Asset Quality | 4. Asset Quality We assess the credit quality of the loan portfolio by monitoring net credit losses, levels of nonperforming assets and delinquencies, and credit quality ratings as defined by management. Nonperforming loans are loans for which we do not accrue interest income, and include commercial and consumer loans and leases, as well as current year TDRs and nonaccruing TDR loans from prior years. Nonperforming loans do not include loans held for sale or PCI loans. Nonperforming assets include nonperforming loans, nonperforming loans held for sale, OREO, and other nonperforming assets. Our nonperforming assets and past due loans were as follows: in millions March 31, December 31, March 31, Total nonperforming loans (a), (b) $ 676 $ 387 $ 437 OREO (c) 14 14 20 Other nonperforming assets 2 2 — Total nonperforming assets $ 692 $ 403 $ 457 Nonperforming assets from discontinued operations - education lending (d) $ 6 $ 7 $ 8 Restructured loans included in nonperforming loans $ 151 $ 159 $ 141 Restructured loans with an allocated specific allowance (e) 59 69 70 Specifically allocated allowance for restructured loans (f) 29 30 39 Accruing loans past due 90 days or more $ 70 $ 72 $ 111 Accruing loans past due 30 through 89 days 237 208 216 (a) Loan balances exclude $11 million, $11 million, and $12 million of PCI loans at March 31, 2016, December 31, 2015, and March 31, 2015, respectively. (b) Includes carrying value of consumer residential mortgage loans in the process of foreclosure of approximately $131 million, $114 million, and $119 million at March 31, 2016, December 31, 2015, and March 31, 2015, respectively. (c) Includes carrying value of foreclosed residential real estate of approximately $11 million, $11 million, and $17 million at March 31, 2016, December 31, 2015, and March 31, 2015, respectively. (d) Restructured loans of approximately $21 million, $21 million, and $18 million are included in discontinued operations at March 31, 2016, December 31, 2015, and March 31, 2015, respectively. See Note 11 (“Acquisitions and Discontinued Operations”) for further discussion. (e) Included in individually impaired loans allocated a specific allowance. (f) Included in allowance for individually evaluated impaired loans. We evaluate purchased loans for impairment in accordance with the applicable accounting guidance. Purchased loans that have evidence of deterioration in credit quality since origination and for which it is probable, at acquisition, that all contractually required payments will not be collected are deemed PCI and initially recorded at fair value without recording an allowance for loan losses. All PCI loans were acquired in 2012. At the 2012 acquisition date, the estimated gross contractual amount receivable of all PCI loans totaled $41 million. The estimated cash flows not expected to be collected (the nonaccretable amount) were $11 million, and the accretable amount was approximately $5 million. The difference between the fair value and the cash flows expected to be collected from the purchased loans is accreted to interest income over the remaining term of the loans. At March 31, 2016, the outstanding unpaid principal balance and carrying value of all PCI loans was $17 million and $11 million, respectively, compared to $17 million and $11 million, respectively, at December 31, 2015, and $19 million and $12 million, respectively, at March 31, 2015. Changes in the accretable yield during the first quarter of 2016 included accretion and net reclassifications of less than $1 million, resulting in an ending balance of $5 million at March 31, 2016. Changes in the accretable yield during 2015 included accretion and net reclassifications of less than $1 million, resulting in an ending balance of $5 million at December 31, 2015, which was unchanged from the ending balance at December 31, 2014. Changes in the accretable yield during the first quarter of 2015 included accretion and net reclassifications of less than $1 million, resulting in an ending balance of $5 million at March 31, 2015. At March 31, 