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Loans Held for Investment (LHFI) and Allowance for Loan Losses, LHFI | 9 Months Ended
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Sep. 30, 2012
Loans Held for Investment (LHFI) and Allowance for Loan Losses, LHFI [Abstract] |
Loans and Allowance for Loan Losses |
Note 4 – | Loans Held for Investment (LHFI) and Allowance for Loan Losses, LHFI
For the periods presented, LHFI consisted of the following ($ in thousands):
|  | September 30, 2012 |  |  | December 31, 2011 |
Loans secured by real estate: |  |  |  |  |  |
Construction, land development and other land loans |  | $ | 460,599 |  |  | $ | 474,082 |
Secured by 1-4 family residential properties |  |  | 1,511,514 |  |  |  | 1,760,930 |
Secured by nonfarm, nonresidential properties |  |  | 1,397,536 |  |  |  | 1,425,774 |
Other |  |  | 184,804 |  |  |  | 204,849 |
Commercial and industrial loans |  |  | 1,163,681 |  |  |  | 1,139,365 |
Consumer loans |  |  | 181,896 |  |  |  | 243,756 |
Other loans |  |  | 627,933 |  |  |  | 608,728 |
LHFI |  |  | 5,527,963 |  |  |  | 5,857,484 |
Less allowance for loan losses, LHFI |  |  | 83,526 |  |  |  | 89,518 |
Net LHFI |  | $ | 5,444,437 |  |  | $ | 5,767,966 |
Loan Concentrations Trustmark does not have any loan concentrations other than those reflected in the preceding table, which exceed 10% of total LHFI. At September 30, 2012, Trustmark's geographic loan distribution was concentrated primarily in its four key market regions, Florida, Mississippi, Tennessee and Texas. A substantial portion of construction, land development and other land loans are secured by real estate in markets in which Trustmark is located. Accordingly, the ultimate collectability of a substantial portion of these loans and the recovery of a substantial portion of the carrying amount of other real estate, are susceptible to changes in market conditions in these areas. Nonaccrual/Impaired LHFI At September 30, 2012 and December 31, 2011, the carrying amounts of nonaccrual LHFI, which are individually evaluated for impairment analysis, were $80.7 million and $110.5 million, respectively. Of this total, all commercial nonaccrual LHFI over $500 thousand were specifically evaluated for impairment (specifically evaluated impaired LHFI) using a fair value approach. The remaining nonaccrual LHFI were not all specifically reviewed and written down to fair value less cost to sell. No material interest income was recognized in the income statement on nonaccrual LHFI for each of the periods ended September 30, 2012 and 2011. All of Trustmark's specifically evaluated impaired LHFI are collateral dependent loans. At September 30, 2012 and December 31, 2011, specifically evaluated impaired LHFI totaled $36.5 million and $68.9 million, respectively. In addition, these specifically evaluated impaired LHFI had a related allowance of $6.6 million and $8.8 million at the end of the respective periods. For collateral dependent loans, when a loan is deemed impaired, the full difference between the carrying amount of the loan and the most likely estimate of the asset's fair value less cost to sell is charged-off. Charge-offs related to specifically evaluated impaired LHFI totaled $11.0 million and $18.4 million for the first nine months of 2012 and 2011, respectively. No provision was recorded to net income for these loans for the first nine months of 2012, while provisions of $6.2 million were charged to net income for these loans for the first nine months of 2011. Fair value estimates for specifically evaluated impaired LHFI are derived from appraised values based on the current market /as is value of the property, normally from recently received and reviewed appraisals. If an appraisal with an inspection date within the past 12 months using the necessary assumptions is not in the file, a new appraisal is ordered. Appraisals are obtained from state-certified appraisers and are based on certain assumptions, which may include construction or development status and the highest and best use of the property. These appraisals are reviewed by the Appraisal Review Department to ensure they are acceptable, and values are adjusted down for costs associated with asset disposal. Once this estimated net realizable value has been determined, the value used in the impairment assessment is updated. At the time a specifically evaluated impaired LHFI is deemed to be impaired, the full difference between book value and the most likely estimate of the asset's net realizable value is charged off. As subsequent events dictate and estimated net realizable values decline, required reserves may be established or further adjustments recorded. At September 30, 2012 and December 31, 2011, nonaccrual LHFI not specifically reviewed for impairment and written down to fair value less cost to sell, totaled $44.2 million and $41.6 million, respectively. In addition, these nonaccrual LHFI had allocated allowance for loan losses of $7.1 million and $3.9 million at the end of the respective periods. The following table details LHFI individually and collectively evaluated for impairment at September 30, 2012 and December 31, 2011 ($ in thousands):
|  | September 30, 2012 |
|  | LHFI Evaluated for Impairment |
|  | Individually |  |  | Collectively |  |  | Total |
Loans secured by real estate: |  |  |  |  |  |  |  |  |
Construction, land development and other land loans |  | $ | 26,077 |  |  | $ | 434,522 |  |  | $ | 460,599 |
Secured by 1-4 family residential properties |  |  | 24,260 |  |  |  | 1,487,254 |  |  |  | 1,511,514 |
Secured by nonfarm, nonresidential properties |  |  | 18,873 |  |  |  | 1,378,663 |  |  |  | 1,397,536 |
Other |  |  | 3,900 |  |  |  | 180,904 |  |  |  | 184,804 |
Commercial and industrial loans |  |  | 6,215 |  |  |  | 1,157,466 |  |  |  | 1,163,681 |
Consumer loans |  |  | 411 |  |  |  | 181,485 |  |  |  | 181,896 |
