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Allowance for Credit Losses | 3 Months Ended
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Dec. 31, 2022
Receivables [Abstract] |
Allowance for Credit Losses | NOTE 5. ALLOWANCE FOR CREDIT LOSSES Regions determines the appropriate level of the allowance on a quarterly basis. The methodology is described in Note 1. Additionally, refer to Note 1 "Summary of Significant Accounting Policies" to the consolidated financial statements to the Annual Report on Form 10-K for the year ended December 31, 2019, for a description of the methodology prior to the adoption of CECL on January 1, 2020. Reflected in the allowance is the impact of the sale of $1.2 billion of unsecured consumer loans at the end of the third quarter of 2022 with an associated allowance of $94 million. In conjunction with the sale, the Company recognized a $63 million fair value mark recorded through charge-offs resulting in a net provision benefit of $31 million. ROLLFORWARD OF ALLOWANCE FOR CREDIT LOSSES The following tables present analyses of the allowance for credit losses by portfolio segment for the years ended December 31, 2022, 2021 and 2020.
| 2022 |
| Commercial |  | Investor Real Estate |  | Consumer |  | Total |
| (In millions) |
Allowance for loan losses, January 1, 2022 | $ | 682 |  |  | $ | 79 |  |  | $ | 718 |  |  | $ | 1,479 |  |
Provision for (benefit from) loan losses | 40 |  |  | 45 |  |  | 163 |  |  | 248 |  |
Loan losses: |  |  |  |  |  |  |  |
Charge-offs | (107) |  |  | (5) |  |  | (263) |  |  | (375) |  |
Recoveries | 50 |  |  | 2 |  |  | 60 |  |  | 112 |  |
Net loan (losses) recoveries | (57) |  |  | (3) |  |  | (203) |  |  | (263) |  |
Allowance for loan losses, December 31, 2022 | 665 |  |  | 121 |  |  | 678 |  |  | 1,464 |  |
Reserve for unfunded credit commitments, January 1, 2022 | 58 |  |  | 8 |  |  | 29 |  |  | 95 |  |
Provision for (benefit from) unfunded credit losses | 14 |  |  | 13 |  |  | (4) |  |  | 23 |  |
Reserve for unfunded credit commitments, December 31, 2022 | 72 |  |  | 21 |  |  | 25 |  |  | 118 |  |
Allowance for credit losses, December 31, 2022 | $ | 737 |  |  | $ | 142 |  |  | $ | 703 |  |  | $ | 1,582 |  |
| 2021
| Commercial |  | Investor Real Estate |  | Consumer |  | Total
| (In millions)
Allowance for loan losses, January 1, 2021 | $ | 1,196 |  |  | $ | 183 |  |  | $ | 788 |  |  | $ | 2,167 |
Provision for (benefit from) loan losses | (445) |  |  | (87) |  |  | 39 |  |  | (493) |
Initial allowance on acquired PCD loans | — |  |  | — |  |  | 9 |  |  | 9
Loan losses: |  |  |  |  |  |  |
Charge-offs | (128) |  |  | (20) |  |  | (180) |  |  | (328) |
Recoveries | 59 |  |  | 3 |  |  | 62 |  |  | 124 |
Net loan losses | (69) |  |  | (17) |  |  | (118) |  |  | (204) |
Allowance for loan losses, December 31, 2021 | 682 |  |  | 79 |  |  | 718 |  |  | 1,479 |
Reserve for unfunded credit commitments, January 1, 2021 | 97 |  |  | 14 |  |  | 15 |  |  | 126 |
Provision for (benefit from) unfunded credit losses | (39) |  |  | (6) |  |  | 14 |  |  | (31) |
Reserve for unfunded credit commitments, December 31, 2021 | 58 |  |  | 8 |  |  | 29 |  |  | 95 |
Allowance for credit losses, December 31, 2021 | $ | 740 |  |  | $ | 87 |  |  | $ | 747 |  |  | $ | 1,574 |
| 2020
| Commercial |  | Investor Real Estate |  | Consumer |  | Total
| (In millions)
Allowance for loan losses, December 31, 2019 | $ | 537 |  |  | $ | 45 |  |  | $ | 287 |  |  | $ | 869 |
Cumulative change in accounting guidance (Note 1) | (3) |  |  | 7 |  |  | 434 |  |  | 438 |
Allowance for loan losses, January 1, 2020 (adjusted for change in accounting guidance) | 534 |  |  | 52 |  |  | 721 |  |  | 1,307 |
Provision for (benefit from) loan losses | 927 |  |  | 129 |  |  | 256 |  |  | 1,312 |
Initial allowance on acquired PCD loans | 60 |  |  | — |  |  | — |  |  | 60 |
Loan losses: |  |  |  |  |  |  |
Charge-offs | (368) |  |  | (1) |  |  | (244) |  |  | (613) |
Recoveries | 43 |  |  | 3 |  |  | 55 |  |  | 101 |
Net loan losses | (325) |  |  | 2 |  |  | (189) |  |  | (512) |
Allowance for loan losses, December 31, 2020 | 1,196 |  |  | 183 |  |  | 788 |  |  | 2,167 |
Reserve for unfunded credit commitments, December 31, 2019 | 41 |  |  | 4 |  |  | — |  |  | 45 |
Cumulative change in accounting guidance (Note 1) | 36 |  |  | 13 |  |  | 14 |  |  | 63 |
Reserve for unfunded credit commitments, January 1, 2020 | 77 |  |  | 17 |  |  | 14 |  |  | 108 |
Provision for (benefit from) unfunded credit losses | 20 |  |  | (3) |  |  | 1 |  |  | 18 |
Reserve for unfunded credit commitments, December 31, 2020 | 97 |  |  | 14 |  |  | 15 |  |  | 126 |
Allowance for credit losses, December 31, 2020 | $ | 1,293 |  |  | $ | 197 |  |  | $ | 803 |  |  | $ | 2,293 |
PORTFOLIO SEGMENT RISK FACTORS The following describe the risk characteristics relevant to each of the portfolio segments. Commercial—The commercial portfolio segment includes commercial and industrial loans to commercial customers for use in normal business operations to finance working capital needs, equipment purchases or other expansion projects. Commercial also includes owner-occupied commercial real estate mortgage loans to operating businesses, which are loans for long-term financing on land and buildings, and are repaid by cash flow generated by business operations. Owner-occupied commercial real estate construction loans are made to commercial businesses for the development of land or construction of a building where the repayment is derived from revenues generated from the business of the borrower. Collection risk in this portfolio is driven by the creditworthiness of underlying borrowers, particularly cash flow from customers’ business operations, and is impacted by sensitivity to several other factors, such as market fluctuations in commodity prices. Investor Real