Income (loss) before income tax expense (benefit) 543 194 (362 ) 375 Income tax expense (benefit) 136 41 (116 ) 61 Net income (loss) $407 $153 ($246 ) $314 Total average assets $73,605 $60,889 $43,181 $177,675 As of and for the Three Months Ended September 30, 2019 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $799 $360 ($14 ) $1,145 Noninterest income 336 133 24 493 Total revenue 1,135 493 10 1,638 Noninterest expense 718 213 42 973 Profit (loss) before provision for credit losses 417 280 (32 ) 665 Provision for credit losses 83 27 (9 ) 101 Income (loss) before income tax expense (benefit) 334 253 (23 ) 564 Income tax expense (benefit) 83 57 (25 ) 115 Net income $251 $196 $2 $449 Total average assets $66,365 $55,614 $40,131 $162,110 As of and for the Nine Months Ended September 30, 2020 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $2,452 $1,205 ($200 ) $3,457 Noninterest income 1,280 413 48 1,741 Total revenue 3,732 1,618 (152 ) 5,198 Noninterest expense 2,215 644 120 2,979 Profit (loss) before provision for credit losses 1,517 974 (272 ) 2,219 Provision for credit losses 232 274 986 1,492 Income (loss) before income tax expense (benefit) 1,285 700 (1,258 ) 727 Income tax expense (benefit) 322 147 (343 ) 126 Net income (loss) $963 $553 ($915 ) $601 Total average assets $71,227 $61,722 $41,943 $174,892 As of and for the Nine Months Ended September 30, 2019 (in millions) Consumer Banking Commercial Banking Other Consolidated Net interest income $2,386 $1,103 ($18 ) $3,471 Noninterest income 860 432 91 1,383 Total revenue 3,246 1,535 73 4,854 Noninterest expense 2,133 639 89 2,861 Profit (loss) before provision for credit losses 1,113 896 (16 ) 1,993 Provision for credit losses 228 73 (18 ) 283 Income before income tax expense (benefit) 885 823 2 1,710 Income tax expense (benefit) 219 184 (34 ) 369 Net income $666 $639 $36 $1,341 Total average assets $65,624 $55,793 $39,927 $161,344

BASIS OF PRESENTATION (Details)

BASIS OF PRESENTATION (Details) - USD ($) $ in Millions	Jan. 01, 2020	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019	Dec. 31, 2019
New Accounting Pronouncements or Change in Accounting Principle [Line Items]
Retained earnings		$ 6,189		$ 6,189		$ 6,498
Income tax expense		$ 61	$ 115	$ 126	$ 369
Cumulative Effect, Period Of Adoption, Adjustment | Accounting Standards Update 2016-13
New Accounting Pronouncements or Change in Accounting Principle [Line Items]
Retained earnings	$ (337)
Income tax expense	(114)
Allowance for credit loss	$ 451

SECURITIES - Narrative (Details

SECURITIES - Narrative (Details) - USD ($) $ in Millions	1 Months Ended	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019	Dec. 31, 2019
Debt Securities, Available-for-sale [Line Items]
Accrued interest receivable on debt securities	$ 57	$ 57		$ 57		$ 58
Taxable interest income from securities		121	$ 153	398	$ 483
Purchases of debt securities available for sale	813			5,547	4,633
Mortgage-backed securities
Debt Securities, Available-for-sale [Line Items]
Securitizations of mortgage loans		34	$ 28	34	$ 72
Retail | Education
Debt Securities, Available-for-sale [Line Items]
Sale of loans	$ 973	$ 973		$ 973

SECURITIES - Schedule of Invest

SECURITIES - Schedule of Investments (Details) - USD ($) $ in Millions		Sep. 30, 2020	Dec. 31, 2019
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-sale, Fair Value	[1]	$ 22,884	$ 20,613
Debt Securities Held-to-maturity, Amortized Cost	[1]	2,578	3,202
Debt Securities Held-to-maturity, Gross Unrealized Gain		131	45
Debt Securities Held-to-maturity, Gross Unrealized Losses		0	(5)
Debt Securities held-to-maturity, Fair Value		2,709	3,242
Equity Securities, Amortized Cost		57	47
Equity Securities, Fair Value		57	47
Other equity securities, Amortized Cost		8	8
Other equity securities, Fair Value		8	8
Total equity securities, at cost, Amortized Cost		605	807
Total equity securities, at cost, Fair Value		605	807
U.S. Treasury and other
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-sale, Amortized Cost		11	71
Debt Securities Available-for-sale, Gross Unrealized Gains		0	0
Debt Securities Available-for-sale, Gross Unrealized Losses		0	0
Debt Securities Available-for-sale, Fair Value		11	71
State and political subdivisions
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-sale, Amortized Cost		4	5
Debt Securities Available-for-sale, Gross Unrealized Gains		0	0
Debt Securities Available-for-sale, Gross Unrealized Losses		0	0
Debt Securities Available-for-sale, Fair Value		4	5
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		20,962	19,803
Debt Securities Available-for-sale, Gross Unrealized Gains		617	143
Debt Securities Available-for-sale, Gross Unrealized Losses		(38)	(71)
Debt Securities Available-for-sale, Fair Value		21,541	19,875
Debt Securities Held-to-maturity, Amortized Cost		2,578	3,202
Debt Securities Held-to-maturity, Gross Unrealized Gain		131	45
Debt Securities Held-to-maturity, Gross Unrealized Losses		0	(5)
Debt Securities held-to-maturity, Fair Value		2,709	3,242
Other/non-agency
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-sale, Amortized Cost		482	638
Debt Securities Available-for-sale, Gross Unrealized Gains		33	24
Debt Securities Available-for-sale, Gross Unrealized Losses		0	0
Debt Securities Available-for-sale, Fair Value		515	662
Total mortgage-backed securities, at fair value
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-sale, Amortized Cost		21,444	20,441
Debt Securities Available-for-sale, Gross Unrealized Gains		650	167
Debt Securities Available-for-sale, Gross Unrealized Losses		(38)	(71)
Debt Securities Available-for-sale, Fair Value		22,056	20,537
Asset-backed securities, at fair value(1)
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-sale, Amortized Cost		813	0
Debt Securities Available-for-sale, Gross Unrealized Gains		0	0
Debt Securities Available-for-sale, Gross Unrealized Losses		0	0
Debt Securities Available-for-sale, Fair Value		813	0
Total debt securities available for sale, at fair value
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Debt Securities Available-for-sale, Amortized Cost		22,272	20,517
Debt Securities Available-for-sale, Gross Unrealized Gains		650	167
Debt Securities Available-for-sale, Gross Unrealized Losses		(38)	(71)
Debt Securities Available-for-sale, Fair Value		22,884	20,613
Money market mutual fund investments
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Equity Securities, Amortized Cost		57	47
Equity Securities, Fair Value		57	47
Federal Reserve Bank stock
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Federal Reserve Bank stock, Amortized Cost		577	577
Federal Reserve Bank stock, Fair Value		577	577
Federal Home Loan Bank stock
Schedule of Available-for-sale and Held-to-maturity Securities [Line Items]
Federal Home Loan Bank stock, Amortized Cost		20	222
Federal Home Loan Bank stock, Fair Value		$ 20	$ 222
[1]	Includes only collateral pledged by the Company where counterparties have the right to sell or pledge the collateral.

SECURITIES - Schedule of Availa

SECURITIES - Schedule of Available for Sale Securities Debt Maturities (Details) $ in Millions	Sep. 30, 2020USD ($)
Amortized cost:
Amortized Cost, Debt securities available for sale, Maturity of 1 Year or Less	$ 15
Amortized Cost, Debt securities available for sale, Maturity of 1-5 Years	147
Amortized Cost, Debt securities available for sale, Maturity of 5-10 Years	2,404
Amortized Cost, Debt securities available for sale, Maturity After 10 Years	19,706
Amortized Cost, Debt securities available for sale, Total	22,272
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	2,578
Amortized Cost, Debt securities held to maturity, Total	2,578
Total amortized cost of debt securities, Maturity of 1 Year or Less	15
Total amortized cost of debt securities, Maturity of 1-5 Years	147
Total amortized cost of debt securities, Maturity of 5-10 Years	2,404
Total amortized cost of debt securities, Maturity After 10 Years	22,284
Total amortized cost of debt securities, Total	24,850
Fair value:
Fair Value, Debt securities available for sale, Maturity of 1 Year or Less	15
Fair Value, Debt securities available for sale, Maturity of 1-5 Years	153
Fair Value, Debt securities available for sale, Maturity of 5-10 Years	2,460
Fair Value, Debt securities available for sale, Maturity After 10 Years	20,256
Fair Value, Debt securities available for sale, Total	22,884
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	2,709
Fair Value, Debt securities held to maturity, Total	2,709
Total fair value of debt securities, Maturity of 1 Year or Less	15
Total fair value of debt securities, Maturity of 1-5 Years	153
Total fair value of debt securities, Maturity of 5-10 Years	2,460
Total fair value of debt securities, Maturity After 10 Years	22,965
Total fair value of debt securities, Total	25,593
U.S. Treasury and other
Amortized cost:
Amortized Cost, Debt securities available for sale, Maturity of 1 Year or Less	11
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	11
Fair value:
Fair Value, Debt securities available for sale, Maturity of 1 Year or Less	11
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	11
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	4
Amortized Cost, Debt securities available for sale, Total	4
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	4
Fair Value, Debt securities available for sale, Total	4
Federal agencies and U.S. government sponsored entities
Amortized cost:
Amortized Cost, Debt securities available for sale, Maturity of 1 Year or Less	4
Amortized Cost, Debt securities available for sale, Maturity of 1-5 Years	147
Amortized Cost, Debt securities available for sale, Maturity of 5-10 Years	1,591
Amortized Cost, Debt securities available for sale, Maturity After 10 Years	19,220
Amortized Cost, Debt securities available for sale, Total	20,962
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	2,578
Amortized Cost, Debt securities held to maturity, Total	2,578
Fair value:
Fair Value, Debt securities available for sale, Maturity of 1 Year or Less	4
Fair Value, Debt securities available for sale, Maturity of 1-5 Years	153
Fair Value, Debt securities available for sale, Maturity of 5-10 Years	1,647
Fair Value, Debt securities available for sale, Maturity After 10 Years	19,737
Fair Value, Debt securities available for sale, Total	21,541
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	2,709
Fair Value, Debt securities held to maturity, Total	2,709
Other/non-agency
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	482
Amortized Cost, Debt securities available for sale, Total	482
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	515
Fair Value, Debt securities available for sale, Total	515
Asset-backed securities
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	813
Amortized Cost, Debt securities available for sale, Maturity After 10 Years	0
Amortized Cost, Debt securities available for sale, Total	813
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	813
Fair Value, Debt securities available for sale, Maturity After 10 Years	0
Fair Value, Debt securities available for sale, Total	$ 813

SECURITIES - Income Recognized

SECURITIES - Income Recognized from Investment Securities (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Debt Securities, Available-for-sale [Line Items]
Gains on sale of debt securities	$ 1	$ 5	$ 4	$ 21
Losses on sale of debt securities	0	0	0	0
Debt securities gains, net	$ 1	5	$ 4	21
Mortgage banking fees
Debt Securities, Available-for-sale [Line Items]
Debt securities gains, net		$ 2		$ 6

SECURITIES - Schedule of Securi

SECURITIES - Schedule of Securities Pledged (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Amortized Cost
Pledged against repurchase agreements	$ 227	$ 265
Pledged against FHLB borrowed funds	478	638
Pledged against derivatives, to qualify for fiduciary powers, and to secure public and other deposits as required by law	3,506	3,670
Fair Value
Pledged against repurchase agreements	234	266
Pledged against FHLB borrowed funds	515	662
Pledged against derivatives, to qualify for fiduciary powers, and to secure public and other deposits as required by law	$ 3,620	$ 3,672

SECURITIES - Schedule of Inve_2

SECURITIES - Schedule of Investments in Continuous Loss Positions (Details) - Federal agencies and U.S. government sponsored entities - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Fair Value
Less than 12 Months	$ 2,524	$ 5,135
12 Months or Longer	0	3,748
Total	2,524	8,883
Gross Unrealized Losses
Less than 12 Months	(38)	(24)
12 Months or Longer	0	(52)
Total	$ (38)	$ (76)

LOANS AND LEASES - Narrative (D

LOANS AND LEASES - Narrative (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019	Dec. 31, 2019
Accounts, Notes, Loans and Financing Receivable [Line Items]
Accrued interest receivable on loans and leases held for investment	$ 470		$ 470		$ 495
Interest income on direct financing lease	17	$ 18	54	$ 58
Retail | Residential mortgages
Accounts, Notes, Loans and Financing Receivable [Line Items]
Proceeds from sale of loans			1,500
Retail | Education
Accounts, Notes, Loans and Financing Receivable [Line Items]
Payments for purchase of loans	801	164	1,700	464
Retail | Other retail
Accounts, Notes, Loans and Financing Receivable [Line Items]
Payments for purchase of loans	101	66	628	66
Retail | Retail loans
Accounts, Notes, Loans and Financing Receivable [Line Items]
Proceeds from sale of loans				628
Retail | Retail TDRs
Accounts, Notes, Loans and Financing Receivable [Line Items]
Proceeds from sale of loans				22
Retail | Residential mortgages
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans pledged as collateral for FHLB borrowed funds	25,200		25,200		25,300
Consumer And Commercial Portfolio Segment | Auto, commercial and commercial real estate loans
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans pledged as collateral to support the contingent ability to borrow at the FRB discount window	39,200		39,200		$ 17,400
Commercial | Education
Accounts, Notes, Loans and Financing Receivable [Line Items]
Proceeds from sale of loans	879		879
Commercial | Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
Proceeds from sale of loans	$ 94	$ 109	$ 356	$ 291

