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Asset Quality | 3 Months Ended
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Mar. 31, 2021
Credit Loss [Abstract] |
Asset Quality | 4. Asset Quality ALLL We estimate the appropriate level of the ALLL on at least a quarterly basis. The methodology is described in Note 1 ("Summary of Significant Accounting Policies") under the heading "Allowance for Loan and Lease Losses" beginning on page 110 of our 2020 Form 10-K. The ALLL at March 31, 2021, represents our current estimate of lifetime credit losses inherent in the loan portfolio at that date. The changes in the ALLL by loan category for the periods indicated are as follows: Three months ended March 31, 2021:
in millions | December 31, 2020 | Provision |  | Charge-offs | Recoveries | March 31, 2021
Commercial and Industrial | $ | 678 |  | $ | (17) |  |  | $ | (73) |  | $ | 8 |  | $ | 596 |
Commercial real estate: |  |  |  |  |  |
Real estate — commercial mortgage | 327 |  | (37) |  |  | (35) |  | 1 |  | 256 |
Real estate — construction | 47 |  | (2) |  |  | — |  | — |  | 45 |
Total commercial real estate loans | 374 |  | (39) |  |  | (35) |  | 1 |  | 301 |
Commercial lease financing | 47 |  | (4) |  |  | (4) |  | 1 |  | 40 |
Total commercial loans | 1,099 |  | (60) |  |  | (112) |  | 10 |  | 937 |
Real estate — residential mortgage | 102 |  | (3) |  |  | — |  | 1 |  | 100 |
Home equity loans | 171 |  | (13) |  |  | (2) |  | 1 |  | 157 |
Consumer direct loans | 128 |  | 4 |  |  | (8) |  | 2 |  | 126 |
Credit cards | 87 |  | (3) |  |  | (6) |  | 2 |  | 80 |
Consumer indirect loans | 39 |  | 1 |  |  | (7) |  | 5 |  | 38 |
Total consumer loans | 527 |  | (14) |  |  | (23) |  | 11 |  | 501 |
Total ALLL — continuing operations | 1,626 |  | (74) |  | (a) | (135) |  | 21 |  | 1,438 |
Discontinued operations | 36 |  | (3) |  |  | (1) |  | 1 |  | 33 |
Total ALLL — including discontinued operations | $ | 1,662 |  | $ | (77) |  |  | $ | (136) |  | $ | 22 |  | $ | 1,471 |
(a)Excludes a credit for losses on lending-related commitments of $19 million. Three months ended March 31, 2020:
in millions | Pre-ASC 326 Adoption December 31, 2019 | Impact of ASC 326 Adoption | January 1, 2020 | Provision |  | Charge-offs | Recoveries | March 31, 2020
Commercial and Industrial | $ | 551 |  | $ | (141) |  | $ | 410 |  | $ | 187 |  |  | $ | (60) |  | $ | 5 |  | $ | 542 |
Commercial real estate: |  |  |  |  |  |  |  |
Real estate — commercial mortgage | 143 |  | 16 |  | 159 |  | 50 |  |  | (3) |  | 1 |  | 207 |
Real estate — construction | 22 |  | (7) |  | 15 |  | 10 |  |  | — |  | — |  | 25 |
Total commercial real estate loans | 165 |  | 9 |  | 174 |  | 60 |  |  | (3) |  | 1 |  | 232 |
Commercial lease financing | 35 |  | 8 |  | 43 |  | 3 |  |  | (2) |  | — |  | 44 |
Total commercial loans | 751 |  | (124) |  | 627 |  | 250 |  |  | (65) |  | 6 |  | 818 |
Real estate — residential mortgage | 7 |  | 77 |  | 84 |  | 5 |  |  | — |  | — |  | 89 |
Home equity loans | 31 |  | 147 |  | 178 |  | 8 |  |  | (4) |  | 2 |  | 184 |
Consumer direct loans | 34 |  | 63 |  | 97 |  | 29 |  |  | (12) |  | 2 |  | 116 |
Credit cards | 47 |  | 35 |  | 82 |  | 31 |  |  | (11) |  | 2 |  | 104 |
Consumer indirect loans | 30 |  | 6 |  | 36 |  | 16 |  |  | (9) |  | 5 |  | 48 |
Total consumer loans | 149 |  | 328 |  | 477 |  | 89 |  |  | (36) |  | 11 |  | 541 |
Total ALLL — continuing operations | 900 |  | 204 |  | 1,104 |  | 339 |  | (a) | (101) |  | 17 |  | 1,359 |
Discontinued operations | 10 |  | 31 |  | 41 |  | 3 |  |  | (2) |  | 1 |  | 43 |
Total ALLL — including discontinued operations | $ | 910 |  | $ | 235 |  | $ | 1,145 |  | $ | 342 |  |  | $ | (103) |  | $ | 18 |  | $ | 1,402 |
(a)Excludes a provision for losses on lending-related commitments of $20 million. As described in Note 1 ("Summary of Significant Accounting Policies"), under the heading “Allowance for Loan and Lease Losses” beginning on page 110 of our 2020 Form 10-K, we estimate the ALLL using relevant available information, from internal and external sources, relating to past events, current conditions, and reasonable and supportable forecasts. In our estimation of expected credit losses, we use a two year reasonable and supportable period across all products. Following this two year period in which supportable forecasts can be generated, for all modeled loan portfolios, we revert expected credit losses to a level that is consistent with our historical information by reverting the macroeconomic variables (model inputs) to their long run average. We revert to historical loss rates for less complex estimation methods for smaller portfolios. A 20 year fixed length look back period is used to calculate the long run average of the macroeconomic variables. A four quarter reversion period is used where the macroeconomic variables linearly revert to their long run average following the two year reasonable and supportable period. We develop our reasonable and supportable forecasts using relevant data including, but not limited to, changes in economic output, unemployment rates, property values, and other factors associated with the credit losses on financial assets. Some macroeconomic variables apply to all portfolio segments, while others are more portfolio specific. The following table discloses key macroeconomic variables for each loan portfolio.
