CREDIT QUALITY AND THE ALLOWANCE FOR CREDIT LOSSES | NOTE 6 - CREDIT QUALITY AND THE ALLOWANCE FOR CREDIT LOSSES Allowance for Credit Losses The Company’s estimate of expected credit losses in its loan and lease portfolios is recorded in the ACL and considers extensive historical loss experience, including the impact of loss mitigation and restructuring programs that the Company offers to borrowers experiencing financial difficulty, as well as projected loss severity as a result of loan default. The ACL is maintained at a level the Company believes to be appropriate to absorb expected lifetime credit losses over the contractual life of a loan or lease and on unfunded lending commitments. The determination of the ACL is based on periodic evaluation of loan and lease portfolios and unfunded lending commitments that are not unconditionally cancellable. A number of relevant underlying factors, including key assumptions and the evaluation of quantitative and qualitative information, are considered. 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 by assessing 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 generally grouped 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 loans, timing and amount of expected draws for unfunded lending commitments, FICO, LTV, and term for retail loans. The mix and level of loan balances, delinquency levels, assigned risk ratings, previous loss experience, current business conditions, amount and timing of expected future cash flows, and factors specific to commercial credits such as competition, business and management performance are also considered. Forward-looking economic assumptions include real GDP, unemployment rate, interest rate curve, and changes in collateral values. This data is accumulated to estimate expected credit losses over the contractual life of the loans and leases, adjusted for expected prepayments. Historical information, such as financial statements for commercial customers or consumer credit ratings, may not be as important to estimating future expected losses as forecasted inputs to the models during volatile economic time periods. The ACL may also be affected by a variety of qualitative factors that the Company considers that are not measured in the statistical procedures including uncertainty related to economic forecasts, loan growth, backtesting 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 determined and applied across the portfolio. Certain loan portfolios don’t require an econometric model to calculate expected credit losses. For these portfolios, approaches that are less data intensive and non-modeled are utilized to estimate credit losses as they are considered more efficient and practical for portfolios that have outstanding balances that are not material (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 are assessed on an individual loan level basis. Generally, measurement of the ACL on an individual loan or lease 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 substantially through the operation or sale of the underlying collateral, rather than by cash flows from the borrower’s operations, income or other resources. Generally, this occurs when cash flows to repay the loan from all other available sources, including guarantors, are expected to be no more than nominal. 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, which 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 decrease to the ACL would be limited to the total amount previously written off for a given loan or lease. Collateral values for residential mortgage and home equity loans are based on appraisals, which are updated every 90 days at a minimum, less estimated costs to sell. At December 31, 2023 and 2022, the Company had collateral-dependent residential mortgage and home equity loans totaling $556 million and $561 million, respectively. Commercial loans are secured by various types of collateral, including real estate, inventory, equipment, accounts receivable, securities and cash, among others. Collateral values are generally based on appraisals for commercial real estate loans, which are updated based on management judgment on a case-by-case basis. At December 31, 2023 and 2022, the Company had collateral-dependent commercial loans totaling $233 million and $21 million, respectively. The amortized cost basis of mortgage loans collateralized by residential real estate for which formal foreclosure proceedings were in-process was $336 million and $250 million as of December 31, 2023 and 2022, respectively. Expected recoveries are considered in management’s estimate of the ACL and may result in a reduction to the ACL balance. A negative ACL for a collateral dependent loan exists if the fair value of the collateral increases in a subsequent reporting period and 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. 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, are considered to estimate 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 in the allowance for loan and lease losses and other liabilities, respectively, in the Consolidated Balance Sheets . The provision for credit losses related to loan and lease portfolios and unfunded lending commitments is reported in provision (benefit) for credit losses in the Consolidated Statements of Operations. 