Other loans |  |  | 922 |  |  |  | 627,011 |  |  |  | 627,933 |
Total |  | $ | 80,658 |  |  | $ | 5,447,305 |  |  | $ | 5,527,963 |
|  | December 31, 2011 |
|  | LHFI Evaluated for Impairment |
|  | Individually |  |  | Collectively |  |  | Total |
Loans secured by real estate: |  |  |  |  |  |  |  |  |
Construction, land development and other land loans |  | $ | 40,413 |  |  | $ | 433,669 |  |  | $ | 474,082 |
Secured by 1-4 family residential properties |  |  | 24,348 |  |  |  | 1,736,582 |  |  |  | 1,760,930 |
Secured by nonfarm, nonresidential properties |  |  | 23,981 |  |  |  | 1,401,793 |  |  |  | 1,425,774 |
Other |  |  | 5,871 |  |  |  | 198,978 |  |  |  | 204,849 |
Commercial and industrial loans |  |  | 14,148 |  |  |  | 1,125,217 |  |  |  | 1,139,365 |
Consumer loans |  |  | 825 |  |  |  | 242,931 |  |  |  | 243,756 |
Other loans |  |  | 872 |  |  |  | 607,856 |  |  |  | 608,728 |
Total |  | $ | 110,458 |  |  | $ | 5,747,026 |  |  | $ | 5,857,484 |
At September 30, 2012 and December 31, 2011, LHFI classified as troubled debt restructurings (TDRs) totaled $26.3 million and $34.2 million, respectively. For TDRs, Trustmark had a related loan loss allowance of $4.6 million and $4.5 million at the end of each respective period. Specific charge-offs related to TDRs totaled $5.3 million and $1.6 million for the nine months ended September 30, 2012 and 2011, respectively. LHFI that are TDRs are charged down to the most likely fair value estimate less a cost to sell estimate for collateral dependent loans, which would approximate net realizable value. The following table illustrates the impact of modifications classified as TDRs for the three and nine months ended September 30, 2012 and 2011 as well as those TDRs modified within the last 12 months for which there was a payment default during the period ($ in thousands):
|  | Three Months Ended September 30, |
|  | 2012 |  |  | 2011 |
Troubled Debt Restructurings |  | Number of Contracts |  | Pre-Modification Outstanding Recorded Investment |  | Post-Modification Outstanding Recorded Investment |  | Number of Contracts |  | Pre-Modification Outstanding Recorded Investment |  | Post-Modification Outstanding Recorded Investment |
Construction, land development and other land loans |  |  | - |  |  | $ | - |  |  | $ | - |  |  |  | 1 |  |  | $ | 1,843 |  |  | $ | 1,843 |
Secured by 1-4 family residential properties |  |  | 39 |  |  |  | 3,695 |  |  |  | 3,691 |  |  |  | 5 |  |  |  | 1,889 |  |  |  | 1,949 |
Other loans secured by real estate |  |  | 1 |  |  |  | 199 |  |  |  | 199 |  |  |  | - |  |  |  | - |  |  |  | - |
Total |  |  | 40 |  |  | $ | 3,894 |  |  | $ | 3,890 |  |  |  | 6 |  |  | $ | 3,732 |  |  | $ | 3,792 |
|  | Nine Months Ended September 30, |
|  | 2012 |  |  | 2011 |
Troubled Debt Restructurings |  | Number of Contracts |  |  | Pre-Modification Outstanding Recorded Investment |  |  | Post-Modification Outstanding Recorded Investment |  |  | Number of Contracts |  |  | Pre-Modification Outstanding Recorded Investment |  |  | Post-Modification Outstanding Recorded Investment |
Construction, land development and other land loans |  |  | 11 |  |  | $ | 4,078 |  |  | $ | 4,078 |  |  |  | 14 |  |  | $ | 9,114 |  |  | $ | 8,447 |
Secured by 1-4 family residential properties |  |  | 44 |  |  |  | 5,062 |  |  |  | 5,069 |  |  |  | 15 |  |  |  | 5,112 |  |  |  | 3,549 |
Secured by nonfarm, nonresidential properties |  |  | 2 |  |  |  | 1,210 |  |  |  | 1,210 |  |  |  | 4 |  |  |  | 4,368 |  |  |  | 4,196 |
Other loans secured by real estate |  |  | 1 |  |  |  | 199 |  |  |  | 199 |  |  |  | - |  |  |  | - |  |  |  | - |
Commercial and industrial |  |  | - |  |  |  | - |  |  |  | - |  |  |  | 2 |  |  |  | 11,998 |  |  |  | 11,531 |
Total |  |  | 58 |  |  | $ | 10,549 |  |  | $ | 10,556 |  |  |  | 35 |  |  | $ | 30,592 |  |  | $ | 27,723 |
|  | Nine Months Ended September 30, |
|  | 2012 |  |  | 2011 |
Troubled Debt Restructurings that Subsequently Defaulted |  | Number of Contracts |  |  | Recorded Investment |  | Number of Contracts |  |  | Recorded Investment |
Construction, land development and other land loans |  |  | 10 |  |  | $ | 3,671 |  |  |  | 2 |  |  | $ | 1,688 |
Secured by 1-4 family residential properties |  |  | 8 |  |  |  | 1,781 |  |  |  | 2 |  |  |  | 1,485 |
Secured by nonfarm, nonresidential properties |  |  | 1 |  |  |  | 870 |  |  |  | - |  |  |  | - |
Total |  |  | 19 |  |  | $ | 6,322 |  |  |  | 4 |  |  | $ | 3,173 |
Trustmark's TDRs have resulted primarily from allowing the borrower to pay interest only for an extended period of time rather than from forgiveness. Accordingly, as shown above, these TDRs have a similar recorded investment for both the pre-modification and post-modification disclosure. Trustmark has utilized loans 90 days or more past due to define payment default in determining TDRs that have subsequently defaulted. At September 30, 2012 and December 31, 2011, the following table details LHFI classified as TDRs by loan type ($ in thousands):
|  | September 30, 2012 |
|  | Accruing |  |  | Nonaccrual |  |  | Total |
Construction, land development and other land loans |  | $ | 235 |  |  | $ | 12,493 |  |  | $ | 12,728 |
Secured by 1-4 family residential properties |  |  | 3,562 |  |  |  | 5,198 |  |  |  | 8,760 |
Secured by nonfarm, nonresidential properties |  |  | - |  |  |  | 4,662 |  |  |  | 4,662 |
Other loans secured by real estate |  |  | - |  |  |  | 199 |  |  |  | 199 |
Total Troubled Debt Restructurings by Type |  | $ | 3,797 |  |  | $ | 22,552 |  |  | $ | 26,349 |
|  | December 31, 2011 |
|  | Accruing |  |  | Nonaccrual |  |  | Total |
Construction, land development and other land loans |  | $ | 241 |  |  | $ | 14,041 |  |  | $ | 14,282 |
Secured by 1-4 family residential properties |  |  | 782 |  |  |  | 3,485 |  |  |  | 4,267 |