LOANS AND LEASES - Summary of L

LOANS AND LEASES - Summary of Loans and Leases Portfolio (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 124,071	$ 119,088
Loans held for sale, at fair value	3,587	1,946
Other loans held for sale	127	1,384
SBA Loans Serviced For Others | CBNA and Other Subsidiaries
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	44	33
Mortgage loans serviced for others | CBNA and Other Subsidiaries
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	80,700	77,500
Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	62,362	57,538
Commercial | Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	45,185	41,479
Commercial | Commercial real estate
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	14,889	13,522
Commercial | Leases
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	2,288	2,537
Commercial | SBA Guaranteed PPP Loans
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	4,700
Retail
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	61,709	61,550
Retail | Residential mortgages
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	19,633	19,083
Retail | Home equity
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	12,322	13,154
Retail | Automobile
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	12,035	12,120
Retail | Education
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	11,631	10,347
Retail | Other retail
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 6,088	$ 6,846

LOANS AND LEASES - Loans Held F

LOANS AND LEASES - Loans Held For Sale (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans held for sale, at fair value	$ 3,587	$ 1,946
Other loans held for sale	127	1,384
Residential loans held for sale
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans held for sale, at fair value	3,425	1,778
Other loans held for sale	0	1,101
Commercial loans held for sale
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans held for sale, at fair value	162	168
Other loans held for sale	$ 127	$ 283

ALLOWANCE FOR CREDIT LOSSES, _3

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Narrative (Details) - USD ($) $ in Millions	Jan. 01, 2020	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019	Dec. 31, 2019
Financing Receivable, Troubled Debt Restructuring [Line Items]
Allowance for credit loss, reserve build	$ 451			$ 989
ACL Balance	1,747	$ 2,736		2,736		$ 1,296
Loans and leases		124,071		124,071		119,088
Mortgage loans collateralized by OREO		129		129		152
Net change to ALLL from modification		(30)	$ 3	(21)	$ 7
Charge-offs from modification of loans		43	1	$ 49	3
High loan to value criteria (exceeds)				90.00%
Commercial
Financing Receivable, Troubled Debt Restructuring [Line Items]
Allowance for credit losses, individually evaluated for impairment		5		$ 5
Accrued interest receivable reversed against interest income		4		7
ACL Balance	539	1,441		1,441		718
Loans and leases		62,362		62,362		57,538
TDR's that defaulted within 12 months of modification date		14	0	53	1
Retail
Financing Receivable, Troubled Debt Restructuring [Line Items]
Accrued interest receivable reversed against interest income		4		13
ACL Balance	1,208	1,295		1,295		578
Loans and leases		61,709		61,709		61,550
TDR's that defaulted within 12 months of modification date		22	$ 9	47	$ 28
Commercial | Commercial
Financing Receivable, Troubled Debt Restructuring [Line Items]
ACL Balance	$ 376	826		826		575
Loans and leases		45,185		$ 45,185		41,479
Collateral Dependent | Home Equity Loan And Residential Mortgages | Retail
Financing Receivable, Troubled Debt Restructuring [Line Items]
Collateral value, valuation frequency period				90 days
Loans and leases		489		$ 489		227
Collateral Dependent | Commercial | Commercial
Financing Receivable, Troubled Debt Restructuring [Line Items]
Loans and leases		144		144		$ 85
Payment Deferral | Commercial
Financing Receivable, Troubled Debt Restructuring [Line Items]
Loan restructuring, modification, amount		$ 795		$ 795
Loan restructuring, modification, percentage of total portfolio		1.40%		1.40%
Payment Deferral | Retail
Financing Receivable, Troubled Debt Restructuring [Line Items]
Loan restructuring, modification, amount		$ 2,400		$ 2,400
Loan restructuring, modification, percentage of total portfolio		3.80%		3.80%
Payment Deferral | Business Banking Portfolio
Financing Receivable, Troubled Debt Restructuring [Line Items]
Loan restructuring, modification, amount		$ 464		$ 464
Loan restructuring, modification, percentage of total portfolio		8.10%		8.10%

ALLOWANCE FOR CREDIT LOSSES, _4

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Summary of Changes in Allowance for Credit Losses (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Allowance for Loan and Lease Losses [Roll Forward]
Provision charged to income			$ 1,492	$ 283
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	$ 2,448	$ 1,227	1,252	1,242
Charge-offs	(257)	(159)	(611)	(453)
Recoveries	38	46	108	145
Net charge-offs	(219)	(113)	(503)	(308)
Provision charged to income	313	149	1,340	329
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	2,542	1,263	2,542	1,263
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	79	93	44	91
Provision for unfunded lending commitments	115	(48)	152	(46)
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	194	45	194	45
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	1,235	680	674	690
Charge-offs	(171)	(35)	(292)	(106)
Recoveries	1	3	7	17
Net charge-offs	(170)	(32)	(285)	(89)
Provision charged to income	224	64	1,076	111
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	1,289	712	1,289	712
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	69	93	44	91
Provision for unfunded lending commitments	83	(48)	111	(46)
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	152	45	152	45
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	1,213	547	578	552
Charge-offs	(86)	(124)	(319)	(347)
Recoveries	37	43	101	128
Net charge-offs	(49)	(81)	(218)	(219)
Provision charged to income	89	85	264	218
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	1,253	551	1,253	551
Retail | Reserve for unfunded lending commitments
Allowance for Loan and Lease Losses [Roll Forward]
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Beginning balance	10	0	0	0
Provision for unfunded lending commitments	32	0	41	0
Allowance for loan and lease losses / Reserve for unfunded lending commitments, Ending balance	42	$ 0	42	$ 0
Cumulative Effect, Period Of Adoption, Adjustment | 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	0		453
Cumulative Effect, Period Of Adoption, Adjustment | 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		(2)
Cumulative Effect, Period Of Adoption, Adjustment | 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	0		(176)
Cumulative Effect, Period Of Adoption, Adjustment | 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	0		(3)
Cumulative Effect, Period Of Adoption, Adjustment | 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	0		629
Cumulative Effect, Period Of Adoption, Adjustment | 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		1
Cumulative Effect, Period Of Adoption, Adjusted Balance | 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	2,448		1,705
Cumulative Effect, Period Of Adoption, Adjusted Balance | 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	79		42
Cumulative Effect, Period Of Adoption, Adjusted Balance | 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	1,235		498
Cumulative Effect, Period Of Adoption, Adjusted Balance | 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	69		41
Cumulative Effect, Period Of Adoption, Adjusted Balance | 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	1,213		1,207
Cumulative Effect, Period Of Adoption, Adjusted Balance | 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	$ 10		$ 1

ALLOWANCE FOR CREDIT LOSSES, _5

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Schedule of Additional Detail on the Cumulative Effect of Change in Accounting Principle (Details) - USD ($) $ in Millions	Sep. 30, 2020	Jan. 01, 2020	Dec. 31, 2019
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 124,071		$ 119,088
ACL Balance	$ 2,736	$ 1,747	$ 1,296
Coverage	2.20%	1.50%	1.10%
Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 62,362		$ 57,538
ACL Balance	$ 1,441	$ 539	$ 718
Coverage	2.30%	0.90%	1.20%
Commercial | Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 45,185		$ 41,479
ACL Balance	$ 826	$ 376	$ 575
Coverage	1.80%	0.90%	1.40%
Commercial | Commercial real estate
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 14,889		$ 13,522
ACL Balance	$ 548	$ 67	$ 124
Coverage	3.70%	0.50%	0.90%
Commercial | Leases
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 2,288		$ 2,537
ACL Balance	$ 67	$ 96	$ 19
Coverage	2.90%	3.80%	0.70%
Commercial | SBA Guaranteed PPP Loans
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 4,700
Coverage reduction, basis points	0.21%
Retail
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 61,709		$ 61,550
ACL Balance	$ 1,295	$ 1,208	$ 578
Coverage	2.10%	2.00%	0.90%
Retail | Residential mortgages
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 19,633		$ 19,083
ACL Balance	$ 133	$ 130	$ 35
Coverage	0.70%	0.70%	0.20%
Retail | Home equity
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 12,322		$ 13,154
ACL Balance	$ 156	$ 156	$ 83
Coverage	1.30%	1.20%	0.60%
Retail | Automobile
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 12,035		$ 12,120
ACL Balance	$ 221	$ 206	$ 123
Coverage	1.80%	1.70%	1.00%
Retail | Education
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 11,631		$ 10,347
ACL Balance	$ 386	$ 414	$ 116
Coverage	3.30%	4.00%	1.10%
Retail | Other retail
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 6,088		$ 6,846
ACL Balance	$ 399	$ 302	$ 221
Coverage	6.60%	4.40%	3.20%
Accounting Standards Update 2016-13
Accounts, Notes, Loans and Financing Receivable [Line Items]
ACL Balance		$ 451
Accounting Standards Update 2016-13 | Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
ACL Balance		(179)
Accounting Standards Update 2016-13 | Commercial | Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
ACL Balance		(199)
Accounting Standards Update 2016-13 | Commercial | Commercial real estate
Accounts, Notes, Loans and Financing Receivable [Line Items]
ACL Balance		(57)
Accounting Standards Update 2016-13 | Commercial | Leases
Accounts, Notes, Loans and Financing Receivable [Line Items]
ACL Balance		77
Accounting Standards Update 2016-13 | Retail
Accounts, Notes, Loans and Financing Receivable [Line Items]
ACL Balance		630
Accounting Standards Update 2016-13 | Retail | Residential mortgages
Accounts, Notes, Loans and Financing Receivable [Line Items]
ACL Balance		95
Accounting Standards Update 2016-13 | Retail | Home equity
Accounts, Notes, Loans and Financing Receivable [Line Items]
ACL Balance		73
Accounting Standards Update 2016-13 | Retail | Automobile
Accounts, Notes, Loans and Financing Receivable [Line Items]
ACL Balance		83
Accounting Standards Update 2016-13 | Retail | Education
Accounts, Notes, Loans and Financing Receivable [Line Items]
ACL Balance		298
Accounting Standards Update 2016-13 | Retail | Other retail
Accounts, Notes, Loans and Financing Receivable [Line Items]
ACL Balance		$ 81