2016, the approximate carrying amount of our commercial nonperforming loans outstanding represented 89% of their original contractual amount owed, total nonperforming loans outstanding represented 88% of their original contractual amount owed, and nonperforming assets in total were carried at 88% of their original contractual amount owed. At March 31, 2016, our 20 largest nonperforming loans totaled $359 million, representing 54% of total loans on nonperforming status. At March 31, 2015, our 20 largest nonperforming loans totaled $123 million, representing 28% of total loans on nonperforming status. Nonperforming loans and loans held for sale reduced expected interest income by $5 million for the three months ended March 31, 2016, and $4 million for the three months ended March 31, 2015. The following tables set forth a further breakdown of individually impaired loans as of March 31, 2016, December 31, 2015, and March 31, 2015: Unpaid Average March 31, 2016 Recorded Principal Specific Recorded in millions Investment (a) Balance (b) Allowance Investment With no related allowance recorded: Commercial, financial and agricultural $ 260 $ 270 — $ 150 Commercial real estate: Commercial mortgage 4 7 — 4 Construction 8 8 — 7 Total commercial real estate loans 12 15 — 11 Total commercial loans 272 285 — 161 Real estate — residential mortgage 23 23 — 23 Home equity loans 68 68 — 65 Consumer indirect loans 1 1 — 1 Total consumer loans 92 92 — 89 Total loans with no related allowance recorded 364 377 — 250 With an allowance recorded: Commercial, financial and agricultural 101 113 $ 28 64 Commercial real estate: Commercial mortgage 4 4 1 5 Total commercial real estate loans 4 4 1 5 Total commercial loans 105 117 29 69 Real estate — residential mortgage 32 32 3 33 Home equity loans 65 65 19 64 Consumer direct loans 3 3 — 3 Credit cards 3 3 — 3 Consumer indirect loans 35 35 3 36 Total consumer loans 138 138 25 139 Total loans with an allowance recorded 243 255 54 208 Total $ 607 $ 632 $ 54 $ 458 (a) The Recorded Investment represents the face amount of the loan increased or decreased by applicable accrued interest, net deferred loan fees and costs, and unamortized premium or discount, and reflects direct charge-offs. This amount is a component of total loans on our consolidated balance sheet. (b) The Unpaid Principal Balance represents the customer’s legal obligation to us. Unpaid Average December 31, 2015 Recorded Principal Specific Recorded in millions Investment (a) Balance (b) Allowance Investment With no related allowance recorded: Commercial, financial and agricultural $ 40 $ 74 — $ 23 Commercial real estate: Commercial mortgage 5 8 — 10 Construction 5 5 — 5 Total commercial real estate loans 10 13 — 15 Total commercial loans 50 87 — 38 Real estate — residential mortgage 23 23 — 24 Home equity loans 61 61 — 62 Consumer direct loans — — — — Credit cards — — — — Consumer indirect loans 1 1 — 1 Total consumer loans 85 85 — 87 Total loans with no related allowance recorded 135 172 — 125 With an allowance recorded: Commercial, financial and agricultural 28 43 $ 7 33 Commercial real estate: Commercial mortgage 5 6 1 6 Construction — — — 1 Total commercial real estate loans 5 6 1 7 Total commercial loans 33 49 8 40 Real estate — residential mortgage 33 33 4 32 Home equity loans 64 64 20 60 Consumer direct loans 3 3 — 4 Credit cards 3 3 — 4 Consumer indirect loans 37 37 3 40 Total consumer loans 140 140 27 140 Total loans with an allowance recorded 173 189 35 180 Total $ 308 $ 361 $ 35 $ 305 (a) The Recorded Investment represents the face amount of the loan increased or decreased by applicable accrued interest, net deferred loan fees and costs, and unamortized premium or discount, and reflects direct charge-offs. This amount is a component of total loans on our consolidated balance sheet. (b) The Unpaid Principal Balance represents the customer’s legal obligation to us. Unpaid Average March 31, 2015 Recorded Principal Specific Recorded in millions Investment (a) Balance (b) Allowance Investment With no related allowance recorded: Commercial, financial and agricultural $ 20 $ 51 — $ 13 Commercial real estate: Commercial mortgage 14 19 — 14 Construction 7 7 — 6 Total commercial real estate loans 21 26 — 20 Total commercial loans 41 77 — 33 Real estate — residential mortgage 23 23 — 23 Home equity loans 63 64 — 63 Consumer indirect loans 1 1 — 2 Total consumer loans 87 88 — 88 Total loans with no related allowance recorded 128 165 — 121 With an allowance recorded: Commercial, financial and agricultural 62 62 $ 20 50 Commercial real estate: Commercial mortgage 6 7 2 6 Construction — — — 1 Total commercial real estate loans 6 7 2 7 Total commercial loans 68 69 22 57 Real estate — residential mortgage 32 32 5 32 Home equity loans 60 60 18 59 Consumer direct loans 3 3 — 3 Credit cards 4 4 — 4 Consumer indirect loans 43 43 4 44 Total consumer loans 142 142 27 142 Total loans with an allowance recorded 210 211 49 199 Total $ 338 $ 376 $ 49 $ 320 (a) The Recorded Investment represents the face amount of the loan increased or decreased by applicable accrued interest, net deferred loan fees and costs, and unamortized premium or discount, and reflects direct charge-offs. This amount is a component of total loans on our consolidated balance sheet. (b) The Unpaid Principal Balance represents the customer’s legal obligation to us. For the three months ended March 31, 2016, and March 31, 2015, interest income recognized on the outstanding balances of accruing impaired loans totaled $4 million and $1 million, respectively. At March 31, 2016, aggregate restructured loans (accrual and nonaccrual loans) totaled $283 million, compared to $280 million at December 31, 2015, and $268 million at March 31, 2015. During the first three months of 2016, we added $23 million in restructured loans, which were partially offset by $20 million in payments and charge-offs. During 2015, we added $99 million in restructured loans, which were partially offset by $89 million in payments and charge-offs. During the first three months of 2015, we added $11 million in restructured loans, which were offset by $13 million in payments and charge-offs. A further breakdown of TDRs included in nonperforming loans by loan category as of March 31, 2016, follows: Pre-modification Post-modification Outstanding Outstanding March 31, 2016 Number Recorded Recorded dollars in millions of Loans Investment Investment LOAN TYPE Nonperforming: Commercial, financial and agricultural 13 $ 58 $ 46 Commercial real estate: Real estate — commercial mortgage 10 13 4 Total commercial loans 23 71 50 Real estate — residential mortgage 323 21 21 Home equity loans 1,350 85 76 Consumer direct loans 29 1 — Credit cards 253 1 1 Consumer indirect loans 94 4 3 Total consumer loans 2,049 112 101 Total nonperforming TDRs 2,072 183 151 Prior-year accruing: (a) Commercial, financial and agricultural 7 5 2 Total commercial loans 7 5 2 Real estate — residential mortgage 532 36 36 Home equity loans 1,149 68 57 Consumer direct loans 41 2 2 Credit cards 488 3 2 Consumer indirect loans 445 59 33 Total consumer loans 2,655 168 130 Total prior-year accruing TDRs 2,662 173 132 Total TDRs 4,734 $ 356 $ 283 (a) All TDRs that were restructured prior to January 1, 2016, and are fully accruing. A further breakdown of TDRs included in nonperforming loans by loan category as of December 31, 2015, follows: Pre-modification Post-modification Outstanding Outstanding December 31, 2015 Number Recorded Recorded dollars in millions of Loans Investment Investment LOAN TYPE Nonperforming: Commercial, financial and agricultural 12 $ 56 $ 45 Commercial real estate: Real estate — commercial mortgage 12 30 7 Total commercial real estate loans 12 30 7 Total commercial loans 24 86 52 Real estate — residential mortgage 366 23 23 Home equity loans 1,262 85 76 Consumer direct loans 28 1 1 Credit cards 339 2 2 Consumer indirect loans 103 6 5 Total consumer loans 2,098 117 107 Total nonperforming TDRs 2,122 203 159 Prior-year accruing: (a) Commercial, financial and agricultural 7 5 2 Commercial real estate: Real estate — commercial mortgage — — — Total commercial real estate