Estate—Loans for real estate development are repaid through cash flow related to the operation, sale or refinance of the property. This portfolio segment includes extensions of credit to real estate developers or investors where repayment is dependent on the sale of real estate or income generated from the real estate collateral. A portion of Regions’ investor real estate portfolio segment consists of loans secured by residential product types (land, single-family and condominium loans) within Regions’ markets. Additionally, this category includes loans made to finance income-producing properties such as apartment buildings, office and industrial buildings, and retail shopping centers. Loans in this portfolio segment are particularly sensitive to the valuation of real estate. Consumer—The consumer portfolio segment includes residential first mortgage, home equity lines, home equity loans, consumer credit card, other consumer—exit portfolios and other consumer loans. Residential first mortgage loans represent loans to consumers to finance a residence. These loans are typically financed over a 15 to 30 year term and, in most cases, are extended to borrowers to finance their primary residence. Home equity lending includes both home equity loans and lines of credit. This type of lending, which is secured by a first or second mortgage on the borrower’s residence, allows customers to borrow against the equity in their home. Real estate market values as of the time the loan or line is secured directly affect the amount of credit extended and, in addition, changes in these values impact the depth of potential losses. Consumer credit card lending includes Regions branded consumer credit card accounts. Other consumer—exit portfolios includes lending initiatives through third parties consisting of loans made through automotive dealerships and other point of sale lending. Regions ceased originating new loans related to these businesses prior to 2020. Other consumer loans include other revolving consumer accounts, indirect and direct consumer loans, and overdrafts. Loans in this portfolio segment are sensitive to unemployment, inflation, and other key consumer economic measures. CREDIT QUALITY INDICATORS The following tables present credit quality indicators for the loan portfolio segments and classes, excluding loans held for sale, as of December 31, 2022 and 2021. The commercial and investor real estate portfolio segments' primary credit quality indicator is internal risk ratings which are detailed by categories related to underlying credit quality and probability of default. Regions assigns these risk ratings at loan origination and reviews the relationship utilizing a risk-based approach on, at minimum, an annual basis or at any time management becomes aware of information affecting the borrowers' ability to fulfill their obligations. Both quantitative and qualitative factors are considered in this review process. These categories are utilized to develop the associated allowance for credit losses. •Pass—includes obligations where the probability of default is considered low; •Special Mention—includes obligations that have potential weakness that may, if not reversed or corrected, weaken the credit or inadequately protect the Company’s position at some future date. Obligations in this category may also be subject to economic or market conditions that may, in the future, have an adverse effect on debt service ability; •Substandard Accrual—includes obligations that exhibit a well-defined weakness that presently jeopardizes debt repayment, even though they are currently performing. These obligations are characterized by the distinct possibility that the Company may incur a loss in the future if these weaknesses are not corrected; •Non-accrual—includes obligations where management has determined that full payment of principal and interest is in doubt. Substandard accrual and non-accrual loans are often collectively referred to as “classified.” Special mention, substandard accrual, and non-accrual loans are often collectively referred to as “criticized and classified.” Regions considers factors such as periodic updates of FICO scores, accrual status, days past due status, unemployment rates, home prices, and geography as credit quality indicators for the consumer loan portfolio. FICO scores are obtained at origination as part of Regions' formal underwriting process. Refreshed FICO scores are obtained by the Company quarterly for all consumer loans, including residential first mortgage loans. Current FICO data is not available for certain loans in the portfolio for various reasons; for example, if customers do not use sufficient credit, an updated score may not be available. These categories are utilized to develop the associated allowance for credit losses. The higher the FICO score the less probability of default and vice versa. The disclosure of credit quality indicators for loan portfolio segments and classes, excluding loans held for sale, is presented by credit quality indicator by vintage year. Regions defines the vintage date for the purposes of disclosure as the date of the most recent credit decision. In general, renewals are categorized as new credit decisions and reflect the renewal date as the vintage date. Loans that are modified as a TDR are considered to be a continuation of the original loan, therefore the origination date of the original loan is reflected as the vintage date. The following tables present applicable credit quality indicators for the loan portfolio segments and classes, excluding loans held for sale, as of December 31, 2022 and 2021. Classes in the commercial and investor real estate portfolio segments are disclosed by risk rating. Classes in the consumer portfolio segment are disclosed by current FICO scores.
