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CREDIT QUALITY AND THE ALLOWANCE FOR CREDIT LOSSES | 3 Months Ended
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Mar. 31, 2025
Receivables [Abstract] |
CREDIT QUALITY AND THE ALLOWANCE FOR CREDIT LOSSES | NOTE 4 - CREDIT QUALITY AND THE ALLOWANCE FOR CREDIT LOSSES Allowance for Credit Losses The Company’s estimate of expected credit losses in its loan and lease portfolios is recorded in the ACL and considers extensive historical loss experience, including the impact of loss mitigation and restructuring programs that the Company offers to borrowers experiencing financial difficulty, as well as projected loss severity as a result of loan default. For a detailed discussion of the ACL reserve methodology and estimation techniques as of December 31, 2024, see Note 6 in the Company’s 2024 Form 10-K. There were no significant changes to the ACL reserve methodology during the three months ended March 31, 2025. The following table presents a summary of changes in the ACL for the three months ended March 31, 2025:
| Three Months Ended March 31, 2025 |  |
(dollars in millions) | Commercial | Retail | Total |  |  |  |
Allowance for loan and lease losses, beginning of period | $1,140 |  | $921 |  | $2,061 |  |  |  |  |
Charge-offs | (85) |  | (149) |  | (234) |  |  |  |  |
Recoveries | 4 |  | 30 |  | 34 |  |  |  |  |
Net charge-offs | (81) |  | (119) |  | (200) |  |  |  |  |
Provision expense (benefit) for loans and leases | 89 |  | 64 |  | 153 |  |  |  |  |
Allowance for loan and lease losses, end of period | 1,148 |  | 866 |  | 2,014 |  |  |  |  |
Allowance for unfunded lending commitments, beginning of period | 155 |  | 43 |  | 198 |  |  |  |  |
Provision expense (benefit) for unfunded lending commitments | 9 |  | (9) |  | — |  |  |  |  |
Allowance for unfunded lending commitments, end of period | 164 |  | 34 |  | 198 |  |  |  |  |
Total allowance for credit losses, end of period | $1,312 |  | $900 |  | $2,212 |  |  |  |  |
During the three months ended March 31, 2025, net charge-offs of $200 million and a provision for expected credit losses of $153 million resulted in a decrease of $47 million to the ACL. During the first quarter of 2025, the Company entered into an agreement to sell $1.9 billion of Non-Core education loans and subsequently reclassified these loans to LHFS. Upon reclassification to LHFS, a $25 million charge-off was recognized. This transaction will settle ratably each quarter throughout 2025, with $200 million settled during the first quarter. As of March 31, 2025, the Company’s ACL economic forecast over a two-year reasonable and supportable period reflects a mild recession inclusive of uncertainties related to the implementation of tariffs and protectionist trade policies, inflationary pressures and geopolitical tensions. This forecast projects peak unemployment of approximately 5.1%, consistent with December 31, 2024, and a start-to-trough real GDP decline of approximately 0.5% and 0.4% at March 31, 2025 and December 31, 2024, respectively, and is generally applied to the retail and commercial and industrial portfolios. More severe economic scenarios are applied within the CRE portfolio, such as general office, with peak unemployment of approximately 9.3% and start-to-trough real GDP decline of approximately 4.4% at March 31, 2025 and December 31, 2024. The following table presents a summary of changes in the ACL for the three months ended March 31, 2024:
| Three Months Ended March 31, 2024 |  |
(dollars in millions) | Commercial | Retail | Total |  |  |  |
Allowance for loan and lease losses, beginning of period | $1,250 |  | $848 |  | $2,098 |  |  |  |  |
Charge-offs | (102) |  | (129) |  | (231) |  |  |  |  |
Recoveries | 17 |  | 33 |  | 50 |  |  |  |  |
Net charge-offs | (85) |  | (96) |  | (181) |  |  |  |  |
Provision expense (benefit) for loans and leases | 69 |  | 100 |  | 169 |  |  |  |  |
Allowance for loan and lease losses, end of period | 1,234 |  | 852 |  | 2,086 |  |  |  |  |
Allowance for unfunded lending commitments, beginning of period | 175 |  | 45 |  | 220 |  |  |  |  |
Provision expense (benefit) for unfunded lending commitments | 16 |  | (14) |  | 2 |  |  |  |  |
Allowance for unfunded lending commitments, end of period | 191 |  | 31 |  | 222 |  |  |  |  |
Total allowance for credit losses, end of period | $1,425 |  | $883 |  | $2,308 |  |  |  |  |