loans — — — Total commercial loans 7 5 2 Real estate — residential mortgage 489 34 34 Home equity loans 1,071 57 49 Consumer direct loans 42 2 2 Credit cards 461 4 2 Consumer indirect loans 430 59 32 Total consumer loans 2,493 156 119 Total prior-year accruing TDRs 2,500 161 121 Total TDRs 4,622 $ 364 $ 280 (a) All TDRs that were restructured prior to January 1, 2015, and are fully accruing. A further breakdown of TDRs included in nonperforming loans by loan category as of March 31, 2015, follows: Pre-modification Post-modification Outstanding Outstanding March 31, 2015 Number Recorded Recorded dollars in millions of Loans Investment Investment LOAN TYPE Nonperforming: Commercial, financial and agricultural 11 $ 25 $ 22 Commercial real estate: Real estate — commercial mortgage 12 37 13 Total commercial real estate loans 12 37 13 Total commercial loans 23 62 35 Real estate — residential mortgage 383 22 22 Home equity loans 1,199 80 73 Consumer direct loans 28 1 1 Credit cards 275 2 1 Consumer indirect loans 143 9 9 Total consumer loans 2,028 114 106 Total nonperforming TDRs 2,051 176 141 Prior-year accruing: (a) Commercial, financial and agricultural 17 6 3 Commercial real estate: Real estate — commercial mortgage 1 2 1 Total commercial real estate loans 1 2 1 Total commercial loans 18 8 4 Real estate — residential mortgage 454 34 34 Home equity loans 1,142 57 49 Consumer direct loans 51 2 2 Credit cards 519 4 2 Consumer indirect loans 505 62 36 Total consumer loans 2,671 159 123 Total prior-year accruing TDRs 2,689 167 127 Total TDRs 4,740 $ 343 $ 268 (a) All TDRs that were restructured prior to January 1, 2015, and are fully accruing. We classify loan modifications as TDRs when a borrower is experiencing financial difficulties and we have granted a concession without commensurate financial, structural, or legal consideration. All commercial and consumer loan TDRs, regardless of size, are individually evaluated for impairment to determine the probable loss content and are assigned a specific loan allowance if deemed appropriate. This designation has the effect of moving the loan from the general reserve methodology (i.e., collectively evaluated) to the specific reserve methodology (i.e., individually evaluated) and may impact the ALLL through a charge-off or increased loan loss provision. These components affect the ultimate allowance level. Additional information regarding TDRs for discontinued operations is provided in Note 11 (“Acquisitions and Discontinued Operations”). Commercial loan TDRs are considered defaulted when principal and interest payments are 90 days past due. Consumer loan TDRs are considered defaulted when principal and interest payments are more than 60 days past due. During the first three months of 2016, there were no commercial loan TDRs and 51 consumer loan TDRs with a combined recorded investment of $3 million that experienced payment defaults after modifications resulting in TDR status during 2015. During the first three months of 2015, there were no significant commercial loan TDRs and 89 consumer loan TDRs with a combined recorded investment of $4 million that experienced payment defaults from modifications resulting in TDR status during 2014. As TDRs are individually evaluated for impairment under the specific reserve methodology, subsequent defaults do not generally have a significant additional impact on the ALLL. Our loan modifications are handled on a case-by-case basis and are negotiated to achieve mutually agreeable terms that maximize loan collectability and meet the borrower’s financial needs. Our concession types are primarily interest rate reductions, forgiveness of principal, and other modifications. The commercial TDR other concession category includes modification of loan terms, covenants, or conditions. The consumer TDR other concession category primarily includes those borrowers’ debts that are discharged through Chapter 7 bankruptcy and have not been formally re-affirmed. The following table shows the post-modification outstanding recorded investment by concession type for our