Segment | Portfolio | Key Macroeconomic Variables (a)
Commercial | Commercial and industrial | BBB corporate bond rate (spread), GDP, industrial production, and unemployment rate
Commercial real estate | BBB corporate bond rate (spread), property and real estate price indices, and unemployment rate
Commercial lease financing | BBB corporate bond rate (spread), GDP, and unemployment rate
Consumer | Real estate — residential mortgage | GDP, home price index, unemployment rate, and 30 year mortgage rate
Home equity | Home price index, unemployment rate, and 30 year mortgage rate
Consumer direct | Unemployment rate and U.S. household income
Consumer indirect | New vehicle sales and unemployment rate
Credit cards | Unemployment rate and U.S. household income
Discontinued operations | Unemployment rate
(a)Variables include all transformations and interactions with other risk drivers. Additionally, variables may have varying impacts at different points in the economic cycle. In addition to macroeconomic drivers, portfolio attributes such as remaining term, outstanding balance, risk ratings, FICO, LTV, and delinquency also drive ALLL changes. Our ALLL models were designed to capture the correlation between economic and portfolio changes. As such, evaluating shifts in individual portfolio attributes and macroeconomic variables in isolation may not be indicative of past or future performance. Economic Outlook As of March 31, 2021, the COVID-19 pandemic has continued to create unprecedented economic uncertainty in the U.S. and globally. We utilized the Moody’s February 2021 Consensus forecast to estimate our expected credit losses as of March 31, 2021. We determined such forecast to be a reasonable view of the outlook for the economy given all available information at quarter end. The baseline scenario reflects modest economic growth over the next two years in markets in which we operate. U.S. GDP continues to rebound with a projected 3.3% annualized growth rate in the first quarter of 2021 and continues to accelerate during the year, which is anticipated to return to pre-pandemic levels by the fourth quarter of 2021 and an overall growth rate of approximately 5% expected for the year. The national unemployment rate forecast is 6.3% in the first quarter of 2021, and expected to decline to 5.4% by the fourth quarter of 2021. To the extent we identified credit risk considerations that were not captured by the third-party economic forecast, we addressed the risk through management’s qualitative adjustments to the ALLL. As a result of the unprecedented economic uncertainty caused by the COVID-19 pandemic, our future loss estimates may vary considerably from our March 31, 2021 assumptions. Commercial Loan Portfolio The ALLL from continuing operations for the commercial segment decreased by $162 million, or 14.7%, from December 31, 2020. The overall decrease in the allowance is driven by improvements in economic forecasts, a slight decline in loan balances, and improving asset quality. The changes to the economic forecast primarily reflect improvements in economic drivers used in our models. The unemployment and GDP positive growth outlook contributes to the overall commercial segment reserve decrease. Expected improvements in real estate price indices lead to a reduction in reserve in our commercial real estate book. Risk rating migrations are driving a modest increase in ALLL levels for the commercial and industrial portfolio. The ALLL results also reflect incremental credit risk considerations as a result of the future economic uncertainties which are addressed through qualitative adjustments. As of March 31, 2021, we concluded that no ALLL is necessary for $6.5 billion in outstanding PPP loans as they are 100% guaranteed by the SBA. Consumer Loan Portfolio The ALLL from continuing operations for the consumer segment decreased by $26 million, or 4.9%, from December 31, 2020. The overall decrease in the allowance is driven by updated economic forecasts that capture an im proving outlook for several drivers and strong portfolio performance. The most meaningful changes to the economic forecast contributing to the reduction in reserves include improvement in the unemployment rate outlook, which impacts all consumer portfolios. In addition, the housing market and HPI outlook continue to display strength, which impacts the residential mortgage and home equity segments. As it relates to the decline in the