Secured by nonfarm, nonresidential properties |  |  | - |  |  |  | 4,135 |  |  |  | 4,135 |
Commercial and industrial |  |  | - |  |  |  | 11,503 |  |  |  | 11,503 |
Total Troubled Debt Restructurings by Type |  | $ | 1,023 |  |  | $ | 33,164 |  |  | $ | 34,187 |
At September 30, 2012 and December 31, 2011, the carrying amount of LHFI evaluated for impairment consisted of the following ($ in thousands):
|  | September 30, 2012 |
|  | LHFI |  |  |  |  |  |  |
|  | Unpaid |  |  | With No Related |  |  | With an |  |  | Total |  |  |  |  |  | Average |
|  | Principal |  |  | Allowance |  |  | Allowance |  |  | Carrying |  |  | Related |  |  | Recorded |
|  | Balance |  |  | Recorded |  |  | Recorded |  |  | Amount |  |  | Allowance |  |  | Investment |
Loans secured by real estate: |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Construction, land development and other land loans |  | $ | 45,951 |  |  | $ | 7,815 |  |  | $ | 18,262 |  |  | $ | 26,077 |  |  | $ | 4,829 |  |  | $ | 33,245 |
Secured by 1-4 family residential properties |  |  | 31,206 |  |  |  | 2,093 |  |  |  | 22,167 |  |  |  | 24,260 |  |  |  | 1,373 |  |  |  | 24,304 |
Secured by nonfarm, nonresidential properties |  |  | 24,003 |  |  |  | 4,424 |  |  |  | 14,449 |  |  |  | 18,873 |  |  |  | 3,259 |  |  |  | 21,427 |
Other |  |  | 5,965 |  |  |  | - |  |  |  | 3,900 |  |  |  | 3,900 |  |  |  | 855 |  |  |  | 4,886 |
Commercial and industrial loans |  |  | 6,791 |  |  |  | 57 |  |  |  | 6,158 |  |  |  | 6,215 |  |  |  | 2,995 |  |  |  | 10,182 |
Consumer loans |  |  | 670 |  |  |  | - |  |  |  | 411 |  |  |  | 411 |  |  |  | 4 |  |  |  | 618 |
Other loans |  |  | 952 |  |  |  | - |  |  |  | 922 |  |  |  | 922 |  |  |  | 336 |  |  |  | 897 |
Total |  | $ | 115,538 |  |  | $ | 14,389 |  |  | $ | 66,269 |  |  | $ | 80,658 |  |  | $ | 13,651 |  |  | $ | 95,559 |
|  | December 31, 2011 |
|  | LHFI |  |  |  |  |  |  |
|  | Unpaid |  |  | With No Related |  |  | With an |  |  | Total |  |  |  |  |  | Average |
|  | Principal |  |  | Allowance |  |  | Allowance |  |  | Carrying |  |  | Related |  |  | Recorded |
|  | Balance |  |  | Recorded |  |  | Recorded |  |  | Amount |  |  | Allowance |  |  | Investment |
Loans secured by real estate: |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Construction, land development and other land loans |  | $ | 58,757 |  |  | $ | 11,123 |  |  | $ | 29,290 |  |  | $ | 40,413 |  |  | $ | 6,547 |  |  | $ | 49,122 |
Secured by 1-4 family residential properties |  |  | 33,746 |  |  |  | 1,560 |  |  |  | 22,788 |  |  |  | 24,348 |  |  |  | 1,348 |  |  |  | 27,330 |
Secured by nonfarm, nonresidential properties |  |  | 27,183 |  |  |  | 13,770 |  |  |  | 10,211 |  |  |  | 23,981 |  |  |  | 2,431 |  |  |  | 26,497 |
Other |  |  | 7,158 |  |  |  | 1,548 |  |  |  | 4,323 |  |  |  | 5,871 |  |  |  | 1,007 |  |  |  | 6,013 |
Commercial and industrial loans |  |  | 16,102 |  |  |  | 8,724 |  |  |  | 5,424 |  |  |  | 14,148 |  |  |  | 1,137 |  |  |  | 15,127 |
Consumer loans |  |  | 1,097 |  |  |  | - |  |  |  | 825 |  |  |  | 825 |  |  |  | 9 |  |  |  | 1,468 |
Other loans |  |  | 2,559 |  |  |  | 220 |  |  |  | 652 |  |  |  | 872 |  |  |  | 185 |  |  |  | 1,132 |
Total |  | $ | 146,602 |  |  | $ | 36,945 |  |  | $ | 73,513 |  |  | $ | 110,458 |  |  | $ | 12,664 |  |  | $ | 126,689 |
Credit Quality Indicators Trustmark's loan portfolio credit quality indicators focus on six key quality ratios that are compared against bank tolerances. The loan indicators are total classified outstanding, total criticized outstanding, nonperforming loans, nonperforming assets, delinquencies and net loan losses. Due to the homogenous nature of consumer loans, Trustmark does not assign a formal internal risk rating to each credit and therefore the criticized and classified measures are unique to commercial loans. In addition to monitoring portfolio credit quality indictors, Trustmark also measures how effectively the lending process is being managed and risks are being identified. As part of an ongoing monitoring process, Trustmark grades the commercial portfolio as it relates to financial statement exceptions, total policy exceptions, collateral exceptions and violations of law as shown below:
| · | Financial Statement Exceptions – focuses on the officers' ongoing efforts to obtain, evaluate and/or document sufficient information to determine the quality and status of the credits. This area includes the quality and condition of the files in terms of content, completeness and organization. Included is an evaluation of the systems/procedures used to insure compliance with policy such as financial statements, review memos and loan agreement covenants.
| · | Underwriting/Policy – evaluates whether credits are adequately analyzed, appropriately structured and properly approved within requirements of bank loan policy. A properly approved credit is approved by adequate authority in a timely manner with all conditions of approval fulfilled. Total policy exceptions measure the level of exceptions to loan policy within a loan portfolio.
| · | Collateral Documentation – focuses on the adequacy of documentation to support the obligation, perfect Trustmark's collateral position and protect collateral value. There are two parts to this measure:
| ü | Collateral exceptions where certain collateral documentation is either not present, is not considered current or has expired.
| ü | 90 days and over collateral exceptions are where certain collateral documentation is either not present, is not considered current or has expired and the exception has been identified in excess of 90 days.
| · | Compliance with Law – focuses on underwriting, documentation, approval and reporting in compliance with banking laws and regulations. Primary emphasis is directed to Financial Institutions Reform, Recovery and Enforcement Act of 1989 (FIRREA) and Regulation O requirements.
