LOANS AND ALLOWANCE FOR CREDIT LOSSES | =760 2,170,986 6.4 % 798,258 2.7 % Total $ 34,196,156 100.0 % $ 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) September 30, 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) $ 150,167 $ 4,699 $ 817 $ — $ — $ — $ — $ 155,683 <600 34 171,317 42,793 36,151 25,047 991 319 276,652 600-639 — 125,017 41,663 34,522 34,026 1,146 1,312 237,686 640-679 428 273,782 95,861 80,680 90,581 1,157 3,363 545,852 680-719 832 522,679 222,693 129,263 149,188 1,534 2,706 1,028,895 720-759 3,315 979,460 435,027 190,525 192,564 1,781 2,918 1,805,590 >=760 5,067 3,378,231 946,154 340,551 186,729 4,633 5,933 4,867,298 Grand Total $ 159,843 $ 5,455,185 $ 1,785,008 $ 811,692 $ 678,135 $ 11,242 $ 16,551 $ 8,917,656 (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) ALLL 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) September 30, 2019 N/A (1) LTV<=70% 70.01-90% 90.01-110% LTV>110% Grand Total FICO Score (dollars in thousands) N/A (1) $ 161,320 $ 1,321 $ 440 $ — $ — $ 163,081 <600 514 216,875 46,576 7,874 4,274 276,113 600-639 385 156,619 35,032 5,109 2,632 199,777 640-679 1,699 286,979 82,090 7,583 3,643 381,994 680-719 4,710 510,948 156,561 13,597 10,333 696,149 720-759 7,099 692,508 221,333 14,447 10,347 945,734 >=760 17,373 1,755,329 431,733 32,130 19,794 2,256,359 Grand Total $ 193,100 $ 3,620,579 $ 973,765 $ 80,740 $ 51,023 $ 4,919,207 (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) ALLL 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) ALLL 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" 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 $50.2 billion at September 30, 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 September 30, 2019 was $2.5 billion , compared to $1.3 billion at December 31, 2018 . LHFS in the residential mortgage portfolio that were originated with the intent to sell were $ 437.9 million as of September 30, 2019 and 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 September 30, 2019 , the carrying value of the personal unsecured HFS portfolio was $1.0 billion . During the second quarter of 2019, the Company entered into an agreement to sell approximately $1.4 billion of performing residential loans to FNMA and approximately $566 million of this loan portfolio was sold during the second quarter for a gain of approximately $7 million . The remaining loans were sold during the third quarter of 2019 for an immaterial gain. In October 2019, SBNA agreed to sell from its portfolio certain restructured residential mortgage and home equity loans (with approximately $187 million of principal balances outstanding) to two unrelated third parties. This transaction is expected to settle in the fourth quarter with an immaterial impact on the Condensed Consolidated Statement of Operations. The loans will be sold with servicing released to the purchasers. This portfolio was classified as held for sale as of September 30, 2019 . On October 4, 2019, SBNA agreed to sell approximately $768 million of equipment finance loans and approximately $74 million of operating leases to an unrelated third party. This transaction is expected to settle in the fourth quarter with an immaterial gain on the sale. SBNA will not retain servicing of the assets. This portfolio was classified as held for sale as of September 30, 2019 . 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 September 30, 2019 and December 31, 2018 , accrued interest receivable on the Company's loans was $499.5 million and $524.0 million , respectively. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) Loan and Lease Portfolio Composition The following presents the composition of gross loans and leases HFI by portfolio and by rate type: September 30, 2019 December 31, 2018 (dollars in thousands) Amount Percent Amount Percent Commercial LHFI: Commercial real estate ("CRE") loans $ 8,725,162 9.6 % $ 8,704,481 10.0 % Commercial and industrial ("C&I") loans 16,087,269 17.8 % 15,738,158 18.1 % Multifamily loans 8,465,070 9.4 % 8,309,115 9.5 % Other commercial (2) 7,441,572 8.2 % 7,630,004 8.8 % Total commercial LHFI 40,719,073 45.0 % 40,381,758 46.4 % Consumer loans secured by real estate: Residential mortgages 8,917,656 9.9 % 9,884,462 11.4 % Home equity loans and lines of credit 4,919,207 5.4 % 5,465,670 6.3 % Total consumer loans secured by real estate 13,836,863 15.3 % 15,350,132 17.7 % Consumer loans not secured by real estate: RICs and auto loans - originated (4) 33,832,932 37.4 % 28,532,085 32.8 % RICs and auto loans - purchased 363,224 0.4 % 803,135 0.9 % Personal unsecured loans 1,325,875 1.5 % 1,531,708 1.8 % Other consumer (3) 342,296 0.4 % 447,050 0.4 % Total consumer loans 49,701,190 55.0 % 46,664,110 53.6 % Total LHFI (1) $ 90,420,263 100.0 % $ 87,045,868 100.0 % Total LHFI: Fixed rate $ 59,122,407 65.4 % $ 56,696,491 65.1 % Variable rate 31,297,856 34.6 % 30,349,377 34.9 % Total LHFI (1) $ 90,420,263 100.0 % $ 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 September 30, 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. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) 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. 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) September 30, 2019 December 31, 2018 RICs - Purchased HFI: Unpaid principal balance ("UPB") (1) $ 371,700 $ 844,582 UPB - FVO (2) 4,403 9,678 Total UPB 376,103 854,260 Purchase marks (3) (12,879 ) (51,125 ) Total RICs - Purchased HFI 363,224 803,135 RICs - Originated HFI: UPB (1) 28,528,963 27,049,875 Net discount (17,997 ) (135,489 ) Total RICs - Originated 28,510,966 26,914,386 SBNA auto loans 5,321,966 1,617,699 Total RICs - originated post-Change in Control 33,832,932 28,532,085 Total RICs and auto loans HFI $ 34,196,156 $ 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 $1.0 million and $2.1 million related to purchase loan portfolios on which we elected to apply the FVO at September 30, 2019 and December 31, 2018 , respectively. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) During the nine-month periods September 30, 2019 and 2018 , SC originated $9.5 billion and $6.5 billion , respectively, in Chrysler Capital loans (including the SBNA originations program), which represented 56% and 48% , respectively, of the UPB of SC's total RIC originations (including the SBNA originations program). As of September 30, 2019 and December 31, 2018 , the carrying value of the auto RIC portfolio consisted of $9.9 billion and $9.0 billion , respectively, of Chrysler Capital loans, which represented 38% and 36% , respectively, of SC's auto RIC portfolio. ACL Rollforward by Portfolio Segment The activity in the ACL by portfolio segment for the three-month and nine-month periods ended September 30, 2019 , and 2018 was as follows: Three-Month Period Ended September 30, 2019 (in thousands) Commercial Consumer Unallocated Total ALLL, beginning of period $ 447,078 $ 3,290,007 $ 46,748 $ 3,783,833 Provision for loan and lease losses 14,251 583,640 — 597,891 Charge-offs (2) (57,276 ) (1,367,404 ) — (1,424,680 ) Recoveries 18,393 760,423 — 778,816 Charge-offs, net of recoveries (38,883 ) (606,981 ) — (645,864 ) ALLL, end of period $ 422,446 $ 3,266,666 $ 46,748 $ 3,735,860 Reserve for unfunded lending commitments, beginning of period $ 83,346 $ 6,060 $ — $ 89,406 Provision for reserve for unfunded lending commitments 5,907 (163 ) — 5,744 Reserve for unfunded lending commitments, end of period 89,253 5,897 — 95,150 