ALLOWANCE FOR CREDIT LOSSES, _6

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Amortized Cost Basis by Credit Quality Indicator (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Financing Receivable, Credit Quality Indicator [Line Items]
Total	$ 124,071	$ 119,088
Commercial
Financing Receivable, Credit Quality Indicator [Line Items]
2020	9,853
2019	11,332
2018	9,674
2017	5,060
2016	3,009
Prior to 2016	5,000
Within the Revolving Period	18,057
Converted to Term	377
Total	62,362	57,538
Commercial | Pass
Financing Receivable, Credit Quality Indicator [Line Items]
2020	9,584
2019	10,556
2018	8,711
2017	4,469
2016	2,540
Prior to 2016	4,482
Within the Revolving Period	16,188
Converted to Term	182
Total	56,712
Commercial | Special Mention
Financing Receivable, Credit Quality Indicator [Line Items]
2020	69
2019	493
2018	368
2017	392
2016	268
Prior to 2016	256
Within the Revolving Period	969
Converted to Term	125
Total	2,940
Commercial | Substandard
Financing Receivable, Credit Quality Indicator [Line Items]
2020	128
2019	223
2018	498
2017	155
2016	142
Prior to 2016	206
Within the Revolving Period	690
Converted to Term	19
Total	2,061
Commercial | Doubtful
Financing Receivable, Credit Quality Indicator [Line Items]
2020	72
2019	60
2018	97
2017	44
2016	59
Prior to 2016	56
Within the Revolving Period	210
Converted to Term	51
Total	649
Commercial | Commercial
Financing Receivable, Credit Quality Indicator [Line Items]
2020	7,648
2019	7,340
2018	5,436
2017	3,039
2016	1,712
Prior to 2016	2,857
Within the Revolving Period	16,823
Converted to Term	330
Total	45,185	41,479
Commercial | Commercial | Pass
Financing Receivable, Credit Quality Indicator [Line Items]
2020	7,478
2019	6,823
2018	4,838
2017	2,747
2016	1,515
Prior to 2016	2,453
Within the Revolving Period	15,115
Converted to Term	182
Total	41,151
Commercial | Commercial | Special Mention
Financing Receivable, Credit Quality Indicator [Line Items]
2020	58
2019	275
2018	237
2017	149
2016	92
Prior to 2016	222
Within the Revolving Period	892
Converted to Term	125
Total	2,050
Commercial | Commercial | Substandard
Financing Receivable, Credit Quality Indicator [Line Items]
2020	60
2019	220
2018	326
2017	100
2016	85
Prior to 2016	140
Within the Revolving Period	630
Converted to Term	19
Total	1,580
Commercial | Commercial | Doubtful
Financing Receivable, Credit Quality Indicator [Line Items]
2020	52
2019	22
2018	35
2017	43
2016	20
Prior to 2016	42
Within the Revolving Period	186
Converted to Term	4
Total	404
Commercial | Commercial real estate
Financing Receivable, Credit Quality Indicator [Line Items]
2020	1,873
2019	3,661
2018	3,959
2017	1,840
2016	1,085
Prior to 2016	1,190
Within the Revolving Period	1,234
Converted to Term	47
Total	14,889	13,522
Commercial | Commercial real estate | Pass
Financing Receivable, Credit Quality Indicator [Line Items]
2020	1,774
2019	3,406
2018	3,608
2017	1,553
2016	825
Prior to 2016	1,112
Within the Revolving Period	1,073
Converted to Term	0
Total	13,351
Commercial | Commercial real estate | Special Mention
Financing Receivable, Credit Quality Indicator [Line Items]
2020	11
2019	216
2018	128
2017	237
2016	171
Prior to 2016	9
Within the Revolving Period	77
Converted to Term	0
Total	849
Commercial | Commercial real estate | Substandard
Financing Receivable, Credit Quality Indicator [Line Items]
2020	68
2019	1
2018	170
2017	50
2016	53
Prior to 2016	66
Within the Revolving Period	60
Converted to Term	0
Total	468
Commercial | Commercial real estate | Doubtful
Financing Receivable, Credit Quality Indicator [Line Items]
2020	20
2019	38
2018	53
2017	0
2016	36
Prior to 2016	3
Within the Revolving Period	24
Converted to Term	47
Total	221
Commercial | Leases
Financing Receivable, Credit Quality Indicator [Line Items]
2020	332
2019	331
2018	279
2017	181
2016	212
Prior to 2016	953
Within the Revolving Period	0
Converted to Term	0
Total	2,288	2,537
Commercial | Leases | Pass
Financing Receivable, Credit Quality Indicator [Line Items]
2020	332
2019	327
2018	265
2017	169
2016	200
Prior to 2016	917
Within the Revolving Period	0
Converted to Term	0
Total	2,210
Commercial | Leases | Special Mention
Financing Receivable, Credit Quality Indicator [Line Items]
2020	0
2019	2
2018	3
2017	6
2016	5
Prior to 2016	25
Within the Revolving Period	0
Converted to Term	0
Total	41
Commercial | Leases | Substandard
Financing Receivable, Credit Quality Indicator [Line Items]
2020	0
2019	2
2018	2
2017	5
2016	4
Prior to 2016	0
Within the Revolving Period	0
Converted to Term	0
Total	13
Commercial | Leases | Doubtful
Financing Receivable, Credit Quality Indicator [Line Items]
2020	0
2019	0
2018	9
2017	1
2016	3
Prior to 2016	11
Within the Revolving Period	0
Converted to Term	0
Total	24
Commercial | SBA Guaranteed PPP Loans
Financing Receivable, Credit Quality Indicator [Line Items]
Total	4,700
Retail
Financing Receivable, Credit Quality Indicator [Line Items]
2020	12,825
2019	12,260
2018	5,972
2017	5,429
2016	4,976
Prior to 2016	7,044
Within the Revolving Period	11,770
Converted to Term	1,433
Total	61,709	61,550
Retail | Residential mortgages
Financing Receivable, Credit Quality Indicator [Line Items]
2020	5,040
2019	3,853
2018	1,485
2017	2,224
2016	3,049
Prior to 2016	3,982
Within the Revolving Period	0
Converted to Term	0
Total	19,633	19,083
Retail | Home equity
Financing Receivable, Credit Quality Indicator [Line Items]
2020	5
2019	43
2018	70
2017	77
2016	47
Prior to 2016	921
Within the Revolving Period	9,752
Converted to Term	1,407
Total	12,322	13,154
Retail | Automobile
Financing Receivable, Credit Quality Indicator [Line Items]
2020	3,552
2019	3,804
2018	2,107
2017	1,433
2016	791
Prior to 2016	348
Within the Revolving Period	0
Converted to Term	0
Total	12,035	12,120
Retail | Education
Financing Receivable, Credit Quality Indicator [Line Items]
2020	2,918
2019	2,864
2018	1,703
2017	1,431
2016	1,031
Prior to 2016	1,684
Within the Revolving Period	0
Converted to Term	0
Total	11,631	10,347
Retail | Other retail
Financing Receivable, Credit Quality Indicator [Line Items]
2020	1,310
2019	1,696
2018	607
2017	264
2016	58
Prior to 2016	109
Within the Revolving Period	2,018
Converted to Term	26
Total	6,088	$ 6,846
Greater than 800 | Retail
Financing Receivable, Credit Quality Indicator [Line Items]
2020	4,231
2019	4,604
2018	2,218
2017	2,513
2016	2,650
Prior to 2016	3,222
Within the Revolving Period	4,632
Converted to Term	360
Total	24,430
Greater than 800 | Retail | Residential mortgages
Financing Receivable, Credit Quality Indicator [Line Items]
2020	1,971
2019	1,983
2018	751
2017	1,297
2016	1,833
Prior to 2016	2,061
Within the Revolving Period	0
Converted to Term	0
Total	9,896
Greater than 800 | Retail | Home equity
Financing Receivable, Credit Quality Indicator [Line Items]
2020	3
2019	9
2018	11
2017	7
2016	5
Prior to 2016	245
Within the Revolving Period	4,319
Converted to Term	360
Total	4,959
Greater than 800 | Retail | Automobile
Financing Receivable, Credit Quality Indicator [Line Items]
2020	780
2019	862
2018	472
2017	358
2016	209
Prior to 2016	91
Within the Revolving Period	0
Converted to Term	0
Total	2,772
Greater than 800 | Retail | Education
Financing Receivable, Credit Quality Indicator [Line Items]
2020	1,191
2019	1,276
2018	810
2017	772
2016	586
Prior to 2016	776
Within the Revolving Period	0
Converted to Term	0
Total	5,411
Greater than 800 | Retail | Other retail
Financing Receivable, Credit Quality Indicator [Line Items]
2020	286
2019	474
2018	174
2017	79
2016	17
Prior to 2016	49
Within the Revolving Period	313
Converted to Term	0
Total	1,392
740-799 | Retail
Financing Receivable, Credit Quality Indicator [Line Items]
2020	5,208
2019	4,237
2018	1,914
2017	1,571
2016	1,309
Prior to 2016	1,744
Within the Revolving Period	3,845
Converted to Term	342
Total	20,170
740-799 | Retail | Residential mortgages
Financing Receivable, Credit Quality Indicator [Line Items]
2020	2,351
2019	1,341
2018	463
2017	612
2016	776
Prior to 2016	977
Within the Revolving Period	0
Converted to Term	0
Total	6,520
740-799 | Retail | Home equity
Financing Receivable, Credit Quality Indicator [Line Items]
2020	1
2019	7
2018	7
2017	7
2016	4
Prior to 2016	204
Within the Revolving Period	3,224
Converted to Term	340
Total	3,794
740-799 | Retail | Automobile
Financing Receivable, Credit Quality Indicator [Line Items]
2020	1,130
2019	1,127
2018	606
2017	406
2016	214
Prior to 2016	87
Within the Revolving Period	0
Converted to Term	0
Total	3,570
740-799 | Retail | Education
Financing Receivable, Credit Quality Indicator [Line Items]
2020	1,307
2019	1,151
2018	621
2017	449
2016	292
Prior to 2016	443
Within the Revolving Period	0
Converted to Term	0
Total	4,263
740-799 | Retail | Other retail
Financing Receivable, Credit Quality Indicator [Line Items]
2020	419
2019	611
2018	217
2017	97
2016	23
Prior to 2016	33
Within the Revolving Period	621
Converted to Term	2
Total	2,023
680-739 | Retail
Financing Receivable, Credit Quality Indicator [Line Items]
2020	2,365
2019	2,211
2018	1,087
2017	768
2016	618
Prior to 2016	1,022
Within the Revolving Period	2,226
Converted to Term	299
Total	10,596
680-739 | Retail | Residential mortgages
Financing Receivable, Credit Quality Indicator [Line Items]
2020	596
2019	408
2018	193
2017	207
2016	317
Prior to 2016	500
Within the Revolving Period	0
Converted to Term	0
Total	2,221
680-739 | Retail | Home equity
Financing Receivable, Credit Quality Indicator [Line Items]
2020	0
2019	4
2018	9
2017	14
2016	8
Prior to 2016	197
Within the Revolving Period	1,671
Converted to Term	293
Total	2,196
680-739 | Retail | Automobile
Financing Receivable, Credit Quality Indicator [Line Items]
2020	1,028
2019	1,012
2018	527
2017	327
2016	170
Prior to 2016	69
Within the Revolving Period	0
Converted to Term	0
Total	3,133
680-739 | Retail | Education
Financing Receivable, Credit Quality Indicator [Line Items]
2020	385
2019	378
2018	217
2017	160
2016	110
Prior to 2016	239
Within the Revolving Period	0
Converted to Term	0
Total	1,489
680-739 | Retail | Other retail
Financing Receivable, Credit Quality Indicator [Line Items]
2020	356
2019	409
2018	141
2017	60
2016	13
Prior to 2016	17
Within the Revolving Period	555
Converted to Term	6
Total	1,557
620-679 | Retail
Financing Receivable, Credit Quality Indicator [Line Items]
2020	846
2019	870
2018	453
2017	310
2016	217
Prior to 2016	541
Within the Revolving Period	601
Converted to Term	208
Total	4,046
620-679 | Retail | Residential mortgages
Financing Receivable, Credit Quality Indicator [Line Items]
2020	101
2019	97
2018	44
2017	51
2016	69
Prior to 2016	235
Within the Revolving Period	0
Converted to Term	0
Total	597
620-679 | Retail | Home equity
Financing Receivable, Credit Quality Indicator [Line Items]
2020	0
2019	8
2018	16
2017	19
2016	12
Prior to 2016	146
Within the Revolving Period	420
Converted to Term	201
Total	822
620-679 | Retail | Automobile
Financing Receivable, Credit Quality Indicator [Line Items]
2020	523
2019	557
2018	300
2017	185
2016	102
Prior to 2016	46
Within the Revolving Period	0
Converted to Term	0
Total	1,713
620-679 | Retail | Education
Financing Receivable, Credit Quality Indicator [Line Items]
2020	27
2019	52
2018	42
2017	36
2016	31
Prior to 2016	108
Within the Revolving Period	0
Converted to Term	0
Total	296
620-679 | Retail | Other retail
Financing Receivable, Credit Quality Indicator [Line Items]
2020	195
2019	156
2018	51
2017	19
2016	3
Prior to 2016	6
Within the Revolving Period	181
Converted to Term	7
Total	618
Less than 620 | Retail
Financing Receivable, Credit Quality Indicator [Line Items]
2020	128
2019	335
2018	300
2017	266
2016	182
Prior to 2016	434
Within the Revolving Period	198
Converted to Term	222
Total	2,065
Less than 620 | Retail | Residential mortgages
Financing Receivable, Credit Quality Indicator [Line Items]
2020	17
2019	23
2018	34
2017	56
2016	54
Prior to 2016	197
Within the Revolving Period	0
Converted to Term	0
Total	381
Less than 620 | Retail | Home equity
Financing Receivable, Credit Quality Indicator [Line Items]
2020	1
2019	15
2018	27
2017	30
2016	18
Prior to 2016	129
Within the Revolving Period	117
Converted to Term	213
Total	550
Less than 620 | Retail | Automobile
Financing Receivable, Credit Quality Indicator [Line Items]
2020	90
2019	245
2018	202
2017	157
2016	96
Prior to 2016	48
Within the Revolving Period	0
Converted to Term	0
Total	838
Less than 620 | Retail | Education
Financing Receivable, Credit Quality Indicator [Line Items]
2020	2
2019	7
2018	13
2017	14
2016	12
Prior to 2016	56
Within the Revolving Period	0
Converted to Term	0
Total	104
Less than 620 | Retail | Other retail
Financing Receivable, Credit Quality Indicator [Line Items]
2020	18
2019	45
2018	24
2017	9
2016	2
Prior to 2016	4
Within the Revolving Period	81
Converted to Term	9
Total	192
No FICO available | Retail
Financing Receivable, Credit Quality Indicator [Line Items]
2020	47
2019	3
2018	0
2017	1
2016	0
Prior to 2016	81
Within the Revolving Period	268
Converted to Term	2
Total	402
No FICO available | Retail | Residential mortgages
Financing Receivable, Credit Quality Indicator [Line Items]
2020	4
2019	1
2018	0
2017	1
2016	0
Prior to 2016	12
Within the Revolving Period	0
Converted to Term	0
Total	18
No FICO available | Retail | Home equity
Financing Receivable, Credit Quality Indicator [Line Items]
2020	0
2019	0
2018	0
2017	0
2016	0
Prior to 2016	0
Within the Revolving Period	1
Converted to Term	0
Total	1
No FICO available | Retail | Automobile
Financing Receivable, Credit Quality Indicator [Line Items]
2020	1
2019	1
2018	0
2017	0
2016	0
Prior to 2016	7
Within the Revolving Period	0
Converted to Term	0
Total	9
No FICO available | Retail | Education
Financing Receivable, Credit Quality Indicator [Line Items]
2020	6
2019	0
2018	0
2017	0
2016	0
Prior to 2016	62
Within the Revolving Period	0
Converted to Term	0
Total	68
No FICO available | Retail | Other retail
Financing Receivable, Credit Quality Indicator [Line Items]
2020	36
2019	1
2018	0
2017	0
2016	0
Prior to 2016	0
Within the Revolving Period	267
Converted to Term	2
Total	$ 306

