LOANS AND ALLOWANCE FOR CREDIT LOSSES | =760 904,270 3.0 % 798,258 2.7 % Total $ 30,456,897 100.0 % $ 29,335,220 100.0 % (1) Consists primarily of loans for which credit scores are not considered in the ALLL model. (2) Credit scores updated quarterly. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) Consumer Lending Asset Quality Indicators-FICO and LTV Ratio For both residential and home equity loans, loss severity assumptions are incorporated in the loan and lease loss reserve models to estimate loan balances that will ultimately charge off. These assumptions are based on recent loss experience within various current LTV bands within these portfolios. LTVs are refreshed quarterly by applying Federal Housing Finance Agency Home price index changes at a state-by-state level to the last known appraised value of the property to estimate the current LTV. The Company's ALLL incorporates the refreshed LTV information to update the distribution of defaulted loans by LTV as well as the associated loss given default for each LTV band. Reappraisals on a recurring basis at the individual property level are not considered cost-effective or necessary; however, reappraisals are performed on certain higher risk accounts to support line management activities, default servicing decisions, or when other situations arise for which the Company believes the additional expense is warranted. Residential mortgage and home equity financing receivables by LTV and FICO range are summarized as follows: Residential Mortgages (1)(3) March 31, 2019 N/A (2) LTV<=70% 70.01-80% 80.01-90% 90.01-100% 100.01-110% LTV>110% Grand Total FICO Score (dollars in thousands) N/A (2) $ 55,818 $ 2,871 $ — $ — $ — $ — $ — $ 58,689 <600 70 209,547 50,759 39,104 26,952 2,843 4,746 334,021 600-639 — 161,343 47,641 35,657 38,920 800 1,483 285,844 640-679 120 311,642 102,931 81,360 100,966 1,908 2,004 600,931 680-719 — 568,546 256,941 144,411 165,126 3,473 3,319 1,141,816 720-759 50 1,099,396 492,524 218,525 204,800 3,987 6,377 2,025,659 >=760 315 3,704,818 1,204,676 384,410 198,569 4,618 8,155 5,505,561 Grand Total $ 56,373 $ 6,058,163 $ 2,155,472 $ 903,467 $ 735,333 $ 17,629 $ 26,084 $ 9,952,521 (1) Excludes LHFS. (2) Residential mortgages and home equity loans and lines of credit in the "N/A" range for LTV or FICO score primarily represent the balance on loans serviced by others, in run-off portfolios or for which a current LTV or FICO score is unavailable. (3) Allowance model considers LTV for financing receivables in first lien position for the Company and combined LTV ("CLTV") for financing receivables in second lien position for the Company. Home Equity Loans and Lines of Credit (2) March 31, 2019 N/A (1) LTV<=70% 70.01-90% 90.01-110% LTV>110% Grand Total FICO Score (dollars in thousands) N/A (1) $ 131,248 $ 1,046 $ 451 $ — $ — $ 132,745 <600 1,066 212,854 62,843 13,389 5,459 295,611 600-639 311 168,783 44,896 5,383 3,412 222,785 640-679 694 304,570 103,486 11,713 5,951 426,414 680-719 710 528,051 195,615 18,069 11,808 754,253 720-759 97 733,174 260,357 17,718 12,157 1,023,503 >=760 1,304 1,842,488 562,711 40,841 26,592 2,473,936 Grand Total $ 135,430 $ 3,790,966 $ 1,230,359 $ 107,113 $ 65,379 $ 5,329,247 (1) Residential mortgages and home equity loans and lines of credit in the "N/A" range for LTV or FICO score primarily represent the balance on loans serviced by others, in run-off portfolios or for which a current LTV or FICO score is unavailable. (2) Allowance model considers LTV for financing receivables in first lien position for the Company and CLTV for financing receivables in second lien position for the Company. Residential Mortgages (1)(3) December 31, 2018 N/A (2) LTV<=70% 70.01-80% 80.01-90% 90.01-100% 100.01-110% LTV>110% Grand Total FICO Score (dollars in thousands) N/A (2) $ 87,808 $ 4,465 $ — $ — $ 423 $ — $ — $ 92,696 <600 69 225,647 54,101 35,625 26,863 2,450 4,604 349,359 600-639 35 157,281 47,712 34,124 37,901 943 1,544 279,540 640-679 — 308,780 112,811 76,512 101,057 1,934 1,767 602,861 680-719 — 560,920 266,877 148,283 175,889 3,630 3,593 1,159,192 720-759 50 1,061,969 535,840 210,046 218,177 4,263 6,704 2,037,049 >=760 213 3,518,916 1,253,733 354,629 220,695 6,477 9,102 5,363,765 Grand Total $ 88,175 $ 5,837,978 $ 2,271,074 $ 859,219 $ 781,005 $ 19,697 $ 27,314 $ 9,884,462 (1) Excludes LHFS. (2) Residential mortgages and home equity loans and lines of credit in the "N/A" range for LTV or FICO score primarily represent the balance on loans serviced by others, in run-off portfolios or for which a current LTV or FICO score is unavailable. (3) Allowance model considers LTV for financing receivables in first lien position for the Company and CLTV for financing receivables in second lien position for the Company. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) Home Equity Loans and Lines of Credit (2) December 31, 2018 N/A (1) LTV<=70% 70.01-90% 90.01-110% LTV>110% Grand Total FICO Score (dollars in thousands) N/A (1) $ 133,436 $ 841 $ 197 $ — $ 5 $ 134,479 <600 1,130 209,536 64,202 14,948 5,988 295,804 600-639 398 166,384 48,543 7,932 2,780 226,037 640-679 919 305,642 112,937 10,311 6,887 436,696 680-719 869 527,374 215,824 17,231 13,482 774,780 720-759 1,139 732,467 292,516 20,812 14,677 1,061,611 >=760 2,280 1,844,830 614,221 46,993 27,939 2,536,263 Grand Total $ 140,171 $ 3,787,074 $ 1,348,440 $ 118,227 $ 71,758 $ 5,465,670 (1) Residential mortgages and home equity loans and lines of credit in the "N/A" range for LTV or FICO score primarily represent the balance on loans serviced by others, in run-off portfolios or for which a current LTV or FICO score is unavailable. (2) Allowance model considers LTV for financing receivables in first lien position for the Company and CLTV for financing receivables in second lien position for the Company. TDR Loans The following table summarizes the Company’s performing and non-performing TDRs at the dates indicated: (in thousands) March 31, 2019 December 31, 2018 Performing $ 4,774,676 $ 5,014,224 Non-performing 720,190 908,128 Total (1) $ 5,494,866 $ 5,922,352 (1) Excludes LHFS. Commercial Loan TDRs All of the Company’s commercial loan modifications are based on the circumstances of the individual customer, including specific customers' complete relationships with the Company. Loan terms are modified to meet each borrower’s specific circumstances at a point in time and may allow for modifications such as term extensions and interest rate reductions. Modifications for commercial loan TDRs generally, although not always, result in bifurcation of the original loan into A and B notes. The A note is restructured to allow for upgraded risk rating and return to accrual status after a sustained period of payment performance has been achieved (typically six months for monthly payment schedules). The B note, if any, is structured as a deficiency note; the balance is charged off but the debt is usually not forgiven. Commercial TDRs are generally placed on non-accrual status until the Company believes repayment under the revised terms is reasonably assured and a sustained period of repayment performance has been achieved (typically six months for a monthly amortizing loan). TDRs are subject to analysis for specific reserves by either calculating the present value of expected future cash flows or, if collateral-dependent, calculating the fair value of the collateral less its estimated cost to sell. The TDR classification will remain on the loan until it is paid in full or liquidated. Consumer Loan TDRs The primary modification program for the Company’s residential mortgage and home equity portfolios is a proprietary program designed to keep customers in their homes and, when appropriate, prevent them from entering into foreclosure. The program is available to all customers facing a financial hardship regardless of their delinquency status. The main goal of the modification program is to review the customer’s entire financial condition to ensure that the proposed modified payment solution is affordable according to a specific DTI ratio range. The main modification benefits of the program allow for term extensions, interest rate reductions, and/or deferment of principal. The Company reviews each customer on a case-by-case basis to determine which benefit or combination of benefits will be offered to achieve the target DTI range. For the Company’s other consumer portfolios, including RICs and auto loans, the terms of the modifications generally include one or a combination of: a reduction of the stated interest rate of the loan to a rate of interest lower than the current market rate for new debt with similar risk or an extension of the maturity date. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) Consumer TDRs excluding RICs are generally placed on non-accrual status until the Company believes repayment under the revised terms is reasonably assured and a sustained period of repayment performance has been achieved (typically six months for a monthly amortizing loan). Any loan that has remained current for the six months immediately prior to modification will remain on accru" id="sjs-B4" xml:space="preserve"> LOANS AND ALLOWANCE FOR CREDIT LOSSES Overall The Company's loans are reported at their outstanding principal balances net of any cumulative charge-offs, unamortized deferred fees and costs and unamortized premiums or discounts. The Company maintains an ACL to provide for losses inherent in its portfolios. Certain loans are pledged as collateral for borrowings, securitizations, or special purpose entities ("SPEs"). These loans totaled $50.4 billion at March 31, 2019 and $49.5 billion at December 31, 2018 . Loans that the Company intends to sell are classified as LHFS. The LHFS portfolio balance at March 31, 2019 was $1.2 billion , compared to $1.3 billion at December 31, 2018 . LHFS in the residential mortgage portfolio are reported at either estimated fair value (if the FVO is elected) or the lower of cost or fair value. For a discussion on the valuation of LHFS at fair value, see Note 14 to the Condensed Consolidated Financial Statements . Loans under SC’s personal lending platform have been classified as HFS and adjustments to lower of cost or market are recorded through Miscellaneous income, net on the Condensed Consolidated Statements of Operations . As of March 31, 2019 , the carrying value of the personal unsecured HFS portfolio was $1.0 billion . Interest