Credit Quality Indicators The Company presents loan and lease portfolio segments and classes by credit quality indicator and vintage year and defines the vintage date for the purpose of this disclosure as the date of the most recent credit decision. Renewals are categorized as new credit decisions and reflect the renewal date as the vintage date, except for renewals of loans modified for borrowers experiencing financial difficulty, or FDMs, which are presented in the original vintage. The Company utilizes internal risk ratings to monitor credit quality for commercial loans and leases. For more information on these ratings see Note 6 in the Company’s 2024 Form 10-K. The following table presents the amortized cost basis of commercial loans and leases by vintage date and internal risk rating as of March 31, 2025:
| Term Loans and Leases by Origination Year |  | Revolving Loans |  |
(dollars in millions) | 2025 |  | 2024 |  | 2023 |  | 2022 |  | 2021 |  | Prior to 2021 |  | Within the Revolving Period | Converted to Term |  | Total
Commercial and industrial |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass | $1,178 |  |  | $5,502 |  |  | $2,312 |  |  | $3,878 |  |  | $2,531 |  |  | $2,593 |  |  | $23,129 |  | $73 |  |  | $41,196 |
Special Mention | — |  |  | 5 |  |  | 77 |  |  | 71 |  |  | 227 |  |  | 139 |  |  | 190 |  | — |  |  | 709 |
Substandard Accrual | — |  |  | 12 |  |  | 55 |  |  | 144 |  |  | 296 |  |  | 294 |  |  | 776 |  | 16 |  |  | 1,593 |
Nonaccrual | — |  |  | — |  |  | 4 |  |  | 83 |  |  | 45 |  |  | 62 |  |  | 83 |  | 6 |  |  | 283 |
Total commercial and industrial | 1,178 |  |  | 5,519 |  |  | 2,448 |  |  | 4,176 |  |  | 3,099 |  |  | 3,088 |  |  | 24,178 |  | 95 |  |  | 43,781 |
Commercial real estate |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass | 774 |  |  | 2,558 |  |  | 1,099 |  |  | 5,193 |  |  | 5,066 |  |  | 5,923 |  |  | 1,361 |  | 4 |  |  | 21,978 |
Special Mention | — |  |  | — |  |  | 100 |  |  | 1,005 |  |  | 355 |  |  | 433 |  |  | 80 |  | 6 |  |  | 1,979 |
Substandard Accrual | — |  |  | 3 |  |  | 79 |  |  | 519 |  |  | 217 |  |  | 1,127 |  |  | 9 |  | 116 |  |  | 2,070 |
Nonaccrual | — |  |  | — |  |  | 3 |  |  | 81 |  |  | 65 |  |  | 545 |  |  | 2 |  | 4 |  |  | 700 |
Total commercial real estate | 774 |  |  | 2,561 |  |  | 1,281 |  |  | 6,798 |  |  | 5,703 |  |  | 8,028 |  |  | 1,452 |  | 130 |  |  | 26,727 |
Total commercial |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass | 1,952 |  |  | 8,060 |  |  | 3,411 |  |  | 9,071 |  |  | 7,597 |  |  | 8,516 |  |  | 24,490 |  | 77 |  |  | 63,174 |
Special Mention | — |  |  | 5 |  |  | 177 |  |  | 1,076 |  |  | 582 |  |  | 572 |  |  | 270 |  | 6 |  |  | 2,688 |
Substandard Accrual | — |  |  | 15 |  |  | 134 |  |  | 663 |  |  | 513 |  |  | 1,421 |  |  | 785 |  | 132 |  |  | 3,663 |
Nonaccrual | — |  |  | — |  |  | 7 |  |  | 164 |  |  | 110 |  |  | 607 |  |  | 85 |  | 10 |  |  | 983 |
Total commercial | $1,952 |  |  | $8,080 |  |  | $3,729 |  |  | $10,974 |  |  | $8,802 |  |  | $11,116 |  |  | $25,630 |  | $225 |  |  | $70,508 |
The following table presents the amortized cost basis of commercial loans and leases by vintage date and internal risk rating as of December 31, 2024:
| Term Loans and Leases by Origination Year |  | Revolving Loans |  |
(dollars in millions) | 2024 |  | 2023 |  | 2022 |  | 2021 |  | 2020 |  | Prior to 2020 |  | Within the Revolving Period | Converted to Term |  | Total
Commercial and industrial |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass | $5,945 |  |  | $2,525 |  |  | $4,194 |  |  | $2,923 |  |  | $895 |  |  | $2,066 |  |  | $21,323 |  | $66 |  |  | $39,937 |
Special Mention | 2 |  |  | 79 |  |  | 98 |  |  | 236 |  |  | 48 |  |  | 48 |  |  | 211 |  | — |  |  | 722 |
Substandard Accrual | 9 |  |  | 64 |  |  | 207 |  |  | 269 |  |  | 139 |  |  | 253 |  |  | 697 |  | 13 |  |  | 1,651 |
Nonaccrual | — |  |  | 11 |  |  | 68 |  |  | 62 |  |  | 5 |  |  | 55 |  |  | 34 |  | 6 |  |  | 241 |
Total commercial and industrial | 5,956 |  |  | 2,679 |  |  | 4,567 |  |  | 3,490 |  |  | 1,087 |  |  | 2,422 |  |  | 22,265 |  | 85 |  |  | 42,551 |
Commercial real estate |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass | 2,720 |  |  | 1,305 |  |  | 5,748 |  |  | 5,412 |  |  | 1,919 |  |  | 4,199 |  |  | 1,434 |  | 4 |  |  | 22,741 |
Special Mention | 1 |  |  | — |  |  | 911 |  |  | 362 |  |  | 175 |  |  | 257 |  |  | 80 |  | 6 |  |  | 1,792 |
Substandard Accrual | 3 |  |  | 22 |  |  | 359 |  |  | 253 |  |  | 275 |  |  | 875 |  |  | 9 |  | 120 |  |  | 1,916 |
Nonaccrual | — |  |  | 67 |  |  | 89 |  |  | 58 |  |  | 90 |  |  | 470 |  |  | 2 |  | — |  |  | 776 |
Total commercial real estate | 2,724 |  |  | 1,394 |  |  | 7,107 |  |  | 6,085 |  |  | 2,459 |  |  | 5,801 |  |  | 1,525 |  | 130 |  |  | 27,225 |
Total commercial |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Pass | 8,665 |  |  | 3,830 |  |  | 9,942 |  |  | 8,335 |  |  | 2,814 |  |  | 6,265 |  |  | 22,757 |  | 70 |  |  | 62,678 |
Special Mention | 3 |  |  | 79 |  |  | 1,009 |  |  | 598 |  |  | 223 |  |  | 305 |  |  | 291 |  | 6 |  |  | 2,514 |