Commercial Credits Trustmark has established a Loan Grading System that consists of ten individual Credit Risk Grades (Risk Ratings) that encompass a range from loans where the expectation of loss is negligible to loans where loss has been established. The model is based on the risk of default for an individual credit and establishes certain criteria to delineate the level of risk across the ten unique Credit Risk Grades. Credit risk grade definitions are as follows:
| · | Risk Rate (RR) 1 through RR 6 – Grades one through six represent groups of loans that are not subject to adverse criticism as defined in regulatory guidance. Loans in these groups exhibit characteristics that represent low to moderate risk measured by using a variety of credit risk criteria such as cash flow coverage, debt service coverage, balance sheet leverage, liquidity, management experience, industry position, prevailing economic conditions, support from secondary sources of repayment and other credit factors that may be relevant to a specific loan. In general, these loans are supported by properly margined collateral and guarantees of principal parties.
| · | Other Assets Especially Mentioned (OAEM) - (RR 7) – a loan that has a potential weakness that if not corrected will lead to a more severe rating. This rating is for credits that are currently protected but potentially weak because of an adverse feature or condition that if not corrected will lead to a further downgrade.
| · | Substandard (RR 8) – a loan that has at least one identified weakness that is well defined. This rating is for credits where the primary sources of repayment are not viable at this time or where either the capital or collateral is not adequate to support the loan and the secondary means of repayment do not provide a sufficient level of support to offset the identified weakness but are sufficient to prevent a loss at this time. While these credits do not demonstrate any level of loss at this time, further deterioration would lead to a further downgrade.
| · | Doubtful (RR 9) – a loan with an identified weakness that does not have a valid secondary source of repayment. Generally these credits have an impaired primary source of repayment and secondary sources are not sufficient to prevent a loss in the credit.
| · | Loss (RR 10) – a loan or a portion of a loan that is deemed to be uncollectible.
By definition, credit risk grades OAEM (RR 7), substandard (RR 8), doubtful (RR 9) and loss (RR 10) are criticized loans while substandard (RR 8), doubtful (RR 9) and loss (RR 10) are classified loans. These definitions are standardized by all bank regulatory agencies and are generally equally applied to each individual lending institution. The remaining credit risk grades are considered pass credits and are solely defined by Trustmark. The credit risk grades represent the probability of default (PD) for an individual credit and as such is not a direct indication of loss given default (LGD). The LGD aspect of the subject risk ratings is neither uniform across the nine primary commercial loan groups or constant between the geographic areas. To account for the variance in the LGD aspects of the risk rate system, the loss expectations for each risk rating is integrated into the allowance for loan loss methodology where the calculated LGD is allotted for each individual risk rating with respect to the individual loan group and unique geographic area. The LGD aspect of the reserve methodology is calculated each quarter as a component of the overall reserve factor for each risk grade by loan group and geographic area. To enhance this process, loans of a certain size that are rated in one of the criticized categories are routinely reviewed to establish an expectation of loss, if any, and if such examination indicates that the level of reserve is not adequate to cover the expectation of loss, a special reserve or impairment is generally applied. The distribution of the losses is accomplished by means of a loss distribution model that assigns a loss factor to each risk rating (1 to 9) in each commercial loan pool. A factor is not applied to risk rate 10 (Loss) as loans classified as Losses are not carried on the bank's books over each quarter end as they are charged off within the period that the loss is determined. The expected loss distribution is spread across the various risk ratings by the perceived level of risk for loss. The nine grade scale above ranges from a negligible risk of loss to an identified loss across its breadth. The loss distribution factors are graduated through the scale on a basis proportional to the degree of risk that appears manifest in each individual rating and assumes that migration through the loan grading system will occur. Each loan officer assesses the appropriateness of the internal risk rating assigned to their credits on an ongoing basis. Trustmark's Asset Review area conducts independent credit quality reviews of the majority of the bank's commercial loan portfolio concentrations both on the underlying credit quality of each individual loan portfolio as well as the adherence to bank loan policy and the loan administration process. In general, Asset Review conducts reviews of each lending area within a six to eighteen month window depending on the overall credit quality results of the individual area. In addition to the ongoing internal risk rate monitoring described above, Trustmark conducts monthly credit quality reviews (CQR) as well as semi-annual analysis and stress testing on all residential real estate development credits and non-owner occupied commercial real estate (CRE) credits of $1.0 million or more as described below:
| · | Trustmark's Credit Quality Review Committee meets monthly and performs the following functions: detailed review and evaluation of all loans of $100 thousand or more that are either delinquent thirty days or more or on nonaccrual, including determination of appropriate risk ratings, accrual status, and appropriate servicing officer; review of risk rate changes for relationships of $100 thousand or more; quarterly review of all nonaccruals less than $100 thousand to determine whether the credit should be charged off, returned to accrual, or remain in nonaccrual status; monthly/quarterly review of continuous action plans for all credits rated seven or worse for relationships of $100 thousand or more; monthly review of all commercial charge-offs of $25 thousand or more for the preceding month.
| · | Residential real estate developments - a development project analysis is performed on all projects regardless of size. Performance of the development is assessed through an evaluation of the number of lots remaining, the payout ratios, and the loan-to-value ratios. Results are stress tested as to absorption and price of lots. This information is reviewed by each senior credit officer for that market to determine the need for any risk rate or accrual status changes.
| · | Non-owner occupied commercial real estate – a cash flow analysis is performed on all projects with an outstanding balance of $1.0 million or more. In addition, credits are stress tested for vacancies and rate sensitivity. Confirmation is obtained that guarantor's financial statements are current, taxes have been paid, and that there are no other issues that need to be addressed. This information is reviewed by each senior credit officer for that market to determine the need for any risk rate or accrual status changes.