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, workout/restructuring expectations of the loan and valuation of the borrower’s equity or 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, credit card and unsecured open-end loans are generally charged-off in the month when the account becomes 180 days past due. Auto, education 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 written down to their net realizable value earlier in the following circumstances: • FDMs that are determined to be collateral dependent. • 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 written 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, 2023: Year Ended December 31, 2023 (dollars in millions) Commercial Retail Total Allowance for loan and lease losses, beginning of period $1,060 $923 $1,983 Charge-offs (285) (472) (757) Recoveries 18 130 148 Net charge-offs (267) (342) (609) Provision expense (benefit) for loans and leases 457 267 724 Allowance for loan and lease losses, end of period 1,250 848 2,098 Allowance for unfunded lending commitments, beginning of period 207 50 257 Provision expense (benefit) for unfunded lending commitments (32) (5) (37) Allowance for unfunded lending commitments, end of period 175 45 220 Total allowance for credit losses, end of period $1,425 $893 $2,318 During the year ended December 31, 2023, net charge-offs of $609 million and a provision for expected credit losses of $687 million resulted in an increase of $78 million to the ACL. Our ACL as of December 31, 2023 accounts for an economic forecast over our two-year reasonable and supportable period with peak unemployment of approximately 5% and peak-to-trough GDP decline of approximately 0.4%. This forecast reflects a mild recession over the two-year reasonable and supportable period. The following tables present a summary of changes in the ACL for the years ended December 31, 2022 and 2021: Year Ended December 31, 2022 (dollars 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. Year Ended December 31, 2021 (dollars 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 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. Renewals are categorized as new credit decisions and reflect the renewal date as the vintage date, except for renewals of loans modified for borrowers experiencing financial difficulty, or FDMs, which are presented in the original vintage. Citizens utilizes internal risk ratings to monitor credit quality for commercial loans and leases. These ratings are assigned at loan origination and are periodically reevaluated utilizing a risk-based approach, annually at a minimum, or any time management becomes aware of information affecting a borrower’s ability to fulfill their obligations. The reevaluation process considers both quantitative and qualitative factors. The following categories are utilized to develop the ACL: • Pass - includes obligations where the probability of default is considered low and repayment in full is expected in accordance with the contractual loan terms; • Special Mention - includes obligations that have potential weakness that, if left uncorrected, may result in deterioration of the Company’s credit position at some future date; • Substandard Accrual - includes obligations that have well-defined weaknesses that could hinder normal repayment or collection of the debt, but are currently performing; • Nonaccrual - includes obligations where management has determined that full payment of principal and interest is in doubt. For more information on nonaccrual loans and leases see “Nonaccrual and Past Due Assets” below. For commercial and industrial loans, the performance of the borrower is monitored in a disciplined and regular manner based upon the level of credit risk inherent in the loan. To evaluate the level of credit risk, an internal risk rating is assigned 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 annually at a minimum. The combination of the PD and LGD assigned ratings, which reflect credit quality characteristics as of the reporting date and are used as inputs into the loss forecasting process, capture both the expectation of default and loss severity in the event of default. Each loan is periodically reviewed by management based on the amount of the lending arrangement and risk rating assessment, with priority given to those loans which are perceived to be of higher risk, or loans for which credit quality is weakening (e.g., payment delinquency). Loans are proactively managed by utilizing various procedures that are customized to the risk of a given loan, including ongoing outreach to the borrower, assessment of the borrower’s financial condition and appraisal of the collateral. Credit risk associated with commercial real estate loans is managed similar to commercial and industrial loans by evaluating PD and LGD. Risks associated with commercial real estate activities are typically correlated to the loan structure, collateral location, project progress and business environment. As a result, these attributes are monitored and utilized in assessing credit risk. 