10-Q


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
 
FORM 10‑Q
 
QUARTERLY REPORT PURSUANT TO SECTION 13 OR 15(d) OF
THE SECURITIES EXCHANGE ACT OF 1934
For the quarterly period ended March 31, 2016
 
Commission file number 001-2979
 
WELLS FARGO & COMPANY
(Exact name of registrant as specified in its charter)
Delaware
 
No. 41-0449260
(State of incorporation)
 
(I.R.S. Employer Identification No.)
 
420 Montgomery Street, San Francisco, California 94163
(Address of principal executive offices)  (Zip Code)
 
Registrant’s telephone number, including area code:  1-866-249-3302 
 
Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.
Yes þ
 
No o

Indicate by check mark whether the registrant has submitted electronically and posted on its corporate Web site, if any, every Interactive Data File required to be submitted and posted pursuant to Rule 405 of Regulation S-T during the preceding 12 months (or for such shorter period that the registrant was required to submit and post such files).
Yes þ
 
No o
 
Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non‑accelerated filer, or a smaller reporting company. See the definitions of “large accelerated filer,” “accelerated filer” and “smaller reporting company” in Rule 12b-2 of the Exchange Act.
 
 
Large accelerated filer    þ
 
Accelerated filer  o
 
 
 
 
 
 
 
Non‑accelerated filer    o (Do not check if a smaller reporting company)
 
Smaller reporting company  o
 
          
Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act).
Yes o
 
No þ
 
Indicate the number of shares outstanding of each of the issuer’s classes of common stock, as of the latest practicable date.
 
 
 
Shares Outstanding
 
 
April 29, 2016
Common stock, $1-2/3 par value
 
5,077,047,651
          




FORM 10-Q
 
CROSS-REFERENCE INDEX
 
PART I
Financial Information
  
Item 1.
Financial Statements
Page
  
Consolidated Statement of Income
  
Consolidated Statement of Comprehensive Income
  
Consolidated Balance Sheet
  
Consolidated Statement of Changes in Equity
  
Consolidated Statement of Cash Flows
  
Notes to Financial Statements
  
  
1

Summary of Significant Accounting Policies  
  
2

Business Combinations
  
3

Federal Funds Sold, Securities Purchased under Resale Agreements and Other Short-Term Investments  
  
4

Investment Securities
  
5

Loans and Allowance for Credit Losses
  
6

Other Assets
  
7

Securitizations and Variable Interest Entities
  
8

Mortgage Banking Activities
  
9

Intangible Assets
  
10

Guarantees, Pledged Assets and Collateral
  
11

Legal Actions
  
12

Derivatives
  
13

Fair Values of Assets and Liabilities
  
14

Preferred Stock
  
15

Employee Benefits
  
16

Earnings Per Common Share
  
17

Other Comprehensive Income
  
18

Operating Segments
  
19

Regulatory and Agency Capital Requirements
Item 2.
Management’s Discussion and Analysis of Financial Condition and Results of Operations (Financial Review)
  
  
Summary Financial Data  
  
Overview
  
Earnings Performance
  
Balance Sheet Analysis
  
Off-Balance Sheet Arrangements  
  
Risk Management
  
Capital Management
  
Regulatory Reform
  
Critical Accounting Policies  
  
Current Accounting Developments
  
Forward-Looking Statements  
  
Risk Factors 
  
Glossary of Acronyms
Item 3.
Quantitative and Qualitative Disclosures About Market Risk
Item 4.
Controls and Procedures
 
 
 
PART II
Other Information
  
Item 1.
Legal Proceedings
Item 1A.
Risk Factors
Item 2.
Unregistered Sales of Equity Securities and Use of Proceeds
Item 6.
Exhibits
 
 
 
 
 
Signature
 
 
Exhibit Index

1



PART I - FINANCIAL INFORMATION

FINANCIAL REVIEW

Summary Financial Data
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
% Change
 
 
 
Quarter ended
 
 
Mar 31, 2016 from
 
 
($ in millions, except per share amounts)
Mar 31, 2016

 
Dec 31, 2015

 
Mar 31, 2015

 
Dec 31, 2015

 
Mar 31, 2015

 
For the Period
 
 
 
 
 
 
 
 
 
 
Wells Fargo net income
$
5,462

 
5,575

 
5,804

 
(2
)%
 
(6
)
 
Wells Fargo net income applicable to common stock
5,085

 
5,203

 
5,461

 
(2
)
 
(7
)
 
