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ALLOWANCE FOR CREDIT LOSSES, NONACCRUAL LOANS AND LEASES, AND CONCENTRATIONS OF CREDIT RISK

9 Months Ended

Sep. 30, 2021

Receivables [Abstract]

ALLOWANCE FOR CREDIT LOSSES, NONACCRUAL LOANS AND LEASES, AND CONCENTRATIONS OF CREDIT RISK

NOTE 4 - ALLOWANCE FOR CREDIT LOSSES, NONACCRUAL LOANS AND LEASES, AND CONCENTRATIONS OF CREDIT RISK

Allowance for Credit Losses    

Recorded in the ACL is management’s estimate of expected credit losses in the Company’s loan and lease portfolios. See Note 5 in the Company’s 2020 Form 10-K for a detailed discussion of the ACL reserve methodology and estimation techniques as of December 31, 2020. There were no significant changes to the ACL reserve methodology in the nine months ended September 30, 2021.

The following table presents a summary of changes in the ALLL and the allowance for unfunded lending commitments for the three months ended and nine months ended September 30, 2021:

			Three Months Ended September 30, 2021												Nine Months Ended September 30, 2021
(in millions)			Commercial			Retail			Total						Commercial			Retail			Total
Allowance for loan and lease losses, beginning of period			$953			$994			$1,947						$1,233			$1,210			$2,443
Charge-offs			(17)			(70)			(87)						(196)			(243)			(439)
Recoveries			3			40			43						37			122			159
Net charge-offs			(14)			(30)			(44)						(159)			(121)			(280)
Provision charged to income			(72)			24			(48)						(207)			(101)			(308)
Allowance for loan and lease losses, end of period			$867			$988			$1,855						$867			$988			$1,855
Allowance for unfunded lending commitments, beginning of period			$121			$13			$134						$186			$41			$227
Provision for unfunded lending commitments			9			6			15						(56)			(22)			(78)
Allowance for unfunded lending commitments, end of period			$130			$19			$149						$130			$19			$149

Overall, an ending ACL balance of $2.0 billion at September 30, 2021 compared to $2.7 billion at December 31, 2020. The difference in ACL as of September 30, 2021 as compared to December 31, 2020 was due to net charge-offs of $280 million, as detailed below, coupled with a credit provision benefit of $386 million. This reflected strong credit performance across the retail and commercial loan portfolios, and improvement in the macroeconomic outlook.     

The decrease in commercial net charge-offs of $126 million for the nine months ended September 30, 2021 as compared to the nine months ended September 30, 2020 reflects the economic recovery following the COVID-19 pandemic and associated lockdowns. Retail net charge-offs were down $97 million in the nine months ended September 30, 2021 as compared to the nine months ended September 30, 2020 as a result of government stimulus and forbearance programs as well as strong collateral values in residential real estate and automobile.

To determine the ACL as of September 30, 2021, Citizens utilized an economic forecast that generally reflects real GDP growth of approximately 5.8% over 2021. The forecast also projects the unemployment rate to be in the range of 5.3% to 6.3% throughout 2021. This forecast reflects an overall improved macroeconomic outlook as compared to December 31, 2020. We continue to utilize our qualitative allowance framework to reassess and adjust ACL reserve levels. Macroeconomic forecast risk, driven by uncertainty and volatility of key macroeconomic variables, is one of the primary factors influencing our qualitative reserve. As the economic recovery following the COVID-19 pandemic has continued, we have assessed risks to the recovery, including potential for continuing impacts from COVID-19 variants, challenges in the global supply chain, and recent inflationary trends, as well as potential impacts from ending monetary and fiscal stimulus programs. In addition to judgment applied to the commercial portfolio as a whole, Citizens continued to apply management judgment

to adjust the modeled reserves in the commercial industry sectors most impacted by the COVID-19 pandemic and associated lockdowns, including CRE retail, CRE office and hospitality and casual dining.

