Loans and Allowance for Credit Losses

3 Months Ended

Mar. 31, 2022

Loans and leases, net of unearned income

Loans and leases, net of unearned income are summarized as follows:


	March 31, 2022		December 31, 2021
	(in thousands)
Real estate - commercial mortgage	$	7,289,376	$	7,279,080
Commercial and industrial (1)	4,156,981		4,208,327
Real-estate - residential mortgage	3,946,741		3,846,750
Real-estate - home equity	1,098,171		1,118,248
Real-estate - construction	1,210,340		1,139,779
Consumer	481,551		464,657
Equipment lease financing and other	310,884		283,557
Overdrafts	1,928		1,988
Gross loans	18,495,972		18,342,386
Unearned income	(19,853)		(17,036)
Net loans	$	18,476,119	$	18,325,350

(1) Includes PPP loans totaling $0.2 billion and $0.3 billion as of March 31, 2022 and December 31, 2021, respectively.

The Corporation segments its loan portfolio by "portfolio segments," as presented in the table above. Certain portfolio segments are further disaggregated by "class segment" for the purpose of estimating credit losses.

Allowance for Credit Losses

The ACL related to loans consists of loans evaluated collectively and individually for expected credit losses. The ACL related to loans represents an estimate of expected credit losses over the expected life of the loans as of the balance sheet date and is recorded as a reduction to net loans. The ACL for OBS credit exposure includes estimated losses on unfunded loan commitments, letters of credit and other OBS credit exposures and is recorded in other liabilities. The total ACL is increased by charges to expense, through the provision for credit losses, and decreased by charge-offs, net of recoveries.

The following table presents the components of the ACL:



	March 31, 2022		December 31, 2021
	(in thousands)
ACL - loans	$	243,705	$	249,001
ACL - OBS credit exposure	13,933		14,533
Total ACL	$	257,638	$	263,534

The following table presents the activity in the ACL:


	Three months ended March 31
	2022		2021
	(in thousands)
Balance at beginning of period	$	263,534	$	291,940
Loans charged off	(1,900)		(8,202)
Recoveries of loans previously charged off	2,954		2,021
Net loans (charged-off) recovered	1,054		(6,181)
Provision for credit losses (1)	(6,950)		(5,500)
Balance at end of period(2)	$	257,638	$	280,259

(1) Includes $(0.6) million and $(0.1) million related to OBS credit exposures for the three months ended March 31, 2022 and 2021, respectively.

(2) Includes $13.9 million and $14.3 million of reserves for OBS credit exposures as of March 31, 2022 and 2021 respectively.

The following table presents the activity in the ACL by portfolio segment:


	Real Estate Commercial Mortgage		Commercial and Industrial		Consumer and Real Estate Home Equity		Real Estate Residential Mortgage		Real Estate Construction		Equipment lease financing, other and overdrafts		Total
	(in thousands)
Three months ended March 31, 2022
Balance at December 31, 2021	$	87,970	$	67,056	$	19,749	$	54,236	$	12,941	$	7,049	$	249,001
Loans charged off	(152)		(227)		(1,052)		—		—		(469)		(1,900)
Recoveries of loans previously charged off	112		1,980		454		222		32		154		2,954
Net loans recovered (charged off)	(40)		1,753		(598)		222		32		(315)		1,054
Provision for loan losses (1)	(8,077)		(2,298)		1,062		1,434		330		1,199		(6,350)
Balance at March 31, 2022	$	79,853	$	66,511	$	20,213	$	55,892	$	13,303	$	7,933	$	243,705
Three months ended March 31, 2021
Balance at December 31, 2020	$	103,425	$	74,771	$	25,137	$	51,995	$	15,608	$	6,633	$	277,567
Loans charged off	(1,837)		(4,319)		(847)		(192)		(39)		(968)		(8,202)
Recoveries of loans previously charged off	174		769		440		95		384		159		2,021
Net loans recovered (charged off)	(1,663)		(3,550)		(407)		(97)		345		(809)		(6,181)
Provision for loan and lease losses (1)	(786)		(27)		(1,588)		(1,903)		(874)		(222)		(5,400)
Balance at March 31, 2021	$	100,976	$	71,194	$	23,142	$	49,995	$	15,079	$	5,602	$	265,986

(1) Provision included in the table only includes the portion related to Net loans.