Diluted earnings per common share
0.99

 
1.00

 
1.04

 
(1
)
 
(5
)
 
Profitability ratios (annualized):
 
 
 
 
 
 
 
 
 
 
Wells Fargo net income to average assets (ROA)
1.21
%
 
1.24

 
1.38

 
(2
)
 
(12
)
 
Wells Fargo net income applicable to common stock to average Wells Fargo common stockholders' equity (ROE)
11.75

 
11.93

 
13.17

 
(2
)
 
(11
)
 
Efficiency ratio (1)
58.7

 
58.4

 
58.8

 
1

 

 
Total revenue
$
22,195

 
21,586

 
21,278

 
3

 
4

 
Pre-tax pre-provision profit (PTPP) (2)
9,167

 
8,987

 
8,771

 
2

 
5

 
Dividends declared per common share
0.375

 
0.375

 
0.350

 

 
7

 
Average common shares outstanding
5,075.7

 
5,108.5

 
5,160.4

 
(1
)
 
(2
)
 
Diluted average common shares outstanding
5,139.4

 
5,177.9

 
5,243.6

 
(1
)
 
(2
)
 
Average loans
$
927,220

 
912,280

 
863,261

 
2

 
7

 
Average assets
1,819,875

 
1,787,287

 
1,707,798

 
2

 
7

 
Average total deposits
1,219,430

 
1,216,809

 
1,174,793

 

 
4

 
Average consumer and small business banking deposits (3)
714,837

 
696,484

 
665,896

 
3

 
7

 
Net interest margin
2.90
%
 
2.92

 
2.95

 
(1
)
 
(2
)
 
At Period End
 
 
 
 
 
 
 
 
 
 
Investment securities
$
334,899

 
347,555

 
324,736

 
(4
)
 
3

 
Loans
947,258

 
916,559

 
861,231

 
3

 
10

 
Allowance for loan losses
11,621

 
11,545

 
12,176

 
1

 
(5
)
 
Goodwill
27,003

 
25,529

 
25,705

 
6

 
5

 
Assets
1,849,182

 
1,787,632

 
1,737,737

 
3

 
6

 
Deposits
1,241,490

 
1,223,312

 
1,196,663

 
1

 
4

 
Common stockholders' equity
175,534

 
172,036

 
168,834

 
2

 
4

 
Wells Fargo stockholders' equity
197,496

 
192,998

 
188,796

 
2

 
5

 
Total equity
198,504

 
193,891

 
189,964

 
2

 
4

 
Capital ratios (4)(5):
 
 
 
 
 
 
 
 
 
 
Total equity to assets
10.73
%
 
10.85

 
10.93

 
(1
)
 
(2
)
 
Risk-based capital:
 
 
 
 
 
 
 
 
 
 
Common Equity Tier 1
10.87

 
11.07

 
10.69

 
(2
)
 
NM

 
Tier 1 capital
12.49

 
12.63

 
12.20

 
(1
)
 
NM

 
Total capital
14.91

 
15.45

 
15.08

 
(3
)
 
NM

 
Tier 1 leverage
9.26

 
9.37

 
9.48

 
(1
)
 
NM

 
Common shares outstanding
5,075.9

 
5,092.1

 
5,162.9

 

 
(2
)
 
Book value per common share (6)
$
34.58

 
33.78

 
32.70

 
2

 
6

 
Common stock price:
 
 
 
 
 
 
 
 
 
 
High
53.27

 
56.34

 
56.29

 
(5
)
 
(5
)
 
Low
44.50

 
49.51

 
50.42

 
(10
)
 
(12
)
 
Period end
48.36

 
54.36

 
54.40

 
(11
)
 
(11
)
 
Team members (active, full-time equivalent)
268,600

 
264,700

 
266,000

 
1

 
1

 
NM - Not meaningful, as approaches differ between periods.
(1)
The efficiency ratio is noninterest expense divided by total revenue (net interest income and noninterest income).
(2)
Pre-tax pre-provision profit (PTPP) is total revenue less noninterest expense. Management believes that PTPP is a useful financial measure because it enables investors and others to assess the Company's ability to generate capital to cover credit losses through a credit cycle.
(3)
Consumer and small business banking deposits are total deposits excluding mortgage escrow and wholesale deposits.
(4)
The risk-based capital ratios presented at March 31, 2016 and December 31, 2015, were calculated under the lower of Standardized or Advanced Approach determined pursuant to Basel III with Transition Requirements. Accordingly, the total capital ratio was calculated under the Advanced Approach and the other ratios were calculated under the Standardized Approach, for both periods, respectively. The risk-based capital ratios were calculated under the Basel III Standardized Approach at March 31, 2015.
(5)
See the "Capital Management" section and Note 19 (Regulatory and Agency Capital Requirements) to Financial Statements in this Report for additional information.
(6)
Book value per common share is common stockholders' equity divided by common shares outstanding.