commercial and consumer accruing and nonaccruing TDRs and other selected financial data. March 31, December 31, March 31, in millions 2016 2015 2015 Commercial loans: Interest rate reduction $ 48 $ 51 $ 12 Forgiveness of principal — 2 2 Other 4 1 25 Total $ 52 $ 54 $ 39 Consumer loans: Interest rate reduction $ 128 $ 132 $ 140 Forgiveness of principal 20 8 4 Other 83 86 85 Total $ 231 $ 226 $ 229 Total commercial and consumer TDRs (a) $ 283 $ 280 $ 268 Total loans 60,438 59,876 57,953 (a) Commitments outstanding to lend additional funds to borrowers whose loan terms have been modified in TDRs are $6 million, $9 million, and $5 million at March 31, 2016, December 31, 2015, and March 31, 2015, respectively. Our policies for determining past due loans, placing loans on nonaccrual, applying payments on nonaccrual loans, and resuming accrual of interest for our commercial and consumer loan portfolios are disclosed in Note 1 (“Summary of Significant Accounting Policies”) under the heading “Nonperforming Loans” beginning on page 121 of our 2015 Form 10-K. At March 31, 2016, approximately $59.4 billion, or 98.4%, of our total loans were current, compared to approximately $59.2 billion, or 98.9% of total loans, at December 31, 2015, and approximately $57.2 billion, or 98.7% of total loans, at March 31, 2015. At March 31, 2016, total past due loans and nonperforming loans of $983 million represented approximately 1.6% of total loans, compared to $667 million, or 1.1% of total loans, at December 31, 2015, and $764 million, or 1.3% of total loans, at March 31, 2015. The following aging analysis of past due and current loans as of March 31, 2016, December 31, 2015, and March 31, 2015, provides further information regarding Key’s credit exposure. 90 and Total Past 30-59 60-89 Greater Due and Purchased March 31, 2016 Days Past Days Past Days Past Nonperforming Nonperforming Credit Total in millions Current Due Due Due Loans Loans Impaired Loans LOAN TYPE Commercial, financial and agricultural $ 31,522 $ 30 $ 31 $ 13 $ 380 $ 454 — $ 31,976 Commercial real estate: Commercial mortgage 8,327 3 3 15 16 37 — 8,364 Construction 807 20 1 1 12 34 — 841 Total commercial real estate loans 9,134 23 4 16 28 71 — 9,205 Commercial lease financing 3,868 18 25 12 11 66 — 3,934 Total commercial loans $ 44,524 $ 71 $ 60 $ 41 $ 419 $ 591 — $ 45,115 Real estate — residential mortgage $ 2,151 $ 10 $ 2 $ 2 $ 59 $ 73 $ 10 $ 2,234 Home equity loans 9,879 45 20 13 191 269 1 10,149 Consumer direct loans 1,564 6 3 5 1 15 — 1,579 Credit cards 764 5 4 7 2 18 — 782 Consumer indirect loans 562 9 2 2 4 17 — 579 Total consumer loans $ 14,920 $ 75 $ 31 $ 29 $ 257 $ 392 $ 11 $ 15,323 Total loans $ 59,444 $ 146 $ 91 $ 70 $ 676 $ 983 $ 11 $ 60,438 90 and Total Past 30-59 60-89 Greater Due and Purchased December 31, 2015 Days Past Days Past Days Past Nonperforming Nonperforming Credit Total in millions Current Due Due Due Loans Loans Impaired Loans LOAN TYPE Commercial, financial and agricultural $ 31,116 $ 11 $ 11 $ 20 $ 82 $ 124 — $ 31,240 Commercial real estate: Commercial mortgage 7,917 8 5 10 19 42 — 7,959 Construction 1,042 1 1 — 9 11 — 1,053 Total commercial real estate loans 8,959 9 6 10 28 53 — 9,012 Commercial lease financing 3,952 33 11 11 13 68 — 4,020 Total commercial loans $ 44,027 $ 53 $ 28 $ 41 $ 123 $ 245 — $ 44,272 Real estate — residential mortgage $ 2,149 $ 14 $ 3 $ 2 $ 64 $ 83 $ 10 $ 2,242 Home equity loans 10,056 50 24 14 190 278 1 10,335 Consumer direct loans 1,580 10 3 5 2 20 — 1,600 Credit cards 785 6 4 9 2 21 — 806 Consumer indirect loans 601 9 4 1 6 20 — 621 Total consumer loans $ 15,171 $ 89 $ 38 $ 31 $ 264 $ 422 $ 11 $ 15,604 Total loans $ 59,198 $ 142 $ 66 $ 72 $ 387 $ 667 $ 11 $ 59,876 90 and Total Past 30-59 60-89 Greater Due and Purchased March 31, 2015 Days Past Days Past Days Past Nonperforming Nonperforming Credit Total in millions Current Due Due Due Loans Loans Impaired Loans LOAN TYPE Commercial, financial and agricultural $ 28,603 $ 36 $ 11 $ 35 $ 98 $ 180 — $ 28,783 Commercial real estate: Commercial mortgage 8,080 5 18 29 30 82 — 