Total ACL, end of period $ 511,699 $ 3,272,563 $ 46,748 $ 3,831,010 Nine-Month Period Ended September 30, 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 59,895 1,624,933 — 1,684,828 Charge-offs (117,591 ) (4,020,570 ) (275 ) (4,138,436 ) Recoveries 39,056 2,253,282 — 2,292,338 Charge-offs, net of recoveries (78,535 ) (1,767,288 ) (275 ) (1,846,098 ) ALLL, end of period $ 422,446 $ 3,266,666 $ 46,748 $ 3,735,860 Reserve for unfunded lending commitments, beginning of period $ 89,472 $ 6,028 $ — $ 95,500 (Release of) / Provision for reserve for unfunded lending commitments (219 ) (131 ) — (350 ) Reserve for unfunded lending commitments, end of period 89,253 5,897 — 95,150 Total ACL, end of period $ 511,699 $ 3,272,563 $ 46,748 $ 3,831,010 Ending balance, individually evaluated for impairment (1) $ 71,241 $ 1,096,563 $ — $ 1,167,804 Ending balance, collectively evaluated for impairment 351,205 2,170,103 46,748 2,568,056 Financing receivables: Ending balance $ 41,564,256 $ 51,336,816 $ — $ 92,901,072 Ending balance, evaluated under the FVO or lower of cost or fair value 845,184 1,716,626 — 2,561,810 Ending balance, individually evaluated for impairment (1) 364,390 4,667,358 — 5,031,748 Ending balance, collectively evaluated for impairment 40,354,682 44,952,832 — 85,307,514 (1) Consists of loans in troubled debt restructuring ("TDR") status. (2) Includes impact for RICs transferred back from held for sale. NOTE 4. LOANS AND ALLOWANCE FOR CREDIT LOSSES (continued) Three-Month Period Ended September 30, 2018 (in thousands) Commercial Consumer Unallocated Total ALLL, beginning of period $ 426,820 $ 3,515,033 $ 47,023 $ 3,988,876 Provision for loan and lease losses 10,637 602,933 — 613,570 Charge-offs (21,353 ) (1,258,144 ) — (1,279,497 ) Recoveries 17,325 616,699 — 634,024 Charge-offs, net of recoveries (4,028 ) (641,445 ) — (645,473 ) ALLL, end of period $ 433,429 $ 3,476,521 $ 47,023 $ 3,956,973 Reserve for unfunded lending commitments, beginning of period $ 81,525 $ 5,448 $ — $ 86,973 (Release of) / Provision for unfunded lending commitments 7,401 43 — 7,444 Loss on unfunded lending commitments (96 ) — — (96 ) Reserve for unfunded lending commitments, end of period 88,830 5,491 — 94,321 Total ACL, end of period $ 522,259 $ 3,482,012 $ 47,023 $ 4,051,294 Nine-Month Period Ended September 30, 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 18,658 1,604,733 — 1,623,391 Charge-offs (70,978 ) (3,524,081 ) — (3,595,059 ) Recoveries 41,953 1,891,801 — 1,933,754 Charge-offs, net of recoveries (29,025 ) (1,632,280 ) — (1,661,305 ) ALLL, end of period $ 433,429 $ 3,476,521 $ 47,023 $ 3,956,973 Reserve for unfunded lending commitments, beginning of period $ 103,835 $ 5,276 $ — $ 109,111 Release of unfunded lending commitments (14,909 ) 215 — (14,694 ) Loss on unfunded lending commitments (96 ) — — (96 ) Reserve for unfunded lending commitments, end of period 88,830 5,491 — 94,321 Total ACL, end of period $ 522,259 $ 3,482,012 $ 47,023 $ 4,051,294 Ending balance, individually evaluated for impairment (1) $ 88,625 $ 1,605,101 $ — $ 1,693,726 Ending balance, collectively evaluated for impairment 344,804 1,871,420 47,023 2,263,247 Financing receivables: Ending balance $ 39,788,670 $ 46,420,276 $ — $ 86,208,946 Ending balance, evaluated under the FVO or lower of cost or fair value 152 1,266,263 — 1,266,415 Ending balance, individually evaluated for impairment (1) 479,710 6,177,635 — 6,657,345 Ending balance, collectively evaluated for impairment 39,308,808 38,976,378 — 78,285,186 (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 Nine-Month Period Ended September 30, 2019 September 30, 2019 (in thousands) Purchased Originated Total Purchased Originated Total ALLL, beginning of