Substandard Accrual | 12 |  |  | 86 |  |  | 566 |  |  | 522 |  |  | 414 |  |  | 1,128 |  |  | 706 |  | 133 |  |  | 3,567 |
Nonaccrual | — |  |  | 78 |  |  | 157 |  |  | 120 |  |  | 95 |  |  | 525 |  |  | 36 |  | 6 |  |  | 1,017 |
Total commercial | $8,680 |  |  | $4,073 |  |  | $11,674 |  |  | $9,575 |  |  | $3,546 |  |  | $8,223 |  |  | $23,790 |  | $215 |  |  | $69,776 |
For retail loans, the Company 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 current FICO score as of March 31, 2025:
| Term Loans by Origination Year |  | Revolving Loans |  |
(dollars in millions) | 2025 |  | 2024 |  | 2023 |  | 2022 |  | 2021 |  | Prior to 2021 |  | Within the Revolving Period | Converted to Term |  | Total
Residential mortgages |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
800+ | $232 |  |  | $1,568 |  |  | $1,369 |  |  | $3,343 |  |  | $5,149 |  |  | $6,701 |  |  | $— |  | $— |  |  | $18,362 |
740-799 | 520 |  |  | 1,410 |  |  | 817 |  |  | 1,537 |  |  | 2,142 |  |  | 3,031 |  |  | — |  | — |  |  | 9,457 |
680-739 | 119 |  |  | 382 |  |  | 295 |  |  | 546 |  |  | 713 |  |  | 1,193 |  |  | — |  | — |  |  | 3,248 |
620-679 | 11 |  |  | 46 |  |  | 76 |  |  | 149 |  |  | 180 |  |  | 494 |  |  | — |  | — |  |  | 956 |
<620 | — |  |  | 18 |  |  | 133 |  |  | 118 |  |  | 163 |  |  | 643 |  |  | — |  | — |  |  | 1,075 |
No FICO available(1) | — |  |  | 1 |  |  | — |  |  | 3 |  |  | 1 |  |  | 11 |  |  | — |  | — |  |  | 16 |
Total residential mortgages | 882 |  |  | 3,425 |  |  | 2,690 |  |  | 5,696 |  |  | 8,348 |  |  | 12,073 |  |  | — |  | — |  |  | 33,114 |
Home equity |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
800+ | — |  |  | 1 |  |  | — |  |  | 3 |  |  | 3 |  |  | 75 |  |  | 5,770 |  | 193 |  |  | 6,045 |
740-799 | — |  |  | — |  |  | — |  |  | 1 |  |  | 3 |  |  | 52 |  |  | 5,382 |  | 224 |  |  | 5,662 |
680-739 | — |  |  | — |  |  | — |  |  | 1 |  |  | 1 |  |  | 43 |  |  | 3,064 |  | 206 |  |  | 3,315 |
620-679 | — |  |  | — |  |  | 1 |  |  | 1 |  |  | 1 |  |  | 19 |  |  | 788 |  | 178 |  |  | 988 |
<620 | — |  |  | — |  |  | 3 |  |  | 2 |  |  | 3 |  |  | 16 |  |  | 501 |  | 313 |  |  | 838 |
No FICO available(1) | — |  |  | — |  |  | — |  |  | — |  |  | — |  |  | — |  |  | 5 |  | — |  |  | 5 |
Total home equity | — |  |  | 1 |  |  | 4 |  |  | 8 |  |  | 11 |  |  | 205 |  |  | 15,510 |  | 1,114 |  |  | 16,853 |
Automobile |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
800+ | — |  |  | — |  |  | 63 |  |  | 343 |  |  | 575 |  |  | 177 |  |  | — |  | — |  |  | 1,158 |
740-799 | — |  |  | — |  |  | 87 |  |  | 376 |  |  | 482 |  |  | 172 |  |  | — |  | — |  |  | 1,117 |
680-739 | — |  |  | — |  |  | 82 |  |  | 289 |  |  | 322 |  |  | 114 |  |  | — |  | — |  |  | 807 |
620-679 | — |  |  | — |  |  | 46 |  |  | 166 |  |  | 167 |  |  | 64 |  |  | — |  | — |  |  | 443 |
<620 | — |  |  | — |  |  | 49 |  |  | 189 |  |  | 200 |  |  | 81 |  |  | — |  | — |  |  | 519 |
No FICO available(1) | — |  |  | — |  |  | — |  |  | — |  |  | — |  |  | — |  |  | — |  | — |  |  | — |
Total automobile | — |  |  | — |  |  | 327 |  |  | 1,363 |  |  | 1,746 |  |  | 608 |  |  | — |  | — |  |  | 4,044 |
Education |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
800+ | 52 |  |  | 282 |  |  | 347 |  |  | 543 |  |  | 1,104 |  |  | 2,081 |  |  | — |  | — |  |  | 4,409 |
740-799 | 75 |  |  | 321 |  |  | 320 |  |  | 463 |  |  | 556 |  |  | 1,064 |  |  | — |  | — |  |  | 2,799 |
680-739 | 29 |  |  | 145 |  |  | 139 |  |  | 193 |  |  | 186 |  |  | 397 |  |  | — |  | — |  |  | 1,089 |
620-679 | 4 |  |  | 42 |  |  | 43 |  |  | 48 |  |  | 45 |  |  | 123 |  |  | — |  | — |  |  | 305 |
<620 | 1 |  |  | 9 |  |  | 15 |  |  | 22 |  |  | 24 |  |  | 72 |  |  | — |  | — |  |  | 143 |
No FICO available(1) | 4 |  |  | 1 |  |  | — |  |  | — |  |  | — |  |  | 29 |  |  | — |  | — |  |  | 34 |
Total education | 165 |  |  | 800 |  |  | 864 |  |  | 1,269 |  |  | 1,915 |  |  | 3,766 |  |  | — |  | — |  |  | 8,779 |
Other retail |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
800+ | 28 |  |  | 155 |  |  | 55 |  |  | 34 |  |  | 13 |  |  | 13 |  |  | 473 |  | — |  |  | 771 |
740-799 | 39 |  |  | 209 |  |  | 77 |  |  | 42 |  |  | 14 |  |  | 14 |  |  | 836 |  | — |  |  | 1,231 |
680-739 | 28 |  |  | 162 |  |  | 69 |  |  | 36 |  |  | 12 |  |  | 11 |  |  | 808 |  | 1 |  |  | 1,127 |
620-679 | 12 |  |  | 79 |  |  | 38 |  |  | 24 |  |  | 8 |  |  | 5 |  |  | 318 |  | 1 |  |  | 485 |
<620 | 2 |  |  | 35 |  |  | 28 |  |  | 30 |  |  | 8 |  |  | 4 |  |  | 236 |  | 1 |  |  | 344 |
No FICO available(1) | 2 |  |  | 2 |  |  | — |  |  | — |  |  | — |  |  | — |  |  | 375 |  | — |  |  | 379 |
Total other retail | 111 |  |  | 642 |  |  | 267 |  |  | 166 |  |  | 55 |  |  | 47 |  |  | 3,046 |  | 3 |  |  | 4,337 |