| December 31, 2022
Term Loans |  | Revolving Loans |  | Revolving Loans Converted to Amortizing |  | Unallocated (1) |  | Total
Origination Year
2022 | 2021 | 2020 | 2019 | 2018 | Prior
(In millions)
Commercial and industrial:
Risk Rating: |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass(2) | $ | 11,948 |  | $ | 7,167 |  | $ | 3,277 |  | $ | 2,297 |  | $ | 1,026 |  | $ | 3,283 |  |  | $ | 19,599 |  |  | $ | — |  |  | $ | 313 |  |  | $ | 48,910 |
Special Mention | 85 |  | 120 |  | 70 |  | 30 |  | 32 |  | 1 |  |  | 282 |  |  | — |  |  | — |  |  | 620 |
Substandard Accrual | 248 |  | 114 |  | 39 |  | 57 |  | 53 |  | 17 |  |  | 500 |  |  | — |  |  | — |  |  | 1,028 |
Non-accrual | 95 |  | 55 |  | 11 |  | 9 |  | 36 |  | 6 |  |  | 135 |  |  | — |  |  | — |  |  | 347 |
Total commercial and industrial | $ | 12,376 |  | $ | 7,456 |  | $ | 3,397 |  | $ | 2,393 |  | $ | 1,147 |  | $ | 3,307 |  |  | $ | 20,516 |  |  | $ | — |  |  | $ | 313 |  |  | $ | 50,905 |
Commercial real estate mortgage—owner-occupied:
Risk Rating: |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass | $ | 1,058 |  | $ | 1,175 |  | $ | 929 |  | $ | 479 |  | $ | 519 |  | $ | 626 |  |  | $ | 89 |  |  | $ | — |  |  | $ | (5) |  |  | $ | 4,870 |
Special Mention | 7 |  | 32 |  | 17 |  | 10 |  | 15 |  | 12 |  |  | 2 |  |  | — |  |  | — |  |  | 95 |
Substandard Accrual | 10 |  | 16 |  | 36 |  | 35 |  | 5 |  | 6 |  |  | 1 |  |  | — |  |  | — |  |  | 109 |
Non-accrual | 1 |  | 2 |  | 9 |  | 1 |  | 5 |  | 11 |  |  | — |  |  | — |  |  | — |  |  | 29 |
Total commercial real estate mortgage—owner-occupied: | $ | 1,076 |  | $ | 1,225 |  | $ | 991 |  | $ | 525 |  | $ | 544 |  | $ | 655 |  |  | $ | 92 |  |  | $ | — |  |  | $ | (5) |  |  | $ | 5,103 |
| December 31, 2022
Term Loans |  | Revolving Loans |  | Revolving Loans Converted to Amortizing |  | Unallocated (1) |  | Total
Origination Year
2022 | 2021 | 2020 | 2019 | 2018 | Prior
(In millions)
Commercial real estate construction—owner-occupied:
Risk Rating: |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass | $ | 115 |  | $ | 79 |  | $ | 22 |  | $ | 15 |  | $ | 15 |  | $ | 38 |  |  | $ | 1 |  |  | $ | — |  |  | $ | — |  |  | $ | 285 |
Special Mention | — |  | — |  | — |  | — |  | 2 |  | — |  |  | — |  |  | — |  |  | — |  |  | 2 |
Substandard Accrual | 2 |  | — |  | 2 |  | — |  | — |  | 1 |  |  | — |  |  | — |  |  | — |  |  | 5 |
Non-accrual | — |  | — |  | 1 |  | 1 |  | — |  | 4 |  |  | — |  |  | — |  |  | — |  |  | 6 |
Total commercial real estate construction—owner-occupied: | $ | 117 |  | $ | 79 |  | $ | 25 |  | $ | 16 |  | $ | 17 |  | $ | 43 |  |  | $ | 1 |  |  | $ | — |  |  | $ | — |  |  | $ | 298 |
Total commercial | $ | 13,569 |  | $ | 8,760 |  | $ | 4,413 |  | $ | 2,934 |  | $ | 1,708 |  | $ | 4,005 |  |  | $ | 20,609 |  |  | $ | — |  |  | $ | 308 |  |  | $ | 56,306 |
Commercial investor real estate mortgage:
Risk Rating: |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass | $ | 2,332 |  | $ | 1,321 |  | $ | 634 |  | $ | 466 |  | $ | 257 |  | $ | 94 |  |  | $ | 490 |  |  | $ | — |  |  | $ | (7) |  |  | $ | 5,587 |
Special Mention | 229 |  | 75 |  | — |  | 18 |  | — |  | 3 |  |  | 38 |  |  | — |  |  | — |  |  | 363 |
Substandard Accrual | 107 |  | — |  | 74 |  | 138 |  | 68 |  | 3 |  |  | — |  |  | — |  |  | — |  |  | 390 |
Non-accrual | 52 |  | — |  | — |  | — |  | — |  | 1 |  |  | — |  |  | — |  |  | — |  |  | 53 |
Total commercial investor real estate mortgage | $ | 2,720 |  | $ | 1,396 |  | $ | 708 |  | $ | 622 |  | $ | 325 |  | $ | 101 |  |  | $ | 528 |  |  | $ | — |  |  | $ | (7) |  |  | $ | 6,393 |
Commercial investor real estate construction:
Risk Rating: |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass | $ | 458 |  | $ | 402 |  | $ | 205 |  | $ | 112 |  | $ | — |  | $ | 1 |  |  | $ | 722 |  |  | $ | — |  |  | $ | (16) |  |  | $ | 1,884 |
Special Mention | 25 |  | 52 |  | — |  | — |  | — |  | — |  |  | 5 |  |  | — |  |  | — |  |  | 82 |
Substandard Accrual | 3 |  | — |  | 17 |  | — |  | — |  | — |  |  | — |  |  | — |  |  | — |  |  | 20 |
Non-accrual | — |  | — |  | — |  | — |  | — |  | — |  |  | — |  |  | — |  |  | — |  |  | — |
Total commercial investor real estate construction | $ | 486 |  | $ | 454 |  | $ | 222 |  | $ | 112 |  | $ | — |  | $ | 1 |  |  | $ | 727 |  |  | $ | — |  |  | $ | (16) |  |  | $ | 1,986 |
Total investor real estate | $ | 3,206 |  | $ | 1,850 |  | $ | 930 |  | $ | 734 |  | $ | 325 |  | $ | 102 |  |  | $ | 1,255 |  |  | $ | — |  |  | $ | (23) |  |  | $ | 8,379 |
Residential first mortgage:
FICO scores |  |  |  |  |  |  |  |  |  |  |  |  |  |