Consumer Credits Loans that do not meet a minimum custom credit score are reviewed quarterly by Management. The Retail Credit Review Committee reviews the volume and percentage of approvals that did not meet the minimum passing custom score by region, individual location, and officer. To assure that Trustmark continues to originate quality loans, this process allows Management to make necessary changes such as changes to underwriting procedures, credit policies, or changes in loan authority to Trustmark personnel. Trustmark monitors the levels and severity of past due consumer loans on a daily basis through its collection activities. A detailed assessment of consumer loan delinquencies is performed monthly at both a product and market level by delivery channel, which incorporates the perceived level of risk at time of underwriting. Trustmark also monitors its consumer loan delinquency trends by comparing them to quarterly industry averages. The allowance calculation methodology delineates the consumer loan portfolio into homogeneous pools of loans that contain similar structure, repayment, collateral and risk profile, which include residential mortgage, direct consumer loans, auto finance, credit cards, and overdrafts. For these pools, the historical loss experience is determined by calculating a 20-quarter rolling average and that loss factor is applied to each homogeneous pool to establish the quantitative aspect of the methodology. Where the loss experience does not fully cover the anticipated loss for a pool, an estimate is also applied to each homogeneous pool to establish the qualitative aspect of the methodology. The qualitative portion is the allocation of perceived risks across the loan portfolio to derive the potential losses that exist at the current point in time. This methodology utilizes five separate factors where each factor is made up of unique components that when weighted and combined produce an estimated level of reserve for each of the loan pools. The five factors include economic indicators, performance trends, management experience, lending policy measures, and credit concentrations. The risk measure for each factor is converted to a scale ranging from 0 (No risk) to 100 (High Risk) to ensure that the combination of such factors is proportional. The determination of the risk measurement for each qualitative factor is done for all four markets combined. The resulting estimated reserve factor is then applied to each pool. The resulting ratings from the individual factors are weighted and summed to establish the weighted average qualitative factor of a specific loan portfolio. This weighted average qualitative factor is then applied over the five loan pools. The table below illustrates the carrying amount of LHFI by credit quality indicator at September 30, 2012 and December 31, 2011 ($ in thousands):
|  | September 30, 2012 |
|  |  |  |  |  | Commercial Loans |
|  |  |  |  |  | Pass - |  |  | Special Mention - |  |  | Substandard - |  |  | Doubtful - |  |  |  |
|  |  |  |  |  | Categories 1-6 |  |  | Category 7 |  |  | Category 8 |  |  | Category 9 |  |  | Subtotal |
Loans secured by real estate: |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Construction, land development and other land loans |  |  |  |  |  | $ | 321,938 |  |  | $ | 23,923 |  |  | $ | 67,703 |  |  | $ | - |  |  | $ | 413,564 |
Secured by 1-4 family residential properties |  |  |  |  |  |  | 115,316 |  |  |  | 1,026 |  |  |  | 14,844 |  |  |  | 40 |  |  |  | 131,226 |
Secured by nonfarm, nonresidential properties |  |  |  |  |  |  | 1,277,544 |  |  |  | 12,607 |  |  |  | 106,338 |  |  |  | - |  |  |  | 1,396,489 |
Other |  |  |  |  |  |  | 173,240 |  |  |  | 451 |  |  |  | 5,640 |  |  |  | - |  |  |  | 179,331 |
Commercial and industrial loans |  |  |  |  |  |  | 1,075,124 |  |  |  | 36,782 |  |  |  | 46,845 |  |  |  | 4,411 |  |  |  | 1,163,162 |
Consumer loans |  |  |  |  |  |  | 343 |  |  |  | - |  |  |  | - |  |  |  | - |  |  |  | 343 |
Other loans |  |  |  |  |  |  | 620,563 |  |  |  | 4 |  |  |  | 611 |  |  |  | 825 |  |  |  | 622,003 |
|  |  |  |  |  | $ | 3,584,068 |  |  | $ | 74,793 |  |  | $ | 241,981 |  |  | $ | 5,276 |  |  | $ | 3,906,118 |
|  | Consumer Loans |  |  |  |
|  |  |  |  | Past Due |  |  | Past Due Greater |  |  |  |  |  |  |  |  |  |
|  | Current |  |  | 30-89 Days |  |  | Than 90 days |  |  | Nonaccrual |  |  | Subtotal |  |  | Total LHFI |
Loans secured by real estate: |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Construction, land development and other land loans |  | $ | 45,790 |  |  | $ | 353 |  |  | $ | - |  |  | $ | 892 |  |  | $ | 47,035 |  |  | $ | 460,599 |
Secured by 1-4 family residential properties |  |  | 1,349,926 |  |  |  | 10,335 |  |  |  | 2,683 |  |  |  | 17,344 |  |  |  | 1,380,288 |  |  |  | 1,511,514 |
Secured by nonfarm, nonresidential properties |  |  | 1,047 |  |  |  | - |  |  |  | - |  |  |  | - |  |  |  | 1,047 |  |  |  | 1,397,536 |