Total retail |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
800+ | 312 |  |  | 2,006 |  |  | 1,834 |  |  | 4,266 |  |  | 6,844 |  |  | 9,047 |  |  | 6,243 |  | 193 |  |  | 30,745 |
740-799 | 634 |  |  | 1,940 |  |  | 1,301 |  |  | 2,419 |  |  | 3,197 |  |  | 4,333 |  |  | 6,218 |  | 224 |  |  | 20,266 |
680-739 | 176 |  |  | 689 |  |  | 585 |  |  | 1,065 |  |  | 1,234 |  |  | 1,758 |  |  | 3,872 |  | 207 |  |  | 9,586 |
620-679 | 27 |  |  | 167 |  |  | 204 |  |  | 388 |  |  | 401 |  |  | 705 |  |  | 1,106 |  | 179 |  |  | 3,177 |
<620 | 3 |  |  | 62 |  |  | 228 |  |  | 361 |  |  | 398 |  |  | 816 |  |  | 737 |  | 314 |  |  | 2,919 |
No FICO available(1) | 6 |  |  | 4 |  |  | — |  |  | 3 |  |  | 1 |  |  | 40 |  |  | 380 |  | — |  |  | 434 |
Total retail | $1,158 |  |  | $4,868 |  |  | $4,152 |  |  | $8,502 |  |  | $12,075 |  |  | $16,699 |  |  | $18,556 |  | $1,117 |  |  | $67,127 |
(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 current FICO score as of December 31, 2024:
| Term Loans by Origination Year |  | Revolving Loans |  |
(dollars in millions) | 2024 |  | 2023 |  | 2022 |  | 2021 |  | 2020 |  | Prior to 2020 |  | Within the Revolving Period | Converted to Term |  | Total
Residential mortgages |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
800+ | $1,230 |  |  | $1,302 |  |  | $3,299 |  |  | $5,109 |  |  | $2,919 |  |  | $3,869 |  |  | $— |  | $— |  |  | $17,728 |
740-799 | 1,757 |  |  | 873 |  |  | 1,568 |  |  | 2,213 |  |  | 1,338 |  |  | 1,923 |  |  | — |  | — |  |  | 9,672 |
680-739 | 425 |  |  | 281 |  |  | 552 |  |  | 697 |  |  | 385 |  |  | 938 |  |  | — |  | — |  |  | 3,278 |
620-679 | 31 |  |  | 61 |  |  | 126 |  |  | 151 |  |  | 101 |  |  | 494 |  |  | — |  | — |  |  | 964 |
<620 | 15 |  |  | 37 |  |  | 76 |  |  | 147 |  |  | 89 |  |  | 703 |  |  | — |  | — |  |  | 1,067 |
No FICO available(1) | 1 |  |  | — |  |  | — |  |  | 1 |  |  | 1 |  |  | 14 |  |  | — |  | — |  |  | 17 |
Total residential mortgages | 3,459 |  |  | 2,554 |  |  | 5,621 |  |  | 8,318 |  |  | 4,833 |  |  | 7,941 |  |  | — |  | — |  |  | 32,726 |
Home equity |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
800+ | 1 |  |  | — |  |  | 3 |  |  | 4 |  |  | 1 |  |  | 76 |  |  | 5,634 |  | 200 |  |  | 5,919 |
740-799 | — |  |  | — |  |  | 1 |  |  | 2 |  |  | 1 |  |  | 65 |  |  | 5,275 |  | 224 |  |  | 5,568 |
680-739 | — |  |  | — |  |  | 1 |  |  | — |  |  | 1 |  |  | 76 |  |  | 2,995 |  | 183 |  |  | 3,256 |
620-679 | — |  |  | 1 |  |  | 4 |  |  | 3 |  |  | 2 |  |  | 60 |  |  | 752 |  | 141 |  |  | 963 |
<620 | — |  |  | 2 |  |  | 6 |  |  | 3 |  |  | 1 |  |  | 59 |  |  | 459 |  | 259 |  |  | 789 |
No FICO available(1) | — |  |  | — |  |  | — |  |  | — |  |  | — |  |  | — |  |  | — |  | — |  |  | — |
Total home equity | 1 |  |  | 3 |  |  | 15 |  |  | 12 |  |  | 6 |  |  | 336 |  |  | 15,115 |  | 1,007 |  |  | 16,495 |
Automobile |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
800+ | — |  |  | 65 |  |  | 380 |  |  | 665 |  |  | 183 |  |  | 58 |  |  | — |  | — |  |  | 1,351 |
740-799 | — |  |  | 92 |  |  | 430 |  |  | 581 |  |  | 176 |  |  | 61 |  |  | — |  | — |  |  | 1,340 |
680-739 | — |  |  | 91 |  |  | 338 |  |  | 385 |  |  | 115 |  |  | 45 |  |  | — |  | — |  |  | 974 |
620-679 | — |  |  | 51 |  |  | 189 |  |  | 194 |  |  | 56 |  |  | 29 |  |  | — |  | — |  |  | 519 |
<620 | — |  |  | 47 |  |  | 197 |  |  | 216 |  |  | 62 |  |  | 38 |  |  | — |  | — |  |  | 560 |
No FICO available(1) | — |  |  | — |  |  | — |  |  | — |  |  | — |  |  | — |  |  | — |  | — |  |  | — |
Total automobile | — |  |  | 346 |  |  | 1,534 |  |  | 2,041 |  |  | 592 |  |  | 231 |  |  | — |  | — |  |  | 4,744 |
Education |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
800+ | 227 |  |  | 373 |  |  | 657 |  |  | 1,517 |  |  | 1,256 |  |  | 1,475 |  |  | — |  | — |  |  | 5,505 |
740-799 | 290 |  |  | 359 |  |  | 571 |  |  | 804 |  |  | 637 |  |  | 811 |  |  | — |  | — |  |  | 3,472 |
680-739 | 110 |  |  | 150 |  |  | 229 |  |  | 261 |  |  | 211 |  |  | 337 |  |  | — |  | — |  |  | 1,298 |
620-679 | 27 |  |  | 48 |  |  | 55 |  |  | 58 |  |  | 51 |  |  | 111 |  |  | — |  | — |  |  | 350 |
<620 | 5 |  |  | 12 |  |  | 21 |  |  | 28 |  |  | 25 |  |  | 60 |  |  | — |  | — |  |  | 151 |
No FICO available(1) | 5 |  |  | — |  |  | — |  |  | — |  |  | — |  |  | 31 |  |  | — |  | — |  |  | 36 |
Total education | 664 |  |  | 942 |  |  | 1,533 |  |  | 2,668 |  |  | 2,180 |  |  | 2,825 |  |  | — |  | — |  |  | 10,812 |
Other retail |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
800+ | 186 |  |  | 65 |  |  | 36 |  |  | 15 |  |  | 11 |  |  | 10 |  |  | 512 |  | — |  |  | 835 |
740-799 | 259 |  |  | 96 |  |  | 46 |  |  | 18 |  |  | 13 |  |  | 11 |  |  | 895 |  | 1 |  |  | 1,339 |