ALLOWANCE FOR CREDIT LOSSES, _7

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Nonaccrual Loans and Leases by Class (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Financing Receivable, Past Due [Line Items]
Nonaccrual loans and leases	$ 1,277	$ 703
90 days past due and accruing	28
Nonaccrual with no related ACL	353
Commercial
Financing Receivable, Past Due [Line Items]
Nonaccrual loans and leases	760	245
90 days past due and accruing	3
Nonaccrual with no related ACL	36
Commercial | Commercial
Financing Receivable, Past Due [Line Items]
Nonaccrual loans and leases	435	240
90 days past due and accruing	3
Nonaccrual with no related ACL	33
Commercial | Commercial real estate
Financing Receivable, Past Due [Line Items]
Nonaccrual loans and leases	323	2
90 days past due and accruing	0
Nonaccrual with no related ACL	3
Commercial | Leases
Financing Receivable, Past Due [Line Items]
Nonaccrual loans and leases	2	3
90 days past due and accruing	0
Nonaccrual with no related ACL	0
Retail
Financing Receivable, Past Due [Line Items]
Nonaccrual loans and leases	517	458
90 days past due and accruing	25
Nonaccrual with no related ACL	317
Retail | Residential mortgages
Financing Receivable, Past Due [Line Items]
Nonaccrual loans and leases	131	93
90 days past due and accruing	17
Nonaccrual with no related ACL	101
Retail | Home equity
Financing Receivable, Past Due [Line Items]
Nonaccrual loans and leases	265	246
90 days past due and accruing	0
Nonaccrual with no related ACL	192
Retail | Automobile
Financing Receivable, Past Due [Line Items]
Nonaccrual loans and leases	80	67
90 days past due and accruing	0
Nonaccrual with no related ACL	18
Retail | Education
Financing Receivable, Past Due [Line Items]
Nonaccrual loans and leases	16	18
90 days past due and accruing	2
Nonaccrual with no related ACL	5
Retail | Other retail
Financing Receivable, Past Due [Line Items]
Nonaccrual loans and leases	25	$ 34
90 days past due and accruing	6
Nonaccrual with no related ACL	$ 1

ALLOWANCE FOR CREDIT LOSSES, _8

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Accruing and Nonaccruing Past Due Amounts (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Financing Receivable, Past Due [Line Items]
Current	$ 122,724	$ 117,946
Total	124,071	119,088
Financing Receivables, 30 to 59 Days Past Due
Financing Receivable, Past Due [Line Items]
Past Due	519	511
Financing Receivables 60 To 89 Days Past Due
Financing Receivable, Past Due [Line Items]
Past Due	261	212
Financing Receivables 90 Days or More Past Due
Financing Receivable, Past Due [Line Items]
Past Due	567	419
Commercial
Financing Receivable, Past Due [Line Items]
Current	61,872	57,358
Total	62,362	57,538
Commercial | Commercial
Financing Receivable, Past Due [Line Items]
Current	44,845	41,340
Total	45,185	41,479
Commercial | Commercial real estate
Financing Receivable, Past Due [Line Items]
Current	14,743	13,520
Total	14,889	13,522
Commercial | Leases
Financing Receivable, Past Due [Line Items]
Current	2,284	2,498
Total	2,288	2,537
Commercial | Financing Receivables, 30 to 59 Days Past Due
Financing Receivable, Past Due [Line Items]
Past Due	196	83
Commercial | Financing Receivables, 30 to 59 Days Past Due | Commercial
Financing Receivable, Past Due [Line Items]
Past Due	105	45
Commercial | Financing Receivables, 30 to 59 Days Past Due | Commercial real estate
Financing Receivable, Past Due [Line Items]
Past Due	90	1
Commercial | Financing Receivables, 30 to 59 Days Past Due | Leases
Financing Receivable, Past Due [Line Items]
Past Due	1	37
Commercial | Financing Receivables 60 To 89 Days Past Due
Financing Receivable, Past Due [Line Items]
Past Due	130	28
Commercial | Financing Receivables 60 To 89 Days Past Due | Commercial
Financing Receivable, Past Due [Line Items]
Past Due	129	27
Commercial | Financing Receivables 60 To 89 Days Past Due | Commercial real estate
Financing Receivable, Past Due [Line Items]
Past Due	0	1
Commercial | Financing Receivables 60 To 89 Days Past Due | Leases
Financing Receivable, Past Due [Line Items]
Past Due	1	0
Commercial | Financing Receivables 90 Days or More Past Due
Financing Receivable, Past Due [Line Items]
Past Due	164	69
Commercial | Financing Receivables 90 Days or More Past Due | Commercial
Financing Receivable, Past Due [Line Items]
Past Due	106	67
Commercial | Financing Receivables 90 Days or More Past Due | Commercial real estate
Financing Receivable, Past Due [Line Items]
Past Due	56	0
Commercial | Financing Receivables 90 Days or More Past Due | Leases
Financing Receivable, Past Due [Line Items]
Past Due	2	2
Retail
Financing Receivable, Past Due [Line Items]
Current	60,852	60,588
Total	61,709	61,550
Retail | Residential mortgages
Financing Receivable, Past Due [Line Items]
Current	19,430	18,947
Total	19,633	19,083
Retail | Home equity
Financing Receivable, Past Due [Line Items]
Current	12,007	12,834
Total	12,322	13,154
Retail | Automobile
Financing Receivable, Past Due [Line Items]
Current	11,825	11,788
Total	12,035	12,120
Retail | Education
Financing Receivable, Past Due [Line Items]
Current	11,585	10,290
Total	11,631	10,347
Retail | Other retail
Financing Receivable, Past Due [Line Items]
Current	6,005	6,729
Total	6,088	6,846
Retail | Financing Receivables, 30 to 59 Days Past Due
Financing Receivable, Past Due [Line Items]
Past Due	323	428
Retail | Financing Receivables, 30 to 59 Days Past Due | Residential mortgages
Financing Receivable, Past Due [Line Items]
Past Due	64	35
Retail | Financing Receivables, 30 to 59 Days Past Due | Home equity
Financing Receivable, Past Due [Line Items]
Past Due	51	91
Retail | Financing Receivables, 30 to 59 Days Past Due | Automobile
Financing Receivable, Past Due [Line Items]
Past Due	147	227
Retail | Financing Receivables, 30 to 59 Days Past Due | Education
Financing Receivable, Past Due [Line Items]
Past Due	28	30
Retail | Financing Receivables, 30 to 59 Days Past Due | Other retail
Financing Receivable, Past Due [Line Items]
Past Due	33	45
Retail | Financing Receivables 60 To 89 Days Past Due
Financing Receivable, Past Due [Line Items]
Past Due	131	184
Retail | Financing Receivables 60 To 89 Days Past Due | Residential mortgages
Financing Receivable, Past Due [Line Items]
Past Due	16	17
Retail | Financing Receivables 60 To 89 Days Past Due | Home equity
Financing Receivable, Past Due [Line Items]
Past Due	29	40
Retail | Financing Receivables 60 To 89 Days Past Due | Automobile
Financing Receivable, Past Due [Line Items]
Past Due	52	81
Retail | Financing Receivables 60 To 89 Days Past Due | Education
Financing Receivable, Past Due [Line Items]
Past Due	12	15
Retail | Financing Receivables 60 To 89 Days Past Due | Other retail
Financing Receivable, Past Due [Line Items]
Past Due	22	31
Retail | Financing Receivables 90 Days or More Past Due
Financing Receivable, Past Due [Line Items]
Past Due	403	350
Retail | Financing Receivables 90 Days or More Past Due | Residential mortgages
Financing Receivable, Past Due [Line Items]
Past Due	123	84
Retail | Financing Receivables 90 Days or More Past Due | Home equity
Financing Receivable, Past Due [Line Items]
Past Due	235	189
Retail | Financing Receivables 90 Days or More Past Due | Automobile
Financing Receivable, Past Due [Line Items]
Past Due	11	24
Retail | Financing Receivables 90 Days or More Past Due | Education
Financing Receivable, Past Due [Line Items]
Past Due	6	12
Retail | Financing Receivables 90 Days or More Past Due | Other retail
Financing Receivable, Past Due [Line Items]
Past Due	$ 28	$ 41

ALLOWANCE FOR CREDIT LOSSES, _9

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Troubled Debt Restructurings (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Accounts, Notes, Loans and Financing Receivable [Line Items]
Unfunded commitments related to TDRs	$ 49	$ 42
Commercial
Accounts, Notes, Loans and Financing Receivable [Line Items]
Troubled Debt Restructuring	294	297
Retail
Accounts, Notes, Loans and Financing Receivable [Line Items]
Troubled Debt Restructuring	$ 715	$ 667

ALLOWANCE FOR CREDIT LOSSES,_10

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Troubled Debt Restructuring Activity (Details) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020USD ($)contract	Sep. 30, 2019USD ($)contract	Sep. 30, 2020USD ($)contract	Sep. 30, 2019USD ($)contract
Interest Rate Reduction
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	505	928	2,259	2,649
Amortized Cost | $	$ 13	$ 14	$ 44	$ 37
Maturity Extension
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	152	34	322	130
Amortized Cost | $	$ 113	$ 4	$ 141	$ 17
Other
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	1,458	809	3,295	1,975
Amortized Cost | $	$ 32	$ 31	$ 173	$ 154
Commercial | Interest Rate Reduction
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	0	2	0	3
Amortized Cost | $	$ 0	$ 0	$ 0	$ 0
Commercial | Maturity Extension
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	12	6	18	19
Amortized Cost | $	$ 103	$ 1	$ 106	$ 2
Commercial | Other
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	2	6	34	24
Amortized Cost | $	$ 1	$ 15	$ 95	$ 102
Commercial | Commercial | Interest Rate Reduction
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	0	2	0	3
Amortized Cost | $	$ 0	$ 0	$ 0	$ 0
Commercial | Commercial | Maturity Extension
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	12	6	18	18
Amortized Cost | $	$ 103	$ 1	$ 106	$ 2
Commercial | Commercial | Other
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	2	6	34	24
Amortized Cost | $	$ 1	$ 15	$ 95	$ 102
Commercial | Commercial real estate | Interest Rate Reduction
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	0	0	0	0
Amortized Cost | $	$ 0	$ 0	$ 0	$ 0
Commercial | Commercial real estate | Maturity Extension
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	0	0	0	1
Amortized Cost | $	$ 0	$ 0	$ 0	$ 0
Commercial | Commercial real estate | Other
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	0	0	0	0
Amortized Cost | $	$ 0	$ 0	$ 0	$ 0
Retail | Interest Rate Reduction
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	505	926	2,259	2,646
Amortized Cost | $	$ 13	$ 14	$ 44	$ 37
Retail | Maturity Extension
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	140	28	304	111
Amortized Cost | $	$ 10	$ 3	$ 35	$ 15
Retail | Other
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	1,456	803	3,261	1,951
Amortized Cost | $	$ 31	$ 16	$ 78	$ 52
Retail | Residential mortgages | Interest Rate Reduction
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	47	12	139	25
Amortized Cost | $	$ 9	$ 2	$ 26	$ 6
Retail | Residential mortgages | Maturity Extension
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	41	8	149	29
Amortized Cost | $	$ 6	$ 2	$ 27	$ 5
Retail | Residential mortgages | Other
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	19	25	60	87
Amortized Cost | $	$ 4	$ 4	$ 11	$ 13
Retail | Home equity | Interest Rate Reduction
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	23	63	96	148
Amortized Cost | $	$ 2	$ 6	$ 8	$ 15
Retail | Home equity | Maturity Extension
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	52	16	107	66
Amortized Cost | $	$ 4	$ 1	$ 8	$ 10
Retail | Home equity | Other
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	104	120	365	358
Amortized Cost | $	$ 6	$ 6	$ 21	$ 21
Retail | Automobile | Interest Rate Reduction
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	25	46	108	111
Amortized Cost | $	$ 1	$ 1	$ 2	$ 2
Retail | Automobile | Maturity Extension
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	47	4	48	16
Amortized Cost | $	$ 0	$ 0	$ 0	$ 0
Retail | Automobile | Other
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	1,119	309	2,212	933
Amortized Cost | $	$ 18	$ 4	$ 35	$ 13
Retail | Education | Interest Rate Reduction
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	0	0	0	0
Amortized Cost | $	$ 0	$ 0	$ 0	$ 0
Retail | Education | Maturity Extension
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	0	0	0	0
Amortized Cost | $	$ 0	$ 0	$ 0	$ 0
Retail | Education | Other
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	140	131	373	211
Amortized Cost | $	$ 3	$ 2	$ 9	$ 5
Retail | Other retail | Interest Rate Reduction
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	410	805	1,916	2,362
Amortized Cost | $	$ 1	$ 5	$ 8	$ 14
Retail | Other retail | Maturity Extension
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	0	0	0	0
Amortized Cost | $	$ 0	$ 0	$ 0	$ 0
Retail | Other retail | Other
Financing Receivable, Troubled Debt Restructuring [Line Items]
Number of Contracts | contract	74	218	251	362
Amortized Cost | $	$ 0	$ 0	$ 2	$ 0

