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ALLOWANCE FOR CREDIT LOSSES | 9 Months Ended
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Sep. 30, 2025
Credit Loss [Abstract] |
ALLOWANCE FOR CREDIT LOSSES | ALLOWANCE FOR CREDIT LOSSES The following table presents ACL activity by portfolio segment.
(dollar amounts in millions) |  |  |  |  |  |  |  |  |  |  |  |  |  |  | Commercial |  | Consumer |  | Total
Three months ended September 30, 2025 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
ALLL balance, beginning of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 1,548 |  |  | $ | 783 |  |  | $ | 2,331 |
Loan and lease charge-offs |  |  |  |  |  |  |  |  |  |  |  |  |  |  | (80) |  |  | (57) |  |  | (137) |
Recoveries of loans and leases previously charged-off |  |  |  |  |  |  |  |  |  |  |  |  |  |  | 44 |  |  | 18 |  |  | 62 |
Provision for loan and lease losses |  |  |  |  |  |  |  |  |  |  |  |  |  |  | 56 |  |  | 62 |  |  | 118 |
ALLL balance, end of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 1,568 |  |  | $ | 806 |  |  | $ | 2,374 |
AULC balance, beginning of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 124 |  |  | $ | 60 |  |  | $ | 184 |
Provision for unfunded lending commitments |  |  |  |  |  |  |  |  |  |  |  |  |  |  | 1 |  |  | 3 |  |  | 4 |
AULC balance, end of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 125 |  |  | $ | 63 |  |  | $ | 188 |
ACL balance, end of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 1,693 |  |  | $ | 869 |  |  | $ | 2,562 |
Three months ended September 30, 2024 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
ALLL balance, beginning of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 1,587 |  |  | $ | 717 |  |  | $ | 2,304 |
Loan and lease charge-offs |  |  |  |  |  |  |  |  |  |  |  |  |  |  | (74) |  |  | (55) |  |  | (129) |
Recoveries of loans and leases previously charged-off |  |  |  |  |  |  |  |  |  |  |  |  |  |  | 20 |  |  | 16 |  |  | 36 |
Provision (benefit) for loan and lease losses |  |  |  |  |  |  |  |  |  |  |  |  |  |  | (35) |  |  | 59 |  |  | 24 |
ALLL balance, end of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 1,498 |  |  | $ | 737 |  |  | $ | 2,235 |
AULC balance, beginning of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 64 |  |  | $ | 55 |  |  | $ | 119 |
Provision for unfunded lending commitments |  |  |  |  |  |  |  |  |  |  |  |  |  |  | 76 |  |  | 6 |  |  | 82 |
AULC balance, end of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 140 |  |  | $ | 61 |  |  | $ | 201 |
ACL balance, end of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 1,638 |  |  | $ | 798 |  |  | $ | 2,436 |
Nine months ended September 30, 2025 |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
ALLL balance, beginning of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 1,484 |  |  | $ | 760 |  |  | $ | 2,244 |
Loan and lease charge-offs |  |  |  |  |  |  |  |  |  |  |  |  |  |  | (210) |  |  | (171) |  |  | (381) |
Recoveries of loans and leases previously charged-off |  |  |  |  |  |  |  |  |  |  |  |  |  |  | 99 |  |  | 55 |  |  | 154 |
Provision for loan and lease losses |  |  |  |  |  |  |  |  |  |  |  |  |  |  | 195 |  |  | 162 |  |  | 357 |
ALLL balance, end of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 1,568 |  |  | $ | 806 |  |  | $ | 2,374 |
AULC balance, beginning of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 144 |  |  | $ | 58 |  |  | $ | 202 |
Provision (benefit) for unfunded lending commitments |  |  |  |  |  |  |  |  |  |  |  |  |  |  | (19) |  |  | 5 |  |  | (14) |
AULC balance, end of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 125 |  |  | $ | 63 |  |  | $ | 188 |
ACL balance, end of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 1,693 |  |  | $ | 869 |  |  | $ | 2,562 |
Nine months ended September 30, 2024
ALLL balance, beginning of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 1,563 |  |  | $ | 692 |  |  | $ | 2,255 |
Loan and lease charge-offs |  |  |  |  |  |  |  |  |  |  |  |  |  |  | (243) |  |  | (159) |  |  | (402) |
Recoveries of loans and leases previously charged-off |  |  |  |  |  |  |  |  |  |  |  |  |  |  | 77 |  |  | 50 |  |  | 127 |
Provision for loan and lease losses |  |  |  |  |  |  |  |  |  |  |  |  |  |  | 101 |  |  | 154 |  |  | 255 |
ALLL balance, end of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 1,498 |  |  | $ | 737 |  |  | $ | 2,235 |
AULC balance, beginning of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 66 |  |  | $ | 79 |  |  | $ | 145 |
Provision (benefit) for unfunded lending commitments |  |  |  |  |  |  |  |  |  |  |  |  |  |  | 74 |  |  | (18) |  |  | 56 |
AULC balance, end of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 140 |  |  | $ | 61 |  |  | $ | 201 |
ACL balance, end of period |  |  |  |  |  |  |  |  |  |  |  |  |  |  | $ | 1,638 |  |  | $ | 798 |  |  | $ | 2,436 |
At September 30, 2025, the ACL was $2.6 billion, a $116 million increase compared to December 31, 2024. The increase in the ACL was driven by loan and lease growth, partially offset by a modest reduction in overall coverage ratios. The ACL coverage ratio at September 30, 2025 is reflective of the current macroeconomic forecast and changes in various risk profiles intended to capture uncertainty not addressed within the quantitative reserve. The commercial ACL was $1.7 billion at September 30, 2025, a $65 million increase compared to December 31, 2024, with the increase primarily due to loan growth, partially offset by a modest reduction in overall coverage ratios. The consumer ACL was $869 million at September 30, 2025, a $51 million increase compared to December 31, 2024, with the increase primarily due to loan growth. The baseline economic scenario used in the September 30, 2025 ACL determination assumes continued tariff uncertainty, but reflects marginal improved performance of the U.S. economy in the near term with minimal change in the overall outlook. In this scenario, the unemployment rate is expected to end 2025 at 4.4%, with peak unemployment of 4.8% through the end of 2026. The Federal Reserve restarted rate cuts in the third quarter of 2025 and is expected to continue with future rate cuts until reaching a federal funds rate of 3% by the end of 2026. The inflation outlook deteriorates slightly as the impacts of tariffs and other trade policies are expected to cascade through the economy, with near-term inflation expected to rise further above the Federal Reserve’s 2% target until the rate begins to decline in the second half of 2026 but still remaining above target. GDP growth, while positive, has slowed to a current level of approximately 1% and is forecasted to remain below 2% through the end of 2026. The economic scenarios used included elevated levels of economic uncertainty, such as the impact of specific challenges in the commercial real estate industry, recent inflation levels, the impacts of U.S. trade policies, the U.S. labor market, the expected path of interest rate changes by the Federal Reserve, and the impact of significant conflicts on-going around the world. Given the uncertainty associated with key economic scenario assumptions, the September 30, 2025 ACL included a general reserve that consists of various risk profile components to address uncertainty not measured within the quantitative transaction reserve.

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