680-739 | 201 |  |  | 87 |  |  | 39 |  |  | 15 |  |  | 11 |  |  | 7 |  |  | 845 |  | 1 |  |  | 1,206 |
620-679 | 97 |  |  | 47 |  |  | 27 |  |  | 10 |  |  | 6 |  |  | 3 |  |  | 335 |  | 1 |  |  | 526 |
<620 | 32 |  |  | 31 |  |  | 34 |  |  | 15 |  |  | 7 |  |  | 3 |  |  | 234 |  | 1 |  |  | 357 |
No FICO available(1) | 5 |  |  | — |  |  | — |  |  | — |  |  | — |  |  | — |  |  | 382 |  | — |  |  | 387 |
Total other retail | 780 |  |  | 326 |  |  | 182 |  |  | 73 |  |  | 48 |  |  | 34 |  |  | 3,203 |  | 4 |  |  | 4,650 |
Total retail |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
800+ | 1,644 |  |  | 1,805 |  |  | 4,375 |  |  | 7,310 |  |  | 4,370 |  |  | 5,488 |  |  | 6,146 |  | 200 |  |  | 31,338 |
740-799 | 2,306 |  |  | 1,420 |  |  | 2,616 |  |  | 3,618 |  |  | 2,165 |  |  | 2,871 |  |  | 6,170 |  | 225 |  |  | 21,391 |
680-739 | 736 |  |  | 609 |  |  | 1,159 |  |  | 1,358 |  |  | 723 |  |  | 1,403 |  |  | 3,840 |  | 184 |  |  | 10,012 |
620-679 | 155 |  |  | 208 |  |  | 401 |  |  | 416 |  |  | 216 |  |  | 697 |  |  | 1,087 |  | 142 |  |  | 3,322 |
<620 | 52 |  |  | 129 |  |  | 334 |  |  | 409 |  |  | 184 |  |  | 863 |  |  | 693 |  | 260 |  |  | 2,924 |
No FICO available(1) | 11 |  |  | — |  |  | — |  |  | 1 |  |  | 1 |  |  | 45 |  |  | 382 |  | — |  |  | 440 |
Total retail | $4,904 |  |  | $4,171 |  |  | $8,885 |  |  | $13,112 |  |  | $7,659 |  |  | $11,367 |  |  | $18,318 |  | $1,011 |  |  | $69,427 |
(1) Represents loans for which an updated FICO score was unavailable (e.g., due to recent profile changes). The following tables present gross charge-offs by vintage date for the Company’s loan and lease portfolios:
| Three Months Ended March 31, 2025
| Term Loans and Leases by Origination Year |  | Revolving Loans |  |
(dollars in millions) | 2025 |  | 2024 |  | 2023 |  | 2022 |  | 2021 |  | Prior to 2021 |  | Within the Revolving Period | Converted to Term |  | Total
Commercial and industrial | $— |  |  | $— |  |  | $1 |  |  | $2 |  |  | $22 |  |  | $— |  |  | $9 |  | $— |  |  | $34 |
Commercial real estate | — |  |  | — |  |  | — |  |  | 8 |  |  | — |  |  | 43 |  |  | — |  | — |  |  | 51 |
Total commercial | — |  |  | — |  |  | 1 |  |  | 10 |  |  | 22 |  |  | 43 |  |  | 9 |  | — |  |  | 85 |
Residential mortgages | — |  |  | — |  |  | — |  |  | — |  |  | — |  |  | 1 |  |  | — |  | — |  |  | 1 |
Home equity | — |  |  | — |  |  | — |  |  | — |  |  | — |  |  | 1 |  |  | 4 |  | — |  |  | 5 |
Automobile | — |  |  | — |  |  | 2 |  |  | 7 |  |  | 7 |  |  | 4 |  |  | — |  | — |  |  | 20 |
Education | — |  |  | 1 |  |  | 2 |  |  | 5 |  |  | 13 |  |  | 35 |  |  | — |  | — |  |  | 56 |
Other retail | 4 |  |  | 15 |  |  | 8 |  |  | 4 |  |  | 2 |  |  | 2 |  |  | 32 |  | — |  |  | 67 |
Total retail | 4 |  |  | 16 |  |  | 12 |  |  | 16 |  |  | 22 |  |  | 43 |  |  | 36 |  | — |  |  | 149 |
Total loans and leases | $4 |  |  | $16 |  |  | $13 |  |  | $26 |  |  | $44 |  |  | $86 |  |  | $45 |  | $— |  |  | $234 |
| Three Months Ended March 31, 2024
| Term Loans and Leases by Origination Year |  | Revolving Loans |  |
(dollars in millions) | 2024 |  | 2023 |  | 2022 |  | 2021 |  | 2020 |  | Prior to 2020 |  | Within the Revolving Period | Converted to Term |  | Total
Commercial and industrial | $— |  |  | $5 |  |  | $1 |  |  | $4 |  |  | $— |  |  | $1 |  |  | $3 |  | $— |  |  | $14 |
Commercial real estate | — |  |  | — |  |  | — |  |  | — |  |  | 59 |  |  | 29 |  |  | — |  | — |  |  | 88 |
Total commercial | — |  |  | 5 |  |  | 1 |  |  | 4 |  |  | 59 |  |  | 30 |  |  | 3 |  | — |  |  | 102 |
Residential mortgages | — |  |  | — |  |  | — |  |  | — |  |  | — |  |  | 2 |  |  | — |  | — |  |  | 2 |
Home equity | — |  |  | — |  |  | — |  |  | — |  |  | — |  |  | 1 |  |  | 2 |  | 1 |  |  | 4 |
Automobile | — |  |  | 2 |  |  | 9 |  |  | 11 |  |  | 3 |  |  | 3 |  |  | — |  | — |  |  | 28 |
Education | — |  |  | — |  |  | 1 |  |  | 6 |  |  | 7 |  |  | 18 |  |  | — |  | — |  |  | 32 |
Other retail | 4 |  |  | 9 |  |  | 4 |  |  | 3 |  |  | — |  |  | 4 |  |  | 39 |  | — |  |  | 63 |
Total retail | 4 |  |  | 11 |  |  | 14 |  |  | 20 |  |  | 10 |  |  | 28 |  |  | 41 |  | 1 |  |  | 129 |
Total loans and leases | $4 |  |  | $16 |  |  | $15 |  |  | $24 |  |  | $69 |  |  | $58 |  |  | $44 |  | $1 |  |  | $231 |
Nonaccrual and Past Due Assets The following tables present an aging analysis of accruing and nonaccrual loans and leases as of March 31, 2025 and December 31, 2024:
| March 31, 2025
|  | Days Past Due and Accruing |  |  |
(dollars in millions) | Current | 30-59 | 60-89 | 90+ | Nonaccrual | Total | Nonaccrual with no related ACL
Commercial and industrial | $43,420 |  | $56 |  | $13 |  | $9 |  | $283 |  | $43,781 |  | $45 |
Commercial real estate | 25,887 |  | 131 |  | 5 |  | 4 |  | 700 |  | 26,727 |  | 19 |