ALLOWANCE FOR CREDIT LOSSES,_11

ALLOWANCE FOR CREDIT LOSSES, NONPERFORMING ASSETS, AND CONCENTRATIONS OF CREDIT RISK - Loans with Indicators of High Credit Risk (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
High loan-to-value
Financing Receivable, Credit Quality Indicator [Line Items]
Total	$ 503	$ 553
High loan-to-value | Residential Mortgages
Financing Receivable, Credit Quality Indicator [Line Items]
Total	408	402
High loan-to-value | Home Equity
Financing Receivable, Credit Quality Indicator [Line Items]
Total	95	151
High loan-to-value | Other Retail
Financing Receivable, Credit Quality Indicator [Line Items]
Total	0	0
Interest-only/negative amortization
Financing Receivable, Credit Quality Indicator [Line Items]
Total	2,594	2,043
Interest-only/negative amortization | Residential Mortgages
Financing Receivable, Credit Quality Indicator [Line Items]
Total	2,594	2,043
Interest-only/negative amortization | Home Equity
Financing Receivable, Credit Quality Indicator [Line Items]
Total	0	0
Interest-only/negative amortization | Other Retail
Financing Receivable, Credit Quality Indicator [Line Items]
Total	0	0
Low introductory rate
Financing Receivable, Credit Quality Indicator [Line Items]
Total	183	235
Low introductory rate | Residential Mortgages
Financing Receivable, Credit Quality Indicator [Line Items]
Total	0	0
Low introductory rate | Home Equity
Financing Receivable, Credit Quality Indicator [Line Items]
Total	0	0
Low introductory rate | Other Retail
Financing Receivable, Credit Quality Indicator [Line Items]
Total	183	235
Multiple characteristics and other
Financing Receivable, Credit Quality Indicator [Line Items]
Total	4
Multiple characteristics and other | Residential Mortgages
Financing Receivable, Credit Quality Indicator [Line Items]
Total	4
Multiple characteristics and other | Home Equity
Financing Receivable, Credit Quality Indicator [Line Items]
Total	0
Multiple characteristics and other | Other Retail
Financing Receivable, Credit Quality Indicator [Line Items]
Total	0
Credit risk, loans with increased credit exposure
Financing Receivable, Credit Quality Indicator [Line Items]
Total	3,284	2,831
Credit risk, loans with increased credit exposure | Residential Mortgages
Financing Receivable, Credit Quality Indicator [Line Items]
Total	3,006	2,445
Credit risk, loans with increased credit exposure | Home Equity
Financing Receivable, Credit Quality Indicator [Line Items]
Total	95	151
Credit risk, loans with increased credit exposure | Other Retail
Financing Receivable, Credit Quality Indicator [Line Items]
Total	$ 183	$ 235

MORTGAGE BANKING - Narrative (D

MORTGAGE BANKING - Narrative (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 124,071	$ 119,088
Mortgage loans serviced for others | Banking Subsidiaries
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 80,700	$ 77,500

MORTGAGE BANKING - Residential

MORTGAGE BANKING - Residential Mortgage Loan Sales (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Residential mortgages
SEC Schedule, 12-29, Real Estate Companies, Investment in Mortgage Loans on Real Estate [Line Items]
Cash Proceeds from residential mortgage loans sold with servicing retained	$ 9,504	$ 6,117	$ 23,668	$ 13,265
Mortgage banking fees
SEC Schedule, 12-29, Real Estate Companies, Investment in Mortgage Loans on Real Estate [Line Items]
Gain on sales	273	88	699	180
Contractually specified servicing, late and other anciliary fees	$ 56	$ 53	$ 169	$ 152

MORTGAGE BANKING - Changes Rela

MORTGAGE BANKING - Changes Related to MSRs - Fair Value Method (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
MSRs
Fair value as of beginning of period			$ 642
Fair value at end of the period	$ 606		606
Residential mortgages
MSRs
Fair value as of beginning of period	568	$ 531	642	$ 600
Amounts capitalized	85	78	238	170
Changes in unpaid principal balance during the period	(55)	(31)	(141)	(88)
Changes in fair value during the period	8	(68)	(323)	(172)
Fair value at end of the period	606	510	606	510
Cumulative Effect, Period Of Adoption, Adjustment | Residential mortgages
MSRs
Fair value as of beginning of period	0	0	190	0
Cumulative Effect, Period Of Adoption, Adjusted Balance | Residential mortgages
MSRs
Fair value as of beginning of period	$ 568	$ 531	$ 832	$ 600

MORTGAGE BANKING - Economic Ass

MORTGAGE BANKING - Economic Assumptions Used to Estimate Value of MSRs (Details) - USD ($) $ in Millions	9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Dec. 31, 2019
Servicing Assets and Servicing Liabilities at Fair Value, Assumptions Used to Estimate Fair Value [Abstract]
MSR portfolio fair value	$ 606		$ 642
Weighted average life (in years)	3 years 9 months 18 days	5 years 6 months
Weighted average constant prepayment rate	19.40%	13.90%
Weighted average option adjusted spread	6.08%	4.40%
Minimum
Servicing Assets at Fair Value [Line Items]
Sensitivity analysis, basis spread	0.50%	0.50%
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	$ 116	$ 116
Decline in fair value due to 50 bps decrease in option adjusted spread	$ 10	$ 12
Maximum
Servicing Assets at Fair Value [Line Items]
Sensitivity analysis, basis spread	1.00%	1.00%
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	$ 169	$ 222
Decline in fair value due to 100 bps decrease in option adjusted spread	$ 21	$ 25

MORTGAGE BANKING - Other Servic

MORTGAGE BANKING - Other Serviced Loans (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 124,071	$ 119,088
Education Loans Serviced For Others
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	866	0
SBA Loans Serviced For Others | CBNA and Other Subsidiaries
Accounts, Notes, Loans and Financing Receivable [Line Items]
Loans and leases	$ 44	$ 33

GOODWILL - Narrative (Details)

GOODWILL - Narrative (Details) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020USD ($)	Sep. 30, 2019USD ($)	Sep. 30, 2020USD ($)reporting_unit	Sep. 30, 2019USD ($)	Dec. 31, 2019USD ($)
Goodwill [Line Items]
Number of reporting units | reporting_unit			2
Goodwill acquired			$ 6
Goodwill impairment loss	$ 0	$ 0	0	$ 0
Amortization of intangibles			6	$ 8
Consumer Banking
Goodwill [Line Items]
Goodwill acquired			0
Goodwill accumulated impairment loss	5,900		5,900		$ 5,900
Commercial Banking
Goodwill [Line Items]
Goodwill acquired			6
Goodwill accumulated impairment loss	$ 50		$ 50		$ 50

GOODWILL - Goodwill Rollforward

GOODWILL - Goodwill Rollforward (Details) $ in Millions	9 Months Ended
	Sep. 30, 2020USD ($)
Goodwill [Roll Forward]
Balance at beginning of period	$ 7,044
Business acquisitions	6
Balance at end of period	7,050
Consumer Banking
Goodwill [Roll Forward]
Balance at beginning of period	2,258
Business acquisitions	0
Balance at end of period	2,258
Commercial Banking
Goodwill [Roll Forward]
Balance at beginning of period	4,786
Business acquisitions	6
Balance at end of period	$ 4,792

VARIABLE INTEREST ENTITIES - Na

VARIABLE INTEREST ENTITIES - Narrative (Details) - USD ($) $ in Millions	1 Months Ended	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019	Dec. 31, 2019
Variable Interest Entity
Lending to special purpose entities included in loans and leases	$ 124,071	$ 124,071		$ 124,071		$ 119,088
Purchases of debt securities available for sale	813			5,547	$ 4,633
Special Purpose Entities | Commitments to extend credit
Variable Interest Entity
Commitment amount	1,300	1,300		1,300		1,200
Special Purpose Entities | Commercial
Variable Interest Entity
Lending to special purpose entities included in loans and leases	1,173	1,173		1,173		1,101
LIHTC Investments
Variable Interest Entity
Net impairment losses recognized in earnings		0	$ 0	0	$ 0
Retail
Variable Interest Entity
Lending to special purpose entities included in loans and leases	61,709	61,709		61,709		61,550
Retail | Education
Variable Interest Entity
Lending to special purpose entities included in loans and leases	11,631	11,631		11,631		$ 10,347
Sale of loans	973	$ 973		$ 973
Gain on sale of loans	$ 32

VARIABLE INTEREST ENTITIES - Sc

VARIABLE INTEREST ENTITIES - Schedule of Variable Interest Entities (Details) - USD ($) $ in Millions		Sep. 30, 2020	Dec. 31, 2019
Variable Interest Entity
Lending to special purpose entities included in loans and leases		$ 124,071	$ 119,088
Securities available for sale	[1]	22,884	20,613
Special Purpose Entities | Commercial
Variable Interest Entity
Lending to special purpose entities included in loans and leases		1,173	1,101
LIHTC Investments
Variable Interest Entity
LIHTC investment included in other assets		1,543	1,401
LIHTC unfunded commitments included in other liabilities		810	716
Renewable Energy
Variable Interest Entity
Renewable energy investments included in other assets		410	355
Asset-backed securities
Variable Interest Entity
Securities available for sale		813	0
Asset-backed securities | Asset-backed securities
Variable Interest Entity
Securities available for sale		$ 813	$ 0
[1]	Includes only collateral pledged by the Company where counterparties have the right to sell or pledge the collateral.

VARIABLE INTEREST ENTITIES - _2

VARIABLE INTEREST ENTITIES - Schedule of Affordable Housing Tax Credit Investments (Details) - LIHTC Investments - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Variable Interest Entity
Tax credits included in income tax expense	$ 40	$ 30	$ 120	$ 99
Amortization expense included in income tax expense	42	33	127	105
Other tax benefits included in income tax expense	$ 10	$ 8	$ 30	$ 24

BORROWED FUNDS - Narrative (Det

BORROWED FUNDS - Narrative (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Debt Instrument [Line Items]
Short-term borrowed funds	$ 252	$ 274
Hedging basis adjustments	2,286	984
Available borrowing capacity	61,700
Federal Home Loan Bank Advances and Letters of Credit | Secured Debt
Debt Instrument [Line Items]
Short-term borrowed funds	3,700	9,800
Federal Home Loan Bank advances
Debt Instrument [Line Items]
Available borrowing capacity	13,200	7,200
Parent Company
Debt Instrument [Line Items]
Principal balance	3,500	2,500
Unamortized deferred issuance costs and/or discounts	(92)	(8)
Banking Subsidiaries
Debt Instrument [Line Items]
Principal balance	5,600	11,500
Unamortized deferred issuance costs and/or discounts	(13)	(13)
Hedging basis adjustments	$ 128	$ 50

BORROWED FUNDS - Long Term Debt

BORROWED FUNDS - Long Term Debt (Details) $ in Millions	1 Months Ended
	Sep. 30, 2020USD ($)note	Dec. 31, 2019USD ($)
Debt Instrument [Line Items]
Long-term borrowed funds	$ 9,109	$ 14,047
Private Exchange Offers
Debt Instrument [Line Items]
Principal amount	$ 621
Number of outstanding subordinated notes exchanged | note	5
Payment for tender offers	$ 11
Parent Company
Debt Instrument [Line Items]
Long-term borrowed funds	3,439
Parent Company | Subordinated Debt | 4.150% fixed-rate subordinated debt, due September 2022
Debt Instrument [Line Items]
Long-term borrowed funds	$ 181	348
Interest rate	4.15%
Parent Company | Subordinated Debt | 3.750% fixed-rate subordinated debt, due July 2024
Debt Instrument [Line Items]
Long-term borrowed funds	$ 159	250
Interest rate	3.75%
Parent Company | Subordinated Debt | 4.023% fixed-rate subordinated debt, due October 2024
Debt Instrument [Line Items]
Long-term borrowed funds	$ 25	42
Interest rate	4.023%
Parent Company | Subordinated Debt | 4.350% fixed-rate subordinated debt, due August 2025
Debt Instrument [Line Items]
Long-term borrowed funds	$ 193	249
Interest rate	4.35%
Parent Company | Subordinated Debt | 4.300% fixed-rate subordinated debt, due December 2025
Debt Instrument [Line Items]
Long-term borrowed funds	$ 450	750
Interest rate	4.30%
Parent Company | Subordinated Debt | 2.638% fixed-rate subordinated debt, due September 2032
Debt Instrument [Line Items]
Long-term borrowed funds	$ 542	0
Interest rate	2.638%
Parent Company | Senior Unsecured Notes | 2.375% fixed-rate senior unsecured debt, due July 2021
Debt Instrument [Line Items]
Long-term borrowed funds	$ 350	349
Interest rate	2.375%
Parent Company | Senior Unsecured Notes | 2.850% fixed-rate senior unsecured notes, due July 2026
Debt Instrument [Line Items]
Long-term borrowed funds	$ 497	496
Interest rate	2.85%
Parent Company | Senior Unsecured Notes | 2.500% fixed-rate senior unsecured notes, due February 2030
Debt Instrument [Line Items]
Long-term borrowed funds	$ 297	0
Interest rate	2.50%
Parent Company | Senior Unsecured Notes | 3.250% fixed-rate senior unsecured notes, due April 2030
Debt Instrument [Line Items]
Long-term borrowed funds	$ 745	0
Interest rate	3.25%
CBNA and Other Subsidiaries
Debt Instrument [Line Items]
Long-term borrowed funds	$ 5,670
CBNA and Other Subsidiaries | Senior Unsecured Notes | 2.250% senior unsecured notes, due March 2020
Debt Instrument [Line Items]
Long-term borrowed funds	$ 0	700
Interest rate	2.25%
CBNA and Other Subsidiaries | Senior Unsecured Notes | 2.678% floating-rate senior unsecured notes, due 2020
Debt Instrument [Line Items]
Long-term borrowed funds	$ 0	300
Interest rate	2.678%
CBNA and Other Subsidiaries | Senior Unsecured Notes | 2.217% floating-rate senior unsecured notes, due 2020
Debt Instrument [Line Items]
Long-term borrowed funds	$ 0	250
Interest rate	2.217%
CBNA and Other Subsidiaries | Senior Unsecured Notes | 2.200% senior unsecured notes, due May 2020
Debt Instrument [Line Items]
Long-term borrowed funds	$ 0	500
Interest rate	2.20%
CBNA and Other Subsidiaries | Senior Unsecured Notes | 2.250% senior unsecured notes, due October 2020
Debt Instrument [Line Items]
Long-term borrowed funds	$ 750	750
Interest rate	2.25%
CBNA and Other Subsidiaries | Senior Unsecured Notes | 2.550% senior unsecured notes, due May 2021
Debt Instrument [Line Items]
Long-term borrowed funds	$ 1,005	991
Interest rate	2.55%
CBNA and Other Subsidiaries | Senior Unsecured Notes | 3.250% senior unsecured notes, due February 2022
Debt Instrument [Line Items]
Long-term borrowed funds	$ 720	711
Interest rate	3.25%
CBNA and Other Subsidiaries | Senior Unsecured Notes | .985% floating-rate senior unsecured notes, due February 2022
Debt Instrument [Line Items]
Long-term borrowed funds	$ 299	299
Interest rate	0.985%
CBNA and Other Subsidiaries | Senior Unsecured Notes | 1.044% floating-rate senior unsecured notes, due May 2022
Debt Instrument [Line Items]
Long-term borrowed funds	$ 250	250
Interest rate	1.044%
CBNA and Other Subsidiaries | Senior Unsecured Notes | 2.650% senior unsecured notes, due May 2022
Debt Instrument [Line Items]
Long-term borrowed funds	$ 512	501
Interest rate	2.65%
CBNA and Other Subsidiaries | Senior Unsecured Notes | 3.700% senior unsecured notes, due March 2023
Debt Instrument [Line Items]
Long-term borrowed funds	$ 530	515
Interest rate	3.70%
CBNA and Other Subsidiaries | Senior Unsecured Notes | 1.168% floating-rate senior unsecured notes, due March 2023
Debt Instrument [Line Items]
Long-term borrowed funds	$ 249	249
Interest rate	1.168%
CBNA and Other Subsidiaries | Senior Unsecured Notes | 2.250% senior unsecured notes, due April 2025
Debt Instrument [Line Items]
Long-term borrowed funds	$ 745	0
Interest rate	2.25%
CBNA and Other Subsidiaries | Senior Unsecured Notes | 3.750% senior unsecured notes, due February 2026
Debt Instrument [Line Items]
Long-term borrowed funds	$ 555	521
Interest rate	3.75%
CBNA and Other Subsidiaries | Federal Home Loan Bank advances
Debt Instrument [Line Items]
Long-term borrowed funds	$ 19	5,008
Weighted average rate	0.943%
CBNA and Other Subsidiaries | Other
Debt Instrument [Line Items]
Long-term borrowed funds	$ 36	$ 18