2

Overview (continued)

This Quarterly Report, including the Financial Review and the Financial Statements and related Notes, contains forward-looking statements, which may include forecasts of our financial results and condition, expectations for our operations and business, and our assumptions for those forecasts and expectations. Do not unduly rely on forward-looking statements. Actual results may differ materially from our forward-looking statements due to several factors. Factors that could cause our actual results to differ materially from our forward-looking statements are described in this Report, including in the “Forward-Looking Statements” section, and the “Risk Factors” and “Regulation and Supervision” sections of our Annual Report on Form 10-K for the year ended December 31, 2015 (2015 Form 10-K).
 
When we refer to “Wells Fargo,” “the Company,” “we,” “our” or “us” in this Report, we mean Wells Fargo & Company and Subsidiaries (consolidated). When we refer to the “Parent,” we mean Wells Fargo & Company. See the Glossary of Acronyms for terms used throughout this Report.
 
Financial Review
 
Overview
Wells Fargo & Company is a diversified, community-based financial services company with $1.8 trillion in assets. Founded in 1852 and headquartered in San Francisco, we provide banking, insurance, investments, mortgage, and consumer and commercial finance through 8,800 locations, 13,000 ATMs, the internet (wellsfargo.com) and mobile banking, and we have offices in 36 countries to support customers who conduct business in the global economy. With approximately 269,000 active, full-time equivalent team members, we serve one in three households in the United States and ranked No. 30 on Fortune’s 2015 rankings of America’s largest corporations. We ranked third in assets and first in the market value of our common stock among all U.S. banks at March 31, 2016.
We use our Vision and Values to guide us toward growth and success. Our vision is to satisfy our customers’ financial needs, help them succeed financially, be recognized as the premier financial services company in our markets and be one of America’s great companies. We aspire to create deep and enduring relationships with our customers by providing them with an exceptional experience and by discovering their needs and delivering the most relevant products, services, advice, and guidance.
We have five primary values, which are based on our vision and provide the foundation for everything we do. First, we value and support our people as a competitive advantage and strive to attract, develop, retain and motivate the most talented people we can find. Second, we strive for the highest ethical standards with our team members, our customers, our communities and our shareholders. Third, with respect to our customers, we strive to base our decisions and actions on what is right for them in everything we do. Fourth, for team members we strive to build and sustain a diverse and inclusive culture – one where they feel valued and respected for who they are as well as for the skills and experiences they bring to our company. Fifth, we also look to each of our team members to be leaders in establishing, sharing and communicating our vision. In addition to our five primary values, one of our key day-to-day priorities is to make risk management a competitive advantage by working hard to ensure that appropriate controls are in place to reduce risks to our customers, maintain and increase our competitive market position, and protect Wells Fargo’s long-term safety, soundness and reputation.
 
Financial Performance
Wells Fargo net income was $5.5 billion in first quarter 2016 with diluted earnings per common share (EPS) of $0.99, compared with $5.8 billion and $1.04, respectively, a year ago. We have now generated quarterly earnings of more than $5 billion for 14 consecutive quarters, one of only two companies in the U.S. to
 
do so, which reflected the ability of our diversified business model and consistent risk discipline to generate consistent financial performance in an uneven economic environment. While our net income declined from a year ago, the first quarter 2015 results included a discrete tax benefit of $359 million, or $0.07 per share, and a $100 million allowance release. We remain focused on meeting the financial needs of our customers and on investing in our businesses so we may continue to meet the evolving needs of our customers in the future.
Compared with a year ago:
revenue was $22.2 billion, up 4%, with growth in both net interest income and noninterest income;
we grew pre-tax pre-provision profit by 5%;
our total loans reached a record $947.3 billion, an increase of $86.0 billion, or 10%;
our deposit franchise generated strong customer and balance growth, with total deposits reaching a record $1.24 trillion, up $44.8 billion, or 4%, and we grew the number of primary consumer checking customers by 5.0% (February 2016 compared with February 2015); and
our solid capital position enabled us to acquire assets from GE Capital and return $3.0 billion to our shareholders.
 