on loans is credited to income as it is earned. Loan origination fees and certain direct loan origination costs are deferred and recognized as adjustments to interest income in the Condensed Consolidated Statements of Operations over the contractual life of the loan utilizing the interest method. Loan origination costs and fees and premiums and discounts on RICs are deferred and recognized in interest income over their estimated lives using estimated prepayment speeds, which are updated on a monthly basis. At March 31, 2019 and December 31, 2018 , accrued interest receivable on the Company's loans was $497.5 million and $524.0 million , respectively. Loan and Lease Portfolio Composition The following presents the composition of the gross loans and leases HFI by portfolio and by rate type: March 31, 2019 December 31, 2018 (dollars in thousands) Amount Percent Amount Percent Commercial LHFI: Commercial real estate ("CRE") loans $ 8,709,750 9.8 % $ 8,704,481 10.0 % Commercial and industrial ("C&I") loans 16,504,188 18.5 % 15,738,158 18.1 % Multifamily loans 8,492,025 9.5 % 8,309,115 9.5 % Other commercial (2) 7,887,508 8.8 % 7,630,004 8.8 % Total commercial LHFI 41,593,471 46.6 % 40,381,758 46.4 % Consumer loans secured by real estate: Residential mortgages 9,952,521 11.2 % 9,884,462 11.4 % Home equity loans and lines of credit 5,329,247 6.0 % 5,465,670 6.3 % Total consumer loans secured by real estate 15,281,768 17.2 % 15,350,132 17.7 % Consumer loans not secured by real estate: RICs and auto loans - originated (4) 29,843,248 33.5 % 28,532,085 32.8 % RICs and auto loans - purchased 613,649 0.7 % 803,135 0.9 % Personal unsecured loans 1,468,889 1.6 % 1,531,708 1.8 % Other consumer (3) 403,235 0.4 % 447,050 0.4 % Total consumer loans 47,610,789 53.4 % 46,664,110 53.6 % Total LHFI (1) $ 89,204,260 100.0 % $ 87,045,868 100.0 % Total LHFI: Fixed rate $ 58,101,354 65.1 % $ 56,696,491 65.1 % Variable rate 31,102,906 34.9 % 30,349,377 34.9 % Total LHFI (1) $ 89,204,260 100.0 % $ 87,045,868 100.0 % (1) Total LHFI includes deferred loan fees, net of deferred origination costs and unamortized purchase premiums, net of discounts as well as purchase accounting adjustments. These items resulted in a net increase in the loan balances of $1.7 billion and $1.4 billion as of March 31, 2019 and December 31, 2018 , respectively. (2) Other commercial includes commercial equipment vehicle financing ("CEVF") leveraged leases and loans. (3) Other consumer primarily includes recreational vehicle ("RV") and marine loans. (4) Beginning in 2018, the Bank has an agreement with SC by which SC provides the Bank with origination support services in connection with the processing, underwriting and purchase of RICs, primarily from Chrysler dealers. Portfolio segments and classes GAAP requires that entities disclose information about the credit quality of their financing receivables at disaggregated levels, specifically defined as “portfolio segments” and “classes,” based on management’s systematic methodology for determining the ACL. The Company utilizes similar categorization compared to the financial statement categorization of loans to model and calculate the ACL and track the credit quality, delinquency and impairment status of the underlying loan populations. In disaggregating its financing receivables portfolio, the Company’s methodology begins with the commercial and consumer segments. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) The commercial segmentation reflects line of business distinctions. The CRE line of business includes C&I owner-occupied real estate and specialized lending for investment real estate. The Company's allowance methodology further classifies loans in this line of business into construction and non-construction loans; however, the methodology for development and determination of the allowance is generally consistent between the two portfolios. "C&I" includes non-real estate-related C&I loans. "Multifamily" represents loans for multifamily residential housing units. “Other commercial” includes loans to global customer relationships in Latin America which are not defined as commercial or consumer for regulatory purposes. The remainder of the portfolio primarily represents the CEVF portfolio. The Company's portfolio classes are substantially the same as its financial statement categorization of loans for consumer loan populations. “Residential mortgages” includes mortgages on residential property, including single family and 1-4 family units. "Home equity loans and lines of credit" include all organic home equity contracts and purchased home equity portfolios. "RICs and auto loans" includes the Company's direct automobile loan portfolios, but excludes RV and marine RICs. "Personal unsecured loans" includes personal revolving loans and credit cards. “Other consumer” includes an acquired portfolio of marine RICs and RV contracts as well as indirect auto loans. In accordance with the Company's accounting policy when establishing the collective ACL for originated loans, the Company's estimate of losses on recorded investment includes the estimate of the related net unaccreted discount balance that is expected at the time of charge-off, while it