Total commercial | 69,307 |  | 187 |  | 18 |  | 13 |  | 983 |  | 70,508 |  | 64 |
Residential mortgages | 32,682 |  | 60 |  | 36 |  | 138 |  | 198 |  | 33,114 |  | 147 |
Home equity | 16,450 |  | 94 |  | 27 |  | — |  | 282 |  | 16,853 |  | 178 |
Automobile | 3,900 |  | 80 |  | 25 |  | — |  | 39 |  | 4,044 |  | 6 |
Education | 8,699 |  | 39 |  | 18 |  | 3 |  | 20 |  | 8,779 |  | 2 |
Other retail | 4,207 |  | 42 |  | 27 |  | 1 |  | 60 |  | 4,337 |  | 1 |
Total retail | 65,938 |  | 315 |  | 133 |  | 142 |  | 599 |  | 67,127 |  | 334 |
Total | $135,245 |  | $502 |  | $151 |  | $155 |  | $1,582 |  | $137,635 |  | $398 |
Guaranteed residential mortgages(1) | $824 |  | $32 |  | $19 |  | $137 |  | $— |  | $1,012 |  | $— |
| December 31, 2024
|  | Days Past Due and Accruing |  |  |
(dollars in millions) | Current | 30-59 | 60-89 | 90+ | Nonaccrual | Total | Nonaccrual with no related ACL
Commercial and industrial | $42,247 |  | $35 |  | $20 |  | $8 |  | $241 |  | $42,551 |  | $31 |
Commercial real estate | 26,212 |  | 204 |  | 27 |  | 6 |  | 776 |  | 27,225 |  | 32 |
Total commercial | 68,459 |  | 239 |  | 47 |  | 14 |  | 1,017 |  | 69,776 |  | 63 |
Residential mortgages | 32,011 |  | 251 |  | 93 |  | 179 |  | 192 |  | 32,726 |  | 142 |
Home equity | 16,097 |  | 88 |  | 27 |  | — |  | 283 |  | 16,495 |  | 182 |
Automobile | 4,563 |  | 100 |  | 33 |  | — |  | 48 |  | 4,744 |  | 6 |
Education | 10,686 |  | 45 |  | 23 |  | 2 |  | 56 |  | 10,812 |  | 4 |
Other retail | 4,504 |  | 46 |  | 31 |  | 1 |  | 68 |  | 4,650 |  | 1 |
Total retail | 67,861 |  | 530 |  | 207 |  | 182 |  | 647 |  | 69,427 |  | 335 |
Total | $136,320 |  | $769 |  | $254 |  | $196 |  | $1,664 |  | $139,203 |  | $398 |
Guaranteed residential mortgages(1) | $696 |  | $119 |  | $55 |  | $172 |  | $— |  | $1,042 |  | $— |
(1) Guaranteed residential mortgages represent loans fully or partially guaranteed by the FHA, VA, and USDA, and are included in the amounts presented for Residential mortgages. At March 31, 2025 and December 31, 2024, the Company had collateral-dependent residential mortgage and home equity loans totaling $397 million and $372 million, respectively, and collateral-dependent commercial loans totaling $513 million and $607 million, respectively. The amortized cost basis of mortgage loans collateralized by residential real estate for which formal foreclosure proceedings were in-process was $302 million and $295 million as of March 31, 2025 and December 31, 2024, respectively. Loan Modifications to Borrowers Experiencing Financial Difficulty The Company offers loan modifications, characterized as FDMs, to retail and commercial borrowers experiencing financial difficulty as a result of its loss mitigation activities that may result in a payment delay, interest rate reduction, term extension, principal forgiveness, or combination thereof. Payment delays consist of modifications that result in a delay of contractual amounts due greater than three months over a rolling 12-month period. Term extensions consist of modifications that result in an extension of the contractual maturity date greater than three months or a significant deferral of principal payments relative to the total outstanding principal balance of the loan. Commercial loan modifications are offered on a case-by-case basis and generally include a payment delay, term extension and/or interest rate reduction. The Company does not typically offer principal forgiveness for commercial loans. Retail loan modifications are offered through structured loan modification programs, which are summarized below. •Forbearance programs provide borrowers experiencing some form of hardship a period of time during which their contractual payment obligations are suspended, resulting in a payment delay and/or term extension. •Other repayment plans are offered due to hardship and include an interest rate reduction and/or term extension designed to enable the borrower to return the loan to current status in an expeditious manner. •Settlement agreements may be executed with borrowers experiencing a long-term hardship or who are delinquent, resulting in principal forgiveness. Upon fulfillment of the terms of the settlement agreement, the unpaid principal amount is forgiven resulting in a charge-off of the outstanding principal balance. •Certain reorganization bankruptcy judgments may result in any one of the four modification types or some combination thereof. The following tables present the period-end amortized cost of loans to borrowers experiencing financial difficulty that were modified during the three months ended March 31, 2025 and 2024, disaggregated by class of financing receivable and modification type. The modification type reflects the cumulative effect of all FDMs received during the indicated period.