Balance Sheet and Liquidity
Our balance sheet maintained its strength in first quarter 2016 as we increased our liquidity position, generated loan and deposit growth, experienced solid credit quality and maintained strong capital levels. We have been able to grow our loans on a year-over-year basis for 19 consecutive quarters (for the past 16 quarters year-over-year loan growth has been 3% or greater). Our loan portfolio increased $30.7 billion from December 31, 2015, and included $24.9 billion from the GE Capital acquisitions. First quarter organic loan growth included commercial and industrial, real estate mortgage, real estate construction, lease financing, real estate 1-4 family first mortgage and automobile.
Our investment securities decreased by $12.7 billion, or 4%, from December 31, 2015, due to securities sales and runoff, partially offset by modest securities purchases due to volatility in the bond market. We had $5 billion of gross purchases during first quarter 2016, compared with last year's average of $26 billion per quarter.
Deposit growth continued in first quarter 2016 with period-end deposits up $18.2 billion, or 1%, from December 31, 2015. This increase reflected growth across our consumer businesses. Our average deposit cost was 10 basis points, up 1 basis point from a year ago, which reflected an increase in deposit pricing for certain wholesale banking customers. We successfully grew our primary consumer checking customers (i.e., customers who actively use their checking account with transactions such as debit card purchases, online bill payments, and direct deposit) by 5.0% (February 2016 compared with February 2015). Our ability to consistently grow primary checking customers is important to


3


our results because these customers have more interactions with us and are significantly more profitable than non-primary customers.

Credit Quality
Solid overall credit results continued in first quarter 2016 as losses remained low and we continued to originate high quality loans, reflecting our long-term risk focus. Net charge-offs were $886 million, or 0.38% (annualized) of average loans, in first quarter 2016, compared with $708 million a year ago (0.33%). While substantially all of the loan portfolio continues to perform well, the oil and gas portfolio remains under significant stress due to low energy prices and excess leverage in this industry. The increases in losses and nonperforming loans in first quarter 2016 were primarily due to continued challenges in this portfolio. Our commercial portfolio net charge-offs were $237 million, or 20 basis points of average commercial loans, in first quarter 2016, compared with net charge-offs of $44 million, or 4 basis points, a year ago. Net consumer credit losses declined to 57 basis points of average consumer loans in first quarter 2016 from 60 basis points in first quarter 2015. Our commercial real estate portfolios were in a net recovery position for the 13th consecutive quarter, reflecting our conservative risk discipline and improved market conditions. Losses on our consumer real estate portfolios declined $84 million from a year ago, down 41%. The lower consumer loss levels reflected the benefit of the improving housing market and our continued focus on originating high quality loans. Approximately 68% of the consumer first mortgage portfolio was originated after 2008, when more stringent underwriting standards were implemented.
The allowance for credit losses in first quarter 2016 reflected an allowance build of $200 million as a higher commercial allowance reflecting continued deterioration within the oil and gas portfolio was partially offset by continued credit quality improvements in the residential real estate portfolio. Since first quarter 2015 we have released $1.8 billion of allowance that was allocated to our residential real estate portfolios while providing $1.4 billion of additional allowance allocated to our oil and gas portfolio, demonstrating the advantage of our diversified loan portfolio. Future allowance levels will be based on a variety of factors, including loan growth, portfolio performance and general economic conditions.
 
Nonperforming assets were up $706 million, or 6%, from December 31, 2015. Nonaccrual loans increased $852 million from the prior quarter driven by a $1.1 billion increase in the oil and gas portfolio and the addition of $343 million of nonaccrual loans from the GE Capital acquisitions, which was within our acquisition underwriting assumptions, partially offset by a $684 million decline in consumer real estate nonaccrual loans and a $76 million decline in commercial real estate nonaccrual loans. In addition, foreclosed assets were down $146 million from the prior quarter.

Capital
Our financial performance in first quarter 2016 resulted in strong capital generation, which increased total equity to $198.5 billion at March 31, 2016, up $4.6 billion from the prior quarter. We returned $3.0 billion to shareholders in first quarter 2016 through common stock dividends and net share repurchases and our net payout ratio (which is the ratio of (i) common stock dividends and share repurchases less issuances and stock compensation-related items, divided by (ii) net income applicable to common stock) was 60%, compared with 61% in the prior quarter. We continued to reduce our common share count through the repurchase of 51.7 million common shares in the quarter. We also entered into a $750 million forward repurchase contract with an unrelated third party in April 2016 that is expected to settle in second quarter 2016 for approximately 15 million shares. We expect to reduce our common shares outstanding through share repurchases throughout the remainder of 2016.
We believe an important measure of our capital strength is the Common Equity Tier 1 ratio under Basel III, fully phased-in, which was 10.61% at March 31, 2016. Likewise, our other regulatory capital ratios remained strong. See the “Capital Management” section in this Report for more information regarding our capital, including the calculation of our regulatory capital amounts.