Above 720 | $ | 2,485 |  | $ | 4,455 |  | $ | 4,765 |  | $ | 899 |  | $ | 327 |  | $ | 2,445 |  |  | $ | — |  |  | $ | — |  |  | $ | — |  |  | $ | 15,376 |
681-720 | 337 |  | 412 |  | 313 |  | 83 |  | 42 |  | 300 |  |  | — |  |  | — |  |  | — |  |  | 1,487 |
620-680 | 168 |  | 183 |  | 129 |  | 53 |  | 34 |  | 295 |  |  | — |  |  | — |  |  | — |  |  | 862 |
Below 620 | 42 |  | 92 |  | 77 |  | 52 |  | 40 |  | 379 |  |  | — |  |  | — |  |  | — |  |  | 682 |
Data not available | 27 |  | 45 |  | 47 |  | 13 |  | 4 |  | 98 |  |  | 2 |  |  | — |  |  | 167 |  |  | 403 |
Total residential first mortgage | $ | 3,059 |  | $ | 5,187 |  | $ | 5,331 |  | $ | 1,100 |  | $ | 447 |  | $ | 3,517 |  |  | $ | 2 |  |  | $ | — |  |  | $ | 167 |  |  | $ | 18,810 |
Home equity lines:
FICO scores |  |  |  |  |  |  |  |  |  |  |  |  |  |
Above 720 | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  |  | $ | 2,620 |  |  | $ | 47 |  |  | $ | — |  |  | $ | 2,667 |
681-720 | — |  | — |  | — |  | — |  | — |  | — |  |  | 369 |  |  | 12 |  |  | — |  |  | 381 |
620-680 | — |  | — |  | — |  | — |  | — |  | — |  |  | 212 |  |  | 11 |  |  | — |  |  | 223 |
Below 620 | — |  | — |  | — |  | — |  | — |  | — |  |  | 99 |  |  | 8 |  |  | — |  |  | 107 |
Data not available | — |  | — |  | — |  | — |  | — |  | — |  |  | 97 |  |  | 4 |  |  | 31 |  |  | 132 |
Total home equity lines | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  |  | $ | 3,397 |  |  | $ | 82 |  |  | $ | 31 |  |  | $ | 3,510 |
Home equity loans
FICO scores |  |  |  |  |  |  |  |  |  |  |  |  |  |
Above 720 | $ | 436 |  | $ | 466 |  | $ | 250 |  | $ | 117 |  | $ | 106 |  | $ | 582 |  |  | $ | — |  |  | $ | — |  |  | $ | — |  |  | $ | 1,957 |
681-720 | 75 |  | 62 |  | 26 |  | 17 |  | 14 |  | 67 |  |  | — |  |  | — |  |  | — |  |  | 261 |
620-680 | 29 |  | 28 |  | 11 |  | 12 |  | 9 |  | 58 |  |  | — |  |  | — |  |  | — |  |  | 147 |
Below 620 | 4 |  | 8 |  | 4 |  | 5 |  | 7 |  | 38 |  |  | — |  |  | — |  |  | — |  |  | 66 |
Data not available | 4 |  | 3 |  | 3 |  | 3 |  | 4 |  | 24 |  |  | — |  |  | — |  |  | 17 |  |  | 58 |
Total home equity loans | $ | 548 |  | $ | 567 |  | $ | 294 |  | $ | 154 |  | $ | 140 |  | $ | 769 |  |  | $ | — |  |  | $ | — |  |  | $ | 17 |  |  | $ | 2,489 |
| December 31, 2022
Term Loans |  | Revolving Loans |  | Revolving Loans Converted to Amortizing |  | Unallocated (1) |  | Total
Origination Year
2022 | 2021 | 2020 | 2019 | 2018 | Prior
(In millions)
Consumer credit card:
FICO scores |  |  |  |  |  |  |  |  |  |  |  |  |  |
Above 720 | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  |  | $ | 719 |  |  | $ | — |  |  | $ | — |  |  | $ | 719 |
681-720 | — |  | — |  | — |  | — |  | — |  | — |  |  | 246 |  |  | — |  |  | — |  |  | 246 |
620-680 | — |  | — |  | — |  | — |  | — |  | — |  |  | 204 |  |  | — |  |  | — |  |  | 204 |
Below 620 | — |  | — |  | — |  | — |  | — |  | — |  |  | 86 |  |  | — |  |  | — |  |  | 86 |
Data not available | — |  | — |  | — |  | — |  | — |  | — |  |  | 9 |  |  | — |  |  | (16) |  |  | (7) |
Total consumer credit card | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  |  | $ | 1,264 |  |  | $ | — |  |  | $ | (16) |  |  | $ | 1,248 |
Other consumer—exit portfolios:
FICO scores |  |  |  |  |  |  |  |  |  |  |  |  |  |
Above 720 | $ | — |  | $ | — |  | $ | — |  | $ | 102 |  | $ | 172 |  | $ | 96 |  |  | $ | — |  |  | $ | — |  |  | $ | — |  |  | $ | 370 |
681-720 | — |  | — |  | — |  | 30 |  | 40 |  | 23 |  |  | — |  |  | — |  |  | — |  |  | 93 |
620-680 | — |  | — |  | — |  | 17 |  | 30 |  | 17 |  |  | — |  |  | — |  |  | — |  |  | 64 |
Below 620 | — |  | — |  | — |  | 7 |  | 17 |  | 10 |  |  | — |  |  | — |  |  | — |  |  | 34 |
Data not available | — |  | — |  | — |  | 1 |  | 3 |  | 3 |  |  | — |  |  | — |  |  | 2 |  |  | 9 |
Total Other consumer- exit portfolios | $ | — |  | $ | — |  | $ | — |  | $ | 157 |  | $ | 262 |  | $ | 149 |  |  | $ | — |  |  | $ | — |  |  | $ | 2 |  |  | $ | 570 |
Other consumer:
FICO scores |  |  |  |  |  |  |  |  |  |  |  |  |  |
Above 720 | $ | 2,072 |  | $ | 674 |  | $ | 382 |  | $ | 215 |  | $ | 99 |  | $ | 80 |  |  | $ | 119 |  |  | $ | — |  |  | $ | — |  |  | $ | 3,641 |
681-720 | 493 |  | 200 |  | 106 |  | 50 |  | 23 |  | 20 |  |  | 66 |  |  | — |  |  | — |  |  | 958 |
620-680 | 348 |  | 153 |  | 73 |  | 34 |  | 19 |  | 15 |  |  | 55 |  |  | — |  |  | — |  |  | 697 |
Below 620 | 102 |  | 69 |  | 38 |  | 20 |  | 12 |  | 8 |  |  | 23 |  |  | — |  |  | — |  |  | 272 |
Data not available | 61 |  | 6 |  | 5 |  | 130 |  | 73 |  | 5 |  |  | 2 |  |  | — |  |  | (153) |  |  | 129 |
Total other consumer | $ | 3,076 |  | $ | 1,102 |  | $ | 604 |  | $ | 449 |  | $ | 226 |  | $ | 128 |  |  | $ | 265 |  |  | $ | — |  |  | $ | (153) |  |  | $ | 5,697 |