8,162 Construction 1,114 10 4 2 12 28 — 1,142 Total commercial real estate loans 9,194 15 22 31 42 110 — 9,304 Commercial lease financing 4,017 9 6 12 20 47 — 4,064 Total commercial loans $ 41,814 $ 60 $ 39 $ 78 $ 160 $ 337 — $ 42,151 Real estate — residential mortgage $ 2,129 $ 12 $ 5 $ 2 $ 72 $ 91 $ 11 $ 2,231 Home equity loans 10,250 43 24 14 191 272 1 10,523 Consumer direct loans 1,527 8 4 6 2 20 — 1,547 Credit cards 708 5 3 9 2 19 — 727 Consumer indirect loans 749 9 4 2 10 25 — 774 Total consumer loans $ 15,363 $ 77 $ 40 $ 33 $ 277 $ 427 $ 12 $ 15,802 Total loans $ 57,177 $ 137 $ 79 $ 111 $ 437 $ 764 $ 12 $ 57,953 The prevalent risk characteristic for both commercial and consumer loans is the risk of loss arising from an obligor’s inability or failure to meet contractual payment or performance terms. Evaluation of this risk is stratified and monitored by the loan risk rating grades assigned for the commercial loan portfolios and the regulatory risk ratings assigned for the consumer loan portfolios. Most extensions of credit are subject to loan grading or scoring. Loan grades are assigned at the time of origination, verified by credit risk management, and periodically re-evaluated thereafter. This risk rating methodology blends our judgment with quantitative modeling. Commercial loans generally are assigned two internal risk ratings. The first rating reflects the probability that the borrower will default on an obligation; the second rating reflects expected recovery rates on the credit facility. Default probability is determined based on, among other factors, the financial strength of the borrower, an assessment of the borrower’s management, the borrower’s competitive position within its industry sector, and our view of industry risk in the context of the general economic outlook. Types of exposure, transaction structure, and collateral, including credit risk mitigants, affect the expected recovery assessment. Credit quality indicators for our commercial and consumer loan portfolios, excluding $11 million and $12 million of PCI loans at March 31, 2016, and March 31, 2015, respectively, based on regulatory classification and payment activity as of March 31, 2016, and March 31, 2015, are as follows: Commercial Credit Exposure Credit Risk Profile by Creditworthiness Category (a) (b) in millions Commercial, financial and agricultural RE — Commercial RE — Construction March 31, December 31, March 31, March 31, December 31, March 31, March 31, December 31, March 31, RATING 2016 2015 2015 2016 2015 2015 2016 2015 2015 Pass $ 30,335 $ 29,921 $ 27,886 $ 8,176 $ 7,800 $ 7,937 $ 796 $ 1,007 $ 1,120 Criticized (Accruing) 1,260 1,236 798 172 139 195 33 37 10 Criticized (Nonaccruing) 381 83 99 16 20 30 12 9 12 Total $ 31,976 $ 31,240 $ 28,783 $ 8,364 $ 7,959 $ 8,162 $ 841 $ 1,053 $ 1,142 Commercial Lease Total March 31, December 31, March 31, March 31, December 31, March 31, RATING 2016 2015 2015 2016 2015 2015 Pass $ 3,878 $ 3,967 $ 3,996 $ 43,185 $ 42,695 $ 40,939 Criticized (Accruing) 45 38 48 1,510 1,450 1,051 Criticized (Nonaccruing) 11 15 20 420 127 161 Total $ 3,934 $ 4,020 $ 4,064 $ 45,115 $ 44,272 $ 42,151 (a) Credit quality indicators are updated on an ongoing basis and reflect credit quality information as of the dates indicated. (b) The term criticized refers to those loans that are internally classified by Key as special mention or worse, which are asset quality categories defined by regulatory authorities. These assets have an elevated level of risk and may have a high probability of default or total loss. Pass rated refers to all loans not classified as criticized. Consumer Credit Exposure Credit Risk Profile by Regulatory Classifications (a) (b) in millions Residential — Prime March 31, December 31, March 31, GRADE 2016 2015 2015 Pass $ 12,107 $ 12,296 $ 12,463 Substandard 265 270 279 Total $ 12,372 $ 12,566 $ 12,742 Credit Risk Profile Based on Payment Activity (a) in millions Consumer direct loans Credit cards Consumer indirect loans March 31, December 31, March 31, March 31, December 31, March 31, March 31, December 