Other |  |  | 5,416 |  |  |  | 33 |  |  |  | - |  |  |  | 24 |  |  |  | 5,473 |  |  |  | 184,804 |
Commercial and industrial loans |  |  | 464 |  |  |  | 45 |  |  |  | - |  |  |  | 10 |  |  |  | 519 |  |  |  | 1,163,681 |
Consumer loans |  |  | 176,663 |  |  |  | 4,246 |  |  |  | 234 |  |  |  | 410 |  |  |  | 181,553 |  |  |  | 181,896 |
Other loans |  |  | 5,930 |  |  |  | - |  |  |  | - |  |  |  | - |  |  |  | 5,930 |  |  |  | 627,933 |
|  | $ | 1,585,236 |  |  | $ | 15,012 |  |  | $ | 2,917 |  |  | $ | 18,680 |  |  | $ | 1,621,845 |  |  | $ | 5,527,963 |
|  | December 31, 2011 |
|  |  |  |  |  | Commercial Loans |
|  |  |  |  |  | Pass - |  |  | Special Mention - |  |  | Substandard - |  |  | Doubtful - |  |  |  |
|  |  |  |  |  | Categories 1-6 |  |  | Category 7 |  |  | Category 8 |  |  | Category 9 |  |  | Subtotal |
Loans secured by real estate: |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Construction, land development and other land loans |  |  |  |  |  | $ | 308,618 |  |  | $ | 26,273 |  |  | $ | 90,175 |  |  | $ | 116 |  |  | $ | 425,182 |
Secured by 1-4 family residential properties |  |  |  |  |  |  | 119,155 |  |  |  | 142 |  |  |  | 16,324 |  |  |  | - |  |  |  | 135,621 |
Secured by nonfarm, nonresidential properties |  |  |  |  |  |  | 1,287,886 |  |  |  | 26,232 |  |  |  | 110,472 |  |  |  | 51 |  |  |  | 1,424,641 |
Other |  |  |  |  |  |  | 188,772 |  |  |  | 130 |  |  |  | 9,312 |  |  |  | - |  |  |  | 198,214 |
Commercial and industrial loans |  |  |  |  |  |  | 1,048,556 |  |  |  | 32,046 |  |  |  | 56,577 |  |  |  | 405 |  |  |  | 1,137,584 |
Consumer loans |  |  |  |  |  |  | 643 |  |  |  | 25 |  |  |  | - |  |  |  | - |  |  |  | 668 |
Other loans |  |  |  |  |  |  | 600,411 |  |  |  | - |  |  |  | 1,834 |  |  |  | 600 |  |  |  | 602,845 |
|  |  |  |  |  | $ | 3,554,041 |  |  | $ | 84,848 |  |  | $ | 284,694 |  |  | $ | 1,172 |  |  | $ | 3,924,755 |
|  | Consumer Loans |  |  |  |
|  |  |  |  | Past Due |  |  | Past Due Greater |  |  |  |  |  |  |  |  |  |
|  | Current |  |  | 30-89 Days |  |  | Than 90 days |  |  | Nonaccrual |  |  | Subtotal |  |  | Total LHFI |
Loans secured by real estate: |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Construction, land development and other land loans |  | $ | 47,253 |  |  | $ | 353 |  |  | $ | - |  |  | $ | 1,294 |  |  | $ | 48,900 |  |  | $ | 474,082 |
Secured by 1-4 family residential properties |  |  | 1,596,800 |  |  |  | 8,477 |  |  |  | 1,306 |  |  |  | 18,726 |  |  |  | 1,625,309 |  |  |  | 1,760,930 |
Secured by nonfarm, nonresidential properties |  |  | 1,133 |  |  |  | - |  |  |  | - |  |  |  | - |  |  |  | 1,133 |  |  |  | 1,425,774 |
Other |  |  | 6,405 |  |  |  | 201 |  |  |  | - |  |  |  | 29 |  |  |  | 6,635 |  |  |  | 204,849 |
Commercial and industrial loans |  |  | 1,626 |  |  |  | 118 |  |  |  | - |  |  |  | 37 |  |  |  | 1,781 |  |  |  | 1,139,365 |
Consumer loans |  |  | 234,593 |  |  |  | 7,172 |  |  |  | 498 |  |  |  | 825 |  |  |  | 243,088 |  |  |  | 243,756 |
Other loans |  |  | 5,848 |  |  |  | 35 |  |  |  | - |  |  |  | - |  |  |  | 5,883 |  |  |  | 608,728 |
|  | $ | 1,893,658 |  |  | $ | 16,356 |  |  | $ | 1,804 |  |  | $ | 20,911 |  |  | $ | 1,932,729 |  |  | $ | 5,857,484 |
Past Due LHFI and LHFS LHFI past due 90 days or more totaled $5.7 million and $4.2 million at September 30, 2012 and December 31, 2011, respectively. The following table provides an aging analysis of past due and nonaccrual LHFI by class at September 30, 2012 and December 31, 2011 ($ in thousands):
|  | September 30, 2012 |
|  | Past Due |  |  |  |  |  |  |  |  |  |
|  |  |  |  | Greater than |  |  |  |  |  |  |  |  | Current |  |  |  |
|  | 30-89 Days |  |  | 90 Days (1) |  |  | Total |  |  | Nonaccrual |  |  | Loans |  |  | Total LHFI |
Loans secured by real estate: |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Construction, land development and other land loans |  | $ | 1,762 |  |  | $ | - |  |  | $ | 1,762 |  |  | $ | 26,077 |  |  | $ | 432,760 |  |  | $ | 460,599 |
Secured by 1-4 family residential properties |  |  | 12,672 |  |  |  | 2,843 |  |  |  | 15,515 |  |  |  | 24,260 |  |  |  | 1,471,739 |  |  |  | 1,511,514 |
Secured by nonfarm, nonresidential properties |  |  | 3,364 |  |  |  | 91 |  |  |  | 3,455 |  |  |  | 18,873 |  |  |  | 1,375,208 |  |  |  | 1,397,536 |
Other |  |  | 184 |  |  |  | - |  |  |  | 184 |  |  |  | 3,900 |  |  |  | 180,720 |  |  |  | 184,804 |
Commercial and industrial loans |  |  | 3,861 |  |  |  | 2,532 |  |  |  | 6,393 |  |  |  | 6,215 |  |  |  | 1,151,073 |  |  |  | 1,163,681 |
Consumer loans |  |  | 4,246 |  |  |  | 233 |  |  |  | 4,479 |  |  |  | 411 |  |  |  | 177,006 |  |  |  | 181,896 |
Other loans |  |  | 74 |  |  |  | - |  |  |  | 74 |  |  |  | 922 |  |  |  | 626,937 |  |  |  | 627,933 |
Total past due LHFI |  | $ | 26,163 |  |  | $ | 5,699 |  |  | $ | 31,862 |  |  | $ | 80,658 |  |  | $ | 5,415,443 |  |  | $ | 5,527,963 |
(1) | - Past due greater than 90 days but still accruing interest.