| Three Months Ended March 31, 2025
(dollars in millions) | Interest Rate Reduction | Term Extension | Payment Delay | Principal Forgiveness | Interest Rate Reduction and Term Extension |  |  | Term Extension and Payment Delay |  |  |  | Total | Total as a % of Loan Class(1)
Commercial and industrial | $32 |  | $141 |  | $2 |  | $— |  | $— |  |  |  | $1 |  |  |  |  | $176 |  | 0.40 | %
Commercial real estate | 10 |  | 172 |  | 73 |  | — |  | — |  |  |  | 25 |  |  |  |  | 280 |  | 1.05 |
Total commercial | 42 |  | 313 |  | 75 |  | — |  | — |  |  |  | 26 |  |  |  |  | 456 |  | 0.65 |
Residential mortgages | 1 |  | 15 |  | 2 |  | — |  | 4 |  |  |  | 1 |  |  |  |  | 23 |  | 0.07 |
Home equity | 1 |  | — |  | 2 |  | — |  | 1 |  |  |  | — |  |  |  |  | 4 |  | 0.02 |
Automobile | — |  | — |  | — |  | — |  | — |  |  |  | — |  |  |  |  | — |  | — |
Education | 2 |  | — |  | — |  | — |  | — |  |  |  | — |  |  |  |  | 2 |  | 0.02 |
Other retail | 6 |  | — |  | — |  | — |  | — |  |  |  | — |  |  |  |  | 6 |  | 0.14 |
Total retail | 10 |  | 15 |  | 4 |  | — |  | 5 |  |  |  | 1 |  |  |  |  | 35 |  | 0.05 |
Total | $52 |  | $328 |  | $79 |  | $— |  | $5 |  |  |  | $27 |  |  |  |  | $491 |  | 0.36 | %
| Three Months Ended March 31, 2024
(dollars in millions) | Interest Rate Reduction | Term Extension | Payment Delay | Principal Forgiveness | Interest Rate Reduction and Term Extension |  |  | Term Extension and Payment Delay |  |  |  | Total | Total as a % of Loan Class(1)
Commercial and industrial | $— |  | $85 |  | $65 |  | $— |  | $1 |  |  |  | $32 |  |  |  |  | $183 |  | 0.42 | %
Commercial real estate | — |  | 443 |  | 24 |  | — |  | 40 |  |  |  | 1 |  |  |  |  | 508 |  | 1.76 |
Total commercial | — |  | 528 |  | 89 |  | — |  | 41 |  |  |  | 33 |  |  |  |  | 691 |  | 0.95 |
Residential mortgages | 1 |  | 37 |  | 5 |  | — |  | 3 |  |  |  | — |  |  |  |  | 46 |  | 0.15 |
Home equity | 1 |  | 1 |  | — |  | — |  | 4 |  |  |  | — |  |  |  |  | 6 |  | 0.04 |
Automobile | — |  | — |  | — |  | — |  | — |  |  |  | — |  |  |  |  | — |  | — |
Education | 3 |  | — |  | 18 |  | — |  | — |  |  |  | — |  |  |  |  | 21 |  | 0.18 |
Other retail | 5 |  | — |  | — |  | — |  | — |  |  |  | — |  |  |  |  | 5 |  | 0.10 |
Total retail | 10 |  | 38 |  | 23 |  | — |  | 7 |  |  |  | — |  |  |  |  | 78 |  | 0.11 |
Total | $10 |  | $566 |  | $112 |  | $— |  | $48 |  |  |  | $33 |  |  |  |  | $769 |  | 0.54 | %
(1) Represents the total amortized cost as of period-end divided by the period-end amortized cost of the corresponding loan class. Accrued interest receivable is excluded from amortized cost and is immaterial. The following tables present the financial effect of loans to borrowers experiencing financial difficulty that were modified during the three months ended March 31, 2025 and 2024, disaggregated by class of financing receivable.
| Three Months Ended March 31, 2025
(dollars in millions) | Weighted-Average Interest Rate Reduction(1) | Weighted-Average Term Extension (in Months)(1) | Weighted-Average Payment Deferral(1) | Amount of Principal Forgiven(2)
Commercial and industrial | 0.81 | % | 10 | $— |  | $— |
Commercial real estate | 0.75 |  | 10 | 1 |  | — |
Residential mortgages | 0.98 |  | 111 | — |  | — |
Home equity | 4.55 |  | 74 | — |  | — |
Automobile | — |  | — |  | — |  | — |
Education | 4.96 |  | — |  | — |  | — |
Other retail | 20.30 |  | — |  | — |  | 2 |
| Three Months Ended March 31, 2024
(dollars in millions) | Weighted-Average Interest Rate Reduction(1) | Weighted-Average Term Extension (in Months)(1) | Weighted-Average Payment Deferral(1) | Amount of Principal Forgiven(2)
Commercial and industrial | 4.49 | % | 9 | $1 |  | $— |
Commercial real estate | 0.53 |  | 16 | 1 |  | — |
Residential mortgages | 2.01 |  | 88 | — |  | — |
Home equity | 3.16 |  | 88 | — |  | — |
Automobile | — |  | — |  | — |  | — |
Education | 4.31 |  | — |  | — |  | — |
Other retail | 19.80 |  | — |  | — |  | 2 |
(1) Weighted based on period-end amortized cost. (2) Amounts are recorded as charge-offs. The following tables present an aging analysis of the period-end amortized cost of loans to borrowers experiencing financial difficulty that were modified during the twelve month period ending March 31, 2025 and 2024, disaggregated by class of financing receivable. A loan in a forbearance or repayment plan is reported as past due according to its contractual terms until contractually modified. Subsequent to modification, it is reported as past due based on its restructured terms.