ALLL due to portfolio factors, shifts are largely driven by attrition activity, targeted portfolio growth and overall strong credit drivers. The ALLL results also reflect incremental credit risk considerations as a result of the economic stress and related borrower assistance programs, which are addressed through qualitative adjustments. Credit Risk Profile The prevalent risk characteristic for both commercial and consumer loans is the risk of loss arising from an obligor’s inability or failure to meet contractual payment or performance terms. Evaluation of this risk is stratified and monitored by the loan risk rating grades assigned for the commercial loan portfolios and the refreshed FICO score assigned for the consumer loan portfolios. The internal risk grades assigned to loans follow our definitions of Pass and Criticized, which are consistent with published definitions of regulatory risk classifications. Loans with a pass rating represent those loans not classified on our rating scale for problem credits, as minimal credit risk has been identified. Criticized loans are those loans that either have a potential weakness deserving management's close attention or have a well-defined weakness that may put full collection of contractual cash flows at risk. Borrower FICO scores provide information about the credit quality of our consumer loan portfolio as they provide an indication as to the likelihood that a debtor will repay its debts. The scores are obtained from a nationally recognized consumer rating agency and are presented in the tables below at the dates indicated. Most extensions of credit are subject to loan grading or scoring. Loan grades are assigned at the time of origination, verified by credit risk management, and periodically re-evaluated thereafter. This risk rating methodology blends our judgment with quantitative modeling. Commercial loans generally are assigned two internal risk ratings. The first rating reflects the probability that the borrower will default on an obligation; the second rating reflects expected recovery rates on the credit facility. Default probability is determined based on, among other factors, the financial strength of the borrower, an assessment of the borrower’s management, the borrower’s competitive position within its industry sector, and our view of industry risk in the context of the general economic outlook. Types of exposure, transaction structure, and collateral, including credit risk mitigants, affect the expected recovery assessment. Commercial Credit Exposure Credit Risk Profile by Creditworthiness Category and Vintage (a)
As of March 31, 2021 | Term Loans | Revolving Loans Amortized Cost Basis | Revolving Loans Converted to Term Loans Amortized Cost Basis |
| Amortized Cost Basis by Origination Year and Internal Risk Rating |
in millions | 2021 | 2020 | 2019 | 2018 | 2017 | Prior | Total
Commercial and Industrial |  |  |  |  |  |  |  |  |
Risk Rating: |  |  |  |  |  |  |  |  |
Pass | $ | 2,246 |  | $ | 11,524 |  | $ | 5,062 |  | $ | 3,728 |  | $ | 2,360 |  | $ | 5,560 |  | $ | 18,992 |  | $ | 81 |  | $ | 49,553 |
Criticized (Accruing) | 4 |  | 96 |  | 220 |  | 217 |  | 223 |  | 340 |  | 1,426 |  | 20 |  | 2,546 |
Criticized (Nonaccruing) | — |  | 8 |  | 19 |  | 64 |  | 13 |  | 54 |  | 227 |  | 2 |  | 387 |
Total commercial and industrial | 2,250 |  | 11,628 |  | 5,301 |  | 4,009 |  | 2,596 |  | 5,954 |  | 20,645 |  | 103 |  | 52,486 |
Real estate — commercial mortgage |  |  |  |  |  |  |  |  |
Risk Rating: |  |  |  |  |  |  |  |  |
Pass | 602 |  | 1,603 |  | 2,916 |  | 1,599 |  | 819 |  | 3,589 |  | 695 |  | 29 |  | 11,852 |
Criticized (Accruing) | — |  | 14 |  | 123 |  | 103 |  | 159 |  | 290 |  | 93 |  | 2 |  | 784 |
Criticized (Nonaccruing) | — |  | — |  | 2 |  | 4 |  | 4 |  | 51 |  | 5 |  | — |  | 66 |
Total real estate — commercial mortgage | 602 |  | 1,617 |  | 3,041 |  | 1,706 |  | 982 |  | 3,930 |  | 793 |  | 31 |  | 12,702 |
Real estate — construction |  |  |  |  |  |  |  |  |
Risk Rating: |  |  |  |  |  |  |  |  |
Pass | 16 |  | 451 |  | 798 |  | 501 |  | 187 |  | 49 |  | 31 |  | — |  | 2,033 |
Criticized (Accruing) | — |  | 4 |  | 14 |  | 51 |  | 18 |  | 1 |  | 1 |  | — |  | 89 |
Criticized (Nonaccruing) | — |  | — |  | — |  | — |  | — |  | — |  | — |  | — |  | — |
Total real estate — construction | 16 |  | 455 |  | 812 |  | 552 |  | 205 |  | 50 |  | 32 |  | — |  | 2,122 |
Commercial lease financing |  |  |  |  |  |  |  |  |