BORROWED FUNDS - Maturities of

BORROWED FUNDS - Maturities of Long-term Borrowed Funds (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Debt Instrument [Line Items]
2020	$ 752
2021	1,364
2022	1,971
2023	780
2024	184
2025 and thereafter	4,058
Total	9,109	$ 14,047
Parent Company
Debt Instrument [Line Items]
2020	0
2021	350
2022	181
2023	0
2024	184
2025 and thereafter	2,724
Total	3,439
CBNA and Other Subsidiaries
Debt Instrument [Line Items]
2020	752
2021	1,014
2022	1,790
2023	780
2024	0
2025 and thereafter	1,334
Total	$ 5,670

DERIVATIVES - Narrative (Detail

DERIVATIVES - Narrative (Details) $ in Millions	Sep. 30, 2020USD ($)
Derivative Instruments and Hedging Activities Disclosure [Abstract]
Net gain (pre-tax) on derivatives expected to be reclassified in next 12 months	$ 2

DERIVATIVES - Schedule of Deriv

DERIVATIVES - Schedule of Derivative Instruments (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Derivative Assets
Derivative assets	$ 2,286	$ 984
Less: Gross amounts offset in the Consolidated Balance Sheets	(187)	(107)
Less: Cash collateral applied	(69)	(70)
Total net derivative fair values presented in the Consolidated Balance Sheets	2,030	807
Derivative Liabilities
Derivative Liabilities	506	322
Less: Gross amounts offset in the Consolidated Balance Sheets	(187)	(107)
Less: Cash collateral applied	(219)	(95)
Total net derivative fair values presented in the Consolidated Balance Sheets	100	120
Derivatives not designated as hedging instruments:
Derivative Assets
Derivative assets	2,282	983
Derivative Liabilities
Derivative Liabilities	505	322
Interest rate contracts
Derivative Assets
Derivative assets	1,765	773
Derivative Liabilities
Derivative Liabilities	217	133
Interest rate contracts | Derivatives designated as hedging instruments:
Derivatives, Fair Value [Line Items]
Notional amount	26,800	29,846
Derivative Assets
Derivative assets	4	1
Derivative Liabilities
Derivative Liabilities	1	0
Interest rate contracts | Derivatives not designated as hedging instruments:
Derivatives, Fair Value [Line Items]
Notional amount	148,161	142,386
Derivative Assets
Derivative assets	1,761	772
Derivative Liabilities
Derivative Liabilities	216	133
Foreign exchange contracts
Derivative Assets
Derivative assets	239	174
Derivative Liabilities
Derivative Liabilities	189	166
Foreign exchange contracts | Derivatives not designated as hedging instruments:
Derivatives, Fair Value [Line Items]
Notional amount	16,448	15,101
Derivative Assets
Derivative assets	239	174
Derivative Liabilities
Derivative Liabilities	189	166
TBA contracts
Derivative Assets
Derivative assets	7
Derivative Liabilities
Derivative Liabilities	34
TBA contracts | Derivatives not designated as hedging instruments:
Derivatives, Fair Value [Line Items]
Notional amount	13,161	0
Derivative Assets
Derivative assets	7	0
Derivative Liabilities
Derivative Liabilities	34	0
Other contracts
Derivative Assets
Derivative assets	275	37
Derivative Liabilities
Derivative Liabilities	66	23
Other contracts | Derivatives not designated as hedging instruments:
Derivatives, Fair Value [Line Items]
Notional amount	8,011	6,868
Derivative Assets
Derivative assets	275	37
Derivative Liabilities
Derivative Liabilities	$ 66	$ 23

DERIVATIVES - Schedule of Fair

DERIVATIVES - Schedule of Fair Value Hedges (Details) - Interest rate swap - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Interest expense - borrowed funds
Derivative Instruments, Gain (Loss) [Line Items]
Derivative	$ (16)	$ 18	$ 82	$ 122
Hedged Item	17	(18)	(78)	(121)
Interest and fees on loans and leases
Derivative Instruments, Gain (Loss) [Line Items]
Derivative	0	(10)	17	(26)
Hedged Item	0	10	(17)	26
Interest income - investment securities
Derivative Instruments, Gain (Loss) [Line Items]
Derivative	7	(13)	(114)	(13)
Hedged Item	$ (7)	$ 13	$ 114	$ 13

DERIVATIVES - Amounts Recorded

DERIVATIVES - Amounts Recorded in Balance Sheet (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Derivative [Line Items]
Carrying amount of hedged assets	$ 0	$ 0
Last-of-layer hedging amount	2,000
Carrying value of hedged asset in lay-of-layer hedging relationship	12,300	15,800
Debt securities available for sale
Derivative [Line Items]
Carrying amount of hedged assets	12,314	15,798
Cumulative amount of fair value hedging adjustments included in the carrying amount of the hedged items	107	(8)
Residential mortgages
Derivative [Line Items]
Carrying amount of hedged assets		976
Cumulative amount of fair value hedging adjustments included in the carrying amount of the hedged items		17
Debt securities available for sale
Derivative [Line Items]
Carrying amount of the hedged liabilities	0	0
Residential mortgages
Derivative [Line Items]
Carrying amount of the hedged liabilities		0
Long-term borrowed funds
Derivative [Line Items]
Carrying amount of the hedged liabilities	4,072	4,689
Cumulative amount of fair value hedging adjustments included in the carrying amount of long-term borrowed funds	$ 128	$ 50

DERIVATIVES - Effect of Derivat

DERIVATIVES - Effect of Derivative Instruments on Net Income and Stockholders' Equity (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Derivative Instruments, Gain (Loss) [Line Items]
Amount of pre-tax net (losses) gains recognized in OCI	$ 0	$ (5)	$ 118	$ 138
Interest Income
Derivative Instruments, Gain (Loss) [Line Items]
Amount of pretax net gains (losses) from OCI into income statement	68	(22)	128	(62)
Interest Expense
Derivative Instruments, Gain (Loss) [Line Items]
Amount of pretax net gains (losses) from OCI into income statement	$ (11)	$ 8	$ (22)	$ 9

DERIVATIVES - Effect of Custome

DERIVATIVES - Effect of Customer Derivatives and Economic Hedges on Net Income (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	$ 7	$ 190	$ 541	$ 357
Economic hedges | Foreign exchange and interest rate products | Customer interest rate contracts
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	7	196	1,276	850
Economic hedges | Foreign exchange and interest rate products | Customer foreign exchange contracts
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	80	(81)	73	(162)
Economic hedges | Foreign exchange and interest rate products | Derivative transactions to hedge interest rate risk
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	1	(182)	(1,245)	(809)
Economic hedges | Foreign exchange and interest rate products | Derivative transactions to hedge foreign exchange risk
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	(126)	130	(77)	224
Economic hedges | Foreign exchange and interest rate products | Other derivative contracts
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	26	0	(30)	0
Economic hedges | Foreign exchange and interest rate products | Derivative transactions to hedge other derivative risk
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	(25)	0	32	0
Economic hedges | Mortgage banking fees | Residential loan commitments
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	36	6	190	22
Economic hedges | Mortgage banking fees | Derivative contracts used to hedge residential loan commitments
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	6	29	(13)	24
Economic hedges | Mortgage banking fees | Derivative contracts used to hedge residential MSRs
Derivative Instruments, Gain (Loss) [Line Items]
Amounts Recognized in Noninterest Income	$ 2	$ 92	$ 335	$ 208

ACCUMULATED OTHER COMPREHENSI_3

ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS) - Schedule of Accumulated Other Comprehensive Income (Loss) (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance	$ 22,418	$ 22,017	$ 22,201	$ 20,817
Other comprehensive income before reclassifications	(44)	38	493	612
Other-than-temporary impairment not recognized in earnings on debt securities	0	(1)	0	0
Amounts reclassified to the Consolidated Statements of Operations	(40)	11	(72)	39
Net other comprehensive income	(84)	48	421	651
Ending balance	22,469	21,851	22,469	21,851
Total AOCI
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance	94	(488)	(411)	(1,096)
Net other comprehensive income	(84)	48	421	651
Ending balance	10	(440)	10	(440)
Net Unrealized (Losses) Gains on Derivatives
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance	54	(6)	3	(143)
Other comprehensive income before reclassifications	0	(4)	88	103
Other-than-temporary impairment not recognized in earnings on debt securities		0
Amounts reclassified to the Consolidated Statements of Operations	(42)	10	(79)	40
Net other comprehensive income	(42)	6	9	143
Ending balance	12	0	12	0
Net Unrealized (Losses) Gains on Debt Securities
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance	448	(25)	1	(490)
Other comprehensive income before reclassifications	(44)	42	405	509
Other-than-temporary impairment not recognized in earnings on debt securities		(1)
Amounts reclassified to the Consolidated Statements of Operations	(1)	(2)	(3)	(10)
Net other comprehensive income	(45)	39	402	499
Ending balance	403	14	403	14
Employee Benefit Plans
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance	(408)	(457)	(415)	(463)
Other comprehensive income before reclassifications	0	0	0	0
Other-than-temporary impairment not recognized in earnings on debt securities		0
Amounts reclassified to the Consolidated Statements of Operations	3	3	10	9
Net other comprehensive income	3	3	10	9
Ending balance	(405)	(454)	(405)	(454)
Cumulative Effect, Period Of Adoption, Adjustment
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Ending balance	(331)	17	(331)	17
Cumulative Effect, Period Of Adoption, Adjustment | Total AOCI
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance				5
Ending balance	$ 0	$ 5	$ 0	5
Cumulative Effect, Period Of Adoption, Adjustment | Net Unrealized (Losses) Gains on Derivatives
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance				0
Cumulative Effect, Period Of Adoption, Adjustment | Net Unrealized (Losses) Gains on Debt Securities
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance				5
Cumulative Effect, Period Of Adoption, Adjustment | Employee Benefit Plans
Accumulated Other Comprehensive Income (Loss), Net of Tax [Roll Forward]
Beginning balance				$ 0

STOCKHOLDERS' EQUITY - Treasury

STOCKHOLDERS' EQUITY - Treasury Stock Narrative (Details) - USD ($) $ in Millions	9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019
Equity [Abstract]
Repurchase of common stock	$ 270	$ 820
Treasury stock purchased (in shares)	7,548,655

STOCKHOLDERS' EQUITY - Authoriz

STOCKHOLDERS' EQUITY - Authorized Preferred Shares (Details) - USD ($) $ / shares in Units, $ in Millions	9 Months Ended
	Sep. 30, 2020	Dec. 31, 2019
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)	2,000,000	1,600,000
Preferred stock, value, issued	$ 1,965	$ 1,570
Series A Preferred Stock
Preferred Stock
Preferred stock, liquidation preference per share (in dollars per share)	$ 1,000
Preferred stock, issued (in shares)	250,000	250,000
Preferred stock, value, issued	$ 247	$ 247
Series B Preferred Stock
Preferred Stock
Preferred stock, liquidation preference per share (in dollars per share)	$ 1,000
Preferred stock, issued (in shares)	300,000	300,000
Preferred stock, value, issued	$ 296	$ 296
Series C Preferred Stock
Preferred Stock
Preferred stock, liquidation preference per share (in dollars per share)	$ 1,000
Preferred stock, issued (in shares)	300,000	300,000
Preferred stock, value, issued	$ 297	$ 297
Series D Preferred Stock
Preferred Stock
Preferred stock, liquidation preference per share (in dollars per share)	$ 1,000
Preferred stock, issued (in shares)	300,000	300,000
Preferred stock, value, issued	$ 293	$ 293
Liquidation preference per depository share (usd per share)	$ 25
Depositary shares issued (in shares)	12,000,000
Depository share interest percentage	2.50%
Series E Preferred Stock
Preferred Stock
Preferred stock, liquidation preference per share (in dollars per share)	$ 1,000
Preferred stock, issued (in shares)	450,000	450,000
Preferred stock, value, issued	$ 437	$ 437
Liquidation preference per depository share (usd per share)	$ 25
Depositary shares issued (in shares)	18,000,000
Depository share interest percentage	2.50%
Series F Preferred Stock
Preferred Stock
Preferred stock, liquidation preference per share (in dollars per share)	$ 1,000
Preferred stock, issued (in shares)	400,000	0
Preferred stock, value, issued	$ 395	$ 0