The ACL includes qualitative adjustments, as appropriate, intended to capture the impact of uncertainties not reflected in the quantitative models. Qualitative adjustments include and consider changes in national, regional and local economic and business conditions, an assessment of the lending environment, including underwriting standards and other factors affecting credit quality.

The impact from qualitative adjustments on the ACL decreased in the first quarter of 2022 due to the improvement in economic conditions.

Several factors as of the end of the first quarter of 2021 in comparison to the end of the fourth quarter of 2020, including improved economic forecasts and a decrease in specific allocations within the ACL for loans evaluated individually, reduced the level of the ACL determined to be necessary as of March 31, 2021.

Non-accrual Loans

All loans individually evaluated for impairment are measured for losses on a quarterly basis. As of March 31, 2022 and December 31, 2021, substantially all of the Corporation’s individually evaluated loans with total commitments greater than or equal to $1.0 million were measured based on the estimated fair value of each loan’s collateral, if any. Collateral could be in the form of real estate, in the case of commercial mortgages and construction loans, or business assets, such as accounts receivable

or inventory, in the case of commercial and industrial loans. Commercial and industrial loans may also be secured by real estate.

As of March 31, 2022 and December 31, 2021, approximately 86% and 98%, respectively, of loans evaluated individually for impairment with principal balances greater than or equal to $1.0 million, whose primary collateral consisted of real estate, were measured at estimated fair value using appraisals performed by state certified third-party appraisers that had been updated in the preceding 12 months.

The following table presents total non-accrual loans, by class segment:


	March 31, 2022						December 31, 2021
	With a Related Allowance		Without a Related Allowance		Total		With a Related Allowance		Without a Related Allowance		Total
	(in thousands)
Real estate - commercial mortgage	$	18,681	$	31,719	$	50,400	$	20,564	$	32,251	$	52,815
Commercial and industrial	12,390		16,100		28,490		12,571		17,570		30,141
Real estate - residential mortgage	31,626		2,294		33,920		35,269		—		35,269
Real estate - home equity	8,145		—		8,145		8,671		—		8,671
Real estate - construction	—		672		672		173		728		901
Consumer	175		—		175		229		—		229
Equipment lease financing and other	5,742		9,255		14,997		6,247		9,393		15,640
	$	76,759	$	60,040	$	136,799	$	83,724	$	59,942	$	143,666

As of March 31, 2022 and December 31, 2021, there were $60.0 million and $59.9 million, respectively, of non-accrual loans that did not have a related allowance for credit losses. The estimated fair values of the collateral securing these loans exceeded their carrying amount, or the loans were previously charged down to realizable collateral values. Accordingly, no specific valuation allowance was considered to be necessary.

Asset Quality

Maintaining an appropriate ACL is dependent on various factors, including the ability to identify potential problem loans in a timely manner. For commercial construction, residential construction, commercial and industrial, and commercial real estate, an internal risk rating process is used. The Corporation believes that internal risk ratings are the most relevant credit quality indicator for these types of loans. The migration of loans through the various internal risk rating categories is a significant component of the ACL methodology for these loans, which bases the probability of default on this migration. Assigning risk ratings involves judgment. The Corporation's loan review officers provide a separate assessment of risk rating accuracy. Risk ratings may be changed based on the ongoing monitoring procedures performed by loan officers or credit administration staff or if specific loan review assessments identify a deterioration or an improvement in the loans.

The following table summarizes designated internal risk rating categories by portfolio segment and loan class, by origination year, in the current period:


		March 31, 2022
		Term Loans Amortized Cost Basis by Origination Year												Revolving Loans		Revolving Loans converted to Term Loans
		(dollars in thousands)												Amortized		Amortized
		2022		2021		2020		2019		2018		Prior		Cost Basis		Cost Basis		Total
Real estate - construction(1)
	Pass	$	12,911	$	242,122	$	392,540	$	95,074	$	59,362	$	129,036	$	32,603	$	—	$	963,648
	Special Mention	—		5,974		767		9,984		—		19,082		—		—		35,807
	Substandard or Lower	—		—		—		—		—		4,549		220		—		4,769
	Total real estate - construction	12,911		248,096		393,307		105,058		59,362		152,667		32,823		—		1,004,224
Real estate - construction(1)
	Current period gross charge-offs	—		—		—		—		—		—		—		—		—
	Current period recoveries	—		—		—		—		—		—		—		32		32
	Total net (charge-offs) recoveries	—		—		—		—		—		—		—		32		32
Commercial and industrial(2)
	Pass	245,683		619,816		466,917		347,857		212,978		704,570		1,232,653		529		3,831,003
	Special Mention	572		18,295		9,196		12,782		8,526		32,872		66,765		—		149,008
	Substandard or Lower	—		953		10,906		37,999		23,750		44,527		58,753		82		176,970
	Total commercial and industrial	246,255		639,064		487,019		398,638		245,254		781,969		1,358,171		611		4,156,981
Commercial and industrial
	Current period gross charge-offs	—		—		(36)		—		(21)		—		(130)		(40)		(227)
	Current period recoveries	—		—		30		95		379		416		493		567		1,980
	Total net (charge-offs) recoveries	—		—		(6)		95		358		416		363		527		1,753
Real estate - commercial mortgage
	Pass	188,756		1,070,853		863,498		823,168		636,889		2,955,373		65,078		—		6,603,615
	Special Mention	96		8,993		65,964		75,021		35,108		177,894		1,387		—		364,463
	Substandard or Lower	—		1,523		8,424		37,366		70,413		201,563		521		1,488		321,298
	Total real estate - commercial mortgage	188,852		1,081,369		937,886		935,555		742,410		3,334,830		66,986		1,488		7,289,376
Real estate - commercial mortgage
	Current period gross charge-offs	—		—		—		—		—		—		—		(152)		(152)
	Current period recoveries	—		—		—		—		—		4		—		108		112
	Total net (charge-offs) recoveries	—		—		—		—		—		4		—		(44)		(40)
Total
	Pass	$	447,350	$	1,932,791	$	1,722,955	$	1,266,099	$	909,229	$	3,788,979	$	1,330,334	$	529	$	11,398,266
	Special Mention	668		33,262		75,927		97,787		43,634		229,848		68,152		—		549,278
	Substandard or Lower	—		2,476		19,330		75,365		94,163		250,639		59,494		1,570		503,037
	Total	$	448,018	$	1,968,529	$	1,818,212	$	1,439,251	$	1,047,026	$	4,269,466	$	1,457,980	$	2,099	$	12,450,581

(1) Excludes real estate - construction - other.

(2) Loans originated in 2021 and 2020 include $0.2 billion of PPP loans that were assigned a rating of Pass based on the existence of a federal government guaranty through the SBA.

The following table summarizes designated internal risk rating categories by portfolio segment and loan class, by origination year, in the prior period:


		December 31, 2021
		Term Loans Amortized Cost Basis by Origination Year												Revolving Loans		Revolving Loans converted to Term Loans
		(dollars in thousands)												Amortized		Amortized
		2021		2020		2019		2018		2017		Prior		Cost Basis		Cost Basis		Total
Real estate - construction(1)
	Pass	$	190,030	$	315,811	$	113,245	$	83,886	$	17,545	$	117,157	$	46,409	$	—	$	884,083
	Special Mention	5,843		775		9,984		20,200		15,724		6,315		—		—		58,841
	Substandard or Lower	—		—		—		—		1,912		4,185		227		—		6,324
	Total real estate - construction	195,873		316,586		123,229		104,086		35,181		127,657		46,636		—		949,248
Real estate - construction(1)
	Current period gross charge-offs	—		—		(39)		—		—		—		—		—		(39)
	Current period recoveries	—		—		39		—		—		1,373		—		—		1,412
	Total net (charge-offs) recoveries	—		—		—		—		—		1,373		—		—		1,373
Commercial and industrial(2)
	Pass	855,924		520,802		396,575		232,805		147,675		581,762		1,177,857		339		3,913,739
	Special Mention	5,386		8,538		33,937		8,301		10,346		23,380		52,386		95		142,369
	Substandard or Lower	1,225		9,775		19,393		24,327		11,912		34,825		49,562		1,200		152,219
	Total commercial and industrial	862,535		539,115		449,905		265,433		169,933		639,967		1,279,805		1,634		4,208,327
Commercial and industrial
	Current period gross charge-offs	(2,977)		(406)		(4,966)		(208)		(286)		(800)		(5,694)		—		(15,337)
	Current period recoveries	6		39		4,691		841		457		2,342		1,211		—		9,587
	Total net (charge-offs) recoveries	(2,971)		(367)		(275)		633		171		1,542		(4,483)		—		(5,750)
Real estate - commercial mortgage
	Pass	1,086,113		899,172		826,866		624,653		712,223		2,356,308		55,370		—		6,560,705
	Special Mention	1,317		60,732		96,508		25,280		33,595		169,732		115		—		387,279
	Substandard or Lower	1,537		8,516		28,810		68,818		69,793		151,450		684		1,488		331,096
	Total real estate - commercial mortgage	1,088,967		968,420		952,184		718,751		815,611		2,677,490		56,169		1,488		7,279,080
Real estate - commercial mortgage
	Current period gross charge-offs	—		—		(14)		(25)		(6,972)		(1,517)		(198)		—		(8,726)
	Current period recoveries	—		—		—		—		983		1,491		—		—		2,474
	Total net (charge-offs) recoveries	—		—		(14)		(25)		(5,989)		(26)		(198)		—		(6,252)
Total
	Pass	$	2,132,067	$	1,735,785	$	1,336,686	$	941,344	$	877,443	$	3,055,227	$	1,279,636	$	339	$	11,358,527
	Special Mention	12,546		70,045		140,429		53,781		59,665		199,427		52,501		95		588,489
	Substandard or Lower	2,762		18,291		48,203		93,145		83,617		190,460		50,473		2,688		489,639
	Total	$	2,147,375	$	1,824,121	$	1,525,318	$	1,088,270	$	1,020,725	$	3,445,114	$	1,382,610	$	3,122	$	12,436,655