Risk Rating: |  |  |  |  |  |  |  |  |
Pass | 152 |  | 952 |  | 931 |  | 462 |  | 416 |  | 1,077 |  | — |  | — |  | 3,990 |
Criticized (Accruing) | — |  | 21 |  | 35 |  | 15 |  | 26 |  | 9 |  | — |  | — |  | 106 |
Criticized (Nonaccruing) | — |  | — |  | 2 |  | 2 |  | 2 |  | 2 |  | — |  | — |  | 8 |
Total commercial lease financing | 152 |  | 973 |  | 968 |  | 479 |  | 444 |  | 1,088 |  |  | — |  | 4,104 |
Total commercial loans | $ | 3,020 |  | $ | 14,673 |  | $ | 10,122 |  | $ | 6,746 |  | $ | 4,227 |  | $ | 11,022 |  | $ | 21,470 |  | $ | 134 |  | $ | 71,414 |
As of December 31, 2020 | Term Loans | Revolving Loans Amortized Cost Basis | Revolving Loans Converted to Term Loans Amortized Cost Basis |  |
| Amortized Cost Basis by Origination Year and Internal Risk Rating |  |
in millions | 2020 | 2019 | 2018 | 2017 | 2016 | Prior | Total |
Commercial and Industrial |  |  |  |  |  |  |  |  |  |
Risk Rating: |  |  |  |  |  |  |  |  |  |
Pass | $ | 13,100 |  | $ | 5,487 |  | $ | 4,040 |  | $ | 2,617 |  | $ | 1,967 |  | $ | 2,709 |  | $ | 19,832 |  | $ | 118 |  | $ | 49,870 |  |
Criticized (Accruing) | 66 |  | 198 |  | 174 |  | 236 |  | 150 |  | 279 |  | 1,527 |  | 22 |  | 2,652 |  |
Criticized (Nonaccruing) | 8 |  | 27 |  | 71 |  | 28 |  | 17 |  | 7 |  | 226 |  | 1 |  | 385 |  |
Total commercial and industrial | 13,174 |  | 5,712 |  | 4,285 |  | 2,881 |  | 2,134 |  | 2,995 |  | 21,585 |  | 141 |  | 52,907 |  |
Real estate — commercial mortgage |  |  |  |  |  |  |  |  |  |
Risk Rating: |  |  |  |  |  |  |  |  |  |
Pass | 1,591 |  | 2,937 |  | 1,737 |  | 867 |  | 765 |  | 3,027 |  | 885 |  | 43 |  | 11,852 |  |
Criticized (Accruing) | 12 |  | 142 |  | 81 |  | 145 |  | 72 |  | 255 |  | 22 |  | 2 |  | 731 |  |
Criticized (Nonaccruing) | — |  | 1 |  | 4 |  | 4 |  | 2 |  | 88 |  | 5 |  | — |  | 104 |  |
Total real estate — commercial mortgage | 1,603 |  | 3,080 |  | 1,822 |  | 1,016 |  | 839 |  | 3,370 |  | 912 |  | 45 |  | 12,687 |  |
Real estate — construction |  |  |  |  |  |  |  |  |  |
Risk Rating: |  |  |  |  |  |  |  |  |  |
Pass | 367 |  | 764 |  | 510 |  | 188 |  | 27 |  | 22 |  | 31 |  | 5 |  | 1,914 |  |
Criticized (Accruing) | — |  | 14 |  | 38 |  | 18 |  | — |  | 2 |  | 1 |  | — |  | 73 |  |
Criticized (Nonaccruing) | — |  | — |  | — |  | — |  | — |  | — |  | — |  | — |  | — |  |
Total real estate — construction | 367 |  | 778 |  | 548 |  | 206 |  | 27 |  | 24 |  | 32 |  | 5 |  | 1,987 |  |
Commercial lease financing |  |  |  |  |  |  |  |  |  |
Risk Rating: |  |  |  |  |  |  |  |  |  |
Pass | 1,076 |  | 1,050 |  | 534 |  | 504 |  | 228 |  | 901 |  | — |  | — |  | 4,293 |  |
Criticized (Accruing) | 10 |  | 35 |  | 15 |  | 26 |  | 7 |  | 4 |  | — |  | — |  | 97 |  |
Criticized (Nonaccruing) | — |  | 2 |  | 2 |  | 2 |  | 2 |  | 1 |  | — |  | — |  | 9 |  |
Total commercial lease financing | 1,086 |  | 1,087 |  | 551 |  | 532 |  | 237 |  | 906 |  | 0 | — |  | 4,399 |  |
Total commercial loans | $ | 16,230 |  | $ | 10,657 |  | $ | 7,206 |  | $ | 4,635 |  | $ | 3,237 |  | $ | 7,295 |  | $ | 22,529 |  | $ | 191 |  | $ | 71,980 |  |
(a)Accrued interest of $143 million and $140 million as of March 31, 2021 and December 31, 2020, respectively, presented in Other Assets on the Consolidated Balance Sheets, was excluded from the amortized cost basis disclosed in these tables. Consumer Credit Exposure Credit Risk Profile by FICO Score and Vintage (a)
As of March 31, 2021 | Term Loans | Revolving Loans Amortized Cost Basis | Revolving Loans Converted to Term Loans Amortized Cost Basis |
| Amortized Cost Basis by Origination Year and FICO Score |
in millions | 2021 | 2020 | 2019 | 2018 | 2017 | Prior | Total
Real estate — residential mortgage |  |  |  |  |  |  |  |  |
FICO Score: |  |  |  |  |  |  |  |  |
750 and above | $ | 1,684 |  | $ | 3,503 |  | $ | 1,326 |  | $ | 159 |  | $ | 213 |  | $ | 1,525 |  | — |  | — |  | $ | 8,410 |
660 to 749 | 300 |  | 534 |  | 245 |  | 63 |  | 40 |  | 384 |  | — |  | — |  | 1,566 |
Less than 660 | 2 |  | 19 |  | 17 |  | 20 |  | 9 |  | 172 |  | — |  | — |  | 239 |
No Score | 1 |  | 1 |  | 2 |  | 2 |  | 6 |  | 73 |  | — |  | — |  | 85 |
Total real estate — residential mortgage | 1,987 |  | 4,057 |  | 1,590 |  | 244 |  | 268 |  | 2,154 |  | — |  | — |  | 10,300 |
Home equity loans |  |  |  |  |  |  |  |  |
FICO Score: |  |  |  |  |  |  |  |  |
750 and above | 407 |  | 943 |  | 367 |  | 151 |  | 182 |  | 926 |  | $ | 2,544 |  | $ | 551 |  | 6,071 |