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. Credit risk associated with leases is managed similar to commercial and industrial loans by evaluating 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 without a new credit decision. Citizens generally reserves the right to not renew the loan or lease until current underwriting is completed and approved. The following table presents the amortized cost basis of commercial loans and leases by vintage date and internal risk rating as of December 31, 2023, and gross charge-offs by vintage date for the year ended December 31, 2023: Term Loans by Origination Year Revolving Loans (dollars in millions) 2023 2022 2021 2020 2019 Prior to 2019 Within the Revolving Period Converted to Term Total Commercial and industrial Pass $3,599 $6,338 $5,049 $1,254 $1,085 $2,031 $21,033 $53 $40,442 Special Mention 59 194 354 29 48 113 368 — 1,165 Substandard Accrual 5 175 325 212 121 284 792 11 1,925 Nonaccrual 1 72 51 4 5 102 53 6 294 Total commercial and industrial 3,664 6,779 5,779 1,499 1,259 2,530 22,246 70 43,826 Gross charge-offs 1 3 34 4 1 34 44 — 121 Commercial real estate Pass 1,906 5,791 6,062 2,555 2,294 3,895 1,975 8 24,486 Special Mention — 713 539 222 183 260 75 — 1,992 Substandard Accrual — 277 203 469 528 939 100 — 2,516 Nonaccrual 1 66 2 23 144 238 3 — 477 Total commercial real estate 1,907 6,847 6,806 3,269 3,149 5,332 2,153 8 29,471 Gross charge-offs — — — 56 13 95 — — 164 Leases Pass 95 174 282 191 62 268 — — 1,072 Special Mention — 27 1 1 2 — — — 31 Substandard Accrual 3 14 12 6 4 3 — — 42 Nonaccrual — — 3 — — — — — 3 Total leases 98 215 298 198 68 271 — — 1,148 Gross charge-offs — — — — — — — — — Total commercial Pass 5,600 12,303 11,393 4,000 3,441 6,194 23,008 61 66,000 Special Mention 59 934 894 252 233 373 443 — 3,188 Substandard Accrual 8 466 540 687 653 1,226 892 11 4,483 Nonaccrual 2 138 56 27 149 340 56 6 774 Total commercial (1) $5,669 $13,841 $12,883 $4,966 $4,476 $8,133 $24,399 $78 $74,445 Gross charge-offs $1 $3 $34 $60 $14 $129 $44 $— $285 (1) In the fourth quarter of 2023, the Company revised its presentation of commercial loans and leases by vintage date and internal risk rating to reflect how the Company currently manages the commercial credit portfolio. The Company now reports Substandard Accrual and Nonaccrual ratings, replacing previously reported ratings of Substandard and Doubtful, respectively. The prior period presentation was revised to conform to the new presentation. For more information regarding the Company’s internal risk ratings, see “Credit Quality Indicators” above. The following table presents the amortized cost basis of commercial loans and leases by vintage date and internal risk rating as of December 31, 2022: Term Loans by Origination Year Revolving Loans (dollars 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 Accrual 148 210 194 254 97 330 554 12 1,799 Nonaccrual 12 22 10 6 43 33 119 4 249 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 Accrual 91 15 75 248 346 591 23 — 1,389 Nonaccrual 1 5 13 60 4 20 — — 103 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 Accrual — 4 3 3 — — — — 10 Nonaccrual — — — — — — — — — 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 Accrual 239 229 272 505 443 921 577 12 3,198 Nonaccrual 13 27 23 66 47 53 119 4 352 Total commercial (1) $14,715 $15,843 $6,633 $6,280 $4,245 $7,076 $27,221 $167 $82,180 (1) In the fourth quarter of 2023, the Company revised its presentation of commercial loans and leases by vintage date and internal risk rating to reflect how the Company currently manages the commercial credit portfolio. The Company now reports Substandard Accrual and Nonaccrual ratings, replacing previously reported ratings of Substandard and Doubtful, respectively. The prior period presentation was revised to conform to the new presentation. For more information regarding the Company’s internal risk ratings, see “Credit Quality Indicators” above. 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 current FICO score as of December 31, 2023, and gross charge-offs by vintage date for the year ended December 31, 2023: Term Loans by Origination Year Revolving Loans (dollars in millions) 2023 2022 2021 2020 2019 Prior to 2019 Within the Revolving Period Converted to Term Total Residential mortgages 800+ $889 $3,067 $5,172 $3,117 $1,131 $3,125 $— $— $16,501 740-799 1,333 1,940 2,560 1,411 592 1,625 — — 9,461 680-739 367 631 758 466 266 873 — — 3,361 620-679 54 135 165 90 121 445 — — 1,010 <620 9 48 104 95 161 561 — — 978 No FICO available (1) 1 — 2 1 3 14 — — 21 Total residential mortgages 2,653 5,821 8,761 5,180 2,274 6,643 — — 31,332 Gross charge-offs — — — 1 1 4 — — 6 Home equity 800+ — 4 4 1 4 91 5,078 222 5,404 740-799 — 1 2 1 3 82 4,708 241 5,038 680-739 1 1 1 2 5 93 2,693 202 2,998 620-679 — 1 1 2 8 77 718 137 944 <620 — 2 1 1 10 80 332 230 656 Total home equity 1 9 9 7 30 423 13,529 1,032 15,040 Gross charge-offs — — — — — 3 8 1 12 Automobile 800+ 81 539 1,062 368 162 47 — — 2,259 740-799 134 671 1,038 