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 and 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, and 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 relevant in 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, regional geographic concentrations, 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. Approaches that are less data intensive and non-modeled are utilized to estimate credit losses for these portfolios, 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 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 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 the corresponding change in the fair value of the collateral during the period. Any decrease to the ACL would be limited to the 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, 2024 and 2023, the Company had collateral-dependent residential mortgage and home equity loans totaling $372 million and $556 million, respectively. The amortized cost basis of mortgage loans collateralized by residential real estate for which formal foreclosure proceedings were in-process was $295 million and $336 million as of December 31, 2024 and 2023, 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, 2024 and 2023, the Company had collateral-dependent commercial loans totaling $607 million and $233 million, 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 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, 2024: Year Ended December 31, 2024 (dollars in millions) Commercial Retail Total Allowance for loan and lease losses, beginning of period $1,250 $848 $2,098 Charge-offs (419) (504) (923) Recoveries 43 134 177 Net charge-offs (376) (370) (746) Provision expense (benefit) for loans and leases 266 443 709 Allowance for loan and lease losses, end of period 1,140 921 2,061 Allowance for unfunded lending commitments, beginning of period 175 45 220 Provision expense (benefit) for unfunded lending commitments (20) (2) (22) Allowance for unfunded lending commitments, end of period 155 43 198 Total allowance for credit losses, end of period $1,295 $964 $2,259 During the year ended December 31, 2024, net charge-offs of $746 million and a provision for expected credit losses of $687 million resulted in a decrease of $59 million to the ACL. As of December 31, 2024, the ACL economic forecast over a two-year reasonable and supportable period was consistent with December 31, 2023, with peak unemployment of approximately 5.1% and start-to-trough real GDP decline of approximately 0.4%. These forecasts reflect 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, 2023 and 2022: 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 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. Credit Quality Indicators The Company presents loan and lease portfolio segments and classes by credit quality indicator and vintage year and 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. The Company utilizes internal risk ratings to monitor credit quality for commercial loans and leases. These ratings are assigned at loan origination and are 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. This 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. An internal risk rating is assigned reflecting the borrower’s PD and LGD to evaluate the level of credit risk. 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 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 CRE loans is managed similar to commercial and industrial loans by evaluating PD and LGD. Risks associated with CRE 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. The Company 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, 2024: Term Loans and Leases by Origination Year Revolving Loans (dollars in millions) 2024 2023 2022 2021 2020 Prior to 2020 Within the Revolving Period Converted to Term Total Commercial and industrial Pass $5,945 $2,525 $4,194 $2,923 $895 $2,066 $21,323 $66 $39,937 Special Mention 2 79 98 236 48 48 211 — 722 Substandard Accrual 9 64 207 269 139 253 697 13 1,651 Nonaccrual — 11 68 62 5 55 34 6 241 Total commercial and industrial 5,956 2,679 4,567 3,490 1,087 2,422 22,265 85 42,551 Commercial real estate Pass 2,720 1,305 5,748 5,412 1,919 4,199 1,434 4 22,741 Special Mention 1 — 911 362 175 257 80 6 1,792 Substandard Accrual 3 22 359 253 275 875 9 120 1,916 Nonaccrual — 67 89 58 90 470 2 — 776 Total commercial real estate 2,724 1,394 7,107 6,085 2,459 5,801 1,525 130 27,225 Total commercial Pass 8,665 3,830 9,942 8,335 2,814 6,265 22,757 70 62,678 Special Mention 3 79 1,009 598 223 305 291 6 2,514 Substandard Accrual 12 86 566 522 414 1,128 706 133 3,567 Nonaccrual — 78 157 120 95 525 36 6 1,017 Total commercial $8,680 $4,073 $11,674 $9,575 $3,546 $8,223 $23,790 $215 $69,776 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: Term Loans and Leases 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 $3,694 $6,512 $5,331 $1,445 $1,147 $2,299 $21,033 $53 $41,514 Special Mention 59 221 355 30 50 113 368 — 1,196 Substandard Accrual 8 189 337 218 125 287 792 11 1,967 Nonaccrual 1 72 54 4 5 102 53 6 297 Total commercial and industrial 3,762 6,994 6,077 1,697 1,327 2,801 22,246 70 44,974 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 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 $5,669 $13,841 $12,883 $4,966 $4,476 $8,133 $24,399 $78 $74,445 For retail loans, the Company 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, 2024: Term Loans by Origination Year Revolving Loans (dollars in millions) 2024 2023 2022 2021 2020 Prior to 2020 Within the Revolving Period Converted to Term Total Residential mortgages 800+ $1,230 $1,302 $3,299 $5,109 $2,919 $3,869 $— $— $17,728 740-799 1,757 873 1,568 2,213 1,338 1,923 — — 9,672 680-739 425 281 552 697 385 938 — — 3,278 620-679 31 61 126 151 101 494 — — 964 <620 15 37 76 147 89 703 — — 1,067 No FICO available (1) 1 — — 1 1 14 — — 17 Total residential mortgages 3,459 2,554 5,621 8,318 4,833 7,941 — — 32,726 Home equity 800+ 1 — 3 4 1 76 