660 to 749 | 121 |  | 386 |  | 172 |  | 65 |  | 63 |  | 280 |  | 1,132 |  | 186 |  | 2,405 |
Less than 660 | 7 |  | 27 |  | 24 |  | 17 |  | 17 |  | 121 |  | 400 |  | 56 |  | 669 |
No Score | — |  | 2 |  | 2 |  | 1 |  | — |  | 2 |  | 5 |  | 1 |  | 13 |
Total home equity loans | 535 |  | 1,358 |  | 565 |  | 234 |  | 262 |  | 1,329 |  | 4,081 |  | 794 |  | 9,158 |
Consumer direct loans |  |  |  |  |  |  |  |  |
FICO Score: |  |  |  |  |  |  |  |  |
750 and above | 499 |  | 1,636 |  | 759 |  | 103 |  | 29 |  | 102 |  | 110 |  | — |  | 3,238 |
660 to 749 | 120 |  | 421 |  | 233 |  | 67 |  | 17 |  | 48 |  | 231 |  | 1 |  | 1,138 |
Less than 660 | 4 |  | 21 |  | 31 |  | 19 |  | 6 |  | 14 |  | 71 |  | — |  | 166 |
No Score | 10 |  | 47 |  | 37 |  | 18 |  | 14 |  | 20 |  | 174 |  | — |  | 320 |
Total consumer direct loans | 633 |  | 2,125 |  | 1,060 |  | 207 |  | 66 |  | 184 |  | 586 |  | 1 |  | 4,862 |
Credit cards |  |  |  |  |  |  |  |  |
FICO Score: |  |  |  |  |  |  |  |  |
750 and above | — |  | — |  | — |  | — |  | — |  | — |  | 441 |  | — |  | 441 |
660 to 749 | — |  | — |  | — |  | — |  | — |  | — |  | 379 |  | — |  | 379 |
Less than 660 | — |  | — |  | — |  | — |  | — |  | — |  | 88 |  | — |  | 88 |
No Score | — |  | — |  | — |  | — |  | — |  | — |  | 1 |  | — |  | 1 |
Total credit cards | — |  | — |  | — |  | — |  | — |  | — |  | 909 |  | — |  | 909 |
Consumer indirect loans |  |  |  |  |  |  |  |  |
FICO Score: |  |  |  |  |  |  |  |  |
750 and above | 135 |  | 880 |  | 851 |  | 329 |  | 158 |  | 105 |  | — |  | — |  | 2,458 |
660 to 749 | — |  | 566 |  | 483 |  | 193 |  | 79 |  | 68 |  | — |  | — |  | 1,389 |
Less than 660 | — |  | 124 |  | 140 |  | 85 |  | 44 |  | 42 |  | — |  | — |  | 435 |
No Score | — |  | — |  | — |  | — |  | — |  | 1 |  | — |  | — |  | 1 |
Total consumer indirect loans | 135 |  | 1,570 |  | 1,474 |  | 607 |  | 281 |  | 216 |  | — |  | — |  | 4,283 |
Total consumer loans | $ | 3,290 |  | $ | 9,110 |  | $ | 4,689 |  | $ | 1,292 |  | $ | 877 |  | $ | 3,883 |  | $ | 5,576 |  | $ | 795 |  | $ | 29,512 |
As of December 31, 2020 | Term Loans | Revolving Loans Amortized Cost Basis | Revolving Loans Converted to Term Loans Amortized Cost Basis |
| Amortized Cost Basis by Origination Year and FICO Score |
in millions | 2020 | 2019 | 2018 | 2017 | 2016 | Prior | Total
Real estate — residential mortgage |  |  |  |  |  |  |  |  |
FICO Score: |  |  |  |  |  |  |  |  |
750 and above | $ | 3,595 |  | $ | 1,620 |  | $ | 194 |  | $ | 254 |  | $ | 537 |  | $ | 1,211 |  | — |  | — |  | $ | 7,411 |
660 to 749 | 710 |  | 284 |  | 76 |  | 48 |  | 100 |  | 332 |  | — |  | — |  | 1,550 |
Less than 660 | 16 |  | 28 |  | 21 |  | 10 |  | 26 |  | 170 |  | — |  | — |  | 271 |
No Score | 1 |  | 2 |  | 2 |  | 7 |  | 2 |  | 52 |  | — |  | — |  | 66 |
Total real estate — residential mortgage | 4,322 |  | 1,934 |  | 293 |  | 319 |  | 665 |  | 1,765 |  | — |  | — |  | 9,298 |
Home equity loans |  |  |  |  |  |  |  |  |
FICO Score: |  |  |  |  |  |  |  |  |
750 and above | 1,043 |  | 404 |  | 168 |  | 202 |  | 190 |  | 839 |  | $ | 2,689 |  | $ | 590 |  | 6,125 |
660 to 749 | 385 |  | 198 |  | 82 |  | 77 |  | 69 |  | 253 |  | 1,237 |  | 206 |  | 2,507 |
Less than 660 | 27 |  | 30 |  | 18 |  | 20 |  | 20 |  | 113 |  | 426 |  | 61 |  | 715 |
No Score | 2 |  | 2 |  | 1 |  | — |  | — |  | 2 |  | 5 |  | 1 |  | 13 |
Total home equity loans | 1,457 |  | 634 |  | 269 |  | 299 |  | 279 |  | 1,207 |  | 4,357 |  | 858 |  | 9,360 |
Consumer direct loans |  |  |  |  |  |  |  |  |
FICO Score: |  |  |  |  |  |  |  |  |
750 and above | 1,840 |  | 883 |  | 115 |  | 32 |  | 16 |  | 57 |  | 119 |  | — |  | 3,062 |
660 to 749 | 479 |  | 268 |  | 80 |  | 22 |  | 14 |  | 33 |  | 254 |  | 1 |  | 1,151 |
Less than 660 | 23 |  | 37 |  | 21 |  | 8 |  | 5 |  | 10 |  | 81 |  | — |  | 185 |
No Score | 65 |  | 35 |  | 21 |  | 21 |  | 10 |  | 11 |  | 153 |  | — |  | 316 |
Total consumer direct loans | 2,407 |  | 1,223 |  | 237 |  | 83 |  | 45 |  | 111 |  | 607 |  | 1 |  | 4,714 |
Credit cards |  |  |  |  |  |  |  |  |
FICO Score: |  |  |  |  |  |  |  |  |
750 and above | — |  | — |  | — |  | — |  | — |  | — |  | 488 |  | — |  | 488 |
660 to 749 | — |  | — |  | — |  | — |  | — |  | — |  | 407 |  | — |  | 407 |
Less than 660 | — |  | — |  | — |  | — |  | — |  | — |  | 93 |  | — |  | 93 |
No Score | — |  | — |  | — |  | — |  | — |  | — |  | 1 |  | — |  | 1 |
Total credit cards | — |  | — |  | — |  | — |  | — |  | — |  | 989 |  | — |  | 989 |