31, March 31, 2016 2015 2015 2016 2015 2015 2016 2015 2015 Performing $ 1,578 $ 1,598 $ 1,545 $ 780 $ 804 $ 725 $ 575 $ 615 $ 764 Nonperforming 1 2 2 2 2 2 4 6 10 Total $ 1,579 $ 1,600 $ 1,547 $ 782 $ 806 $ 727 $ 579 $ 621 $ 774 Total March 31, December 31, March 31, 2016 2015 2015 Performing $ 2,933 $ 3,017 $ 3,034 Nonperforming 7 10 14 Total $ 2,940 $ 3,027 $ 3,048 (a) Credit quality indicators are updated on an ongoing basis and reflect credit quality information as of the dates indicated. (b) Our past due payment activity to regulatory classification conversion is as follows: pass = less than 90 days; and substandard = 90 days and greater plus nonperforming loans. We determine the appropriate level of the ALLL on at least a quarterly basis. The methodology is described in Note 1 (“Summary of Significant Accounting Policies”) under the heading “Allowance for Loan and Lease Losses” beginning on page 122 of our 2015 Form 10-K. We apply expected loss rates to existing loans with similar risk characteristics as noted in the credit quality indicator table above and exercise judgment to assess the impact of qualitative factors such as changes in economic conditions, changes in credit policies or underwriting standards, and changes in the level of credit risk associated with specific industries and markets. For all commercial and consumer loan TDRs, regardless of size, as well as impaired commercial loans with an outstanding balance of $2.5 million or greater, we conduct further analysis to determine the probable loss content and assign a specific allowance to the loan if deemed appropriate. We estimate the extent of the individual impairment for commercial loans and TDRs by comparing the recorded investment of the loan with the estimated present value of its future cash flows, the fair value of its underlying collateral, or the loan’s observable market price. Secured consumer loan TDRs that are discharged through Chapter 7 bankruptcy and not formally re-affirmed are adjusted to reflect the fair value of the underlying collateral, less costs to sell. Non-Chapter 7 consumer loan TDRs are combined in homogenous pools and assigned a specific allocation based on the estimated present value of future cash flows using the loan’s effective interest rate. A specific allowance also may be assigned — even when sources of repayment appear sufficient — if we remain uncertain about whether the loan will be repaid in full. On at least a quarterly basis, we evaluate the appropriateness of our loss estimation methods to reduce differences between estimated incurred losses and actual losses. The ALLL at March 31, 2016, represents our best estimate of the probable credit losses inherent in the loan portfolio at that date. Commercial loans generally are charged off in full or charged down to the fair value of the underlying collateral when the borrower’s payment is 180 days past due. Consumer loans generally are charged off when payments are 120 days past due. Home equity and residential mortgage loans generally are charged down to net realizable value when payment is 180 days past due. Credit card loans, and similar unsecured products, are charged off when payments are 180 days past due. At March 31, 2016, the ALLL was $826 million, or 1.37% of loans, compared to $794 million, or 1.37% of loans, at March 31, 2015. At March 31, 2016, the ALLL was 122.2% of nonperforming loans, compared to 181.7% at March 31, 2015. A summary of the changes in the ALLL for the periods indicated is presented in the table below: Three months ended March 31, in millions 2016 2015 Balance at beginning of period — continuing operations $ 796 $ 794 Charge-offs (60 ) (47 ) Recoveries 14 19 Net loans and leases charged off (46 ) (28 ) Provision for loan and lease losses from continuing operations 76 29 Foreign currency translation adjustment — (1 ) Balance at end of period — continuing operations $ 826 $ 794 The changes in the ALLL by loan category for the periods indicated are as follows: December 31, March 31, in millions 2015 Provision Charge-offs Recoveries 2016 