The following table presents a summary of changes in the ALLL and the allowance for unfunded lending commitments for the three months and nine months ended September 30, 2020:

			Three Months Ended September 30, 2020												Nine Months Ended September 30, 2020
(in millions)			Commercial			Retail			Total						Commercial			Retail			Total
Allowance for loan and lease losses, beginning of period			$1,235			$1,213			$2,448						$674			$578			$1,252
Cumulative effect of change in accounting principle			—			—			—						(176)			629			453
Allowance for loan and lease losses, beginning of period, adjusted			1,235			1,213			2,448						498			1,207			1,705
Charge-offs			(171)			(86)			(257)						(292)			(319)			(611)
Recoveries			1			37			38						7			101			108
Net charge-offs			(170)			(49)			(219)						(285)			(218)			(503)
Provision charged to income			224			89			313						1,076			264			1,340
Allowance for loan and lease losses, end of period			$1,289			$1,253			$2,542						$1,289			$1,253			$2,542
Allowance for unfunded lending commitments, beginning of period			$69			$10			$79						$44			$—			$44
Cumulative effect of change in accounting principle			—			—			—						(3)			1			(2)
Allowance for unfunded lending commitments, beginning of period, adjusted			69			10			79						41			1			42
Provision for unfunded lending commitments			83			32			115						111			41			152
Allowance for unfunded lending commitments, end of period			$152			$42			$194						$152			$42			$194

Credit Quality Indicators

The Company presents loan and lease portfolio segments and classes by credit quality indicator and vintage year. Citizens defines the vintage date for the purpose of this 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 modified in a TDR are considered a continuation of the original loan and vintage date corresponds with the most recent credit decision.

For commercial loans and leases, Citizens utilizes regulatory classification ratings to monitor credit quality. The assignment of regulatory classification ratings occurs at loan origination and are periodically re-evaluated by Citizens utilizing a risk-based approach, including any time management becomes aware of information affecting the borrowers' ability to fulfill their obligations. The review process considers both quantitative and qualitative factors. Loans with a “pass” rating are those that the Company believes will fully repay in accordance with the contractual loan terms. Commercial loans and leases identified as “criticized” have some weakness or potential weakness that indicate an increased probability of future loss. Citizens groups “criticized” loans into three categories, “special mention,” “substandard,” and “doubtful.” Special mention loans have potential weaknesses that, if left uncorrected, may result in deterioration of the Company’s credit position at some future date. Substandard loans are inadequately protected loans; these loans have well-defined weaknesses that could hinder normal repayment or collection of the debt. Doubtful loans have the same weaknesses as substandard, with the added characteristic that the possibility of loss is high and collection of the full amount of the loan is improbable.

The following table presents the amortized cost basis of commercial loans and leases, by vintage date and regulatory classification rating, as of September 30, 2021:

			Term Loans by Origination Year																																				Revolving Loans
(in millions)			2021						2020						2019						2018						2017						Prior to 2017						Within the Revolving Period			Converted to Term						Total
Commercial and industrial
Pass(1)			$6,411						$4,086						$4,723						$3,079						$1,723						$2,480						$16,578			$138						$39,218
Special Mention			4						47						226						148						55						182						451			2						1,115
Substandard			40						110						229						121						91						227						550			18						1,386
Doubtful			26						8						12						21						11						17						37			3						135
Total commercial and industrial			6,481						4,251						5,190						3,369						1,880						2,906						17,616			161						41,854
Commercial real estate
Pass			1,073						2,586						3,835						2,484						863						1,343						962			—						13,146
Special Mention			46						3						148						99						169						151						—			—						616
Substandard			28						97						91						279						150						81						9			—						735
Doubtful			—						9						—						—						—						2						—			—						11
Total commercial real estate			1,147						2,695						4,074						2,862						1,182						1,577						971			—						14,508
Leases
Pass			284						281						191						180						79						504						—			—						1,519
Special Mention			2						16						2						8						5						16						—			—						49
Substandard			1						16						6						—						—						1						—			—						24
Doubtful			—						—						—						—						—						1						—			—						1
Total leases			287						313						199						188						84						522						—			—						1,593
Total commercial
Pass(1)			7,768						6,953						8,749						5,743						2,665						4,327						17,540			138						53,883
Special Mention			52						66						376						255						229						349						451			2						1,780
Substandard			69						223						326						400						241						309						559			18						2,145
Doubtful			26						17						12						21						11						20						37			3						147
Total commercial			$7,915						$7,259						$9,463						$6,419						$3,146						$5,005						$18,587			$161						$57,955

(1) Includes $1.9 billion of PPP loans designated as pass that are fully guaranteed by the SBA originating in 2021 and 2020.