Total consumer loans | $ | 6,683 |  | $ | 6,856 |  | $ | 6,229 |  | $ | 1,860 |  | $ | 1,075 |  | $ | 4,563 |  |  | $ | 4,928 |  |  | $ | 82 |  |  | $ | 48 |  |  | $ | 32,324 |
Total Loans | $ | 23,458 |  | $ | 17,466 |  | $ | 11,572 |  | $ | 5,528 |  | $ | 3,108 |  | $ | 8,670 |  |  | $ | 26,792 |  |  | $ | 82 |  |  | $ | 333 |  |  | $ | 97,009 |
| December 31, 2021
Term Loans |  | Revolving Loans |  | Revolving Loans Converted to Amortizing |  | Unallocated (1) |  | Total
Origination Year
2021 | 2020 | 2019 | 2018 | 2017 | Prior
(In millions)
Commercial and industrial:
Risk Rating: |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass(2) | $ | 11,098 |  | $ | 5,231 |  | $ | 3,711 |  | $ | 1,781 |  | $ | 1,625 |  | $ | 2,611 |  |  | $ | 15,794 |  |  | $ | — |  |  | $ | (60) |  |  | $ | 41,791 |
Special Mention | 54 |  | 43 |  | 177 |  | 147 |  | 25 |  | 77 |  |  | 383 |  |  | — |  |  | — |  |  | 906 |
Substandard Accrual | 83 |  | 76 |  | 57 |  | 90 |  | 17 |  | 12 |  |  | 421 |  |  | — |  |  | — |  |  | 756 |
Non-accrual | 70 |  | 22 |  | 45 |  | 9 |  | 11 |  | 15 |  |  | 133 |  |  | — |  |  | — |  |  | 305 |
Total commercial and industrial | $ | 11,305 |  | $ | 5,372 |  | $ | 3,990 |  | $ | 2,027 |  | $ | 1,678 |  | $ | 2,715 |  |  | $ | 16,731 |  |  | $ | — |  |  | $ | (60) |  |  | $ | 43,758 |
Commercial real estate mortgage—owner-occupied:
Risk Rating: |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass | $ | 1,404 |  | $ | 1,095 |  | $ | 671 |  | $ | 663 |  | $ | 381 |  | $ | 724 |  |  | $ | 122 |  |  | $ | — |  |  | $ | (7) |  |  | $ | 5,053 |
Special Mention | 7 |  | 48 |  | 12 |  | 11 |  | 12 |  | 16 |  |  | 1 |  |  | — |  |  | — |  |  | 107 |
Substandard Accrual | 3 |  | 8 |  | 34 |  | 11 |  | 6 |  | 12 |  |  | 1 |  |  | — |  |  | — |  |  | 75 |
Non-accrual | 3 |  | 6 |  | 7 |  | 10 |  | 12 |  | 14 |  |  | — |  |  | — |  |  | — |  |  | 52 |
Total commercial real estate mortgage—owner-occupied: | $ | 1,417 |  | $ | 1,157 |  | $ | 724 |  | $ | 695 |  | $ | 411 |  | $ | 766 |  |  | $ | 124 |  |  | $ | — |  |  | $ | (7) |  |  | $ | 5,287 |
| December 31, 2021
Term Loans |  | Revolving Loans |  | Revolving Loans Converted to Amortizing |  | Unallocated (1) |  | Total
Origination Year
2021 | 2020 | 2019 | 2018 | 2017 | Prior
(In millions)
Commercial real estate construction—owner-occupied:
Risk Rating: |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass | $ | 68 |  | $ | 61 |  | $ | 24 |  | $ | 30 |  | $ | 20 |  | $ | 42 |  |  | $ | 1 |  |  | $ | — |  |  | $ | — |  |  | $ | 246 |
Special Mention | — |  | — |  | — |  | 2 |  | 1 |  | 2 |  |  | — |  |  | — |  |  | — |  |  | 5 |
Substandard Accrual | — |  | — |  | — |  | 2 |  | — |  | — |  |  | — |  |  | — |  |  | — |  |  | 2 |
Non-accrual | 1 |  | 1 |  | — |  | — |  | 1 |  | 8 |  |  | — |  |  | — |  |  | — |  |  | 11 |
Total commercial real estate construction—owner-occupied: | $ | 69 |  | $ | 62 |  | $ | 24 |  | $ | 34 |  | $ | 22 |  | $ | 52 |  |  | $ | 1 |  |  | $ | — |  |  | $ | — |  |  | $ | 264 |
Total commercial | $ | 12,791 |  | $ | 6,591 |  | $ | 4,738 |  | $ | 2,756 |  | $ | 2,111 |  | $ | 3,533 |  |  | $ | 16,856 |  |  | $ | — |  |  | $ | (67) |  |  | $ | 49,309 |
Commercial investor real estate mortgage:
Risk Rating: |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass | $ | 1,783 |  | $ | 808 |  | $ | 900 |  | $ | 580 |  | $ | 144 |  | $ | 95 |  |  | $ | 487 |  |  | $ | — |  |  | $ | (4) |  |  | $ | 4,793 |
Special Mention | 23 |  | 84 |  | 223 |  | 21 |  | 1 |  | 9 |  |  | — |  |  | — |  |  | — |  |  | 361 |
Substandard Accrual | 52 |  | 85 |  | 94 |  | 31 |  | 15 |  | — |  |  | 7 |  |  | — |  |  | — |  |  | 284 |
Non-accrual | — |  | — |  | — |  | 1 |  | — |  | 2 |  |  | — |  |  | — |  |  | — |  |  | 3 |
Total commercial investor real estate mortgage | $ | 1,858 |  | $ | 977 |  | $ | 1,217 |  | $ | 633 |  | $ | 160 |  | $ | 106 |  |  | $ | 494 |  |  | $ | — |  |  | $ | (4) |  |  | $ | 5,441 |
Commercial investor real estate construction:
Risk Rating: |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass | $ | 135 |  | $ | 343 |  | $ | 404 |  | $ | 82 |  | $ | 1 |  | $ | 1 |  |  | $ | 593 |  |  | $ | — |  |  | $ | (11) |  |  | $ | 1,548 |
Special Mention | — |  | 12 |  | 26 |  | — |  | — |  | — |  |  | — |  |  | — |  |  | — |  |  | 38 |
Substandard Accrual | — |  | — |  | — |  | — |  | — |  | — |  |  | — |  |  | — |  |  | — |  |  | — |
Non-accrual | — |  | — |  | — |  | — |  | — |  | — |  |  | — |  |  | — |  |  | — |  |  | — |
Total commercial investor real estate construction | $ | 135 |  | $ | 355 |  | $ | 430 |  | $ | 82 |  | $ | 1 |  | $ | 1 |  |  | $ | 593 |  |  | $ | — |  |  | $ | (11) |  |  | $ | 1,586 |
