ALLOWANCE FOR CREDIT LOSSES, NONACCRUAL LOANS AND LEASES, AND CONCENTRATIONS OF CREDIT RISK | NOTE 6 - ALLOWANCE FOR CREDIT LOSSES, NONACCRUAL 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 allowance for unfunded lending commitments (collectively the ACL). 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 cancellable considering a number of relevant underlying factors, including key assumptions and evaluation of quantitative and qualitative information. 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, resulting 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. 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 reversion period to historical credit loss information. 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 and industrial, commercial real estate, residential mortgage), 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), 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 affected by sensitivity analysis for certain industry sectors or loan classes, including CRE office. 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. Nonaccrual commercial and industrial, and commercial real estate loans with an outstanding balance of $5 million or greater and all commercial and industrial, 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. A loan is considered to be collateral dependent when repayment of the loan is expected to be provided solely by the underlying collateral, rather than by cash flows from the borrower’s operations, income or other resources. Loans that are deemed to be collateral dependent are written down to the fair value, less costs to sell, 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 FHA, VA or USDA. Residential mortgages that received extended forbearance and were subsequently modified as a result of COVID-19 will be placed on nonaccrual sooner than those that were not on extended forbearance, and will return to accrual status only following a sustained period of repayment performance. 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 cancellable. 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 allowance for unfunded lending commitments. The Company does not recognize a reserve for future draws from credit lines that are unconditionally cancellable (e.g., credit cards). The ALLL and the allowance 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. Loan Charge-Offs Commercial loans are charged off when available information indicates that a loan or portion thereof is determined to be uncollectible. The determination of whether to recognize a charge-off involves many factors, including the prioritization of the Company’s claim in bankruptcy, expectations of the workout/restructuring of the loan and valuation of the borrower’s equity or the loan collateral. Retail loans are generally fully charged-off or written down to the net realizable value of the underlying collateral, with an offset to the ALLL, upon reaching specified stages of delinquency in accordance with standards established by the FFIEC. Residential real estate loans, credit card loans and unsecured open-end loans are generally charged off in the month when the account becomes 180 days past due. Auto loans, education loans and unsecured closed end loans are generally charged off in the month when the account becomes 120 days past due. Certain retail loans will be charged off or charged down to their net realizable value earlier than the FFIEC charge-off standards in the following circumstances: • Loans modified in a TDR that are determined to be collateral-dependent. • Residential real estate loans that received extended forbearance and were subsequently modified as a result of COVID-19 • Loans to borrowers who have experienced an event (e.g., bankruptcy) that suggests a loss is either known or highly certain. ◦ Residential real estate and auto loans are charged down to fair value less costs to sell within 60 days of receiving notification of the bankruptcy filing, unless repayment is likely to occur, or when the loan subsequently becomes 60 days past due. ◦ Credit card loans are fully charged off