(1) Excludes real estate - construction - other.

(2) Loans originated in 2021 and 2020 include $0.3 billion of PPP loans that were assigned a rating of Pass based on the existence of a federal government guaranty through the SBA.

The Corporation considers the performance of the loan portfolio and its impact on the ACL. The Corporation does not assign internal risk ratings to smaller balance, homogeneous loans, such as home equity, residential mortgage, construction loans to individuals secured by residential real estate, consumer and equipment lease financing. For these loans, the most relevant credit quality indicator is delinquency status and the Corporation evaluates credit quality based on the aging status of the loan. The following tables present the amortized cost of these loans based on payment activity, by origination year, for the periods shown:


		March 31, 2022
		Term Loans Amortized Cost Basis by Origination Year												Revolving Loans		Revolving Loans converted to Term Loans
		(dollars in thousands)												Amortized		Amortized
		2022		2021		2020		2019		2018		Prior		Cost Basis		Cost Basis		Total
Consumer and real estate - home equity
	Performing	$	53,362	$	145,950	$	96,504	$	68,114	$	61,230	$	158,366	$	965,477	$	19,237	$	1,568,240
	Nonperforming	—		150		118		59		75		2,096		8,969		15		11,482
	Total consumer and real estate - home equity	53,362		146,100		96,622		68,173		61,305		160,462		974,446		19,252		1,579,722
Consumer and real estate - home equity
	Current period gross charge-offs	—		(587)		(70)		(108)		(16)		(205)		(66)		—		(1,052)
	Current period recoveries	—		42		72		29		16		169		126		—		454
	Total net (charge-offs) recoveries	—		(545)		2		(79)		—		(36)		60		—		(598)
Real estate - residential mortgage
	Performing	202,665		1,581,675		1,089,264		319,209		96,585		617,755		—		—		3,907,153
	Nonperforming	—		801		6,229		2,408		3,710		26,440		—		—		39,588
	Total real estate - residential mortgage	202,665		1,582,476		1,095,493		321,617		100,295		644,195		—		—		3,946,741
Real estate - residential mortgage
	Current period gross charge-offs	—		—		—		—		—		—		—		—		—
	Current period recoveries	—		—		4		—		27		191		—		—		222
	Total net (charge-offs) recoveries	—		—		4		—		27		191		—		—		222
Equipment lease financing and other
	Performing	95,224		53,218		55,272		41,466		28,155		24,324		—		—		297,659
	Nonperforming	—		—		—		—		—		15,153		—		—		15,153
	Total leasing and other	95,224		53,218		55,272		41,466		28,155		39,477		—		—		312,812
Equipment lease financing and other
	Current period gross charge-offs	—		—		—		—		—		(469)		—		—		(469)
	Current period recoveries	—		1		20		5		3		125		—		—		154
	Total net (charge-offs) recoveries	—		1		20		5		3		(344)		—		—		(315)
Construction - other
	Performing	18,085		154,762		27,874		—		5,028		—		367		—		206,116
	Nonperforming	—		—		—		—		—		—		—		—		—
	Total construction - other	18,085		154,762		27,874		—		5,028		—		367		—		206,116