Consumer indirect loans |  |  |  |  |  |  |  |  |
FICO Score: |  |  |  |  |  |  |  |  |
750 and above | 1,092 |  | 924 |  | 369 |  | 188 |  | 69 |  | 66 |  | — |  | — |  | 2,708 |
660 to 749 | 653 |  | 558 |  | 232 |  | 97 |  | 36 |  | 47 |  | — |  | — |  | 1,623 |
Less than 660 | 143 |  | 163 |  | 99 |  | 54 |  | 25 |  | 28 |  | — |  | — |  | 512 |
No Score | 1 |  | — |  | — |  | — |  | — |  | — |  | — |  | — |  | 1 |
Total consumer indirect loans | 1,889 |  | 1,645 |  | 700 |  | 339 |  | 130 |  | 141 |  | — |  | — |  | 4,844 |
Total consumer loans | $ | 10,075 |  | $ | 5,436 |  | $ | 1,499 |  | $ | 1,040 |  | $ | 1,119 |  | $ | 3,224 |  | $ | 5,953 |  | $ | 859 |  | $ | 29,205 |
(a)Accrued interest of $98 million and $101 million as of March 31, 2021 and December 31, 2020, respectively, presented in Other Assets on the Consolidated Balance Sheets, was excluded from the amortized cost basis disclosed in this table. Nonperforming and Past Due Loans Our policies for determining past due loans, placing loans on nonaccrual, applying payments on nonaccrual loans, and resuming accrual of interest for our commercial and consumer loan portfolios are disclosed in Note 1 (“Summary of Significant Accounting Policies”) under the heading “Nonperforming Loans” beginning on page 108 of our 2020 Form 10-K. Under the CARES Act as well as banking regulator interagency guidance, certain loan modifications to borrowers experiencing financial distress as a result of the economic impacts created by the COVID-19 pandemic may not be required to be reported as past due. For COVID-19 related loan modifications which occurred from March 1, 2020, through March 31, 2021, and met the loan modification criteria under either the CARES Act or the criteria specified by the regulatory agencies, we have elected to re-age to current status all commercial loans and consumer loans that are not secured by real-estate and freeze the delinquency status of consumer real estate secured loans as of the modification or forbearance grant date. At March 31, 2021, th e portfolio loans and leases in active deferral or forebearance as part of our COVID-19 hardship relief programs totaled $384 million, of which $328 million of loan modifications and forbearances made under the criteria of either the CARES Act, banking regulator interagency guidance, or short-term forbearance policies were not reported as nonperforming. The following aging analysis of past due and current loans as of March 31, 2021, and December 31, 2020, provides further information regarding Key’s credit exposure. Aging Analysis of Loan Portfolio(a)
March 31, 2021 | Current | 30-59 Days Past Due (b) | 60-89 Days Past Due (b) | 90 and Greater Days Past Due (b) | Non-performing Loans | Total Past Due and Non-performing Loans | Total Loans (c)
in millions
LOAN TYPE |  |  |  |  |  |  |
Commercial and industrial | $ | 52,000 |  | $ | 42 |  | $ | 16 |  | $ | 41 |  | $ | 387 |  | $ | 486 |  | $ | 52,486 |
Commercial real estate: |  |  |  |  |  |  |
Commercial mortgage | 12,580 |  | 17 |  | 14 |  | 25 |  | 66 |  | 122 |  | 12,702 |
Construction | 2,113 |  | 8 |  | 1 |  | — |  | — |  | 9 |  | 2,122 |
Total commercial real estate loans | 14,693 |  | 25 |  | 15 |  | 25 |  | 66 |  | 131 |  | 14,824 |
Commercial lease financing | 4,088 |  | 7 |  | 1 |  | — |  | 8 |  | 16 |  | 4,104 |
Total commercial loans | $ | 70,781 |  | $ | 74 |  | $ | 32 |  | $ | 66 |  | $ | 461 |  | $ | 633 |  | $ | 71,414 |
Real estate — residential mortgage | $ | 10,190 |  | $ | 9 |  | $ | 4 |  | $ | 2 |  | $ | 95 |  | $ | 110 |  | $ | 10,300 |
Home equity loans | 8,958 |  | 31 |  | 11 |  | 10 |  | 148 |  | 200 |  | 9,158 |
Consumer direct loans | 4,844 |  | 4 |  | 4 |  | 5 |  | 5 |  | 18 |  | 4,862 |
Credit cards | 892 |  | 4 |  | 3 |  | 7 |  | 3 |  | 17 |  | 909 |
Consumer indirect loans | 4,250 |  | 12 |  | 3 |  | 2 |  | 16 |  | 33 |  | 4,283 |
Total consumer loans | $ | 29,134 |  | $ | 60 |  | $ | 25 |  | $ | 26 |  | $ | 267 |  | $ | 378 |  | $ | 29,512 |
Total loans | $ | 99,915 |  | $ | 134 |  | $ | 57 |  | $ | 92 |  | $ | 728 |  | $ | 1,011 |  | $ | 100,926 |
(a)Amounts in table represent amortized cost and exclude loans held for sale. (b)Accrued interest of $242 million presented in Other Assets on the Consolidated Balance Sheets is excluded from the amortized cost basis disclosed in this table. (c)Net of unearned income, net of deferred fees and costs, and unamortized discounts and premiums.