|  | December 31, 2011 |
|  | Past Due |  |  |  |  |  |  |  |  |  |
|  |  |  |  | Greater than |  |  |  |  |  |  |  |  | Current |  |  |  |
|  | 30-89 Days |  |  | 90 Days (1) |  |  | Total |  |  | Nonaccrual |  |  | Loans |  |  | Total LHFI |
Loans secured by real estate: |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Construction, land development and other land loans |  | $ | 1,784 |  |  | $ | 1,657 |  |  | $ | 3,441 |  |  | $ | 40,413 |  |  | $ | 430,228 |  |  | $ | 474,082 |
Secured by 1-4 family residential properties |  |  | 9,755 |  |  |  | 1,306 |  |  |  | 11,061 |  |  |  | 24,348 |  |  |  | 1,725,521 |  |  |  | 1,760,930 |
Secured by nonfarm, nonresidential properties |  |  | 9,925 |  |  |  | - |  |  |  | 9,925 |  |  |  | 23,981 |  |  |  | 1,391,868 |  |  |  | 1,425,774 |
Other |  |  | 879 |  |  |  | - |  |  |  | 879 |  |  |  | 5,871 |  |  |  | 198,099 |  |  |  | 204,849 |
Commercial and industrial loans |  |  | 1,646 |  |  |  | 769 |  |  |  | 2,415 |  |  |  | 14,148 |  |  |  | 1,122,802 |  |  |  | 1,139,365 |
Consumer loans |  |  | 7,172 |  |  |  | 498 |  |  |  | 7,670 |  |  |  | 825 |  |  |  | 235,261 |  |  |  | 243,756 |
Other loans |  |  | 3,104 |  |  |  | - |  |  |  | 3,104 |  |  |  | 872 |  |  |  | 604,752 |  |  |  | 608,728 |
Total past due LHFI |  | $ | 34,265 |  |  | $ | 4,230 |  |  | $ | 38,495 |  |  | $ | 110,458 |  |  | $ | 5,708,531 |  |  | $ | 5,857,484 |
(1) | - Past due greater than 90 days but still accruing interest.
LHFS past due 90 days or more totaled $39.5 million and $39.4 million at September 30, 2012 and December 31, 2011, respectively. LHFS past due 90 days or more are serviced loans eligible for repurchase, which are fully guaranteed by GNMA. GNMA optional repurchase programs allow financial institutions to buy back individual delinquent mortgage loans that meet certain criteria from the securitized loan pool for which the institution provides servicing. At the servicer's option and without GNMA's prior authorization, the servicer may repurchase such a delinquent loan for an amount equal to 100 percent of the remaining principal balance of the loan. This buy-back option is considered a conditional option until the delinquency criteria are met, at which time the option becomes unconditional. When Trustmark is deemed to have regained effective control over these loans under the unconditional buy-back option, the loans can no longer be reported as sold and must be brought back onto the balance sheet as loans held for sale, regardless of whether Trustmark intends to exercise the buy-back option. These loans are reported as held for sale with the offsetting liability being reported as short-term borrowings. Trustmark did not exercise its buy-back option on any delinquent loans serviced for GNMA during the first nine months of 2012 or 2011. Allowance for Loan Losses, LHFI Trustmark's allowance for loan loss methodology for commercial loans is based upon regulatory guidance from its primary regulator and GAAP. The methodology delineates the commercial purpose and commercial construction loan portfolios into nine separate loan types (or pools), which had similar characteristics, such as, repayment, collateral and risk profiles. The nine basic loan pools are further segregated into Trustmark's four key market regions, Florida, Mississippi, Tennessee and Texas, to take into consideration the uniqueness of each market. A 10-point risk rating system is utilized for each separate loan pool to apply a reserve factor consisting of quantitative and qualitative components to determine the needed allowance by each loan type. As a result, there are 360 risk rate factors for commercial loan types. The nine separate pools are segmented below: Commercial Purpose Loans
| · | Real Estate – Owner Occupied
| · | Real Estate – Non-Owner Occupied
| · | Working Capital
| · | Non-Working Capital
| · | Land
| · | Lots and Development
| · | Political Subdivisions
Commercial Construction Loans
| · | 1 to 4 Family
| · | Non-1 to 4 Family
During the third quarter of 2011, Trustmark altered the quantitative factors of the allowance for loan loss methodology to reflect a twelve-quarter rolling average of net charge-offs. The quantitative factors utilized in determining the required reserve are intended to reflect a twelve-quarter rolling average, one quarter in arrears, by loan type within each key market region, unless subsequent market factors suggest that a different method is called for. This alteration to Trustmark's methodology allows for a greater sensitivity to current trends, such as economic changes as well as current loss profiles, which creates a more accurate depiction of historical losses. Prior to converting to a twelve-quarter rolling average, the quantitative factors reflected a three-year rolling average for Trustmark's commercial loan book of business. The qualitative factors are determined through the utilization of eight separate factors made up of unique characteristics that, when weighted and combined, produce an estimated level of reserve for each loan type. The qualitative factors considered are the following:
| · | National and regional economic trends and conditions
| · | Impact of recent performance trends
| · | Experience, ability and effectiveness of management
| · | Adherence to Trustmark's loan policies, procedures and internal controls
| · | Collateral, financial and underwriting exception trends