4


Earnings Performance
Wells Fargo net income for first quarter 2016 was $5.5 billion ($0.99 diluted earnings per common share), compared with $5.8 billion ($1.04 diluted per share) for first quarter 2015. Our first quarter 2016 earnings reflected continued strong execution of our business strategy as we continued to satisfy our customers' financial needs. We generated revenue across many of our businesses and grew loans and deposits. Our financial performance in first quarter 2016, compared with the same period a year ago, benefited from a $681 million increase in net interest income, which was offset by a $478 million increase in our provision for credit losses and a $521 million increase in noninterest expense. While our net income declined from a year ago, the first quarter 2015 results included a discrete tax benefit of $359 million primarily from a reduction in the reserve for uncertain tax positions due to audit resolutions of prior period matters with U.S federal and state taxing authorities.
Revenue, the sum of net interest income and noninterest income, was $22.2 billion in first quarter 2016, compared with $21.3 billion in first quarter 2015. The diversified revenue generated by our businesses continued to be balanced between net interest income and noninterest income. The increase in revenue for first quarter 2016, compared with the same period in 2015, was mostly due to an increase in net interest income, reflecting increases in income from trading assets, investment securities, loans, and financing leases. In first quarter 2016, net interest income of $11.7 billion represented 53% of revenue, compared with $11.0 billion (52%) in the same period in 2015.
Noninterest income was $10.5 billion in first quarter 2016, representing 47% of revenue, compared with $10.3 billion (48%) in first quarter 2015. Noninterest income reflected an increase in lease income related to operating leases acquired in the GE Capital transactions, gain from the sale of our crop insurance business, as well as the net impact of hedge ineffectiveness primarily on our long-term debt hedges.
Noninterest expense was $13.0 billion in first quarter 2016, compared with $12.5 billion for the same period in 2015. The increase in noninterest expense reflected higher operating lease expense due to the leases acquired in the GE Capital transactions as well as increases in operating losses, salaries, and employee benefits, partially offset by lower foreclosed assets expense. Noninterest expense as a percentage of revenue (efficiency ratio) was 58.7% in first quarter 2016, compared with 58.8% in first quarter 2015.
 
Net Interest Income
Net interest income is the interest earned on debt securities, loans (including yield-related loan fees) and other interest-earning assets minus the interest paid on deposits, short-term borrowings and long-term debt. The net interest margin is the average yield on earning assets minus the average interest rate paid for deposits and our other sources of funding. Net interest income and the net interest margin are presented on a taxable-equivalent basis in Table 1 to consistently reflect income from taxable and tax-exempt loans and securities based on a 35% federal statutory tax rate.
While the Company believes that it has the ability to increase net interest income over time, net interest income and the net interest margin in any one period can be significantly affected by a variety of factors including the mix and overall size of our earning assets portfolio and the cost of funding those assets. In addition, some variable sources of interest income, such as resolutions from purchased credit-impaired (PCI) loans, loan
 