Total
	Performing	$	369,336	$	1,935,605	$	1,268,914	$	428,789	$	190,998	$	800,445	$	965,844	$	19,237	$	5,979,168
	Nonperforming	—		951		6,347		2,467		3,785		43,689		8,969		15		66,223
	Total	$	369,336	$	1,936,556	$	1,275,261	$	431,256	$	194,783	$	844,134	$	974,813	$	19,252	$	6,045,391


		December 31, 2021
		Term Loans Amortized Cost Basis by Origination Year												Revolving Loans		Revolving Loans converted to Term Loans
		(dollars in thousands)												Amortized		Amortized
		2021		2020		2019		2018		2017		Prior		Cost Basis		Cost Basis		Total
Consumer and Real estate - home equity
	Performing	$	162,441	$	102,918	$	73,769	$	68,564	$	33,254	$	135,412	$	990,842	$	3,999	$	1,571,199
	Nonperforming	122		101		60		51		314		2,348		8,512		198		11,706
	Total consumer and real estate - home equity	162,563		103,019		73,829		68,615		33,568		137,760		999,354		4,197		1,582,905
Consumer and Real estate - home equity
	Current period gross charge-offs	(175)		(491)		(496)		(238)		(224)		(411)		(1,274)		—		(3,309)
	Current period recoveries	—		223		131		131		167		1,048		645		—		2,345
	Total net (charge-offs) recoveries	(175)		(268)		(365)		(107)		(57)		637		(629)		—		(964)
Real estate - residential mortgage
	Performing	1,548,174		1,133,602		344,625		113,801		198,164		468,842		—		—		3,807,208
	Nonperforming	—		6,753		2,189		3,424		2,844		24,332		—		—		39,542
	Total real estate - residential mortgage	1,548,174		1,140,355		346,814		117,225		201,008		493,174		—		—		3,846,750
Real estate - residential mortgage
	Current period gross charge-offs	—		(626)		(148)		(125)		(4)		(387)		—		—		(1,290)
	Current period recoveries	—		—		1		18		—		264		92		—		375
	Total net (charge-offs) recoveries	—		(626)		(147)		(107)		(4)		(123)		92		—		(915)
Equipment lease financing and other
	Performing	97,077		65,316		49,591		34,107		22,444		1,369		—		—		269,904
	Nonperforming	—		—		—		—		15,503		138		—		—		15,641
	Total leasing and other	97,077		65,316		49,591		34,107		37,947		1,507		—		—		285,545
Equipment lease financing and other
	Current period gross charge-offs	(975)		(1,276)		—		—		—		—		—		—		(2,251)
	Current period recoveries	255		539		88		10		18		43		—		—		953
	Total net (charge-offs) recoveries	(720)		(737)		88		10		18		43		—		—		(1,298)
Construction - other
	Performing	144,652		40,040		638		5,028		—		—		—		—		190,358
	Nonperforming	—		—		—		—		173		—		—		—		173
	Total construction - other	144,652		40,040		638		5,028		173		—		—		—		190,531




Total
	Performing	$	1,952,344	$	1,341,876	$	468,623	$	221,500	$	253,862	$	605,623	$	990,842	$	3,999	$	5,838,669
	Nonperforming	122		6,854		2,249		3,475		18,834		26,818		8,512		198		67,062
	Total	$	1,952,466	$	1,348,730	$	470,872	$	224,975	$	272,696	$	632,441	$	999,354	$	4,197	$	5,905,731

The following table presents non-performing assets:


	March 31, 2022		December 31, 2021
	(in thousands)
Non-accrual loans	$	136,799	$	143,666
Loans 90 days or more past due and still accruing	24,182		8,453
Total non-performing loans	160,981		152,119
OREO (1)	2,014		1,817
Total non-performing assets	$	162,995	$	153,936

(1) Excludes $4.7 million and $6.4 million of residential mortgage properties for which formal foreclosure proceedings were in process as of March 31, 2022 and December 31, 2021, respectively.