period $ 118,040 $ 2,946,957 $ 3,064,997 $ 193,742 $ 2,992,576 $ 3,186,318 (Release of) / Provision for loan and lease losses (17,667 ) 576,621 558,954 (66,227 ) 1,593,236 1,527,009 Charge-offs (1) (32,967 ) (1,283,124 ) (1,316,091 ) (119,230 ) (3,757,525 ) (3,876,755 ) Recoveries 22,135 724,837 746,972 81,256 2,137,004 2,218,260 Charge-offs, net of recoveries (10,832 ) (558,287 ) (569,119 ) (37,974 ) (1,620,521 ) (1,658,495 ) ALLL, end of period $ 89,541 $ 2,965,291 $ 3,054,832 $ 89,541 $ 2,965,291 $ 3,054,832 Three-Month Period Ended Nine-Month Period Ended September 30, 2018 September 30, 2018 (in thousands) Purchased Originated Total Purchased Originated Total ALLL, beginning of period $ 266,221 $ 2,993,354 $ 3,259,575 $ 384,167 $ 2,862,356 $ 3,246,523 (Release of) / Provision for loan and lease losses (15,312 ) 614,696 599,384 (61,173 ) 1,604,603 1,543,430 Charge-offs (71,969 ) (1,142,162 ) (1,214,131 ) (253,744 ) (3,152,911 ) (3,406,655 ) Recoveries 38,330 569,394 607,724 148,020 1,721,234 1,869,254 Charge-offs, net of recoveries (33,639 ) (572,768 ) (606,407 ) (105,724 ) (1,431,677 ) (1,537,401 ) ALLL, end of period $ 217,270 $ 3,035,282 $ 3,252,552 $ 217,270 $ 3,035,282 $ 3,252,552 (1) Includes loans transferred to held for sale. 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) September 30, 2019 December 31, 2018 Non-accrual loans: Commercial: CRE $ 101,042 $ 88,500 C&I 160,835 189,827 Multifamily 3,298 13,530 Other commercial 29,814 72,841 Total commercial loans 294,989 364,698 Consumer: Residential mortgages 185,891 216,815 Home equity loans and lines of credit 110,092 115,813 RICs and auto loans - originated 1,405,829 1,455,406 RICs - purchased 37,615 89,916 Personal unsecured loans 3,470 3,602 Other consumer 9,686 9,187 Total consumer loans 1,752,583 1,890,739 Total non-accrual loans 2,047,572 2,255,437 Other real estate owned ("OREO") 80,760 107,868 Repossessed vehicles 223,831 224,046 Foreclosed and other repossessed assets 2,325 1,844 Total OREO and other repossessed assets 306,916 333,758 Total non-performing assets $ 2,354,488 $ 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: September 30, 2019 (in thousands) 30-89 90 Total Current Total Recorded Investment Commercial: CRE $ 22,434 $ 63,920 $ 86,354 $ 8,638,808 $ 8,725,162 $ — C&I (1) 86,513 67,818 154,331 16,009,942 16,164,273 — Multifamily 8,502 1,703 10,205 8,454,865 8,465,070 — Other commercial (2) 19,414 30,376 49,790 8,159,961 8,209,751 — Consumer: Residential mortgages (3) 156,658 177,988 334,646 9,177,670 9,512,316 — Home equity loans and lines of credit (4) 43,864 80,248 124,112 4,835,387 4,959,499 — RICs and auto loans - originated 3,887,285 342,102 4,229,387 29,603,545 33,832,932 — RICs and auto loans - purchased 117,427 8,890 126,317 236,907 363,224 — Personal unsecured loans (5) 92,435 92,641 185,076 2,141,474 2,326,550 87,520 Other consumer 11,534 10,829 22,363 319,932 342,295 — Total $ 4,446,066 $ 876,515 $ 5,322,581 $ 87,578,491 $ 92,901,072 $ 87,520 (1) C&I loans includes $77.0 million of LHFS at September 30, 2019 . (2) Other commercial includes $768.2 million of LHFS at September 30, 2019 . (3) Residential mortgages includes $594.7 million of LHFS at September 30, 2019 . (4) Home equity loans and lines of credit includes $40.3 million of LHFS at September 30, 2019 . (5) Personal unsecured loans includes $1.0 billion of LHFS at September 30, 2019 . As of December 31, 2018 (in thousands) 30-89 90 Total Current Total 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 (1) 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 (2) 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: September 30, 2019 (in thousands) Recorded Investment (1) UPB Related Average With no related