prepayment fees and collection of interest on nonaccrual loans, can vary from period to period. Net interest income growth has been challenged during the prolonged low interest rate environment as higher yielding loans and securities have runoff and been replaced with lower yielding assets.
Net interest income on a taxable-equivalent basis was $12.0 billion in first quarter 2016, compared with $11.2 billion for the same period a year ago. The net interest margin was 2.90% for first quarter 2016, down from 2.95% in the same period a year ago. The increase in net interest income in first quarter 2016 from the same period a year ago was driven by growth in commercial and consumer loans, including the GE Capital transactions that closed in first quarter 2016, increased trading income, growth in investment securities, and higher short-term interest rates. Funding expense increased in first quarter 2016 compared with first quarter 2015 largely due to higher long-term debt interest expense. Deposit expense was higher compared with first quarter 2015 predominantly due to an increase in wholesale pricing resulting from higher short-term interest rates.
The decline in net interest margin in first quarter 2016, compared with the same period a year ago, was primarily due to customer-driven deposit growth and higher long-term debt balances, including pre-funding for the GE Capital acquisition. As a result of growth in funding balances, net interest margin was diluted by an increase in cash, federal funds sold, and other short-term investments, which was partially offset by growth in loans, trading, and the benefit of higher short-term interest rates. During first quarter 2016, we closed substantially all of the previously announced acquisition of certain commercial lending businesses and assets from GE Capital. A portion of the assets were acquired in January 2016 with additional assets acquired in March 2016. The remaining assets are anticipated to be acquired in the second half of 2016.
Average earning assets increased $117.5 billion in first quarter 2016, compared with the same period a year ago, as average loans increased $64.0 billion, average investment securities increased $28.1 billion, and average trading assets increased $17.5 billion from the same period a year ago. In addition, average federal funds sold and other short-term investments increased $9.0 billion in first quarter 2016, compared with the same period a year ago.
Deposits are an important low-cost source of funding and affect both net interest income and the net interest margin. Deposits include noninterest-bearing deposits, interest-bearing
checking, market rate and other savings, savings certificates,
other time deposits, and deposits in foreign offices. Average deposits of $1.22 trillion remained relatively stable in first quarter 2016, compared with $1.17 trillion in first quarter 2015, and represented 132% of average loans in first quarter 2016 compared with 136% a year ago. Average deposits decreased to 74% of average earning assets in first quarter 2016 compared with 77% for the same period a year ago as the growth in total loans and investment securities outpaced deposit growth.


5


Table 1: Average Balances, Yields and Rates Paid (Taxable-Equivalent Basis) (1)(2)
  
Quarter ended March 31,
 
 
  
 
  
 
2016

 
  
 
  
 
2015

(in millions)
Average
balance

 
Yields/
rates

 
Interest
income/
expense

 
Average
balance

 
Yields/
rates

 
Interest
income/
expense

Earning assets
 
 
 
 
 
 
 
 
 
 
 
Federal funds sold, securities purchased under resale agreements and other short-term investments
$
284,697

 
0.49
%
 
$
344

 
275,731

 
0.28
%
 
$
190

Trading assets
80,464

 
3.01

 
605

 
62,977

 
2.88

 
453

Investment securities (3): 
 
 
 
 
 
 
 
 
 
 
 
Available-for-sale securities:
 
 
 
 
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
34,474

 
1.59

 
136

 
26,163

 
1.55

 
100

Securities of U.S. states and political subdivisions
50,512

 
4.24

 
535

 
44,948

 
4.20

 
472

Mortgage-backed securities:
 
 
 
 
 
 
 
 
 
 
 
Federal agencies
96,423

 
2.80

 
675

 
102,193

 
2.76

 
706

Residential and commercial
20,827

 
5.20

 
271

 
23,938

 
5.71

 
342

Total mortgage-backed securities
117,250

 
3.23

 
946

 
126,131

 
3.32

 
1,048

Other debt and equity securities
53,558

 
3.21

 
429

 
47,051

 
3.43

 
400

Total available-for-sale securities
255,794

 
3.20

 
2,046

 
244,293

 
3.32

 
2,020

Held-to-maturity securities:
 
 
 
 
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
44,664

 
2.20

 
244

 
42,869

 
2.21

 
234

Securities of U.S. states and political subdivisions
2,156

 
5.41

 
29

 
1,948

 
5.16

 
25

Federal agency mortgage-backed securities
28,114

 
2.49

 
175

 
11,318

 
1.87

 
53

Other debt securities
4,598

 
1.92

 
22

 
6,792

 
1.72

 
29

Total held-to-maturity securities
79,532

 
2.37

 
470

 
62,927

 
2.19

 
341

Total investment securities
335,326

 
3.01

 
2,516

 
307,220

 
3.08

 
2,361

Mortgages held for sale (4)
17,870

 
3.59

 
161

 
19,583

 
3.61

 
177

Loans held for sale (4)
282

 
3.23

 
2

 
700

 
2.67

 
5

Loans:
 
 
 
 
 
 
 
 
 
 
 
Commercial:
 
 
 
 
 
 
 
 
 
 
 
Commercial and industrial – U.S.
257,727

 
3.39

 
2,177

 
227,682

 
3.28

 
1,844

Commercial and industrial – Non U.S.
49,508

 
2.10

 
258

 
45,062

 
1.88

 
209

Real estate mortgage
122,739

 
3.41

 
1,040

 
111,497

 
3.57

 
981

Real estate construction
22,603

 
3.61

 
203

 
19,492

 
3.52

 
169

Lease financing
15,047

 
4.74

 
178

 
12,319

 
4.95

 
152

Total commercial
467,624

 
3.31

 
3,856

 
416,052

 
3.26

 
3,355

Consumer:
 