considers the entire unaccreted discount for loan portfolios purchased at a discount as available to absorb the credit losses when determining the ACL specific to these portfolios. This accounting policy is not applicable to the purchased loan portfolios acquired with evidence of credit deterioration, on which we elected to apply the FVO. The RIC and auto loan portfolio is comprised of: (1) RICs originated by SC prior to the first quarter 2014 consolidation and change in control of SC (the “Change in Control"), (2) RICs originated by SC after the Change in Control, and (3) auto loans originated by SBNA. The composition of the portfolio segment is as follows: (in thousands) March 31, 2019 December 31, 2018 RICs - Purchased HFI: Unpaid principal balance ("UPB") (1) $ 645,381 $ 844,582 UPB - FVO (2) 7,492 9,678 Total UPB 652,873 854,260 Purchase marks (3) (39,224 ) (51,125 ) Total RICs - Purchased HFI 613,649 803,135 RICs - Originated HFI: UPB (1) 27,621,076 27,049,875 Net discount (105,819 ) (135,489 ) Total RICs - Originated 27,515,257 26,914,386 SBNA auto loans 2,327,991 1,617,699 Total RICs - originated post-Change in Control 29,843,248 28,532,085 Total RICs and auto loans HFI $ 30,456,897 $ 29,335,220 (1) UPB does not include amounts related to the loan receivables - unsecured and loan receivables from dealers due to the short-term and revolving nature of these receivables. (2) The Company elected to account for these loans, which were acquired with evidence of credit deterioration, under the FVO. (3) Includes purchase marks of $1.7 million and $2.1 million related to purchase loan portfolios on which we elected to apply the FVO at March 31, 2019 and December 31, 2018 , respectively. During the three-month periods March 31, 2019 and 2018 , SC originated $2.4 billion and $2.0 billion , respectively, in Chrysler Capital loans (which excludes the SBNA originations program), which represented 61% and 46% , respectively, of the UPB of the Company's total RIC originations. As of March 31, 2019 and December 31, 2018 , the Company's carrying value of its auto RIC portfolio consisted of $9.2 billion and $9.0 billion , respectively, of Chrysler Capital loans (excluding the SBNA originations program), which represented 36% and 36% , respectively, of the Company's auto RIC portfolio. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) ACL Rollforward by Portfolio Segment The activity in the ACL by portfolio segment for the three-month periods ended March 31, 2019 , and 2018 was as follows: Three-Month Period Ended March 31, 2019 (in thousands) Commercial Consumer Unallocated Total ALLL, beginning of period $ 441,086 $ 3,409,021 $ 47,023 $ 3,897,130 Provision for loan and lease losses 21,974 581,052 — 603,026 Charge-offs (23,601 ) (1,424,618 ) (275 ) (1,448,494 ) Recoveries 8,532 782,901 — 791,433 Charge-offs, net of recoveries (15,069 ) (641,717 ) (275 ) (657,061 ) ALLL, end of period $ 447,991 $ 3,348,356 $ 46,748 $ 3,843,095 Reserve for unfunded lending commitments, beginning of period $ 89,472 $ 6,028 $ — $ 95,500 (Release of) / Provision for reserve for unfunded lending commitments (2,909 ) 94 — (2,815 ) Reserve for unfunded lending commitments, end of period 86,563 6,122 — 92,685 Total ACL, end of period $ 534,554 $ 3,354,478 $ 46,748 $ 3,935,780 Ending balance, individually evaluated for impairment (1) $ 95,309 $ 1,319,385 $ — $ 1,414,694 Ending balance, collectively evaluated for impairment 352,682 2,028,971 46,748 2,428,401 Financing receivables: Ending balance $ 41,637,571 $ 48,779,267 $ — $ 90,416,838 Ending balance, evaluated under the FVO or lower of cost or fair value 44,099 1,267,594 — 1,311,693 Ending balance, individually evaluated for impairment (1) 447,725 5,346,965 — 5,794,690 Ending balance, collectively evaluated for impairment 41,145,747 42,164,708 — 83,310,455 (1) Consists of loans in troubled debt restructuring ("TDR") status. Three-Month Period Ended March 31, 2018 (in thousands) Commercial Consumer Unallocated Total ALLL, beginning of period $ 443,796 $ 3,504,068 $ 47,023 $ 3,994,887 Provision for loan and lease losses 41,232 531,894 — 573,126 Charge-offs (32,960 ) (1,222,427 ) — (1,255,387 ) Recoveries 10,006 661,744 — 671,750 Charge-offs, net of recoveries (22,954 ) (560,683 ) — (583,637 ) ALLL, end of period $ 462,074 $ 3,475,279 $ 47,023 $ 3,984,376 Reserve for unfunded lending commitments, beginning of period $ 108,805 $ 306 $ — $ 109,111 Release of unfunded lending commitments (19,263 ) 17 — (19,246 ) Reserve for unfunded lending commitments, end of period 89,542 323 — 89,865 Total ACL, end of period $ 551,616 $ 3,475,602 $ 47,023 $ 4,074,241 Ending balance, individually evaluated for impairment (1) $ 94,993 $ 1,749,597 $ — $ 1,844,590 Ending balance, collectively evaluated for impairment 367,081 1,725,682 47,023 2,139,786 Financing receivables: Ending balance $ 38,400,180 $ 43,774,298 $ — $ 82,174,478 Ending balance, evaluated under the FVO or lower of cost or fair value 195,721 1,798,347 — 1,994,068 Ending balance, individually evaluated for impairment (1) 568,557 6,432,443 — 7,001,000 Ending balance, collectively evaluated for impairment 37,635,902 35,543,508 — 73,179,410 (1) Consists of loans in TDR status. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) The following table presents the activity in the allowance for loan losses for RICs acquired in the Change in Control and those originated by SC subsequent to the Change in Control. Three-Month Period Ended March 31, 2019 (in thousands) Purchased Originated Total ALLL, beginning of period $ 193,742 $ 2,992,576 $ 3,186,318 (Release of) / Provision for loan and lease losses (24,084 ) 569,931 545,847 Charge-offs (51,312 ) (1,331,904 ) (1,383,216 ) Recoveries 33,533 739,847 773,380 Charge-offs, net of recoveries (17,779 ) (592,057 ) (609,836 ) ALLL, end of period $ 151,879 $ 2,970,450 $ 3,122,329 Three-Month Period Ended March 31, 2018 (in thousands) Purchased Originated Total ALLL, beginning of period $ 384,167 $ 2,862,356 $ 3,246,523 (Release of) / Provision for loan and lease losses (15,830 ) 538,505 522,675 Charge-offs (105,510 ) (1,082,006 ) (1,187,516 ) Recoveries 59,899 594,952 654,851 Charge-offs, net of recoveries (45,611 ) (487,054 ) (532,665 ) ALLL, end of period $ 322,726 $ 2,913,807 $ 3,236,533 Non-accrual loans by Class of Financing Receivable The recorded investment in non-accrual loans disaggregated by class of financing receivables and other non-performing assets is summarized as follows: (in thousands) March 31, 2019 December 31, 2018 Non-accrual loans: Commercial: CRE $ 82,504 $ 88,500 C&I 214,093 189,827 Multifamily 8,994 13,530 Other commercial 87,390 72,841 Total commercial loans 392,981 364,698 Consumer: Residential mortgages 207,344 216,815 Home equity loans and lines of credit 112,445 115,813 RICs and auto loans - originated 1,184,193 1,455,406 RICs - purchased 66,935 89,916 Personal unsecured loans 3,538 3,602 Other consumer 8,769 9,187 Total consumer loans 1,583,224 1,890,739 Total non-accrual loans 1,976,205 2,255,437 Other real estate owned ("OREO") 106,097 107,868 Repossessed vehicles 196,886 224,046 Foreclosed and other repossessed assets 2,507 1,844 Total OREO and other repossessed assets 305,490 333,758 Total non-performing assets $ 2,281,695 $ 2,589,195 NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) Age Analysis of Past Due Loans The Company generally considers an account delinquent when an obligor fails to pay substantially all (defined as 90% ) of the scheduled payment by the due date. The age of recorded investments in past due loans and accruing loans 90 days or greater past due disaggregated by class of financing receivables is summarized as follows: As of: March 31, 2019 (in thousands) 30-89 90 Total Current Total (1) Recorded Investment Commercial: CRE $ 27,837 $ 66,700 $ 94,537 $ 8,615,213 $ 8,709,750 $ — C&I (1) 105,259 53,293 158,552 16,389,735 16,548,287 — Multifamily 46,087 1,599 47,686 8,444,339 8,492,025 — Other commercial 63,542 4,548 68,090 7,819,419 7,887,509 — Consumer: Residential mortgages 164,566 161,019 325,585 9,821,397 10,146,982 — Home equity loans and lines of credit 51,584 76,379 127,963 5,201,284 5,329,247 — RICs and auto loans - originated 3,247,752 299,021 3,546,773 26,296,475 29,843,248 — RICs and auto loans - purchased 169,793 12,489 182,282 431,367 613,649 — Personal unsecured loans 97,577 89,978 187,555 2,255,351 2,442,906 86,413 Other consumer 15,465 11,981 27,446 375,789 403,235 — Total $ 3,989,462 $ 777,007 $ 4,766,469 $ 85,650,369 $ 90,416,838 $ 86,413 (1) C&I loans includes $44.1 million of LHFS at March 31, 2019 . (2) Residential mortgages includes $194.5 million of LHFS at March 31, 2019 . (3) Personal unsecured loans includes $1.0 billion of LHFS at March 31, 2019 . As of December 31, 2018 (in thousands) 30-89 90 Total Current Total (1) Recorded Commercial: CRE $ 20,179 $ 49,317 $ 69,496 $ 8,634,985 $ 8,704,481 $ — C&I 61,495 74,210 135,705 15,602,453 15,738,158 — Multifamily 1,078 4,574 5,652 8,303,463 8,309,115 — Other commercial 16,081 5,330 21,411 7,608,593 7,630,004 6 Consumer: Residential mortgages 186,222 171,265 357,487 9,741,496 10,098,983 — Home equity loans and lines of credit 58,507 79,860 138,367 5,327,303 5,465,670 — RICs and auto loans - originated 4,076,015 419,819 4,495,834 24,036,251 28,532,085 — RICs and auto loans - purchased 242,604 21,923 264,527 538,608 803,135 — Personal unsecured loans 93,675 102,463 196,138 2,404,327 2,600,465 98,973 Other consumer 16,261 13,782 30,043 417,007 447,050 — Total $ 4,772,117 $ 942,543 $ 5,714,660 $ 82,614,486 $ 88,329,146 $ 98,979 (1) Residential mortgages included $214.5 million of LHFS at December 31, 2018 . (2) Personal unsecured loans included $1.1 billion of LHFS at December 31, 2018 . NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) Impaired Loans by Class of Financing Receivable Impaired loans are generally defined as all TDRs plus commercial non-accrual loans in excess of $1.0 million . Impaired loans disaggregated by class of financing receivables are summarized as follows: March 31, 2019 (in thousands) Recorded Investment (1) UPB Related Average With no related allowance recorded: Commercial: CRE $ 74,425 $ 83,594 $ — $ 76,741 C&I 42,472 52,697 — 34,166 Multifamily 10,077 10,984 — 14,169 Other commercial 13,528 13,563 — 10,438 Consumer: Residential mortgages 141,221 194,953 — 143,060 Home equity loans and lines of credit 45,176 47,208 — 45,623 RICs