The following table presents the amortized cost basis of commercial loans and leases, by vintage date and regulatory classification rating, as of December 31, 2020:

			Term Loans by Origination Year																																				Revolving Loans
(in millions)			2020						2019						2018						2017						2016						Prior to 2016						Within the Revolving Period			Converted to Term						Total
Commercial and industrial
Pass(1)			$8,036						$5,730						$4,180						$2,174						$1,157						$1,980						$17,281			$340						$40,878
Special Mention			34						264						163						84						60						173						771			34						1,583
Substandard			91						195						248						100						81						127						600			22						1,464
Doubtful			65						10						34						38						3						31						63			4						248
Total commercial and industrial			8,226						6,199						4,625						2,396						1,301						2,311						18,715			400						44,173
Commercial real estate
Pass			1,848						2,836						2,810						1,106						566						919						3,271			—						13,356
Special Mention			19						130						121						92						94						48						300			—						804
Substandard			116						2						65						5						53						26						149			—						416
Doubtful			16						26						8						—						—						2						24			—						76
Total commercial real estate			1,999						2,994						3,004						1,203						713						995						3,744			—						14,652
Leases
Pass			455						246						229						139						180						673						—			—						1,922
Special Mention			3						4						2						4						2						18						—			—						33
Substandard			—						2						2						4						4						—						—			—						12
Doubtful			—						—						—						—						—						1						—			—						1
Total leases			458						252						233						147						186						692						—			—						1,968
Total commercial
Pass(1)			10,339						8,812						7,219						3,419						1,903						3,572						20,552			340						56,156
Special Mention			56						398						286						180						156						239						1,071			34						2,420
Substandard			207						199						315						109						138						153						749			22						1,892
Doubtful			81						36						42						38						3						34						87			4						325
Total commercial			$10,683						$9,445						$7,862						$3,746						$2,200						$3,998						$22,459			$400						$60,793

(1) Includes $4.2 billion of PPP loans designated as pass that are fully guaranteed by the SBA originating in 2020.

For retail loans, Citizens utilizes FICO credit scores and the loan’s payment and delinquency status to monitor credit quality. Management believes FICO scores are the strongest indicator of credit losses over the contractual life of the loan and assist management in predicting the borrower’s future payment performance. Scores are based on current and historical national industry-wide consumer level credit performance data.

The following table presents the amortized cost basis of retail loans, by vintage date and FICO scores, as of September 30, 2021:

			Term Loans by Origination Year																																				Revolving Loans
(in millions)			2021						2020						2019						2018						2017						Prior to 2017						Within the Revolving Period			Converted to Term						Total
Residential mortgages
800+			$1,585						$3,179						$1,403						$395						$784						$2,389						$—			$—						$9,735
740-799			2,607						2,087						853						265						384						1,253						—			—						7,449
680-739			639						613						356						173						185						611						—			—						2,577
620-679			84						117						169						103						112						306						—			—						891
<620			8						56						166						167						165						281						—			—						843
No FICO available(1)			2						5						1						—						—						10						—			—						18
Total residential mortgages			4,925						6,057						2,948						1,103						1,630						4,850						—			—						21,513
Home equity
800+			—						2						6						6						4						154						4,333			294						4,799
740-799			1						1						5						5						8						137						3,405			299						3,861
680-739			—						1						8						13						17						151						1,665			250						2,105
620-679			—						3						13						23						19						123						345			176						702
<620			—						2						16						22						21						96						86			179						422
Total home equity			1						9						48						69						69						661						9,834			1,198						11,889
Automobile
800+			1,287						897						608						286						183						84						—			—						3,345
740-799			1,781						1,177						707						344						195						85						—			—						4,289
680-739			1,436						958						589						277						154						69						—			—						3,483
620-679			680						436						297						156						89						45						—			—						1,703
<620			120						142						168						118						75						45						—			—						668
No FICO available(1)			4						—						—						—						—						—						—			—						4
Total automobile			5,308						3,610						2,369						1,181						696						328						—			—						13,492
Education
800+			1,080						1,865						921						566						519						951						—			—						5,902
740-799			1,245						1,743						730						402						297						550						—			—						4,967
680-739			369						526						246						150						113						278						—			—						1,682
620-679			29						60						41						34						28						105						—			—						297
<620			2						8						11						11						10						46						—			—						88
No FICO available(1)			10						—						—						—						—						54						—			—						64
Total education			2,735						4,202						1,949						1,163						967						1,984						—			—						13,000
Other retail
800+			134						288						154						79						37						35						366			—						1,093
740-799			211						395						216						103						47						29						711			2						1,714
680-739			179						308						151						69						29						14						667			5						1,422
620-679			114						150						51						24						8						5						264			5						621
<620			19						39						19						11						3						3						78			6						178
No FICO available(1)			120						7						—						—						—						—						313			1						441
Total other retail			777						1,187						591						286						124						86						2,399			19						5,469
Total retail
800+			4,086						6,231						3,092						1,332						1,527						3,613						4,699			294						24,874
740-799			5,845						5,403						2,511						1,119						931						2,054						4,116			301						22,280
680-739			2,623						2,406						1,350						682						498						1,123						2,332			255						11,269
620-679			907						766						571						340						256						584						609			181						4,214
<620			149						247						380						329						274						471						164			185						2,199
No FICO available(1)			136						12						1						—						—						64						313			1						527
Total retail			$13,746						$15,065						$7,905						$3,802						$3,486						$7,909						$12,233			$1,217						$65,363