Total investor real estate | $ | 1,993 |  | $ | 1,332 |  | $ | 1,647 |  | $ | 715 |  | $ | 161 |  | $ | 107 |  |  | $ | 1,087 |  |  | $ | — |  |  | $ | (15) |  |  | $ | 7,027 |
Residential first mortgage:
FICO scores |  |  |  |  |  |  |  |  |  |  |  |  |  |
Above 720 | $ | 4,020 |  | $ | 5,280 |  | $ | 1,106 |  | $ | 426 |  | $ | 612 |  | $ | 2,601 |  |  | $ | — |  |  | $ | — |  |  | $ | — |  |  | $ | 14,045 |
681-720 | 449 |  | 366 |  | 108 |  | 57 |  | 69 |  | 353 |  |  | — |  |  | — |  |  | — |  |  | 1,402 |
620-680 | 246 |  | 161 |  | 78 |  | 50 |  | 44 |  | 378 |  |  | — |  |  | — |  |  | — |  |  | 957 |
Below 620 | 39 |  | 58 |  | 49 |  | 47 |  | 47 |  | 451 |  |  | — |  |  | — |  |  | — |  |  | 691 |
Data not available | 56 |  | 46 |  | 20 |  | 7 |  | 11 |  | 111 |  |  | 9 |  |  | — |  |  | 157 |  |  | 417 |
Total residential first mortgage | $ | 4,810 |  | $ | 5,911 |  | $ | 1,361 |  | $ | 587 |  | $ | 783 |  | $ | 3,894 |  |  | $ | 9 |  |  | $ | — |  |  | $ | 157 |  |  | $ | 17,512 |
Home equity lines:
FICO scores |  |  |  |  |  |  |  |  |  |  |  |  |  |
Above 720 | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  |  | $ | 2,761 |  |  | $ | 49 |  |  | $ | — |  |  | $ | 2,810 |
681-720 | — |  | — |  | — |  | — |  | — |  | — |  |  | 380 |  |  | 12 |  |  | — |  |  | 392 |
620-680 | — |  | — |  | — |  | — |  | — |  | — |  |  | 254 |  |  | 11 |  |  | — |  |  | 265 |
Below 620 | — |  | — |  | — |  | — |  | — |  | — |  |  | 132 |  |  | 8 |  |  | — |  |  | 140 |
Data not available | — |  | — |  | — |  | — |  | — |  | — |  |  | 105 |  |  | 5 |  |  | 27 |  |  | 137 |
Total home equity lines | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  |  | $ | 3,632 |  |  | $ | 85 |  |  | $ | 27 |  |  | $ | 3,744 |
| December 31, 2021
Term Loans |  | Revolving Loans |  | Revolving Loans Converted to Amortizing |  | Unallocated (1) |  | Total
Origination Year
2021 | 2020 | 2019 | 2018 | 2017 | Prior
(In millions)
Home equity loans
FICO scores |  |  |  |  |  |  |  |  |  |  |  |  |  |
Above 720 | $ | 544 |  | $ | 320 |  | $ | 155 |  | $ | 144 |  | $ | 217 |  | $ | 588 |  |  | $ | — |  |  | $ | — |  |  | $ | — |  |  | $ | 1,968 |
681-720 | 82 |  | 35 |  | 26 |  | 22 |  | 23 |  | 71 |  |  | — |  |  | — |  |  | — |  |  | 259 |
620-680 | 34 |  | 14 |  | 13 |  | 12 |  | 15 |  | 59 |  |  | — |  |  | — |  |  | — |  |  | 147 |
Below 620 | 6 |  | 3 |  | 6 |  | 7 |  | 11 |  | 46 |  |  | — |  |  | — |  |  | — |  |  | 79 |
Data not available | 2 |  | 3 |  | 3 |  | 4 |  | 5 |  | 22 |  |  | — |  |  | — |  |  | 18 |  |  | 57 |
Total home equity loans | $ | 668 |  | $ | 375 |  | $ | 203 |  | $ | 189 |  | $ | 271 |  | $ | 786 |  |  | $ | — |  |  | $ | — |  |  | $ | 18 |  |  | $ | 2,510 |
Consumer credit card:
FICO scores |  |  |  |  |  |  |  |  |  |  |  |  |  |
Above 720 | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  |  | $ | 675 |  |  | $ | — |  |  | $ | — |  |  | $ | 675 |
681-720 | — |  | — |  | — |  | — |  | — |  | — |  |  | 240 |  |  | — |  |  | — |  |  | 240 |
620-680 | — |  | — |  | — |  | — |  | — |  | — |  |  | 194 |  |  | — |  |  | — |  |  | 194 |
Below 620 | — |  | — |  | — |  | — |  | — |  | — |  |  | 81 |  |  | — |  |  | — |  |  | 81 |
Data not available | — |  | — |  | — |  | — |  | — |  | — |  |  | 8 |  |  | — |  |  | (14) |  |  | (6) |
Total consumer credit card | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  | $ | — |  |  | $ | 1,198 |  |  | $ | — |  |  | $ | (14) |  |  | $ | 1,184 |
Other consumer- exit portfolios:
FICO scores |  |  |  |  |  |  |  |  |  |  |  |  |  |
Above 720 | $ | — |  | $ | — |  | $ | 157 |  | $ | 318 |  | $ | 135 |  | $ | 81 |  |  | $ | — |  |  | $ | — |  |  | $ | — |  |  | $ | 691 |
681-720 | — |  | — |  | 47 |  | 71 |  | 32 |  | 20 |  |  | — |  |  | — |  |  | — |  |  | 170 |
620-680 | — |  | — |  | 28 |  | 50 |  | 24 |  | 17 |  |  | — |  |  | — |  |  | — |  |  | 119 |
Below 620 | — |  | — |  | 10 |  | 31 |  | 16 |  | 13 |  |  | — |  |  | — |  |  | — |  |  | 70 |
Data not available | — |  | — |  | 2 |  | 5 |  | 4 |  | 3 |  |  | — |  |  | — |  |  | 7 |  |  | 21 |
Total other consumer- exit portfolios | $ | — |  | $ | — |  | $ | 244 |  | $ | 475 |  | $ | 211 |  | $ | 134 |  |  | $ | — |  |  | $ | — |  |  | $ | 7 |  |  | $ | 1,071 |
Other consumer:
FICO scores |  |  |  |  |  |  |  |  |  |  |  |  |  |
Above 720 | $ | 1,555 |  | $ | 844 |  | $ | 543 |  | $ | 222 |  | $ | 66 |  | $ | 76 |  |  | $ | 116 |  |  | $ | — |  |  | $ | — |  |  | $ | 3,422 |
681-720 | 381 |  | 203 |  | 131 |  | 58 |  | 19 |  | 18 |  |  | 56 |  |  | — |  |  | — |  |  | 866 |
620-680 | 232 |  | 125 |  | 72 |  | 37 |  | 15 |  | 13 |  |  | 40 |  |  | — |  |  | — |  |  | 534 |