and auto loans - originated — — — 1 RICs and auto loans - purchased 5,565 7,149 — 6,313 Personal unsecured loans 20 20 — 12 Other consumer 3,195 3,195 — 3,393 With an allowance recorded: Commercial: CRE 51,918 59,844 6,951 55,390 C&I 176,353 196,603 64,850 178,266 Multifamily — — — — Other commercial 65,921 65,921 23,508 62,918 Consumer: Residential mortgages 255,166 291,999 28,234 254,566 Home equity loans and lines of credit 64,226 74,872 4,294 62,383 RICs and auto loans - originated 4,318,164 4,331,157 1,133,183 4,474,389 RICs and auto loans - purchased 494,097 558,409 146,232 554,084 Personal unsecured loans 15,685 15,814 6,210 15,934 Other consumer 10,014 12,971 1,232 10,037 Total: Commercial $ 434,694 $ 483,206 $ 95,309 $ 432,088 Consumer 5,352,529 5,537,747 1,319,385 5,569,795 Total $ 5,787,223 $ 6,020,953 $ 1,414,694 $ 6,001,883 (1) Recorded investment includes deferred loan fees, net of deferred origination costs and unamortized purchase premiums, net of discounts, as well as purchase accounting adjustments. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) The Company recognized interest income, not including the impact of purchase accounting adjustments, of $205.4 million for the three-month period ended March 31, 2019 on approximately $4.8 billion of TDRs that were in performing status as of March 31, 2019 . December 31, 2018 (in thousands) Recorded Investment (1) UPB Related Average With no related allowance recorded: Commercial: CRE $ 79,056 $ 88,960 $ — $ 102,731 C&I 25,859 36,067 — 54,200 Multifamily 18,260 19,175 — 14,074 Other commercial 7,348 7,380 — 4,058 Consumer: Residential mortgages 144,899 201,905 — 126,110 Home equity loans and lines of credit 46,069 48,021 — 49,233 RICs and auto loans - originated 1 1 — 1 RICs and auto loans - purchased 7,061 9,071 — 11,627 Personal unsecured loans 4 4 — 42 Other consumer 3,591 3,591 — 6,574 With an allowance recorded: Commercial: CRE 58,861 66,645 6,449 78,271 C&I 180,178 197,937 66,329 178,474 Multifamily — — — 3,101 Other commercial 59,914 59,914 21,342 68,813 Consumer: Residential mortgages 253,965 289,447 29,156 288,029 Home equity loans and lines of credit 60,540 71,475 4,272 62,684 RICs and auto loans - originated 4,630,614 4,652,013 1,231,164 4,742,820 RICs and auto loans - purchased 614,071 694,000 184,545 890,274 Personal unsecured loans 16,182 16,446 6,875 16,330 Other consumer 10,060 13,275 1,162 10,826 Total: Commercial $ 429,476 $ 476,078 $ 94,120 $ 503,722 Consumer 5,787,057 5,999,249 1,457,174 6,204,550 Total $ 6,216,533 $ 6,475,327 $ 1,551,294 $ 6,708,272 (1) Recorded investment includes deferred loan fees, net of deferred origination costs and unamortized purchase premiums, net of discounts, as well as purchase accounting adjustments. The Company recognized interest income, not including the impact of purchase accounting adjustments, of $761.0 million for the year ended December 31, 2018 on approximately $5.0 billion of TDRs that were in performing status as of December 31, 2018 . Commercial Lending Asset Quality Indicators The Company's Risk Department performs a credit analysis and classifies certain loans over an internal threshold based on the commercial lending classifications described below: PASS. Asset is well-protected by the current net worth and paying capacity of the obligor or guarantors, if any, or by the fair value less costs to acquire and sell any underlying collateral in a timely manner. SPECIAL MENTION. Asset has potential weaknesses that deserve management’s close attention, which, if left uncorrected, may result in deterioration of the repayment prospects for an asset at some future date. Special mention assets are not adversely classified. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) SUBSTANDARD. Asset is inadequately protected by the current net worth and paying capacity of the obligor or by the collateral pledged, if any. A well-defined weakness or weaknesses exist that jeopardize the liquidation of the debt. The loans are characterized by the distinct possibility that the Company will sustain some loss if deficiencies are not corrected. DOUBTFUL. Exhibits the inherent weaknesses of a substandard credit. Additional characteristics exist that make collection or liquidation in full highly questionable and improbable, on the basis of currently known facts, conditions and values. Possibility of loss is extremely high, but because of certain important and reasonable specific pending factors which may work to the advantage and strengthening of the credit, an estimated loss cannot yet be determined. LOSS. Credit is considered uncollectible and of such little value that it does not warrant consideration as an active asset. There may be some recovery or salvage value, but there is doubt as to whether, how much or when the recovery would occur. Commercial loan credit quality indicators by class of financing receivables are summarized as follows: March 31, 2019 CRE C&I Multifamily Remaining Total (1) (in thousands) Rating: Pass $ 7,751,438 $ 14,741,539 $ 8,262,331 $ 7,500,488 $ 38,255,796 Special mention 538,203 782,001 204,314 280,641 1,805,159 Substandard 373,474 455,380 25,380 40,328 894,562 Doubtful 3,889 38,786 — 66,052 108,727 N/A (2) 