December 31, 2020 | Current | 30-59 Days Past Due (b) | 60-89 Days Past Due (b) | 90 and Greater Days Past Due (b) | Non-performing Loans | Total Past Due and Non-performing Loans |  | Total Loans (c)
in millions
LOAN TYPE |  |  |  |  |  |  |  |
Commercial and industrial | $ | 52,396 |  | $ | 36 |  | $ | 50 |  | $ | 40 |  | $ | 385 |  | $ | 511 |  |  | $ | 52,907 |
Commercial real estate: |  |  |  |  |  |  |  |
Commercial mortgage | 12,548 |  | 9 |  | 5 |  | 21 |  | 104 |  | 139 |  |  | 12,687 |
Construction | 1,986 |  | — |  | — |  | 1 |  | — |  | 1 |  |  | 1,987 |
Total commercial real estate loans | 14,534 |  | 9 |  | 5 |  | 22 |  | 104 |  | 140 |  |  | 14,674 |
Commercial lease financing | 4,369 |  | 21 |  | 1 |  | — |  | 8 |  | 30 |  |  | 4,399 |
Total commercial loans | $ | 71,299 |  | $ | 66 |  | $ | 56 |  | $ | 62 |  | $ | 497 |  | $ | 681 |  |  | $ | 71,980 |
Real estate — residential mortgage | $ | 9,173 |  | $ | 11 |  | $ | 3 |  | $ | 1 |  | $ | 110 |  | $ | 125 |  |  | $ | 9,298 |
Home equity loans | 9,143 |  | 34 |  | 20 |  | 9 |  | 154 |  | 217 |  |  | 9,360 |
Consumer direct loans | 4,694 |  | 7 |  | 4 |  | 4 |  | 5 |  | 20 |  |  | 4,714 |
Credit cards | 972 |  | 5 |  | 3 |  | 7 |  | 2 |  | 17 |  |  | 989 |
Consumer indirect loans | 4,792 |  | 25 |  | 7 |  | 3 |  | 17 |  | 52 |  |  | 4,844 |
Total consumer loans | $ | 28,774 |  | $ | 82 |  | $ | 37 |  | $ | 24 |  | $ | 288 |  | $ | 431 |  |  | $ | 29,205 |
Total loans | $ | 100,073 |  | $ | 148 |  | $ | 93 |  | $ | 86 |  | $ | 785 |  | $ | 1,112 |  |  | $ | 101,185 |
(a)Amounts in table represent amortized cost and exclude loans held for sale. (b)Accrued interest of $241 million presented in Other Assets on the Consolidated Balance Sheets is excluded from the amortized cost basis disclosed in this table. (c)Net of unearned income, net of deferred fees and costs, and unamortized discounts and premiums. At March 31, 2021, the approximate carrying amount of our commercial nonperforming loans outstanding represented 68% of their original contractual amount owed, total nonperforming loans outstanding represented 75% of their original contractual amount owed, and nonperforming assets in total were carried at 81% of their original contractual amount owed. Nonperforming loans reduced expected interest income by $7 million for the three months ended March 31, 2021, and $6 million for the three months ended March 31, 2020. The amortized cost basis of nonperforming loans on nonaccrual status for which there is no related allowance for credit losses was $461 million at March 31, 2021. Collateral-dependent Financial Assets We classify financial assets as collateral-dependent when our borrower is experiencing financial difficulty, and we expect repayment to be provided substantially through the operation or sale of the collateral. Our commercial loans have collateral that includes commercial machinery, commercial properties, and commercial real estate construction projects. Our consumer loans have collateral that includes residential real estate, automobiles, boats, and RVs. There were no significant changes in the extent to which collateral secures our collateral-dependent financial assets during the three months ended March 31, 2021. TDRs We classify loan modifications as TDRs when a borrower is experiencing financial difficulties and we have granted a concession without commensurate financial, structural, or legal consideration. Our loan modifications are handled on a case-by-case basis and are negotiated to achieve mutually agreeable terms that maximize loan collectability and meet the borrower’s financial needs. Under the CARES Act as well as banking regulator interagency guidance, certain loan modifications to borrowers experiencing financial distress as a result of the economic impacts created by the COVID-19 pandemic may not be required to be treated as TDRs under U.S. GAAP. We elected to suspend TDR accounting for $328 million of COVID-19 related loan modifications as of March 31, 2021 as such loan modifications met the criteria under either the CARES Act or banking regulator interagency guidance. Commitments outstanding to lend additional funds to borrowers whose loan terms have been modified in TDRs were $14 million and $1 million at March 31, 2021, and December 31, 2020, respectively. The consumer TDR other concession category in the table below primarily includes those borrowers’ debts that are discharged through Chapter 7 bankruptcy and have not been formally re-affirmed. At March 31, 2021, and December 31, 2020, the recorded investment of consumer residential mortgage loans in the process of foreclosure was approxima tely $83 million and $92 million, respectively. The following table shows the post-modification outstanding recorded investment by concession type for our commercial and consumer accruing and nonaccruing TDRs that occurred during the periods indicated:
| Three Months Ended March 31, |  |
in millions | 2021 | 2020 |  |  |
Commercial loans: |  |  |  |  |
Extension of Maturity Date | 41 |  | $ | — |  |  |  |
Payment or Covenant Modification/Deferment | 10 |  | — |  |  |  |