within 60 days of receiving notification of the bankruptcy filing or other event. ◦ Education loans are generally charged off when the loan becomes 60 days past due after receiving notification of a bankruptcy. • Auto loans are written down to fair value less costs to sell upon repossession of the collateral. The following table presents a summary of changes in the ACL for the year ended December 31, 2022: Year Ended December 31, 2022 (in millions) Commercial Retail Total Allowance for loan and lease losses, beginning of period $821 $937 $1,758 Allowance on PCD loans and leases at acquisition 99 2 101 Charge-offs (1) (70) (364) (434) Recoveries 18 146 164 Net charge-offs (52) (218) (270) Provision expense (benefit) for loans and leases (2) 192 202 394 Allowance for loan and lease losses, end of period 1,060 923 1,983 Allowance for unfunded lending commitments, beginning of period 153 23 176 Provision expense (benefit) for unfunded lending commitments 53 27 80 Allowance on PCD unfunded lending commitments at acquisition 1 — 1 Allowance for unfunded lending commitments, end of period 207 50 257 Total allowance for credit losses, end of period $1,267 $973 $2,240 (1) Excludes $34 million of charge-offs previously taken by Investors or recognized upon completion of the Investors acquisition under purchase accounting for the year ended December 31, 2022. The initial allowance for loan and lease losses on PCD assets included these amounts and, after charging these amounts off upon acquisition, the net impact for PCD assets was $101 million of additional allowance for loan and lease losses. (2) Includes $169 million of initial provision expense related to non-PCD loans and leases acquired from HSBC and Investors for the year ended December 31, 2022. During the year ended December 31, 2022, net charge-offs of $270 million, the ACL on PCD loans and leases and unfunded lending commitments at acquisition of $102 million, and a credit provision of $474 million resulted in an increase of $306 million to the ACL. The retail NCO ratio remained relatively flat compared to 2021. The commercial NCO ratio decreased compared to 2021, as credit performance remained strong. Our ACL as of December 31, 2022 accounts for an economic forecast over our two-year reasonable and supportable period with peak unemployment of approximately 6%, peak-to-trough GDP decline of approximately 1.4%, and collateral value peak-to-trough declines of approximately 13% in home and approximately 16% in used auto and truck. This forecast incorporates the increased risk of a moderate recession beginning in the fourth quarter of 2022 and persisting for four consecutive quarters. The following tables present a summary of changes in the ACL for the years ended December 31, 2021 and 2020: Year Ended December 31, 2021 (in millions) Commercial Retail Total Allowance for loan and lease losses, beginning of period $1,233 $1,210 $2,443 Charge-offs (218) (321) (539) Recoveries 54 160 214 Net charge-offs (164) (161) (325) Provision expense (benefit) for loans and leases (248) (112) (360) Allowance for loan and lease losses, end of period 821 937 1,758 Allowance for unfunded lending commitments, beginning of period 186 41 227 Provision expense (benefit) for unfunded lending commitments (33) (18) (51) Allowance for unfunded lending commitments, end of period 153 23 176 Total allowance for credit losses, end of period $974 $960 $1,934 Year Ended December 31, 2020 (in millions) Commercial Retail Total Allowance for loan and lease losses, beginning of period $674 $578 $1,252 Cumulative effect of change in accounting principle (176) 629 453 Allowance for loan and lease losses, beginning of period, adjusted 498 1,207 1,705 Charge-offs (437) (406) (843) Recoveries 12 138 150 Net charge-offs (425) (268) (693) Provision expense (benefit) for loans and leases 1,160 271 1,431 Allowance for loan and lease losses, end of period 1,233 1,210 2,443 Allowance for unfunded lending commitments, beginning of period 44 — 44 Cumulative effect of change in accounting principle (3) 1 (2) Allowance for unfunded lending