42,746 530,581 — — 573,327 Total commercial loans $ 8,709,750 $ 16,548,287 $ 8,492,025 $ 7,887,509 $ 41,637,571 (1) Financing receivables include LHFS. (2) Consists of loans that have not been assigned a regulatory rating. December 31, 2018 CRE C&I Multifamily Remaining Total (1) (in thousands) Rating: Pass $ 7,655,627 $ 14,003,134 $ 8,072,407 $ 7,466,419 $ 37,197,587 Special mention 628,097 772,704 204,262 67,313 1,672,376 Substandard 373,356 408,515 32,446 36,255 850,572 Doubtful 4,655 38,373 — 60,017 103,045 N/A (2) 42,746 515,432 — — 558,178 Total commercial loans $ 8,704,481 $ 15,738,158 $ 8,309,115 $ 7,630,004 $ 40,381,758 (1) Financing receivables include LHFS. (2) Consists of loans that have not been assigned a regulatory rating. Consumer Lending Asset Quality Indicators-Credit Score Consumer financing receivables for which either an internal or external credit score is a core component of the allowance model are summarized by credit score as follows: Credit Score Range (2) March 31, 2019 December 31, 2018 (dollars in thousands) RICs and auto loans Percent RICs and auto loans Percent No FICO ®(1) $ 3,236,902 10.6 % $ 3,136,449 10.7 % <600 15,208,232 49.9 % 14,884,385 50.7 % 600-639 5,414,127 17.8 % 5,185,412 17.7 % 640-679 4,968,013 16.3 % 4,758,394 16.2 % 680-719 369,272 1.2 % 289,270 1.0 % 720-759 356,081 1.2 % 283,052 1.0 % >=760 904,270 3.0 % 798,258 2.7 % Total $ 30,456,897 100.0 % $ 29,335,220 100.0 % (1) Consists primarily of loans for which credit scores are not considered in the ALLL model. (2) Credit scores updated quarterly. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) Consumer Lending Asset Quality Indicators-FICO and LTV Ratio For both residential and home equity loans, loss severity assumptions are incorporated in the loan and lease loss reserve models to estimate loan balances that will ultimately charge off. These assumptions are based on recent loss experience within various current LTV bands within these portfolios. LTVs are refreshed quarterly by applying Federal Housing Finance Agency Home price index changes at a state-by-state level to the last known appraised value of the property to estimate the current LTV. The Company's ALLL incorporates the refreshed LTV information to update the distribution of defaulted loans by LTV as well as the associated loss given default for each LTV band. Reappraisals on a recurring basis at the individual property level are not considered cost-effective or necessary; however, reappraisals are performed on certain higher risk accounts to support line management activities, default servicing decisions, or when other situations arise for which the Company believes the additional expense is warranted. Residential mortgage and home equity financing receivables by LTV and FICO range are summarized as follows: Residential Mortgages (1)(3) March 31, 2019 N/A (2) LTV<=70% 70.01-80% 80.01-90% 90.01-100% 100.01-110% LTV>110% Grand Total FICO Score (dollars in thousands) N/A (2) $ 55,818 $ 2,871 $ — $ — $ — $ — $ — $ 58,689 <600 70 209,547 50,759 39,104 26,952 2,843 4,746 334,021 600-639 — 161,343 47,641 35,657 38,920 800 1,483 285,844 640-679 120 311,642 102,931 81,360 100,966 1,908 2,004 600,931 680-719 — 568,546 256,941 144,411 165,126 3,473 3,319 1,141,816 720-759 50 1,099,396 492,524 218,525 204,800 3,987 6,377 2,025,659 >=760 315 3,704,818 1,204,676 384,410 198,569 4,618 8,155 5,505,561 Grand Total $ 56,373 $ 6,058,163 $ 2,155,472 $ 903,467 $ 735,333 $ 17,629 $ 26,084 $ 9,952,521 (1) Excludes LHFS. (2) Residential mortgages and home equity loans and lines of credit in the "N/A" range for LTV or FICO score primarily represent the balance on loans serviced by others, in run-off portfolios or for which a current LTV or FICO score is unavailable. (3) Allowance model considers LTV for financing receivables in first lien position for the Company and combined LTV ("CLTV") for financing receivables in second lien position for the Company. Home Equity Loans and Lines of Credit (2) March 31, 2019 N/A (1) LTV<=70% 70.01-90% 90.01-110% LTV>110% Grand Total FICO Score (dollars in thousands) N/A (1) $ 131,248 $ 1,046 $ 451 $ — $ — $ 132,745 <600 1,066 212,854 62,843 13,389 5,459 295,611 600-639 311 168,783 44,896 5,383 3,412 222,785 640-679 694 304,570 103,486 11,713 5,951 426,414 680-719 710 528,051 195,615 18,069 11,808 754,253 720-759 97 733,174 260,357 17,718 12,157 1,023,503 >=760 1,304 1,842,488 562,711 40,841 26,592 2,473,936 Grand Total $ 135,430 $ 3,790,966 $ 1,230,359 $ 107,113 $ 65,379 $ 5,329,247 (1) Residential mortgages and home equity loans and lines of credit in the "N/A" range for LTV or FICO score primarily represent the balance on loans serviced by others, in run-off portfolios or for which a current LTV or FICO score is unavailable. (2) Allowance model considers LTV for financing receivables in first lien position for the Company and CLTV for financing receivables in second lien position for the Company. Residential Mortgages (1)(3) December 31, 2018 N/A (2) LTV<=70% 70.01-80% 80.01-90% 90.01-100% 100.01-110% LTV>110% Grand Total FICO Score (dollars in thousands) N/A (2) $ 87,808 $ 4,465 $ — $ — $ 423 $ — $ — $ 92,696 <600 69 225,647 54,101 35,625 26,863 2,450 4,604 349,359 