375 165 52 — — 2,435 680-739 147 577 708 252 118 39 — — 1,841 620-679 94 316 345 112 65 26 — — 958 <620 44 232 291 100 66 32 — — 765 No FICO available (1) — — — — — — — — — Total automobile 500 2,335 3,444 1,207 576 196 — — 8,258 Gross charge-offs 3 34 41 14 12 9 — — 113 Education 800+ 296 671 1,637 1,418 600 1,185 — — 5,807 740-799 368 694 1,050 850 369 678 — — 4,009 680-739 143 289 333 273 134 298 — — 1,470 620-679 30 65 68 58 32 107 — — 360 <620 5 18 25 23 15 55 — — 141 No FICO available (1) 10 — 1 — — 36 — — 47 Total education 852 1,737 3,114 2,622 1,150 2,359 — — 11,834 Gross charge-offs — 5 19 25 17 45 — — 111 Other retail 800+ 183 70 38 35 16 18 500 — 860 740-799 258 87 46 45 21 19 963 1 1,440 680-739 214 76 39 39 18 11 973 2 1,372 620-679 118 48 23 19 6 4 419 2 639 <620 31 35 18 14 4 2 251 2 357 No FICO available (1) 7 1 — 1 — — 373 — 382 Total other retail 811 317 164 153 65 54 3,479 7 5,050 Gross charge-offs 49 24 8 8 11 9 121 — 230 Total retail 800+ 1,449 4,351 7,913 4,939 1,913 4,466 5,578 222 30,831 740-799 2,093 3,393 4,696 2,682 1,150 2,456 5,671 242 22,383 680-739 872 1,574 1,839 1,032 541 1,314 3,666 204 11,042 620-679 296 565 602 281 232 659 1,137 139 3,911 <620 89 335 439 233 256 730 583 232 2,897 No FICO available (1) 18 1 3 2 3 50 373 — 450 Total retail $4,817 $10,219 $15,492 $9,169 $4,095 $9,675 $17,008 $1,039 $71,514 Gross charge-offs $52 $63 $68 $48 $41 $70 $129 $1 $472 (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 current FICO score as of December 31, 2022: Term Loans by Origination Year Revolving Loans (dollars 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). Nonaccrual and Past Due Assets Nonaccrual loans and leases are those on which accrual of interest is 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 a loan is placed on nonaccrual status the accrued interest receivable is reversed against interest income and the amortization of any net deferred fees is suspended. Interest collected on nonaccrual loans and leases for which the ultimate collectability of principal is uncertain are generally applied to reduce the carrying value of the asset first. Otherwise, interest income may be recognized to the extent of the cash received if the loan is deemed fully collectible. A loan or lease may be returned to accrual status if: • no principal and interest payments are due and unpaid, and repayment of the remaining contractual principal and interest is expected; • the loan or lease has otherwise become well-secured and in the process of collection; or • the borrower has made regularly scheduled payments in full for the prior six months and it is reasonably assured that the loan or lease will be brought 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 accrual 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 due to 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, 2023 and 2022: December 31, 2023 Days Past Due and Accruing (dollars in millions) Current 30-59 60-89 90+ Nonaccrual Total Nonaccrual with no related ACL Commercial and industrial $43,447 $61 $18 $6 $294 $43,826 $30 Commercial real estate 28,745 150 59 40 477 29,471 71 Leases 1,144 1 — — 3 1,148 — Total commercial 73,336 212 77 46 774 74,445 101 Residential mortgages (1) 30,499 282 118 256 177 31,332 144 Home equity 14,640 82 33 — 285 15,040 198 Automobile 8,005 144 48 — 61 8,258 7 Education 11,732 49 23 2 28 11,834 3 Other retail 4,899 49 34 29 39 5,050 — Total retail 69,775 606 256 287 590 71,514 352 Total $143,111 $818 $333 $333 $1,364 $145,959 $453 Guaranteed residential mortgages (1) $675 $128 $76 $243 $— $1,122 $— (1) Guaranteed residential mortgages represent loans fully or partially guaranteed by the FHA, VA and USDA, and are included in the amounts presented for Residential mortgages. December 31, 2022 Days Past Due and Accruing (dollars 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 Guaranteed residential mortgages (1) $789 $57 $34 $316 $— $1,196 $— (1) Guaranteed residential mortgages represent loans fully or partially guaranteed by the FHA, VA and USDA, and are included in the amounts presented for Residential mortgages. Loan Modifications to Borrowers Experiencing Financial Difficulty Effective January 1, 2023, the Company adopted accounting guidance that eliminates the separate recognition and measurement of TDRs. Upon adoption of this guidance, all loan modifications to borrowers experiencing financial difficulty, or FDMs, are evaluated to determine whether the modification should be accounted for as a new loan or a continuation of the existing loan. The existing loan is derecognized and the restructured loan is accounted for as a new loan if the effective yield on the restructured loan is at least equal to the effective yield for comparable loans with similar collection risk and the modification to the original loan is more than minor. Any unamortized fees and costs from the original loan are recognized in interest income when the new loan is granted. If a loan restructuring does not meet these conditions, the existing loan’s amortized cost basis is carried forward and the modified loan is accounted for as a continuation of |