Total | 51 |  | $ | — |  |  |  |
Consumer loans: |  |  |  |  |
Interest rate reduction | $ | 2 |  | $ | 9 |  |  |  |
Other | 4 |  | 9 |  |  |  |
Total | $ | 6 |  | $ | 18 |  |  |  |
Total TDRs | $ | 57 |  | $ | 18 |  |  |  |
The following table summarizes the change in the post-modification outstanding recorded investment of our accruing and nonaccruing TDRs during the periods indicated:
| Three Months Ended March 31, |
in millions | 2021 | 2020 |  |
Balance at beginning of the period | $ | 363 |  | $ | 347 |  |  |
Additions | 59 |  | 17 |  |  |
Payments | (21) |  | (18) |  |  |
Charge-offs | (25) |  | (6) |  |  |
Balance at end of period | $ | 376 |  | $ | 340 |  |  |
A further breakdown of TDRs included in nonperforming loans by loan category for the periods indicated are as follows:
| March 31, 2021 |  | December 31, 2020
| Number of Loans | Pre-modification Outstanding Recorded Investment | Post-modification Outstanding Recorded Investment |  | Number of Loans | Pre-modification Outstanding Recorded Investment | Post-modification Outstanding Recorded Investment
dollars in millions
LOAN TYPE |  |  |  |  |  |  |
Nonperforming: |  |  |  |  |  |  |
Commercial and industrial | 57 |  | $ | 128 |  | $ | 87 |  |  | 66 |  | $ | 136 |  | $ | 92 |
Commercial real estate: |  |  |  |  |  |  |
Commercial mortgage | 5 |  | 62 |  | 34 |  |  | 7 |  | 62 |  | 50 |
Total commercial real estate loans | 5 |  | 62 |  | 34 |  |  | 7 |  | 62 |  | 50 |
Total commercial loans | 62 |  | 190 |  | 121 |  |  | 73 |  | 198 |  | 142 |
Real estate — residential mortgage | 206 |  | 25 |  | 24 |  |  | 258 |  | 35 |  | 34 |
Home equity loans | 564 |  | 35 |  | 32 |  |  | 630 |  | 41 |  | 37 |
Consumer direct loans | 203 |  | 4 |  | 3 |  |  | 212 |  | 3 |  | 3 |
Credit cards | 265 |  | 2 |  | 2 |  |  | 356 |  | 2 |  | 2 |
Consumer indirect loans | 776 |  | 14 |  | 10 |  |  | 861 |  | 15 |  | 11 |
Total consumer loans | 2,014 |  | 80 |  | 71 |  |  | 2,317 |  | 96 |  | 87 |
Total nonperforming TDRs | 2,076 |  | 270 |  | 192 |  |  | 2,390 |  | 294 |  | 229 |
Prior-year accruing:(a) |  |  |  |  |  |  |
Commercial and industrial | 12 |  | 43 |  | 41 |  |  | 3 |  | 5 |  | — |
Commercial real estate |  |  |  |  |  |  |
Commercial mortgage | — |  | — |  | — |  |  | — |  | — |  | — |
Total commercial real estate loans | — |  | — |  | — |  |  | — |  | — |  | — |
Total commercial loans | 12 |  | 43 |  | 41 |  |  | 3 |  | 5 |  | — |
Real estate — residential mortgage | 513 |  | 44 |  | 39 |  |  | 485 |  | 37 |  | 31 |
Home equity loans | 1,779 |  | 107 |  | 84 |  |  | 1,781 |  | 106 |  | 83 |
Consumer direct loans | 202 |  | 5 |  | 3 |  |  | 163 |  | 4 |  | 3 |
Credit cards | 638 |  | 4 |  | 2 |  |  | 536 |  | 3 |  | 1 |
Consumer indirect loans | 787 |  | 28 |  | 15 |  |  | 775 |  | 29 |  | 16 |
Total consumer loans | 3,919 |  | 188 |  | 143 |  |  | 3,740 |  | 179 |  | 134 |
Total prior-year accruing TDRs | 3,931 |  | 231 |  | 184 |  |  | 3,743 |  | 184 |  | 134 |
Total TDRs | 6,007 |  | $ | 501 |  | $ | 376 |  |  | 6,133 |  | $ | 478 |  | $ | 363 |
(a)All TDRs that were restructured prior to January 1, 2021, and January 1, 2020, and are fully accruing. Commercial loan TDRs are considered defaulted when principal and interest payments are 90 days past due. Consumer loan TDRs are considered defaulted when principal and interest payments are more than 60 days past due. During the three months ended March 31, 2021, there were two commercial loan TDRs and 36 consumer loan TDRs with a combined recorded investment of $1 million that experienced payment defaults after modifications resulting in TDR status during 2020. During the three months ended March 31, 2020, there were no commercial loan TDRs and 84 consumer loan TDRs with a combined recorded investment of $2 million that experienced payment defaults after modifications resulting in TDR status during 2019. Liability for Credit Losses on Off Balance Sheet Exposures The liability for credit losses inherent in unfunded lending-related commitments, such as letters of credit and unfunded loan commitments, and certain financial guarantees is included in “accrued expense and other liabilities” on the balance sheet. Changes in the liability for credit losses on off balance sheet exposures are summarized as follows:
| Three months ended March 31, |
in millions | 2021 | 2020 |  |
Balance at the end of the prior period | $ | 197 |  | $ | 68 |  |  |
Liability for credit losses on contingent guarantees at the end of the prior period | — |  | 7 |  |  |
Cumulative effect from change in accounting principle (a), (b) | — |  | 66 |  |  |
Balance at beginning of period | 197 |  | 141 |  |  |
Provision (credit) for losses on off balance sheet exposures | (19) |  | 20 |  |  |
Balance at end of period | $ | 178 |  | $ | 161 |  |  |
(a)The cumulative effect from change in accounting principle relates to the January 1, 2020, adoption of ASU 2016-13. (b)The three months ended March 31, 2020, amount exclud es $4 million related to the provision for other financial assets.

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