600-639 35 157,281 47,712 34,124 37,901 943 1,544 279,540 640-679 — 308,780 112,811 76,512 101,057 1,934 1,767 602,861 680-719 — 560,920 266,877 148,283 175,889 3,630 3,593 1,159,192 720-759 50 1,061,969 535,840 210,046 218,177 4,263 6,704 2,037,049 >=760 213 3,518,916 1,253,733 354,629 220,695 6,477 9,102 5,363,765 Grand Total $ 88,175 $ 5,837,978 $ 2,271,074 $ 859,219 $ 781,005 $ 19,697 $ 27,314 $ 9,884,462 (1) Excludes LHFS. (2) Residential mortgages and home equity loans and lines of credit in the "N/A" range for LTV or FICO score primarily represent the balance on loans serviced by others, in run-off portfolios or for which a current LTV or FICO score is unavailable. (3) Allowance model considers LTV for financing receivables in first lien position for the Company and CLTV for financing receivables in second lien position for the Company. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) Home Equity Loans and Lines of Credit (2) December 31, 2018 N/A (1) LTV<=70% 70.01-90% 90.01-110% LTV>110% Grand Total FICO Score (dollars in thousands) N/A (1) $ 133,436 $ 841 $ 197 $ — $ 5 $ 134,479 <600 1,130 209,536 64,202 14,948 5,988 295,804 600-639 398 166,384 48,543 7,932 2,780 226,037 640-679 919 305,642 112,937 10,311 6,887 436,696 680-719 869 527,374 215,824 17,231 13,482 774,780 720-759 1,139 732,467 292,516 20,812 14,677 1,061,611 >=760 2,280 1,844,830 614,221 46,993 27,939 2,536,263 Grand Total $ 140,171 $ 3,787,074 $ 1,348,440 $ 118,227 $ 71,758 $ 5,465,670 (1) Residential mortgages and home equity loans and lines of credit in the "N/A" range for LTV or FICO score primarily represent the balance on loans serviced by others, in run-off portfolios or for which a current LTV or FICO score is unavailable. (2) Allowance model considers LTV for financing receivables in first lien position for the Company and CLTV for financing receivables in second lien position for the Company. TDR Loans The following table summarizes the Company’s performing and non-performing TDRs at the dates indicated: (in thousands) March 31, 2019 December 31, 2018 Performing $ 4,774,676 $ 5,014,224 Non-performing 720,190 908,128 Total (1) $ 5,494,866 $ 5,922,352 (1) Excludes LHFS. Commercial Loan TDRs All of the Company’s commercial loan modifications are based on the circumstances of the individual customer, including specific customers' complete relationships with the Company. Loan terms are modified to meet each borrower’s specific circumstances at a point in time and may allow for modifications such as term extensions and interest rate reductions. Modifications for commercial loan TDRs generally, although not always, result in bifurcation of the original loan into A and B notes. The A note is restructured to allow for upgraded risk rating and return to accrual status after a sustained period of payment performance has been achieved (typically six months for monthly payment schedules). The B note, if any, is structured as a deficiency note; the balance is charged off but the debt is usually not forgiven. Commercial TDRs are generally placed on non-accrual status until the Company believes repayment under the revised terms is reasonably assured and a sustained period of repayment performance has been achieved (typically six months for a monthly amortizing loan). TDRs are subject to analysis for specific reserves by either calculating the present value of expected future cash flows or, if collateral-dependent, calculating the fair value of the collateral less its estimated cost to sell. The TDR classification will remain on the loan until it is paid in full or liquidated. Consumer Loan TDRs The primary modification program for the Company’s residential mortgage and home equity portfolios is a proprietary program designed to keep customers in their homes and, when appropriate, prevent them from entering into foreclosure. The program is available to all customers facing a financial hardship regardless of their delinquency status. The main goal of the modification program is to review the customer’s entire financial condition to ensure that the proposed modified payment solution is affordable according to a specific DTI ratio range. The main modification benefits of the program allow for term extensions, interest rate reductions, and/or deferment of principal. The Company reviews each customer on a case-by-case basis to determine which benefit or combination of benefits will be offered to achieve the target DTI range. For the Company’s other consumer portfolios, including RICs and auto loans, the terms of the modifications generally include one or a combination of: a reduction of the stated interest rate of the loan to a rate of interest lower than the current market rate for new debt with similar risk or an extension of the maturity date. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) Consumer TDRs excluding RICs are generally placed on non-accrual status until the Company believes repayment under the revised terms is reasonably assured and a sustained period of repayment performance has been achieved (typically six months for a monthly amortizing loan). Any loan that has remained current for the six months immediately prior to modification will remain on accru |