Below 620 | 66 |  | 50 |  | 33 |  | 20 |  | 8 |  | 7 |  |  | 17 |  |  | — |  |  | — |  |  | 201 |
Data not available | 62 |  | 7 |  | 156 |  | 91 |  | 4 |  | 4 |  |  | 2 |  |  | — |  |  | 78 |  |  | 404 |
Total other consumer | $ | 2,296 |  | $ | 1,229 |  | $ | 935 |  | $ | 428 |  | $ | 112 |  | $ | 118 |  |  | $ | 231 |  |  | $ | — |  |  | $ | 78 |  |  | $ | 5,427 |
Total consumer loans | $ | 7,774 |  | $ | 7,515 |  | $ | 2,743 |  | $ | 1,679 |  | $ | 1,377 |  | $ | 4,932 |  |  | $ | 5,070 |  |  | $ | 85 |  |  | $ | 273 |  |  | $ | 31,448 |
Total Loans | $ | 22,558 |  | $ | 15,438 |  | $ | 9,128 |  | $ | 5,150 |  | $ | 3,649 |  | $ | 8,572 |  |  | $ | 23,013 |  |  | $ | 85 |  |  | $ | 191 |  |  | $ | 87,784 |
________ (1)These amounts consist of fees that are not allocated at the loan level and loans serviced by third parties wherein Regions does not receive FICO or vintage information. (2)Commercial and industrial lending includes PPP lending in the 2021 vintage year. AGING AND NON-ACCRUAL ANALYSIS The following tables include an aging analysis of DPD and loans on non-accrual status for each portfolio segment and class as of December 31, 2022 and December 31, 2021. Loans on non-accrual status with no related allowance are comprised of commercial loans that totaled $151 million and $127 million as of December 31, 2022 and 2021, respectively. Non–accrual loans with no related allowance typically include loans where the underlying collateral is deemed sufficient to recover all remaining principal. Loans that have been fully charged-off do not appear in the tables below.
| 2022
| Accrual Loans |  |  |  |  |  |
| 30-59 DPD |  | 60-89 DPD |  | 90+ DPD |  | Total 30+ DPD |  | Total Accrual |  | Non-accrual |  | Total
| (In millions)
Commercial and industrial | $ | 36 |  |  | $ | 20 |  |  | $ | 30 |  |  | $ | 86 |  |  | $ | 50,558 |  |  | $ | 347 |  |  | $ | 50,905 |
Commercial real estate mortgage—owner-occupied | 7 |  |  | 2 |  |  | 1 |  |  | 10 |  |  | 5,074 |  |  | 29 |  |  | 5,103 |
Commercial real estate construction—owner-occupied | — |  |  | — |  |  | — |  |  | — |  |  | 292 |  |  | 6 |  |  | 298 |
Total commercial | 43 |  |  | 22 |  |  | 31 |  |  | 96 |  |  | 55,924 |  |  | 382 |  |  | 56,306 |
Commercial investor real estate mortgage | — |  |  | — |  |  | 40 |  |  | 40 |  |  | 6,340 |  |  | 53 |  |  | 6,393 |
Commercial investor real estate construction | — |  |  | — |  |  | — |  |  | — |  |  | 1,986 |  |  | — |  |  | 1,986 |
Total investor real estate | — |  |  | — |  |  | 40 |  |  | 40 |  |  | 8,326 |  |  | 53 |  |  | 8,379 |
Residential first mortgage | 87 |  |  | 45 |  |  | 81 |  |  | 213 |  |  | 18,779 |  |  | 31 |  |  | 18,810 |
Home equity lines | 18 |  |  | 12 |  |  | 15 |  |  | 45 |  |  | 3,482 |  |  | 28 |  |  | 3,510 |
Home equity loans | 8 |  |  | 3 |  |  | 8 |  |  | 19 |  |  | 2,483 |  |  | 6 |  |  | 2,489 |
Consumer credit card | 9 |  |  | 7 |  |  | 15 |  |  | 31 |  |  | 1,248 |  |  | — |  |  | 1,248 |
Other consumer—exit portfolios | 7 |  | 3 |  | 1 |  | 11 |  | 570 |  | — |  | 570
Other consumer | 46 |  |  | 21 |  |  | 17 |  |  | 84 |  |  | 5,697 |  |  | — |  |  | 5,697 |
Total consumer | 175 |  |  | 91 |  |  | 137 |  |  | 403 |  |  | 32,259 |  |  | 65 |  |  | 32,324 |
| $ | 218 |  |  | $ | 113 |  |  | $ | 208 |  |  | $ | 539 |  |  | $ | 96,509 |  |  | $ | 500 |  |  | $ | 97,009 |
| 2021
| Accrual Loans |  |  |  |  |  |
| 30-59 DPD |  | 60-89 DPD |  | 90+ DPD |  | Total 30+ DPD |  | Total Accrual |  | Non-accrual |  | Total
| (In millions)
Commercial and industrial | $ | 35 |  |  | $ | 29 |  |  | $ | 5 |  |  | $ | 69 |  |  | $ | 43,453 |  |  | $ | 305 |  |  | $ | 43,758 |
Commercial real estate mortgage—owner-occupied | 3 |  |  | 1 |  |  | 1 |  |  | 5 |  |  | 5,235 |  |  | 52 |  |  | 5,287 |
Commercial real estate construction—owner-occupied | — |  |  | — |  |  | — |  |  | — |  |  | 253 |  |  | 11 |  |  | 264 |
Total commercial | 38 |  |  | 30 |  |  | 6 |  |  | 74 |  |  | 48,941 |  |  | 368 |  |  | 49,309 |
Commercial investor real estate mortgage | — |  |  | — |  |  | — |  |  | — |  |  | 5,438 |  |  | 3 |  |  | 5,441 |
Commercial investor real estate construction | — |  |  | — |  |  | — |  |  | — |  |  | 1,586 |  |  | — |  |  | 1,586 |
Total investor real estate | — |  |  | — |  |  | — |  |  | — |  |  | 7,024 |  |  | 3 |  |  | 7,027 |
Residential first mortgage | 73 |  |  | 31 |  |  | 123 |  |  | 227 |  |  | 17,479 |  |  | 33 |  |  | 17,512 |
Home equity lines | 15 |  |  | 6 |  |  | 21 |  |  | 42 |  |  | 3,704 |  |  | 40 |  |  | 3,744 |
Home equity loans | 7 |  |  | 4 |  |  | 12 |  |  | 23 |  |  | 2,503 |  |  | 7 |  |  | 2,510 |