STOCKHOLDERS' EQUITY - Dividend

STOCKHOLDERS' EQUITY - Dividends (Details) - USD ($) $ / shares in Units, $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Class of Stock [Line Items]
Dividends declared per share of common stock (in usd per share)	$ 0.39	$ 0.36	$ 1.17	$ 1
Common stock dividends declared and paid	$ 168	$ 162	$ 504	$ 459
Preferred stock dividends declared and paid	$ 25	$ 17	$ 75	$ 50
Series A Preferred Stock
Class of Stock [Line Items]
Dividends declared per share of preferred stock (in usd per share)	$ 10.90	$ 27.50	$ 51.88	$ 55
Series B Preferred Stock
Class of Stock [Line Items]
Dividends declared per share of preferred stock (in usd per share)	0	0	30	30
Series C Preferred Stock
Class of Stock [Line Items]
Dividends declared per share of preferred stock (in usd per share)	15.94	15.94	47.81	47.81
Series D Preferred Stock
Class of Stock [Line Items]
Dividends declared per share of preferred stock (in usd per share)	15.88	15.88	47.63	43.57
Series E Preferred Stock
Class of Stock [Line Items]
Dividends declared per share of preferred stock (in usd per share)	12.50	0	37.50	0
Series F Preferred Stock
Class of Stock [Line Items]
Dividends declared per share of preferred stock (in usd per share)	$ 19.15	$ 0	$ 19.15	$ 0
Dividends Declared
Class of Stock [Line Items]
Common stock dividends declared and paid	$ 168	$ 162	$ 504	$ 459
Preferred stock dividends declared and paid	25	17	75	50
Dividends Declared | Series A Preferred Stock
Class of Stock [Line Items]
Preferred stock dividends declared and paid	3	7	13	14
Dividends Declared | Series B Preferred Stock
Class of Stock [Line Items]
Preferred stock dividends declared and paid	0	0	9	9
Dividends Declared | Series C Preferred Stock
Class of Stock [Line Items]
Preferred stock dividends declared and paid	4	5	14	14
Dividends Declared | Series D Preferred Stock
Class of Stock [Line Items]
Preferred stock dividends declared and paid	4	5	14	13
Dividends Declared | Series E Preferred Stock
Class of Stock [Line Items]
Preferred stock dividends declared and paid	6	0	17	0
Dividends Declared | Series F Preferred Stock
Class of Stock [Line Items]
Preferred stock dividends declared and paid	8	0	8	0
Dividends Paid
Class of Stock [Line Items]
Common stock dividends declared and paid	168	162	504	459
Preferred stock dividends declared and paid	28	18	73	48
Dividends Paid | Series A Preferred Stock
Class of Stock [Line Items]
Preferred stock dividends declared and paid	3	0	10	7
Dividends Paid | Series B Preferred Stock
Class of Stock [Line Items]
Preferred stock dividends declared and paid	9	9	18	20
Dividends Paid | Series C Preferred Stock
Class of Stock [Line Items]
Preferred stock dividends declared and paid	5	4	15	13
Dividends Paid | Series D Preferred Stock
Class of Stock [Line Items]
Preferred stock dividends declared and paid	5	5	15	8
Dividends Paid | Series E Preferred Stock
Class of Stock [Line Items]
Preferred stock dividends declared and paid	6	0	15	0
Dividends Paid | Series F Preferred Stock
Class of Stock [Line Items]
Preferred stock dividends declared and paid	$ 0	$ 0	$ 0	$ 0

COMMITMENTS AND CONTINGENCIES -

COMMITMENTS AND CONTINGENCIES - Narrative (Details) $ in Millions	9 Months Ended	12 Months Ended
	Sep. 30, 2020USD ($)counterparty	Dec. 31, 2019USD ($)	Dec. 31, 2003
Risk Participation Agreements [Abstract]
Risk participation agreements number of counterparties | counterparty	84
Risk participation agreements, maximum term	9 years
Commercial real estate loans held for sale | Purchase commitment
Other Commitments [Abstract]
Unsettled commercial loan trade purchases	$ 69	$ 183
Unsettled commercial loan trade sales	$ 143	$ 236
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
Financial standby letters of credit
Letters of Credit [Abstract]
Letters of credit outstanding, term	P10Y
Commercial letters of credit
Letters of Credit [Abstract]
Letters of credit outstanding, term	P1Y

COMMITMENTS AND CONTINGENCIES_2

COMMITMENTS AND CONTINGENCIES - Schedule of Outstanding Off-balance sheet Arrangements (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Other Commitments [Line Items]
Commitment amount	$ 75,485	$ 75,040
Commitments to extend credit
Other Commitments [Line Items]
Commitment amount	73,173	72,743
Letters of credit
Other Commitments [Line Items]
Commitment amount	2,132	2,190
Risk participation agreements
Other Commitments [Line Items]
Commitment amount	103	37
Loans sold with recourse
Other Commitments [Line Items]
Commitment amount	48	37
Marketing rights
Other Commitments [Line Items]
Commitment amount	$ 29	$ 33

FAIR VALUE MEASUREMENTS - Resid

FAIR VALUE MEASUREMENTS - Residential Mortgage and Commercial Real Estate Loans Held For Sale (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Aggregate Fair Value	$ 3,587	$ 1,946
Residential loans held for sale
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Aggregate Fair Value	3,425	1,778
Level 2
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Aggregate Fair Value	3,587	1,946
Level 2 | Residential loans held for sale
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Aggregate Fair Value	3,425	1,778
Aggregate Unpaid Principal	3,256	1,727
Aggregate Fair Value Greater (Less) Aggregate Unpaid Principal	169	51
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	162	168
Aggregate Unpaid Principal	172	175
Aggregate Fair Value Greater (Less) Aggregate Unpaid Principal	$ (10)	$ (7)

FAIR VALUE MEASUREMENTS - Chang

FAIR VALUE MEASUREMENTS - Changes in Fair Value for Assets with Fair Value Option (Details) - Level 2 - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Residential loans held for sale | Mortgage banking fees
Fair Value, Option, Quantitative Disclosures [Line Items]
Changes in fair value	$ 46	$ (4)	$ 149	$ 5
Commercial and commercial real estate loans held for sale, at fair value | Other income
Fair Value, Option, Quantitative Disclosures [Line Items]
Changes in fair value	$ 6	$ 0	$ (2)	$ 4

FAIR VALUE MEASUREMENTS - Sched

FAIR VALUE MEASUREMENTS - Schedule of Fair Value Measurements (Details) - USD ($) $ in Millions		Sep. 30, 2020	Dec. 31, 2019
Assets
Securities available for sale	[1]	$ 22,884	$ 20,613
Loans held for sale, at fair value		3,587	1,946
Mortgage servicing rights		606	642
Derivative assets		2,286	984
Equity investment securities, at fair value		57	47
Total assets		29,420	24,232
Liabilities
Total derivative liabilities		506	322
Total liabilities		506	322
Money market mutual fund investments
Assets
Equity investment securities, at fair value		57	47
Interest rate contracts
Assets
Derivative assets		1,765	773
Liabilities
Total derivative liabilities		217	133
Foreign exchange contracts
Assets
Derivative assets		239	174
Liabilities
Total derivative liabilities		189	166
TBA contracts
Assets
Derivative assets		7
Liabilities
Total derivative liabilities		34
Other contracts
Assets
Derivative assets		275	37
Liabilities
Total derivative liabilities		66	23
Level 1
Assets
Securities available for sale		11	71
Loans held for sale, at fair value		0	0
Derivative assets		0	0
Equity investment securities, at fair value		57	47
Total assets		68	118
Liabilities
Total derivative liabilities		0	0
Total liabilities		0	0
Level 1 | Money market mutual fund investments
Assets
Equity investment securities, at fair value		57	47
Level 1 | Interest rate contracts
Assets
Derivative assets		0	0
Liabilities
Total derivative liabilities		0	0
Level 1 | Foreign exchange contracts
Assets
Derivative assets		0	0
Liabilities
Total derivative liabilities		0	0
Level 1 | TBA contracts
Assets
Derivative assets		0
Liabilities
Total derivative liabilities		0
Level 1 | Other contracts
Assets
Derivative assets		0	0
Liabilities
Total derivative liabilities		0	0
Level 2
Assets
Securities available for sale		22,060	20,542
Loans held for sale, at fair value		3,587	1,946
Derivative assets		2,077	965
Equity investment securities, at fair value		0	0
Total assets		27,724	23,453
Liabilities
Total derivative liabilities		506	322
Total liabilities		506	322
Level 2 | Money market mutual fund investments
Assets
Equity investment securities, at fair value		0	0
Level 2 | Interest rate contracts
Assets
Derivative assets		1,765	773
Liabilities
Total derivative liabilities		217	133
Level 2 | Foreign exchange contracts
Assets
Derivative assets		239	174
Liabilities
Total derivative liabilities		189	166
Level 2 | TBA contracts
Assets
Derivative assets		7
Liabilities
Total derivative liabilities		34
Level 2 | Other contracts
Assets
Derivative assets		66	18
Liabilities
Total derivative liabilities		66	23
Level 3
Assets
Securities available for sale		813	0
Loans held for sale, at fair value		0	0
Derivative assets		209	19
Equity investment securities, at fair value		0	0
Total assets		1,628	661
Liabilities
Total derivative liabilities		0	0
Total liabilities		0	0
Level 3 | Money market mutual fund investments
Assets
Equity investment securities, at fair value		0	0
Level 3 | Interest rate contracts
Assets
Derivative assets		0	0
Liabilities
Total derivative liabilities		0	0
Level 3 | Foreign exchange contracts
Assets
Derivative assets		0	0
Liabilities
Total derivative liabilities		0	0
Level 3 | TBA contracts
Assets
Derivative assets		0
Liabilities
Total derivative liabilities		0
Level 3 | Other contracts
Assets
Derivative assets		209	19
Liabilities
Total derivative liabilities		0	0
Mortgage-backed securities
Assets
Securities available for sale		22,056	20,537
Mortgage-backed securities | Level 1
Assets
Securities available for sale		0	0
Mortgage-backed securities | Level 2
Assets
Securities available for sale		22,056	20,537
Mortgage-backed securities | Level 3
Assets
Securities available for sale		0	0
Asset-backed securities
Assets
Securities available for sale		813
Asset-backed securities | Level 1
Assets
Securities available for sale		0
Asset-backed securities | Level 2
Assets
Securities available for sale		0
Asset-backed securities | Level 3
Assets
Securities available for sale		813
State and political subdivisions
Assets
Securities available for sale		4	5
State and political subdivisions | Level 1
Assets
Securities available for sale		0	0
State and political subdivisions | Level 2
Assets
Securities available for sale		4	5
State and political subdivisions | Level 3
Assets
Securities available for sale		0	0
U.S. Treasury and other
Assets
Securities available for sale		11	71
U.S. Treasury and other | Level 1
Assets
Securities available for sale		11	71
U.S. Treasury and other | Level 2
Assets
Securities available for sale		0	0
U.S. Treasury and other | Level 3
Assets
Securities available for sale		0	0
Residential loans held for sale
Assets
Loans held for sale, at fair value		3,425	1,778
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		3,425	1,778
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		162	168
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		162	168
Commercial loans held for sale | Level 3
Assets
Loans held for sale, at fair value		0	0
Residential mortgages
Assets
Mortgage servicing rights		606	642
Residential mortgages | Level 1
Assets
Mortgage servicing rights		0	0
Residential mortgages | Level 2
Assets
Mortgage servicing rights		0	0
Residential mortgages | Level 3
Assets
Mortgage servicing rights		$ 606	$ 642
[1]	Includes only collateral pledged by the Company where counterparties have the right to sell or pledge the collateral.