(1) Represents loans for which an updated FICO score was unavailable (e.g., due to recent profile changes).

The following table presents the amortized cost basis of retail loans, by vintage date and FICO scores, as of December 31, 2020:

			Term Loans by Origination Year																																				Revolving Loans
(in millions)			2020						2019						2018						2017						2016						Prior to 2016						Within the Revolving Period			Converted to Term						Total
Residential mortgages
800+			$2,687						$1,885						$638						$1,129						$1,615						$1,755						$—			$—						$9,709
740-799			2,931						1,133						398						527						743						904						—			—						6,636
680-739			784						351						162						172						295						458						—			—						2,222
620-679			97						94						44						56						66						223						—			—						580
<620			12						28						35						58						50						185						—			—						368
No FICO available(1)			1						2						1						5						1						14						—			—						24
Total residential mortgages			6,512						3,493						1,278						1,947						2,770						3,539						—			—						19,539
Home equity
800+			2						8						10						7						5						216						4,319			344						4,911
740-799			2						6						7						6						5						180						3,234			331						3,771
680-739			1						6						10						15						8						179						1,632			284						2,135
620-679			—						10						18						21						14						136						402			195						796
<620			1						17						30						29						18						122						105			214						536
Total home equity			6						47						75						78						50						833						9,692			1,368						12,149
Automobile
800+			1,056						812						424						312						169						62						—			—						2,835
740-799			1,514						1,022						531						344						172						59						—			—						3,642
680-739			1,347						889						461						282						138						47						—			—						3,164
620-679			669						484						259						157						84						32						—			—						1,685
<620			140						242						189						137						79						34						—			—						821
No FICO available(1)			2						—						—						—						—						4						—			—						6
Total automobile			4,728						3,449						1,864						1,232						642						238						—			—						12,153
Education
800+			1,817						1,363						849						781						578						777						—			—						6,165
740-799			1,797						1,009						541						387						251						423						—			—						4,408
680-739			450						294						173						127						90						221						—			—						1,355
620-679			26						35						33						28						25						95						—			—						242
<620			2						5						10						10						8						41						—			—						76
No FICO available(1)			2						—						—						—						—						60						—			—						62
Total education			4,094						2,706						1,606						1,333						952						1,617						—			—						12,308
Other retail
800+			461						380						163						77						15						44						341			—						1,481
740-799			620						460						184						81						19						31						638			2						2,035
680-739			495						302						111						48						10						13						561			5						1,545
620-679			248						104						37						14						3						5						174			7						592
<620			24						30						17						6						1						3						77			8						166
No FICO available(1)			54						1						—						—						—						—						272			2						329
Total other retail			1,902						1,277						512						226						48						96						2,063			24						6,148
Total retail
800+			6,023						4,448						2,084						2,306						2,382						2,854						4,660			344						25,101
740-799			6,864						3,630						1,661						1,345						1,190						1,597						3,872			333						20,492
680-739			3,077						1,842						917						644						541						918						2,193			289						10,421
620-679			1,040						727						391						276						192						491						576			202						3,895
<620			179						322						281						240						156						385						182			222						1,967
No FICO available(1)			59						3						1						5						1						78						272			2						421
Total retail			$17,242						$10,972						$5,335						$4,816						$4,462						$6,323						$11,755			$1,392						$62,297

(1) Represents loans for which an updated FICO score was unavailable (e.g., due to recent profile changes).