| · | Credit concentrations
| · | Acquisitions
| · | Catastrophe
The measure for each qualitative factor is converted to a scale ranging from 0 (No risk) to 100 (High Risk), other than the last two factors, which are applied on a dollar-for-dollar basis, to ensure that the combination of such factors is proportional. The resulting ratings from the individual factors are weighted and summed to establish the weighted average qualitative factor of a specific loan portfolio within each key market region. This weighted average qualitative factor is then distributed over the nine primary loan pools within each key market region based on the ranking by risk of each. Changes in the allowance for loan losses, LHFI were as follows ($ in thousands):
|  | Nine Months Ended September 30, |
|  | 2012 |  |  | 2011 |
Balance at January 1, |  | $ | 89,518 |  |  | $ | 93,510 |
Loans charged-off |  |  | (22,547 | ) |  |  | (37,312 | )
Recoveries |  |  | 9,254 |  |  |  | 9,634 |
Net charge-offs |  |  | (13,293 | ) |  |  | (27,678 | )
Provision for loan losses, LHFI |  |  | 7,301 |  |  |  | 23,631 |
Balance at September 30, |  | $ | 83,526 |  |  | $ | 89,463 |
The following tables detail the balance in the allowance for loan losses, LHFI by portfolio segment at September 30, 2012 and 2011, respectively ($ in thousands):
|  | 2012 |
|  | Balance |  |  |  |  |  |  |  |  | Provision for |  |  | Balance |
|  | January 1, |  |  | Charge-offs |  |  | Recoveries |  |  | Loan Losses |  |  | September 30, |
Loans secured by real estate: |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Construction, land development and other land loans |  | $ | 27,220 |  |  | $ | (2,944 | ) |  | $ | - |  |  | $ | (1,732 | ) |  | $ | 22,544 |
Secured by 1-4 family residential properties |  |  | 12,650 |  |  |  | (3,238 | ) |  |  | 364 |  |  |  | 2,203 |  |  |  | 11,979 |
Secured by nonfarm, nonresidential properties |  |  | 24,358 |  |  |  | (5,409 | ) |  |  | - |  |  |  | 3,823 |  |  |  | 22,772 |
Other |  |  | 3,079 |  |  |  | (1,602 | ) |  |  | - |  |  |  | 733 |  |  |  | 2,210 |
Commercial and industrial loans |  |  | 15,868 |  |  |  | (2,985 | ) |  |  | 2,123 |  |  |  | 3,428 |  |  |  | 18,434 |
Consumer loans |  |  | 3,656 |  |  |  | (2,360 | ) |  |  | 4,189 |  |  |  | (2,620 | ) |  |  | 2,865 |
Other loans |  |  | 2,687 |  |  |  | (4,009 | ) |  |  | 2,578 |  |  |  | 1,466 |  |  |  | 2,722 |
Total allowance for loan losses, LHFI |  | $ | 89,518 |  |  | $ | (22,547 | ) |  | $ | 9,254 |  |  | $ | 7,301 |  |  | $ | 83,526 |
|  | Disaggregated by Impairment Method |
|  | Individually |  |  | Collectively |  |  | Total |
Loans secured by real estate: |  |  |  |  |  |  |  |  |
Construction, land development and other land loans |  | $ | 4,829 |  |  | $ | 17,715 |  |  | $ | 22,544 |
Secured by 1-4 family residential properties |  |  | 1,373 |  |  |  | 10,606 |  |  |  | 11,979 |
Secured by nonfarm, nonresidential properties |  |  | 3,259 |  |  |  | 19,513 |  |  |  | 22,772 |
Other |  |  | 855 |  |  |  | 1,355 |  |  |  | 2,210 |
Commercial and industrial loans |  |  | 2,995 |  |  |  | 15,439 |  |  |  | 18,434 |
Consumer loans |  |  | 4 |  |  |  | 2,861 |  |  |  | 2,865 |
Other loans |  |  | 336 |  |  |  | 2,386 |  |  |  | 2,722 |
Total allowance for loan losses, LHFI |  | $ | 13,651 |  |  | $ | 69,875 |  |  | $ | 83,526 |
|  | 2011 |
|  | Balance |  |  |  |  |  |  |  |  | Provision for |  |  | Balance |
|  | January 1, |  |  | Charge-offs |  |  | Recoveries |  |  | Loan Losses |  |  | September 30, |
Loans secured by real estate: |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Construction, land development and other land loans |  | $ | 35,562 |  |  | $ | (14,375 | ) |  | $ | - |  |  | $ | 8,353 |  |  | $ | 29,540 |
Secured by 1-4 family residential properties |  |  | 13,051 |  |  |  | (7,461 | ) |  |  | 410 |  |  |  | 5,538 |  |  |  | 11,538 |
Secured by nonfarm, nonresidential properties |  |  | 20,980 |  |  |  | (3,124 | ) |  |  | - |  |  |  | 4,882 |  |  |  | 22,738 |
Other |  |  | 1,582 |  |  |  | (577 | ) |  |  | - |  |  |  | 1,969 |  |  |  | 2,974 |
Commercial and industrial loans |  |  | 14,775 |  |  |  | (3,811 | ) |  |  | 2,259 |  |  |  | 2,529 |  |  |  | 15,752 |
Consumer loans |  |  | 5,400 |  |  |  | (4,410 | ) |  |  | 4,475 |  |  |  | (1,474 | ) |  |  | 3,991 |
Other loans |  |  | 2,160 |  |  |  | (3,554 | ) |  |  | 2,490 |  |  |  | 1,834 |  |  |  | 2,930 |
Total allowance for loan losses, LHFI |  | $ | 93,510 |  |  | $ | (37,312 | ) |  | $ | 9,634 |  |  | $ | 23,631 |  |  | $ | 89,463 |
|  | Disaggregated by Impairment Method |
|  | Individually |  |  | Collectively |  |  | Total |
Loans secured by real estate: |  |  |  |  |  |  |  |  |
Construction, land development and other land loans |  | $ | 4,165 |  |  | $ | 25,375 |  |  | $ | 29,540 |
Secured by 1-4 family residential properties |  |  | 540 |  |  |  | 10,998 |  |  |  | 11,538 |
Secured by nonfarm, nonresidential properties |  |  | 1,510 |  |  |  | 21,228 |  |  |  | 22,738 |
Other |  |  | 1,008 |  |  |  | 1,966 |  |  |  | 2,974 |
Commercial and industrial loans |  |  | 1,454 |  |  |  | 14,298 |  |  |  | 15,752 |
Consumer loans |  |  | 10 |  |  |  | 3,981 |  |  |  | 3,991 |
Other loans |  |  | 275 |  |  |  | 2,655 |  |  |  | 2,930 |
Total allowance for loan losses, LHFI |  | $ | 8,962 |  |  | $ | 80,501 |  |  | $ | 89,463 |

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