FAIR VALUE MEASUREMENTS - Sch_2

FAIR VALUE MEASUREMENTS - Schedule of Assets Measured on Recurring Basis Level 3 Rollforward (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Residential mortgages
Fair Value, Assets Measured on Recurring Basis, Unobservable Input Reconciliation, Calculation [Roll Forward]
Beginning balance	$ 568	$ 531	$ 642	$ 600
Issuances	85	78	238	170
Acquired MSRs	0		0
Settlements	(55)	(31)	(141)	(88)
Change in fair value during the period	8	(68)	(323)	(172)
Transfers from Level 2 to Level 3		0		0
Ending balance	606	510	606	510
Asset-backed securities
Fair Value, Assets Measured on Recurring Basis, Unobservable Input Reconciliation, Calculation [Roll Forward]
Beginning balance	0		0
Issuances	0		0
Acquired MSRs	813		813
Settlements	0		0
Change in fair value during the period	0		0
Ending balance	813		813
Other Derivative Contracts
Fair Value, Assets Measured on Recurring Basis, Unobservable Input Reconciliation, Calculation [Roll Forward]
Beginning balance	173	25	19	0
Issuances	283	61	688	104
Acquired MSRs	0		0
Settlements	(372)	(64)	(792)	(107)
Change in fair value during the period	125	4	294	11
Transfers from Level 2 to Level 3		0		18
Ending balance	209	$ 26	209	$ 26
Cumulative Effect, Period Of Adoption, Adjustment | Residential mortgages
Fair Value, Assets Measured on Recurring Basis, Unobservable Input Reconciliation, Calculation [Roll Forward]
Beginning balance	0		190
Cumulative Effect, Period Of Adoption, Adjustment | Asset-backed securities
Fair Value, Assets Measured on Recurring Basis, Unobservable Input Reconciliation, Calculation [Roll Forward]
Beginning balance	0		0
Cumulative Effect, Period Of Adoption, Adjustment | Other Derivative Contracts
Fair Value, Assets Measured on Recurring Basis, Unobservable Input Reconciliation, Calculation [Roll Forward]
Beginning balance	0		0
Cumulative Effect, Period Of Adoption, Adjusted Balance | Residential mortgages
Fair Value, Assets Measured on Recurring Basis, Unobservable Input Reconciliation, Calculation [Roll Forward]
Beginning balance	568		832
Cumulative Effect, Period Of Adoption, Adjusted Balance | Asset-backed securities
Fair Value, Assets Measured on Recurring Basis, Unobservable Input Reconciliation, Calculation [Roll Forward]
Beginning balance	0		0
Cumulative Effect, Period Of Adoption, Adjusted Balance | Other Derivative Contracts
Fair Value, Assets Measured on Recurring Basis, Unobservable Input Reconciliation, Calculation [Roll Forward]
Beginning balance	$ 173		$ 19

FAIR VALUE MEASUREMENTS - Unobs

FAIR VALUE MEASUREMENTS - Unobservable Inputs Used and Valuation Techniques (Details) - Level 3	Sep. 30, 2020
Mortgage servicing rights | Minimum | Discounted Cash Flow | Constant prepayment rate
Fair Value Measurement Inputs and Valuation Techniques [Line Items]
Mortgage servicing rights, measurement input	0.1087
Mortgage servicing rights | Minimum | Discounted Cash Flow | Option adjusted spread
Fair Value Measurement Inputs and Valuation Techniques [Line Items]
Mortgage servicing rights, measurement input	3.5
Mortgage servicing rights | Maximum | Discounted Cash Flow | Constant prepayment rate
Fair Value Measurement Inputs and Valuation Techniques [Line Items]
Mortgage servicing rights, measurement input	0.3732
Mortgage servicing rights | Maximum | Discounted Cash Flow | Option adjusted spread
Fair Value Measurement Inputs and Valuation Techniques [Line Items]
Mortgage servicing rights, measurement input	10.6
Mortgage servicing rights | Weighted Average | Discounted Cash Flow | Constant prepayment rate
Fair Value Measurement Inputs and Valuation Techniques [Line Items]
Mortgage servicing rights, measurement input	0.1940
Mortgage servicing rights | Weighted Average | Discounted Cash Flow | Option adjusted spread
Fair Value Measurement Inputs and Valuation Techniques [Line Items]
Mortgage servicing rights, measurement input	6.08
Asset-backed securities | Discounted Cash Flow | Conditional prepayment rate
Fair Value Measurement Inputs and Valuation Techniques [Line Items]
Asset-Backed Securities, measurement input	0.0800
Asset-backed securities | Discounted Cash Flow | Constant default rate
Fair Value Measurement Inputs and Valuation Techniques [Line Items]
Asset-Backed Securities, measurement input	0.0185
Other derivative contracts | Minimum | Internal Model | Pull through rate
Fair Value Measurement Inputs and Valuation Techniques [Line Items]
Other derivative contracts, measurement input	0.1172
Other derivative contracts | Minimum | Internal Model | MSR value
Fair Value Measurement Inputs and Valuation Techniques [Line Items]
Other derivative contracts, measurement input	0.2673
Other derivative contracts | Maximum | Internal Model | Pull through rate
Fair Value Measurement Inputs and Valuation Techniques [Line Items]
Other derivative contracts, measurement input	1
Other derivative contracts | Maximum | Internal Model | MSR value
Fair Value Measurement Inputs and Valuation Techniques [Line Items]
Other derivative contracts, measurement input	1.2427
Other derivative contracts | Weighted Average | Internal Model | Pull through rate
Fair Value Measurement Inputs and Valuation Techniques [Line Items]
Other derivative contracts, measurement input	0.8245
Other derivative contracts | Weighted Average | Internal Model | MSR value
Fair Value Measurement Inputs and Valuation Techniques [Line Items]
Other derivative contracts, measurement input	0.8138

FAIR VALUE MEASUREMENTS - Sch_3

FAIR VALUE MEASUREMENTS - Schedule of Gain (Loss) on Assets and Liabilities Measured on Nonrecurring Basis Included in Earnings (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Nonrecurring measurement basis | 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	$ (21)	$ (8)	$ (65)	$ (36)

FAIR VALUE MEASUREMENTS - Sch_4

FAIR VALUE MEASUREMENTS - Schedule of Fair Value Measurements on a Nonrecurring Basis (Details) - USD ($) $ in Millions	Sep. 30, 2020	Dec. 31, 2019
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Premises and equipment, net	$ 747	$ 761
Nonrecurring measurement basis
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Collateral-dependent loans	633	312
Level 1 | Nonrecurring measurement basis
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Collateral-dependent loans	0	0
Level 2 | Nonrecurring measurement basis
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Collateral-dependent loans	633	312
Level 3 | Nonrecurring measurement basis
Fair Value, Assets and Liabilities Measured on Recurring and Nonrecurring Basis [Line Items]
Collateral-dependent loans	$ 0	$ 0

FAIR VALUE MEASUREMENTS - Sch_5

FAIR VALUE MEASUREMENTS - Schedule of Financial Instruments not Recorded at Fair Value (Details) - USD ($) $ in Millions		Sep. 30, 2020	Dec. 31, 2019
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Securities held to maturity, carrying value	[1]	$ 2,578	$ 3,202
Securities held-to-maturity, fair value		2,709	3,242
Equity securities, at cost, carrying value		605	807
Equity securities, at cost, fair value		605	807
Other loans held for sale, carrying value		127	1,384
Other loans held for sale, fair value		127	1,384
Loans and leases		124,071	119,088
Loans and leases, fair value		125,498	119,792
Deposits, carrying value		142,921	125,313
Deposits, fair value		143,004	125,340
Short-term borrowed funds, carrying value		252	274
Short-term borrowed funds, fair value		252	274
Long-term borrowed funds, carrying value		9,109	14,047
Long-term borrowed funds, fair value		9,568	14,228
Level 1
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Securities held to maturity, carrying value		0	0
Securities held-to-maturity, fair value		0	0
Equity securities, at cost, carrying value		0	0
Equity securities, at cost, fair value		0	0
Other loans held for sale, carrying value		0	0
Other loans held for sale, fair value		0	0
Loans and leases		0	0
Loans and leases, fair value		0	0
Deposits, carrying value		0	0
Deposits, fair value		0	0
Short-term borrowed funds, carrying value		0	0
Short-term borrowed funds, fair value		0	0
Long-term borrowed funds, carrying value		0	0
Long-term borrowed funds, fair value		0	0
Level 2
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Securities held to maturity, carrying value		2,578	3,202
Securities held-to-maturity, fair value		2,709	3,242
Equity securities, at cost, carrying value		597	807
Equity securities, at cost, fair value		597	807
Other loans held for sale, carrying value		0	0
Other loans held for sale, fair value		0	0
Loans and leases		633	312
Loans and leases, fair value		633	312
Deposits, carrying value		142,921	125,313
Deposits, fair value		143,004	125,340
Short-term borrowed funds, carrying value		252	274
Short-term borrowed funds, fair value		252	274
Long-term borrowed funds, carrying value		9,109	14,047
Long-term borrowed funds, fair value		9,568	14,228
Level 3
Fair Value, Balance Sheet Grouping, Financial Statement Captions [Line Items]
Securities held to maturity, carrying value		0	0
Securities held-to-maturity, fair value		0	0
Equity securities, at cost, carrying value		8	0
Equity securities, at cost, fair value		8	0
Other loans held for sale, carrying value		127	1,384
Other loans held for sale, fair value		127	1,384
Loans and leases		123,438	118,776
Loans and leases, fair value		124,865	119,480
Deposits, carrying value		0	0
Deposits, fair value		0	0
Short-term borrowed funds, carrying value		0	0
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]	Includes only collateral pledged by the Company where counterparties have the right to sell or pledge the collateral.

NONINTEREST INCOME - Narrative

NONINTEREST INCOME - Narrative (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Trust and investment services fees
Disaggregation of Revenue [Line Items]
Trailing commission income	$ 3	$ 4	$ 10	$ 11

NONINTEREST INCOME - Components

NONINTEREST INCOME - Components of Revenue from Contracts with Customers (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	$ 258	$ 285	$ 779	$ 863
Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	173	210	509	611
Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	85	75	270	252
Service charges and fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	96	127	298	375
Service charges and fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	71	102	222	298
Service charges and fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	25	25	76	77
Card fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	56	67	160	190
Card fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	49	57	136	162
Card fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	7	10	24	28
Capital markets fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	50	38	163	140
Capital markets fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	0	0	0	0
Capital markets fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	50	38	163	140
Trust and investment services fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	53	50	151	150
Trust and investment services fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	53	50	151	150
Trust and investment services fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	0	0	0	0
Other banking fees
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	3	3	7	8
Other banking fees | Consumer Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	0	1	0	1
Other banking fees | Commercial Banking
Disaggregation of Revenue [Line Items]
Revenue from contracts with customers	$ 3	$ 2	$ 7	$ 7

NONINTEREST INCOME - Other Inco

NONINTEREST INCOME - Other Income (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Other Income and Expenses [Abstract]
Bank-owned life insurance	$ 13	$ 14	$ 41	$ 41

OTHER OPERATING EXPENSE (Detail

OTHER OPERATING EXPENSE (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Other Income and Expenses [Abstract]
Promotional expense	$ 24	$ 31	$ 75	$ 86
Other	71	96	242	269
Other operating expense	$ 95	$ 127	$ 317	$ 355

EARNINGS PER SHARE (Details)

EARNINGS PER SHARE (Details) - USD ($) $ / shares in Units, $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Numerator (basic and diluted):
Net income	$ 314	$ 449	$ 601	$ 1,341
Less: Preferred stock dividends	25	17	75	50
Net income available to common stockholders	$ 289	$ 432	$ 526	$ 1,291
Denominator:
Weighted-average common shares outstanding - basic (in shares)	426,846,096	445,703,987	427,058,412	454,802,186
Dilutive common shares: share-based awards (in shares)	1,146,253	1,430,608	1,083,946	1,416,569
Weighted-average common shares outstanding - diluted (in shares)	427,992,349	447,134,595	428,142,358	456,218,755
Earnings per common share:
Basic (in dollars per share)	$ 0.68	$ 0.97	$ 1.23	$ 2.84
Diluted (in dollars per share)	$ 0.68	$ 0.97	$ 1.23	$ 2.83
Share-based awards excluded from diluted earnings per share computation (in shares)	1,193,668	772	1,249,785	359,952

BUSINESS OPERATING SEGMENTS - N

BUSINESS OPERATING SEGMENTS - Narrative (Details)	9 Months Ended
	Sep. 30, 2020segment
Segment Reporting [Abstract]
Number of segments	2

BUSINESS OPERATING SEGMENTS - A

BUSINESS OPERATING SEGMENTS - Assets by Segment (Details) - USD ($) $ in Millions	3 Months Ended		9 Months Ended
	Sep. 30, 2020	Sep. 30, 2019	Sep. 30, 2020	Sep. 30, 2019
Segment Reporting Information [Line Items]
Net interest income	$ 1,137	$ 1,145	$ 3,457	$ 3,471
Noninterest income	654	493	1,741	1,383
Total revenue	1,791	1,638	5,198	4,854
Noninterest expense	988	973	2,979	2,861
Profit (loss) before provision for credit losses	803	665	2,219	1,993
Provision for credit losses	428	101	1,492	283
Income before income tax expense	375	564	727	1,710
Income tax expense (benefit)	61	115	126	369
NET INCOME	314	449	601	1,341
Total average assets	177,675	162,110	174,892	161,344
Operating Segments | Consumer Banking
Segment Reporting Information [Line Items]
Net interest income	845	799	2,452	2,386
Noninterest income	495	336	1,280	860
Total revenue	1,340	1,135	3,732	3,246
Noninterest expense	742	718	2,215	2,133
Profit (loss) before provision for credit losses	598	417	1,517	1,113
Provision for credit losses	55	83	232	228
Income before income tax expense	543	334	1,285	885
Income tax expense (benefit)	136	83	322	219
NET INCOME	407	251	963	666
Total average assets	73,605	66,365	71,227	65,624
Operating Segments | Commercial Banking
Segment Reporting Information [Line Items]
Net interest income	421	360	1,205	1,103
Noninterest income	144	133	413	432
Total revenue	565	493	1,618	1,535
Noninterest expense	210	213	644	639
Profit (loss) before provision for credit losses	355	280	974	896
Provision for credit losses	161	27	274	73
Income before income tax expense	194	253	700	823
Income tax expense (benefit)	41	57	147	184
NET INCOME	153	196	553	639
Total average assets	60,889	55,614	61,722	55,793
Other
Segment Reporting Information [Line Items]
Net interest income	(129)	(14)	(200)	(18)
Noninterest income	15	24	48	91
Total revenue	(114)	10	(152)	73
Noninterest expense	36	42	120	89
Profit (loss) before provision for credit losses	(150)	(32)	(272)	(16)
Provision for credit losses	212	(9)	986	(18)
Income before income tax expense	(362)	(23)	(1,258)	2
Income tax expense (benefit)	(116)	(25)	(343)	(34)
NET INCOME	(246)	2	(915)	36
Total average assets	$ 43,181	$ 40,131	$ 41,943	$ 39,927