 
 
 
 
 
 
 
 
 
 
Real estate 1-4 family first mortgage
274,722

 
4.05

 
2,782

 
265,823

 
4.13

 
2,741

Real estate 1-4 family junior lien mortgage
52,236

 
4.39

 
571

 
58,880

 
4.27

 
621

Credit card
33,366

 
11.61

 
963

 
30,380

 
11.78

 
883

Automobile
60,114

 
5.67

 
848

 
56,004

 
5.95

 
821

Other revolving credit and installment
39,158

 
5.99

 
584

 
36,122

 
6.01

 
535

Total consumer
459,596

 
5.02

 
5,748

 
447,209

 
5.05

 
5,601

Total loans (4)
927,220

 
4.16

 
9,604

 
863,261

 
4.19

 
8,956

Other
5,808

 
2.06

 
30

 
4,730

 
5.41

 
63

Total earning assets
$
1,651,667

 
3.22
%
 
$
13,262

 
1,534,202

 
3.21
%
 
$
12,205

Funding sources
 
 
 
 
 
 
 
 
 
 
 
Deposits:
 
 
 
 
 
 
 
 
 
 
 
Interest-bearing checking
$
38,711

 
0.12
%
 
$
11

 
39,155

 
0.05
%
 
$
5

Market rate and other savings
651,551

 
0.07

 
107

 
613,413

 
0.06

 
97

Savings certificates
27,880

 
0.45

 
31

 
34,608

 
0.75

 
64

Other time deposits
58,206

 
0.74

 
107

 
56,549

 
0.39

 
56

Deposits in foreign offices
97,682

 
0.21

 
51

 
105,537

 
0.14

 
36

Total interest-bearing deposits
874,030

 
0.14

 
307

 
849,262

 
0.12

 
258

Short-term borrowings
107,857

 
0.25

 
67

 
71,712

 
0.11

 
18

Long-term debt
216,883

 
1.56

 
842

 
183,763

 
1.32

 
604

Other liabilities
16,492

 
2.14

 
89

 
16,894

 
2.30

 
97

Total interest-bearing liabilities
1,215,262

 
0.43

 
1,305

 
1,121,631

 
0.35

 
977

Portion of noninterest-bearing funding sources
436,405

 


 

 
412,571

 


 

Total funding sources
$
1,651,667

 
0.32

 
1,305

 
1,534,202

 
0.26

 
977

Net interest margin and net interest income on a taxable-equivalent basis (5)
 
 
2.90
%
 
$
11,957

 
 
 
2.95
%
 
$
11,228

Noninterest-earning assets
 
 
 
 
 
 
 
 
 
 
 
Cash and due from banks
$
17,995

 
  
 
  
 
17,059

 
  
 
  
Goodwill
26,069

 
  
 
  
 
25,705

 
  
 
  
Other
124,144

 
 
 
 
 
130,832

 
 
 
 
Total noninterest-earning assets
$
168,208

 
 
 
 
 
173,596

 
 
 
 
Noninterest-bearing funding sources
 
 
 
 
 
 
  
 
 
 
 
Deposits
$
345,400

 
 
 
 
 
325,531

 
 
 
 
Other liabilities
62,627

 
 
 
 
 
71,988

 
 
 
 
Total equity
196,586

 
 
 
 
 
188,648

 
 
 
 
Noninterest-bearing funding sources used to fund earning assets
(436,405
)
 
 
 
 
 
(412,571
)
 
 
 
 
Net noninterest-bearing funding sources
$
168,208

 
 
 
 
 
173,596

 
 
 
 
Total assets
$
1,819,875

 
 
 
 
 
1,707,798

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(1)
Our average prime rate was 3.50% and 3.25% for the quarters ended March 31, 2016 and 2015, respectively. The average three-month London Interbank Offered Rate (LIBOR) was 0.62% and 0.26% for the quarters ended March 31, 2016 and 2015, respectively.
(2)
Yields/rates and amounts include the effects of hedge and risk management activities associated with the respective asset and liability categories.
(3)
Yields and rates are based on interest income/expense amounts for the period, annualized based on the accrual basis for the respective accounts. The average balance amounts represent amortized cost for the periods presented.
(4)
Nonaccrual loans and related income are included in their respective loan categories.
(5)
Includes taxable-equivalent adjustments of $290 million and $242 million for the quarters ended March 31, 2016 and 2015, respectively, primarily related to tax-exempt income on certain loans and securities. The federal statutory tax rate utilized was 35% for the periods presented.