commitments, beginning of period, adjusted 41 1 42 Provision expense (benefit) for unfunded lending commitments 145 40 185 Allowance for unfunded lending commitments, end of period 186 41 227 Total allowance for credit losses, end of period $1,419 $1,251 $2,670 Credit Quality Indicators The Company presents loan and lease portfolio segments and classes 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 a continuation of the original loan and vintage date corresponds with the most recent credit decision. For commercial loans and leases, Citizens utilizes regulatory classification ratings to monitor credit quality. The assignment of regulatory classification ratings occurs at loan origination and are periodically re-evaluated by Citizens utilizing a risk-based approach, including any time management becomes aware of information affecting the borrowers' ability to fulfill their obligations. The review process considers both quantitative and qualitative factors. Loans with a “pass” rating are those that the Company believes will fully repay in accordance with the contractual loan terms. Commercial loans and leases identified as “criticized” have some weakness or potential weakness that indicate an increased probability of future loss. Citizens groups “criticized” loans 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 characteristic that the possibility of loss is high and collection of the full amount of the loan is improbable. Additional credit quality information is discussed below for each loan class. For commercial and industrial loans, Citizens monitors the performance of the borrower in a disciplined and regular manner based upon the level of credit risk inherent in the loan. To evaluate the level of credit risk, management assigns an internal risk rating reflecting the borrower’s PD and LGD. This two-dimensional credit risk rating methodology provides granularity in the risk monitoring process. These ratings are generally reviewed at least annually. The combination of the PD and LGD ratings assigned to commercial and industrial loans, capturing both the combination of expectations of default and loss severity in the event of default, reflects credit quality characteristics as of the reporting date and are used as inputs into the loss forecasting process. Based upon the amount of the lending arrangement and risk rating assessment, management periodically reviews each loan, prioritizing those loans which are perceived to be of higher risk, based upon PDs and LGDs, or loans for which credit quality is weakening (e.g., payment delinquency). Citizens proactively manages loans by using various procedures that are customized to the risk of a given loan, including ongoing outreach to the borrower, assessment of the borrower’s financial conditions and appraisal of the collateral. Credit risk associated with commercial real estate projects and commercial mortgages are managed similar to commercial and industrial loans by evaluating PD and LGD. Risks associated with commercial real estate activities tend to be correlated to the loan structure and collateral location, project progress and business environment. As a result, these attributes are also monitored and utilized in assessing credit risk. As with the commercial and industrial loan class, periodic reviews are also performed to assess market/geographic risk and business unit/industry risk, which may result in increased scrutiny on loans that are perceived to be of higher risk, had adverse changes in risk ratings and/or areas that concern management. These reviews are designed to assess risk and facilitate actions to mitigate such risks. Citizens manages credit risk associated with financing leases similar to commercial and industrial loans by analyzing PD and LGD. Reviews are generally performed annually based upon the dollar amount of the lease and the level of credit risk, and may be more frequent if circumstances warrant. The review process includes analysis of the following factors: equipment value/residual value, exposure levels, jurisdiction risk, industry risk, guarantor requirements, and