allowance recorded: Commercial: CRE $ 74,090 $ 79,893 $ — $ 76,573 C&I 20,675 22,445 — 23,267 Multifamily 4,692 5,581 — 11,476 Other commercial 3,274 3,291 — 5,311 Consumer: Residential mortgages 130,222 180,404 — 137,561 Home equity loans and lines of credit 43,031 45,206 — 44,550 RICs and auto loans - originated — — — 1 RICs and auto loans - purchased 3,387 4,352 — 5,224 Personal unsecured loans 3 3 — 4 Other consumer 3,131 3,131 — 3,361 With an allowance recorded: Commercial: CRE 79,453 88,366 22,199 69,157 C&I 150,641 194,830 47,019 165,410 Other commercial 18,855 18,855 2,023 39,385 Consumer: Residential mortgages 240,473 276,231 27,164 247,219 Home equity loans and lines of credit 63,421 74,401 4,314 61,981 RICs and auto loans - originated 3,850,726 3,851,881 971,193 4,240,670 RICs and auto loans - purchased 310,601 351,029 88,137 462,336 Personal unsecured loans 15,125 15,367 4,658 15,654 Other consumer 10,626 13,563 1,097 10,343 Total: Commercial $ 351,680 $ 413,261 $ 71,241 $ 390,579 Consumer 4,670,746 4,815,568 1,096,563 5,228,904 Total $ 5,022,426 $ 5,228,829 $ 1,167,804 $ 5,619,483 (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 $492.9 million for the nine-month period ended September 30, 2019 on approximately $4.1 billion of TDRs that were in performing status as of September 30, 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: September 30, 2019 CRE C&I Multifamily Remaining Total (1) (in thousands) Rating: Pass $ 7,757,692 $ 14,356,417 $ 8,208,885 $ 7,877,207 $ 38,200,201 Special mention 503,424 716,502 234,240 263,749 1,717,915 Substandard 419,570 402,184 21,945 68,310 912,009 Doubtful 1,730 47,331 — 485 49,546 N/A (2) 42,746 641,839 — — 684,585 Total commercial loans $ 8,725,162 $ 16,164,273 $ 8,465,070 $ 8,209,751 $ 41,564,256 (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) September 30, 2019 December 31, 2018 (dollars in thousands) RICs and auto loans Percent RICs and auto loans Percent No FICO ®(1) $ 3,205,955 9.4 % $ 3,136,449 10.7 % <600 15,495,142 45.3 % 14,884,385 50.7 % 600-639 5,974,294 17.5 % 5,185,412 17.7 % 640-679 5,723,096 16.7 % 4,758,394 16.2 % 680-719 794,847 2.3 % 289,270 1.0 % 720-759 831,836 2.4 % 283,052 1.0 % >=760 2,170,986 6.4 % 798,258 2.7 % Total $ 34,196,156 100.0 % $ 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) September 30, 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) $ 150,167 $ 4,699 $ 817 $ — $ — $ — $ — $ 155,683 <600 34 171,317 42,793 36,151 25,047 991 319 276,652 600-639 — 125,017 41,663 34,522 34,026 1,146 1,312 237,686 640-679 428 273,782 95,861 80,680 90,581 1,157 3,363 545,852 680-719 832 522,679 222,693 129,263 149,188 1,534 2,706 1,028,895 720-759 3,315 979,460 435,027 190,525 192,564 1,781 2,918 1,805,590 >=760 5,067 3,378,231 946,154 340,551 186,729 4,633 5,933 4,867,298 Grand Total $ 159,843 $ 5,455,185 $ 1,785,008 $ 811,692 $ 678,135 $ 11,242 $ 16,551 $ 8,917,656 (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) ALLL 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) September 30, 2019 N/A (1) LTV<=70% 70.01-90% 90.01-110% LTV>110% Grand Total FICO Score (dollars in thousands) N/A (1) $ 161,320 $ 1,321 $ 440 $ — $ — $ 163,081 <600 514 216,875 46,576 7,874 4,274 276,113 600-639 385 156,619 35,032 5,109 2,632 199,777 640-679 1,699 286,979 82,090 7,583 3,643 381,994 680-719 4,710 510,948 156,561 13,597 10,333 696,149 720-759 7,099 692,508 221,333 14,447 10,347 945,734 >=760 17,373 1,755,329 431,733 32,130 19,794 2,256,359 Grand Total $ 193,100 $ 3,620,579 $ 973,765 $ 80,740 $ 51,023 $ 4,919,207 (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) ALLL 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) ALLL 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 |