5,634 200 5,919 740-799 — — 1 2 1 65 5,275 224 5,568 680-739 — — 1 — 1 76 2,995 183 3,256 620-679 — 1 4 3 2 60 752 141 963 <620 — 2 6 3 1 59 459 259 789 No FICO available (1) — — — — — — — — — Total home equity 1 3 15 12 6 336 15,115 1,007 16,495 Automobile 800+ — 65 380 665 183 58 — — 1,351 740-799 — 92 430 581 176 61 — — 1,340 680-739 — 91 338 385 115 45 — — 974 620-679 — 51 189 194 56 29 — — 519 <620 — 47 197 216 62 38 — — 560 No FICO available (1) — — — — — — — — — Total automobile — 346 1,534 2,041 592 231 — — 4,744 Education 800+ 227 373 657 1,517 1,256 1,475 — — 5,505 740-799 290 359 571 804 637 811 — — 3,472 680-739 110 150 229 261 211 337 — — 1,298 620-679 27 48 55 58 51 111 — — 350 <620 5 12 21 28 25 60 — — 151 No FICO available (1) 5 — — — — 31 — — 36 Total education 664 942 1,533 2,668 2,180 2,825 — — 10,812 Other retail 800+ 186 65 36 15 11 10 512 — 835 740-799 259 96 46 18 13 11 895 1 1,339 680-739 201 87 39 15 11 7 845 1 1,206 620-679 97 47 27 10 6 3 335 1 526 <620 32 31 34 15 7 3 234 1 357 No FICO available (1) 5 — — — — — 382 — 387 Total other retail 780 326 182 73 48 34 3,203 4 4,650 Total retail 800+ 1,644 1,805 4,375 7,310 4,370 5,488 6,146 200 31,338 740-799 2,306 1,420 2,616 3,618 2,165 2,871 6,170 225 21,391 680-739 736 609 1,159 1,358 723 1,403 3,840 184 10,012 620-679 155 208 401 416 216 697 1,087 142 3,322 <620 52 129 334 409 184 863 693 260 2,924 No FICO available (1) 11 — — 1 1 45 382 — 440 Total retail $4,904 $4,171 $8,885 $13,112 $7,659 $11,367 $18,318 $1,011 $69,427 (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, 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 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 No FICO available (1) — — — — — — — — — Total home equity 1 9 9 7 30 423 13,529 1,032 15,040 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 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 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 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 (1) Represents loans for which an updated FICO score was unavailable (e.g., due to recent profile changes). The following tables present gross charge-offs by vintage date for the Company’s loan and lease portfolios: Year Ended December 31, 2024 Term Loans and Leases by Origination Year Revolving Loans (dollars in millions) 2024 2023 2022 2021 2020 Prior to 2020 Within the Revolving Period Converted to Term Total Commercial and industrial $— $— $15 $31 $1 $22 $38 $— $107 Commercial real estate — — 1 23 145 143 — — 312 Total commercial — — 16 54 146 165 38 — 419 Residential mortgages — — — — — 4 — — 4 Home equity — — — — — 5 11 2 18 Automobile — 6 34 34 10 10 — — 94 Education 1 5 12 24 25 59 — — 126 Other retail 42 24 10 6 3 10 167 — 262 Total retail 43 35 56 64 38 88 178 2 504 Total loans and leases $43 $35 $72 $118 $184 $253 $216 $2 $923 Year Ended December 31, 2023 Term Loans and Leases 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 $1 $3 $34 $4 $1 $34 $44 $— $121 Commercial real estate — — — 56 13 95 — — 164 Total commercial 1 3 34 60 14 129 44 — 285 Residential mortgages — — — 1 1 4 — — 6 Home equity — — — — — 3 8 1 12 Automobile 3 34 41 14 12 9 — — 113 Education — 5 19 25 17 45 — — 111 Other retail 49 24 8 8 11 9 121 — 230 Total retail 52 63 68 48 41 70 129 1 472 Total loans and leases $53 $66 $102 $108 $55 $199 $173 $1 $757 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. Upon return to accrual status, interest payments received and applied to the carrying value of a loan or lease while on nonaccrual status are accreted into interest income over the remaining life of the loan or lease using the effective interest method. Commercial and industrial loans and commercial real estate loans 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 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 and nonaccrual loans and leases as of December 31, 2024 and 2023: December 31, 2024 Days Past Due and Accruing (dollars in millions) Current 30-59 60-89 90+ Nonaccrual Total Nonaccrual with no related ACL Commercial and industrial $42,247 $35 $20 $8 $241 $42,551 $31 Commercial real estate 26,212 204 27 6 776 27,225 32 Total commercial 68,459 239 47 14 1,017 69,776 63 Residential mortgages 32,011 251 93 179 192 32,726 142 Home equity 16,097 88 27 — 283 16,495 182 Automobile 4,563 100 33 — 48 4,744 6 Education 10,686 45 23 2 56 10,812 4 Other retail 4,504 46 31 1 68 4,650 1 Total retail 67,861 530 207 182 647 69,427 335 Total $136,320 $769 $254 $196 $1,664 $139,203 $398 Guaranteed residential mortgages (1) $696 $119 $55 $172 $— $1,042 $— 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 $44,591 $62 $18 $6 $297 $44,974 $30 Commercial real estate 28,745 150 59 40 477 29,471 71 Total commercial 73,336 212 77 46 774 74,445 101 Residential mortgages 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. Loan Modifications to Borrowers Experiencing Financial Difficulty 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 the existing loan. FDMs are generally accounted for as a continuation of the existing loan given the terms are typically not at market rates. The Company offers loan modifications, characterized as FDMs, to retail and commercial borrowers experiencing financial difficulty as a result of its loss mitigation activities that may result in a payment delay, interest rate reduction, term extension, principal forgiveness, or combination thereof. Payment delays consist of modifications that result in a delay of contractual amounts due greater than three months over a rolling 12-month period. Term extensions consist of modifications that result in an extension of the contractual maturity date greater than three months or a significant deferral of principal payments relative to the total outstanding principal balance of the loan. Commercial loan modifications are offered on a case-by-case basis and generally include a payment delay, term extension and/or interest rate reduction. The Company does |