regulatory compliance as applicable. Commercial loans with renewal terms in the original contract are recognized as current year originations upon renewal unless the loan automatically renewed with no new credit decision. Citizens generally reserves the right to not renew the loan or lease until current underwriting has been completed and approved. The following table presents the amortized cost basis of commercial loans and leases, by vintage date and regulatory classification rating, as of December 31, 2022: Term Loans by Origination Year Revolving Loans (in millions) 2022 2021 2020 2019 2018 Prior to 2018 Within the Revolving Period Converted to Term Total Commercial and industrial Pass $8,304 $8,469 $2,224 $2,074 $1,334 $1,952 $24,211 $148 $48,716 Special Mention 124 189 120 74 48 153 364 — 1,072 Substandard 150 218 203 255 99 349 597 14 1,885 Doubtful 10 14 1 5 41 14 76 2 163 Total commercial and industrial 8,588 8,890 2,548 2,408 1,522 2,468 25,248 164 51,836 Commercial real estate Pass 5,767 6,442 3,639 3,066 2,145 3,536 1,888 3 26,486 Special Mention 1 119 103 390 99 113 62 — 887 Substandard 92 18 79 253 350 610 23 — 1,425 Doubtful — 2 9 55 — 1 — — 67 Total commercial real estate 5,860 6,581 3,830 3,764 2,594 4,260 1,973 3 28,865 Leases Pass 263 363 250 99 128 345 — — 1,448 Special Mention 4 5 2 6 1 3 — — 21 Substandard — 4 3 3 — — — — 10 Doubtful — — — — — — — — — Total leases 267 372 255 108 129 348 — — 1,479 Total commercial Pass 14,334 15,274 6,113 5,239 3,607 5,833 26,099 151 76,650 Special Mention 129 313 225 470 148 269 426 — 1,980 Substandard 242 240 285 511 449 959 620 14 3,320 Doubtful 10 16 10 60 41 15 76 2 230 Total commercial $14,715 $15,843 $6,633 $6,280 $4,245 $7,076 $27,221 $167 $82,180 The following table presents the amortized cost basis of commercial loans and leases, by vintage date and regulatory classification rating, as of December 31, 2021: Term Loans by Origination Year Revolving Loans (in millions) 2021 2020 2019 2018 2017 Prior to 2017 Within the Revolving Period Converted to Term Total Commercial and industrial Pass $10,218 $3,336 $3,599 $2,284 $1,426 $1,863 $19,406 $122 $42,254 Special Mention 47 71 155 114 41 64 316 1 809 Substandard 97 112 215 81 50 201 521 17 1,294 Doubtful 1 9 9 22 10 16 74 2 143 Total commercial and industrial 10,363 3,528 3,978 2,501 1,527 2,144 20,317 142 44,500 Commercial real estate Pass 2,766 2,417 3,181 1,756 626 1,119 1,451 3 13,319 Special Mention 45 42 113 100 27 79 — — 406 Substandard 27 — 88 267 78 59 9 — 528 Doubtful 1 9 — — — 1 — — 11 Total commercial real estate 2,839 2,468 3,382 2,123 731 1,258 1,460 3 14,264 Leases Pass 447 262 134 144 66 459 — — 1,512 Special Mention 10 15 — 5 3 16 — — 49 Substandard 1 16 5 2 — — — — 24 Doubtful — — — — — 1 — — 1 Total leases 458 293 139 151 69 476 — — 1,586 Total commercial Pass 13,431 6,015 6,914 4,184 2,118 3,441 20,857 125 57,085 Special Mention 102 128 268 219 71 159 316 1 1,264 Substandard 125 128 308 350 128 260 530 17 1,846 Doubtful 2 18 9 22 10 18 74 2 155 Total commercial $13,660 $6,289 $7,499 $4,775 $2,327 $3,878 $21,777 $145 $60,350 For retail loans, Citizens utilizes FICO credit scores and the loan’s payment and delinquency status to monitor credit quality. Management believes FICO scores are the strongest indicator of credit losses over the contractual life of the loan and assist management in predicting the borrower’s future payment performance. Scores are based on current and historical national industry-wide consumer level credit performance data. The following table presents the amortized cost basis of retail loans, by vintage date and FICO scores, as of December 31, 2022: Term Loans by Origination Year Revolving Loans (in millions) 2022 2021 2020 2019 2018 Prior to 2018 Within the Revolving Period Converted to Term Total Residential mortgages 800+ $2,132 $4,943 $3,143 $1,180 $363 $3,081 $— $— $14,842 740-799 2,376 2,991 1,660 638 257 1,635 — — 9,557 680-739 769 899 502 308 149 851 — — 3,478 620-679 125 168 135 138 99 422 — — 1,087 <620 17 68 77 165 147 455 — — 929 No FICO available (1) 2 2 2 3 2 17 — — 28 Total