Nonaccrual and Past Due Assets

The following table presents nonaccrual loans and leases and loans accruing and 90 days or more past due:

			As of September 30, 2021												As of December 31, 2020
(in millions)			Nonaccrual loans and leases			90+ days past due and accruing			Nonaccrual with no related ACL						Nonaccrual loans and leases			90+ days past due and accruing			Nonaccrual with no related ACL
Commercial and industrial			$170			$4			$61						$280			$20			$56
Commercial real estate			98			—			1						176			—			2
Leases			1			—			—						2			1			—
Total commercial			269			4			62						458			21			58
Residential mortgages(1)			164			293			142						167			30			96
Home equity			216			—			188						276			—			207
Automobile			55			—			29						72			—			17
Education			23			1			2						18			2			2
Other retail			20			14			2						28			9			—
Total retail			478			308			363						561			41			322
Total loans and leases			$747			$312			$425						$1,019			$62			$380

(1) 90+ days past due and accruing includes $289 million and $21 million of loans fully or partially guaranteed by the FHA, VA, and USDA for September 30, 2021 and December 31, 2020, respectively.

Interest income is generally not recognized for loans and leases that are on nonaccrual status. The Company reverses accrued interest receivable with a charge to interest income upon classifying the loan or lease as nonaccrual.

    The following table presents an analysis of the age of both accruing and nonaccrual loan and lease past due amounts:

			September 30, 2021																		December 31, 2020
			Days Past Due																		Days Past Due
(in millions)			Current-29			30-59			60-89			90+			Total						Current-29			30-59			60-89			90+			Total
Commercial and industrial			$41,783			$25			$3			$43			$41,854						$43,817			$223			$16			$117			$44,173
Commercial real estate			14,402			3			5			98			14,508						14,531			1			85			35			14,652
Leases			1,591			—			1			1			1,593						1,956			9			—			3			1,968
Total commercial			57,776			28			9			142			57,955						60,304			233			101			155			60,793
Residential mortgages(1)			20,861			155			57			440			21,513						19,291			59			21			168			19,539
Home equity			11,654			35			16			184			11,889						11,848			61			28			212			12,149
Automobile			13,318			117			42			15			13,492						11,901			170			65			17			12,153
Education			12,941			33			14			12			13,000						12,255			33			13			7			12,308
Other retail			5,371			39			28			31			5,469						6,047			38			29			34			6,148
Total retail			64,145			379			157			682			65,363						61,342			361			156			438			62,297
Total			$121,921			$407			$166			$824			$123,318						$121,646			$594			$257			$593			$123,090

(1) 90+ days past due includes $289 million and $44 million of loans fully or partially guaranteed by the FHA, VA, and USDA at September 30, 2021 and December 31, 2020, respectively.

At September 30, 2021 and December 31, 2020, the Company had collateral-dependent residential mortgage and home equity loans totaling $543 million and $552 million, respectively. At September 30, 2021 and December 31, 2020, the Company had collateral-dependent commercial loans totaling $42 million and $206 million, respectively.

The amortized cost basis of mortgage loans collateralized by residential real estate for which formal foreclosure proceedings were in process was $150 million and $119 million as of September 30, 2021 and December 31, 2020, respectively.

Troubled Debt Restructurings

The following tables summarize loans modified during the three and nine months ended September 30, 2021 and 2020. The balances represent the post-modification outstanding amortized cost basis and may include loans that became TDRs during the period and were subsequently paid off in full, charged off, or sold prior to period end. Pre-modification balances for modified loans approximate the post-modification balances shown.

									Three Months Ended September 30, 2021
									Amortized Cost Basis
(dollars in millions)			Number of Contracts									Interest Rate Reduction(1)						Maturity Extension(2)									Other(3)						Total
Commercial and industrial			7									$—									$38									$10						$48
Total commercial			7									—									38									10						48
Residential mortgages			101									2									7									7						16
Home equity			69									—									1									3						4
Automobile			224									—									—									1						1
Education			226									—									—									8						8
Other retail			549									3									—									1						4
Total retail			1,169									5									8									20						33
Total			1,176									$5									$46									$30						$81

												Three Months Ended September 30, 2020
												Amortized Cost Basis
(dollars in millions)			Number of Contracts									Interest Rate Reduction(1)									Maturity Extension(2)									Other(3)						Total
Commercial and industrial			14									$—									$103									$1						$104
Total commercial			14									—									103									1						104
Residential mortgages			107									9									6									4						19
Home equity			179									2									4									6						12
Automobile			1,191									1									—									18						19
Education			140									—									—									3						3
Other retail			484									1									—									—						1
Total retail			2,101									13									10									31						54
Total			2,115									$13									$113									$32						$158