| March 31, 2025
|  | Days Past Due and Accruing |  |
(dollars in millions) | Current | 30-59 | 60-89 | 90+ | Nonaccrual | Total
Commercial and industrial | $311 |  | $17 |  | $— |  | $3 |  | $51 |  | $382 |
Commercial real estate | 380 |  | 33 |  | — |  | — |  | 385 |  | 798 |
Total commercial | 691 |  | 50 |  | — |  | 3 |  | 436 |  | 1,180 |
Residential mortgages | 51 |  | 4 |  | 3 |  | 17 |  | 19 |  | 94 |
Home equity | 9 |  | — |  | 1 |  | — |  | 12 |  | 22 |
Automobile | — |  | — |  | — |  | — |  | — |  | — |
Education | 8 |  | — |  | — |  | — |  | 1 |  | 9 |
Other retail | 13 |  | 2 |  | 1 |  | — |  | 1 |  | 17 |
Total retail | 81 |  | 6 |  | 5 |  | 17 |  | 33 |  | 142 |
Total | $772 |  | $56 |  | $5 |  | $20 |  | $469 |  | $1,322 |
| March 31, 2024
|  | Days Past Due and Accruing |  |
(dollars in millions) | Current | 30-59 | 60-89 | 90+ | Nonaccrual | Total
Commercial and industrial | $223 |  | $1 |  | $5 |  | $— |  | $144 |  | $373 |
Commercial real estate | 667 |  | 38 |  | 5 |  | 33 |  | 136 |  | 879 |
Total commercial | 890 |  | 39 |  | 10 |  | 33 |  | 280 |  | 1,252 |
Residential mortgages | 71 |  | 17 |  | — |  | 22 |  | 15 |  | 125 |
Home equity | 5 |  | — |  | — |  | — |  | 10 |  | 15 |
Automobile | — |  | — |  | — |  | — |  | — |  | — |
Education | 51 |  | 1 |  | — |  | — |  | 6 |  | 58 |
Other retail | 10 |  | 1 |  | 1 |  | — |  | 1 |  | 13 |
Total retail | 137 |  | 19 |  | 1 |  | 22 |  | 32 |  | 211 |
Total | $1,027 |  | $58 |  | $11 |  | $55 |  | $312 |  | $1,463 |
The following tables present the period-end amortized cost of loans to borrowers experiencing financial difficulty that defaulted during the period presented and were modified within the previous 12 months preceding the default, disaggregated by class of financing receivable and modification type. The modification type reflects the cumulative effect of all FDMs at the time of default. A loan is considered to be in default if, subsequent to modification, it becomes 90 or more days past due or is placed on nonaccrual status.
| Three Months Ended March 31, 2025
(dollars in millions) | Interest Rate Reduction | Term Extension | Payment Delay |  | Interest Rate Reduction and Term Extension |  |  |  |  |  |  | Total
Commercial and industrial | $— |  | $— |  | $— |  |  | $— |  |  |  |  |  |  |  | $— |
Commercial real estate | — |  | 71 |  | — |  |  | — |  |  |  |  |  |  |  | 71 |
Total commercial | — |  | 71 |  | — |  |  | — |  |  |  |  |  |  |  | 71 |
Residential mortgages | — |  | 5 |  | 1 |  |  | 2 |  |  |  |  |  |  |  | 8 |
Home equity | 1 |  | — |  | — |  |  | 1 |  |  |  |  |  |  |  | 2 |
Automobile | — |  | — |  | — |  |  | — |  |  |  |  |  |  |  | — |
Education | — |  | — |  | — |  |  | — |  |  |  |  |  |  |  | — |
Other retail | 1 |  | — |  | — |  |  | — |  |  |  |  |  |  |  | 1 |
Total retail | 2 |  | 5 |  | 1 |  |  | 3 |  |  |  |  |  |  |  | 11 |
Total | $2 |  | $76 |  | $1 |  |  | $3 |  |  |  |  |  |  |  | $82 |
| Three Months Ended March 31, 2024
(dollars in millions) | Interest Rate Reduction | Term Extension | Payment Delay |  | Interest Rate Reduction and Term Extension |  |  |  |  |  |  | Total
Commercial and industrial | $— |  | $34 |  | $— |  |  | $— |  |  |  |  |  |  |  | $34 |
Commercial real estate | — |  | 38 |  | — |  |  | — |  |  |  |  |  |  |  | 38 |
Total commercial | — |  | 72 |  | — |  |  | — |  |  |  |  |  |  |  | 72 |
Residential mortgages | — |  | 6 |  | — |  |  | — |  |  |  |  |  |  |  | 6 |
Home equity | — |  | — |  | — |  |  | — |  |  |  |  |  |  |  | — |
Automobile | — |  | — |  | — |  |  | — |  |  |  |  |  |  |  | — |
Education | 2 |  | — |  | — |  |  | — |  |  |  |  |  |  |  | 2 |
Other retail | — |  | — |  | — |  |  | — |  |  |  |  |  |  |  | — |
Total retail | 2 |  | 6 |  | — |  |  | — |  |  |  |  |  |  |  | 8 |
Total | $2 |  | $78 |  | $— |  |  | $— |  |  |  |  |  |  |  | $80 |
Unfunded commitments related to loans modified during the three months ended March 31, 2025 were $157 million at March 31, 2025. Unfunded commitments related to loans modified during the year ended December 31, 2024 were $206 million at December 31, 2024.

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