residential mortgages 5,421 9,071 5,519 2,432 1,017 6,461 — — 29,921 Home equity 800+ 4 5 2 5 6 110 4,958 267 5,357 740-799 2 2 1 4 6 97 4,350 274 4,736 680-739 1 1 1 6 11 114 2,296 234 2,664 620-679 — 1 2 9 16 93 558 143 822 <620 — — 2 12 18 82 178 172 464 Total home equity 7 9 8 36 57 496 12,340 1,090 14,043 Automobile 800+ 650 1,453 584 324 120 54 — — 3,185 740-799 962 1,606 649 343 134 56 — — 3,750 680-739 920 1,187 460 254 102 44 — — 2,967 620-679 554 586 205 133 62 28 — — 1,568 <620 188 309 130 106 56 31 — — 820 No FICO available (1) 2 — — — — — — — 2 Total automobile 3,276 5,141 2,028 1,160 474 213 — — 12,292 Education 800+ 548 1,720 1,567 694 410 1,068 — — 6,007 740-799 735 1,351 1,126 486 267 609 — — 4,574 680-739 363 423 356 170 103 288 — — 1,703 620-679 54 76 62 38 29 102 — — 361 <620 6 16 20 12 11 50 — — 115 No FICO available (1) 6 — — — — 42 — — 48 Total education 1,712 3,586 3,131 1,400 820 2,159 — — 12,808 Other retail 800+ 182 105 93 48 25 27 491 — 971 740-799 230 134 121 68 31 25 974 1 1,584 680-739 175 109 103 52 21 14 993 4 1,471 620-679 108 65 52 18 8 4 435 4 694 <620 35 30 25 9 4 2 190 6 301 No FICO available (1) 12 1 3 — — — 380 1 397 Total other retail 742 444 397 195 89 72 3,463 16 5,418 Total retail 800+ 3,516 8,226 5,389 2,251 924 4,340 5,449 267 30,362 740-799 4,305 6,084 3,557 1,539 695 2,422 5,324 275 24,201 680-739 2,228 2,619 1,422 790 386 1,311 3,289 238 12,283 620-679 841 896 456 336 214 649 993 147 4,532 <620 246 423 254 304 236 620 368 178 2,629 No FICO available (1) 22 3 5 3 2 59 380 1 475 Total retail $11,158 $18,251 $11,083 $5,223 $2,457 $9,401 $15,803 $1,106 $74,482 (1) Represents loans for which an updated FICO score was unavailable (e.g., due to recent profile changes). The following table presents the amortized cost basis of retail loans, by vintage date and FICO scores, as of December 31, 2021: Term Loans by Origination Year Revolving Loans (in millions) 2021 2020 2019 2018 2017 Prior to 2017 Within the Revolving Period Converted to Term Total Residential mortgages 800+ $2,431 $3,017 $1,230 $342 $672 $2,139 $— $— $9,831 740-799 4,015 1,876 746 246 360 1,086 — — 8,329 680-739 1,116 572 335 152 172 585 — — 2,932 620-679 111 130 161 93 107 276 — — 878 <620 24 66 164 162 157 257 — — 830 No FICO available (1) 3 8 1 — — 10 — — 22 Total residential mortgages 7,700 5,669 2,637 995 1,468 4,353 — — 22,822 Home equity 800+ — 2 5 5 3 134 4,394 281 4,824 740-799 — 1 4 5 7 122 3,514 278 3,931 680-739 — 1 7 14 16 134 1,738 243 2,153 620-679 — 3 11 19 17 112 363 167 692 <620 — 2 16 23 20 87 91 176 415 Total home equity — 9 43 66 63 589 10,100 1,145 12,015 Automobile 800+ 1,887 829 538 244 148 57 — — 3,703 740-799 2,418 1,051 615 288 156 58 — — 4,586 680-739 1,968 827 500 234 123 48 — — 3,700 620-679 1,029 378 257 131 72 32 — — 1,899 <620 164 142 155 103 62 32 — — 658 No FICO available (1) 3 — — — — — — — 3 Total automobile 7,469 3,227 2,065 1,000 561 227 — — 14,549 Education 800+ 1,361 1,771 840 514 470 880 — — 5,836 740-799 1,555 1,577 672 371 275 514 — — 4,964 680-739 512 474 229 140 107 262 — — 1,724 620-679 50 66 45 34 28 99 — — 322 <620 5 11 12 12 10 45 — — 95 No FICO available (1) 4 — — — — 52 — — 56 Total education 3,487 3,899 1,798 1,071 890 1,852 — — 12,997 Other retail 800+ 233 214 122 65 30 29 386 — 1,079 740-799 323 296 173 84 38 26 764 2 1,706 680-739 246 240 122 56 23 12 709 5 1,413 620-679 149 119 43 19 7 4 299 5 645 <620 32 37 17 10 3 2 100 6 207 No FICO available (1) 44 5 — — — — 330 1 380 Total other retail 1,027 911 477 234 101 73 2,588 19 5,430 Total retail 800+ 5,912 5,833 2,735 1,170 1,323 3,239 4,780 281 25,273 740-799 8,311 4,801 2,210 994 836 1,806 4,278 280 23,516 680-739 3,842 2,114 1,193 596 441 1,041 2,447 248 11,922 620-679 1,339 696 517 296 231 523 662 172 4,436 <620 225 258 364 310 252 423 191 182 2,205 No FICO available (1) 54 13 1 — — 62 330 1 461 Total retail $19,683 $13,715 $7,020 $3,366 $3,083 $7,094 $12,688 $1,164 $67,813 (1) Represents loans for which an updated FICO score was unavailable (e.g., due to recent profile changes). Nonaccrual and Past Due Assets Nonaccrual loans and