												Nine Months Ended September 30, 2021
												Amortized Cost Basis
(dollars in millions)			Number of Contracts									Interest Rate Reduction(1)									Maturity Extension(2)									Other(3)						Total
Commercial and industrial			29									$—									$44									$64						$108
Total commercial			29									—									44									64						108
Residential mortgages			814									14									133									54						201
Home equity			318									3									9									10						22
Automobile			1,272									1									—									14						15
Education			638									—									—									21						21
Other retail			1,764									7									—									2						9
Total retail			4,806									25									142									101						268
Total			4,835									$25									$186									$165						$376

												Nine Months Ended September 30, 2020
												Amortized Cost Basis
(dollars in millions)			Number of Contracts									Interest Rate Reduction(1)									Maturity Extension(2)									Other(3)						Total
Commercial and industrial			52									$—									$106									$95						$201
Total commercial			52									—									106									95						201
Residential mortgages			348									26									27									11						64
Home equity			568									8									8									21						37
Automobile			2,368									2									—									35						37
Education			373									—									—									9						9
Other retail			2,167									8									—									2						10
Total retail			5,824									44									35									78						157
Total			5,876									$44									$141									$173						$358

(1) Includes modifications that consist of multiple concessions, one of which is an interest rate reduction.

(2) Includes modifications that consist of multiple concessions, one of which is a maturity extension (unless one of the other concessions was an interest rate reduction).

(3) Includes modifications other than interest rate reductions or maturity extensions, such as lowering scheduled payments for a specified period of time, principal forgiveness, and capitalizing arrearages. Also included are the following: deferrals, trial modifications, certain bankruptcies, loans in forbearance and prepayment plans. Modifications can include the deferral of accrued interest resulting in post-modification balances being higher than pre-modification.

Modified TDRs resulted in charge-offs of $1 million and $43 million for the three months ended September 30, 2021 and 2020, respectively. Citizens recorded $5 million and $49 million of charge-offs related to TDRs for the nine months ended September 30, 2021 and 2020, respectively.

Unfunded commitments related to TDRs were $51 million and $49 million at September 30, 2021 and December 31, 2020, respectively.

The following table provides a summary of TDRs that defaulted (became 90 days or more past due) within 12 months of their modification date:

			Three Months Ended September 30,																								Nine Months Ended September 30,
(dollars in millions)			2021						2020																		2021						2020
Commercial TDRs			$—						$14																		$23						$53
Retail TDRs(1)			37						22																		66						47
Total			$37						$36																		$89						$100

(1) Includes $34 million and $6 million of loans fully or partially government guaranteed by the FHA, VA, and USDA for the three months ended September 30, 2021 and 2020, respectively and $37 million and $14 million of loans fully or partially government guaranteed by the FHA, VA, and USDA for the nine months ended September 30, 2021 and 2020, respectively.

Concentrations of Credit Risk

Most of the Company’s lending activity is with customers located in the New England, Mid-Atlantic, and Midwest regions. Generally, loans are collateralized by assets including real estate, inventory, accounts receivable, other personal property, and investment securities. As of September 30, 2021 and December 31, 2020, Citizens had a significant amount of loans collateralized by residential and commercial real estate. There were no significant concentration risks within the commercial loan or retail loan portfolios. Exposure to credit losses arising from lending transactions may fluctuate with fair values of collateral supporting loans, which may not perform according to contractual agreements. The Company’s policy is to collateralize loans to the extent necessary. However, based on the financial strength of the applicant and facts Citizens will grant unsecured loans.

Certain loan products, including residential mortgages, home equity loans and lines of credit, and credit cards, have contractual features that may increase credit exposure to the Company in the event of an increase in interest rates or a decline in housing values. These products include loans that exceed 90% of the value of the underlying collateral (high LTV loans), interest-only residential mortgages, and loans with low introductory rates. The following tables present balances of loans with these characteristics:

			September 30, 2021
(in millions)			Residential Mortgages									Home Equity			Other Retail			Education			Total
High loan-to-value			$179									$18			$—			$—			$197
Interest-only			3,317									—			—			1			3,318
Low introductory rate			—									—			156			—			156
Multiple characteristics and other			2									—			—			—			2
Total			$3,498									$18			$156			$1			$3,673

			December 31, 2020
(in millions)			Residential Mortgages									Home Equity			Other Retail						Total
High loan-to-value			$289									$64			$—						$353
Interest-only			2,801									—			—						2,801
Low introductory rate			—									—			170						170
Total			$3,090									$64			$170						$3,324

X

- Definition

The entire disclosure for allowance for credit losses.

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-Publisher FASB
-Name Accounting Standards Codification
-Topic 310
-URI http://asc.fasb.org/topic&trid=2196771

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