The following tables present the aging of the amortized cost basis of loans, by class segment:


	30-59		60-89		≥ 90 Days
	Days Past		Days Past		Past Due		Non-
	Due		Due		and Accruing		Accrual		Current		Total
	(in thousands)
March 31, 2022
Real estate – commercial mortgage	$	3,869	$	725	$	13,790	$	50,400	$	7,220,592	$	7,289,376
Commercial and industrial(1)	5,107		606		1,702		28,490		4,121,076		4,156,981
Real estate – residential mortgage	29,343		4,040		5,388		33,920		3,874,050		3,946,741
Real estate – home equity	4,326		727		2,729		8,145		1,082,244		1,098,171
Real estate – construction	1,139		—		—		672		1,208,529		1,210,340
Consumer	2,762		669		417		175		477,528		481,551
Equipment lease financing and other	261		—		156		14,997		277,545		292,959
Total	$	46,807	$	6,767	$	24,182	$	136,799	$	18,261,564	$	18,476,119

(1) Includes PPP loans totaling $0.2 billion as of March 31, 2022.


	30-59 Days Past Due		60-89 Days Past Due		≥ 90 Days Past Due and Accruing		Non- accrual		Current		Total
	(in thousands)
December 31, 2021
Real estate – commercial mortgage	$	1,089	$	1,750	$	1,229	$	52,815	$	7,222,197	$	7,279,080
Commercial and industrial(1)	5,457		1,932		488		30,141		4,170,309		4,208,327
Real estate – residential mortgage	22,957		2,920		4,130		35,269		3,781,474		3,846,750
Real estate – home equity	4,369		1,154		2,253		8,671		1,101,801		1,118,248
Real estate – construction	1,318		—		—		901		1,137,560		1,139,779
Consumer	3,561		876		353		229		459,638		464,657
Equipment lease financing and other	226		27		—		15,640		252,616		268,509
Total	$	38,977	$	8,659	$	8,453	$	143,666	$	18,125,595	$	18,325,350

(1) Includes PPP loans totaling $0.3 billion as of December 31, 2021.

Collateral-Dependent Loans

A loan is considered to be collateral-dependent when the debtor is experiencing financial difficulty and repayment is expected to be provided substantially through the sale or operation of the collateral. For all classes of loans deemed collateral-dependent, the Corporation elected the practical expedient to estimate expected credit losses based on the collateral’s fair value less cost to sell. In most cases, the Corporation records a partial charge-off to reduce the loan’s carrying value to the collateral’s fair value less cost to sell. Substantially all of the collateral supporting collateral-dependent financial assets consists of various types of

real estate, including residential properties, commercial properties, such as retail centers, office buildings, and lodging, agriculture land, and vacant land.

Troubled Debt Restructurings

Restructured loan modifications may include payment schedule modifications, interest rate concessions, bankruptcies, principal reduction or some combination of these concessions. The restructured loan modifications primarily included maturity date extensions, rate modifications and payment schedule modifications.

The following table presents TDRs, by class segment:


	March 31, 2022		December 31, 2021
	(in thousands)
Real estate - commercial mortgage	$	3,563	$	3,464
Commercial and industrial	1,903		1,857
Real estate - residential mortgage	11,700		11,948
Real estate - home equity	12,028		12,218

Consumer	2		5

Total accruing TDRs	29,196		29,492
Non-accrual TDRs (1)	52,125		55,945
Total TDRs	$	81,321	$	85,437

(1) Included in non-accrual loans in the preceding table detailing non-performing assets.

The following table presents TDRs, by class segment, for loans that were modified during the three months ended March 31, 2022 and 2021:


	Three months ended March 31
	2022			2021
	Number of Loans	Post-Modification Recorded Investment		Number of Loans	Post-Modification Recorded Investment
	(dollars in thousands)
Commercial and industrial	1	$	82	4	$	1,894
Real estate - commercial mortgage	1	150		2	4,162
Real estate - residential mortgage	4	293		23	7,626

Real estate - home equity	—	—		5	148
Real estate - construction	—	—		1	154
Consumer	5	329		—	—
Total	11	$	854	35	$	13,984

In accordance with regulatory guidance, payment schedule modifications granted after March 13, 2020 to borrowers impacted by the effects of the COVID-19 pandemic and who were not delinquent at the time of the payment schedule modifications have been excluded from TDRs. As of March 31, 2022, $13.1 million in recorded investment remains in active COVID-19 deferral programs.