Consumer credit card | 9 |  |  | 6 |  |  | 12 |  |  | 27 |  |  | 1,184 |  |  | — |  |  | 1,184 |
Other consumer—exit portfolios | 10 |  | 4 |  | 2 |  | 16 |  | 1,071 |  | — |  | 1,071
Other consumer | 31 |  |  | 15 |  |  | 13 |  |  | 59 |  |  | 5,427 |  |  | — |  |  | 5,427 |
Total consumer | 145 |  |  | 66 |  |  | 183 |  |  | 394 |  |  | 31,368 |  |  | 80 |  |  | 31,448 |
| $ | 183 |  |  | $ | 96 |  |  | $ | 189 |  |  | $ | 468 |  |  | $ | 87,333 |  |  | $ | 451 |  |  | $ | 87,784 |
TROUBLED DEBT RESTRUCTURINGS Regions regularly modifies commercial and investor real estate loans in order to facilitate a workout strategy. Typical modifications include accommodations, such as renewals and forbearances. The majority of Regions’ commercial and investor real estate TDRs are the result of renewals of classified loans at an interest rate that is not considered to be a market interest rate. For smaller dollar commercial loans, Regions may periodically grant interest rate and other term concessions, similar to those under the consumer program described below. Regions works to meet the individual needs of consumer borrowers to stem foreclosure through its CAP. Regions designed the program to allow for customer-tailored modifications with the goal of keeping customers in their homes and avoiding foreclosure where possible. Modification may be offered to any borrower experiencing financial hardship regardless of the borrower’s payment status. Consumer TDRs primarily involve an interest rate concession, however under the CAP, Regions may also offer a short-term deferral, a term extension, a new loan product, or a combination of these options. For loans restructured under the CAP, Regions expects to collect the original contractually due principal. The gross original contractual interest may be collectible, depending on the terms modified. All CAP modifications are considered TDRs regardless of the term because they are concessionary in nature and because the customer documents a financial hardship in order to participate. As provided initially in the CARES Act and subsequently extended through the Consolidated Appropriations Act, certain loan modifications related to the COVID-19 pandemic beginning March 1, 2020 through January 1, 2022 were eligible for relief from TDR classification. Regions elected this provision of both Acts; therefore, modified loans that met the required guidelines for relief are not considered TDRs and are excluded from the 2021 disclosures below. The following tables present the end of period balance for loans modified in a TDR during the periods presented by portfolio segment and class, and the financial impact of those modifications. The tables include modifications made to new TDRs, as well as renewals of existing TDRs.
| 2022
|  |  |  |  | Financial Impact of Modifications Considered TDRs
| Number of Obligors |  | Recorded Investment |  | Increase in Allowance at Modification
| (Dollars in millions)
Commercial and industrial | 50 |  | $ | 174 |  |  | $ | — |
Commercial real estate mortgage—owner-occupied | 11 |  | 5 |  | —
Commercial real estate construction—owner-occupied | — |  | 3 |  | —
Total commercial | 61 |  | 182 |  | —
Commercial investor real estate mortgage | 5 |  | 48 |  | —
Commercial investor real estate construction | — |  | — |  | —
Total investor real estate | 5 |  | 48 |  | —
Residential first mortgage | 983 |  | 135 |  | 6
Home equity lines | 94 |  | 6 |  | 4
Home equity loans | 208 |  | 14 |  | —
Consumer credit card | 4 |  | — |  | —
Other consumer—exit portfolios | — |  | — |  | —
Other consumer | 5 |  | — |  | —
Total consumer | 1294 |  | 155 |  | 10
| 1360 |  | $ | 385 |  |  | $ | 10 |
| 2021
|  |  |  |  | Financial Impact of Modifications Considered TDRs
| Number of Obligors |  | Recorded Investment |  | Increase in Allowance at Modification
| (Dollars in millions)
Commercial and industrial | 65 |  | $ | 116 |  |  | $ | — |
Commercial real estate mortgage—owner-occupied | 28 |  | 11 |  |  | — |
Commercial real estate construction—owner-occupied | 2 |  | 2 |  |  | — |
Total commercial | 95 |  | 129 |  |  | — |
Commercial investor real estate mortgage | 8 |  | 77 |  |  | — |
Commercial investor real estate construction | — |  | — |  |  | — |
Total investor real estate | 8 |  | 77 |  |  | — |
Residential first mortgage | 492 |  | 85 |  |  | 8 |
Home equity lines | 7 |  | 1 |  |  | — |
Home equity loans | 72 |  | 6 |  |  | — |
Consumer credit card | 1 |  | — |  |  | — |
Other consumer- exit portfolios | — |  | — |  |  | — |
Other consumer | 80 |  | 3 |  |  | — |
Total consumer | 652 |  | 95 |  |  | 8 |
| 755 |  | $ | 301 |  |  | $ | 8 |

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