leases are those on which accrual of interest has been suspended. Loans (other than certain retail loans insured by U.S. government agencies) are placed on nonaccrual status when full payment of principal and interest is in doubt, unless the loan is both well secured and in the process of collection. When the Company places a loan on nonaccrual status, the accrued unpaid interest receivable is reversed against interest income and amortization of any net deferred fees is suspended. Interest collections on nonaccrual loans and leases for which the ultimate collectability of principal is uncertain are generally applied to first reduce the carrying value of the asset. Otherwise, interest income may be recognized to the extent of the cash received. A loan or lease may be returned to accrual status if: • principal and interest payments have been brought current, and the Company expects repayment of the remaining contractual principal and interest; • the loan or lease has otherwise become well-secured and in the process of collection; or • the borrower has been making regularly scheduled payments in full for the prior six months and the Company is reasonably assured that the loan or lease will be brought fully current within a reasonable period. Commercial and industrial loans, commercial real estate loans, and leases are generally placed on nonaccrual status when contractually past due 90 days or more, or earlier if management believes that the probability of collection is insufficient to warrant further accrual. Some of these loans and leases may remain on accrual status when contractually past due 90 days or more if management considers the loan collectible. Residential mortgages are generally placed on nonaccrual status when past due 120 days, or sooner if determined to be collateral dependent, unless repayment of the loan is fully or partially guaranteed by the FHA, VA or USDA. Credit card balances are placed on nonaccrual status when past due 90 days or more and are restored to accruing status if they subsequently become less than 90 days past due. All other retail loans are generally placed on nonaccrual status when past due 90 days or more, or earlier if management believes that the probability of collection is insufficient to warrant further accrual. Loans less than 90 days past due may be placed on nonaccrual status upon the death of the borrower, fraud or bankruptcy. The following tables present an aging analysis of accruing loans and leases, and nonaccrual loans and leases as of December 31, 2022 and 2021: December 31, 2022 Days Past Due and Accruing (in millions) Current 30-59 60-89 90+ Nonaccrual Total Nonaccrual with no related ACL Commercial and industrial $51,389 $152 $25 $21 $249 $51,836 $64 Commercial real estate 28,665 51 45 1 103 28,865 7 Leases 1,475 4 — — — 1,479 — Total commercial 81,529 207 70 22 352 82,180 71 Residential mortgages (1) 29,228 95 45 319 234 29,921 187 Home equity 13,719 64 19 — 241 14,043 185 Automobile 12,039 152 45 — 56 12,292 9 Education 12,718 36 17 4 33 12,808 3 Other retail 5,294 44 30 22 28 5,418 1 Total retail 72,998 391 156 345 592 74,482 385 Total $154,527 $598 $226 $367 $944 $156,662 $456 December 31, 2021 Days Past Due and Accruing (in millions) Current 30-59 60-89 90+ Nonaccrual Total Nonaccrual with no related ACL Commercial and industrial $44,247 $47 $26 $9 $171 $44,500 $36 Commercial real estate 14,247 6 — — 11 14,264 1 Leases 1,570 14 1 — 1 1,586 — Total commercial 60,064 67 27 9 183 60,350 37 Residential mortgages (1) 21,918 102 52 549 201 22,822 137 Home equity 11,745 38 12 — 220 12,015 186 Automobile 14,324 131 39 — 55 14,549 22 Education 12,926 34 13 1 23 12,997 2 Other retail 5,331 40 23 16 20 5,430 2 Total retail 66,244 345 139 566 519 67,813 349 Total $126,308 $412 $166 $575 $702 $128,163 $386 (1) 90+ days past due and accruing includes $316 million and $544 million of loans fully or partially guaranteed by the FHA, VA and USDA at December 31, 2022 and 2021, respectively. 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 a loan or lease as nonaccrual. Certain commercial and consu |