Commercial, financial and agricultural $ 450 $ 50 $ (26 ) $ 3 $ 477 Real estate — commercial mortgage 134 — (1 ) 2 135 Real estate — construction 25 (3 ) — 1 23 Commercial lease financing 47 (1 ) (3 ) — 43 Total commercial loans 656 46 (30 ) 6 678 Real estate — residential mortgage 18 2 (2 ) 2 20 Home equity loans 57 14 (10 ) 3 64 Consumer direct loans 20 5 (6 ) 1 20 Credit cards 32 6 (8 ) 1 31 Consumer indirect loans 13 3 (4 ) 1 13 Total consumer loans 140 30 (30 ) 8 148 Total ALLL — continuing operations 796 76 (a) (60 ) 14 826 Discontinued operations 28 2 (9 ) 3 24 Total ALLL — including discontinued operations $ 824 $ 78 $ (69 ) $ 17 $ 850 (a) Excludes a provision for losses on lending-related commitments of $13 million. December 31, March 31, in millions 2014 Provision Charge-offs Recoveries 2015 Commercial, financial and agricultural $ 391 $ 21 $ (12 ) $ 5 $ 405 Real estate — commercial mortgage 148 — (2 ) 2 148 Real estate — construction 28 1 (1 ) — 28 Commercial lease financing 56 (3 ) (2 ) 4 55 Total commercial loans 623 19 (17 ) 11 636 Real estate — residential mortgage 23 — (2 ) — 21 Home equity loans 71 (3 ) (8 ) 3 63 Consumer direct loans 22 3 (6 ) 2 21 Credit cards 33 7 (8 ) — 32 Consumer indirect loans 22 2 (6 ) 3 21 Total consumer loans 171 9 (30 ) 8 158 Total ALLL — continuing operations 794 28 (a) (47 ) 19 794 Discontinued operations 29 2 (10 ) 4 25 Total ALLL — including discontinued operations $ 823 $ 30 $ (57 ) $ 23 $ 819 (a) Includes a $1 million foreign currency translation adjustment. Excludes provision for losses on lending-related commitments of $6 million. Our ALLL from continuing operations increased by $32 million, or 4%, from the first quarter of 2015. Our allowance applies expected loss rates to our existing loans with similar risk characteristics as well as any adjustments to reflect our current assessment of qualitative factors, such as changes in economic conditions, underwriting standards, and concentrations of credit. Our commercial ALLL increased by $42 million, or 6.6%, from the first quarter of 2015 primarily because of loan growth and increased incurred loss estimates. The increase in these incurred loss estimates during 2015 was primarily due to the continued decline in oil and gas prices since 2014. Partially offsetting this increase was a decrease in our consumer ALLL of $10 million, or 6.3%, from the first quarter of 2015. Our consumer ALLL decrease was primarily due to continued improvement in credit metrics, such as delinquency, average credit bureau score, and loan to value, which have decreased expected loss rates since 2014. The continued improvement in the consumer portfolio credit quality metrics from the first quarter of 2015 was primarily due to continued improved credit quality and benefits of relatively stable economic conditions. For continuing operations, the loans outstanding individually evaluated for impairment totaled $607 million, with a corresponding allowance of $54 million at March 31, 2016. Loans outstanding collectively evaluated for impairment totaled $59.8 billion, with a corresponding allowance of $771 million at March 31, 2016. At March 31, 2016, PCI loans evaluated for impairment totaled $11 million, with a corresponding allowance of $1 million. There was no provision for loan and lease losses on these PCI loans during the quarter ended March 31, 2016. At March 31, 2015, the loans outstanding individually evaluated for impairment totaled $338 million, with a corresponding allowance of $49 million. Loans outstanding collectively evaluated for impairment totaled $57.6 billion, with a corresponding allowance of $744 million at March 31, 2015. At March 31, 2015, PCI loans evaluated for impairment totaled $12 million, with a corresponding allowance of $1 million. There was no provision for loan and lease losses on these PCI loans during the quarter ended March 31, 2015. A breakdown of the individual and collective ALLL and the corresponding loan balances as of March 31, 2016, follows: Allowance Outstanding Individually Collectively Purchased Individually Coll |