6

Earnings Performance (continued)




Noninterest Income
Table 2: Noninterest Income
 
Quarter ended Mar 31,
 
 
 
(in millions)
2016

 
2015

 
% Change

Service charges on deposit accounts
$
1,309

 
1,215

 
8
 %
Trust and investment fees:
 
 
 
 
 
Brokerage advisory, commissions and other fees
2,239

 
2,380

 
(6
)
Trust and investment management
815

 
852

 
(4
)
Investment banking
331

 
445

 
(26
)
Total trust and investment fees
3,385

 
3,677

 
(8
)
Card fees
941

 
871

 
8

Other fees:
 
 
 
 

Charges and fees on loans
313

 
309

 
1

Cash network fees
131

 
125

 
5

Commercial real estate brokerage commissions
117

 
129

 
(9
)
Letters of credit fees
78

 
88

 
(11
)
Wire transfer and other remittance fees
92

 
87

 
6

All other fees (1)(2)(3)
202

 
340

 
(41
)
Total other fees
933


1,078

 
(13
)
Mortgage banking:
 
 
 
 

Servicing income, net
850

 
523

 
63

Net gains on mortgage loan origination/sales activities
748

 
1,024

 
(27
)
Total mortgage banking
1,598


1,547

 
3

Insurance
427

 
430

 
(1
)
Net gains (losses) from trading activities
200

 
408

 
(51
)
Net gains on debt securities
244

 
278

 
(12
)
Net gains from equity investments
244

 
370

 
(34
)
Lease income
373

 
132

 
183

Life insurance investment income
154

 
145

 
6

All other (3)
720

 
141

 
411

Total
$
10,528


10,292

 
2

(1)
Wire transfer and other remittance fees, reflected in all other fees prior to 2016, have been separately disclosed.
(2)
All other fees have been revised to include merchant processing fees for all periods presented.
(3)
Effective fourth quarter 2015, the Company's proportionate share of its merchant services joint venture earnings is included in all other income.

Noninterest income was $10.5 billion and $10.3 billion for first quarter 2016 and 2015, respectively. This income represented 47% of revenue for first quarter 2016, compared with 48% for the same period in 2015. Noninterest income in first quarter 2016 benefited from the previously announced sale of our crop insurance business, hedge ineffectiveness primarily on our long-term debt hedges, and the increase in lease income related to the GE Capital acquisitions we completed in the quarter. Many of our businesses, including credit and debit cards, middle market banking, international, mortgage banking, and venture capital, also grew noninterest income in first quarter 2016.
Service charges on deposit accounts were $1.3 billion in first quarter 2016, compared with $1.2 billion in first quarter 2015. The increase was driven by higher overdraft fees, account growth and higher fees from commercial product sales and commercial product re-pricing.
Brokerage advisory, commissions and other fees are received for providing full-service and discount brokerage services predominantly to retail brokerage clients. Income from these brokerage-related activities include asset-based fees for advisory accounts, which are based on the market value of the client’s assets, and transactional commissions based on the number and size of transactions executed at the client’s direction. These fees decreased to $2.2 billion in first quarter 2016 from $2.4 billion
 
for the same period in 2015. The decrease was predominantly due to lower brokerage transaction revenue and lower asset-based fees as a result of lower market values at the end of the prior quarter pricing period. Retail brokerage client assets totaled $1.42 trillion at March 31, 2016, compared with $1.44 trillion at March 31, 2015, with all retail brokerage services provided by our Wealth and Investment Management (WIM) operating segment. For additional information on retail brokerage client assets, see the discussion and Tables 4d and 4e in the "Operating Segment Results – Wealth and Investment Management – Retail Brokerage Client Assets" section in this Report.
We earn trust and investment management fees from managing and administering assets, including mutual funds, institutional separate accounts, corporate trust, personal trust, employee benefit trust and agency assets. Trust and investment management fee income is predominantly from client assets under management (AUM) for which the fees are determined based on a tiered scale relative to the market value of the AUM. AUM consists of assets for which we have investment management discretion. Our AUM totaled $645.7 billion at March 31, 2016, compared with $660.2 billion at March 31, 2015, with substantially all of our AUM managed by our WIM operating segment. Additional information regarding our WIM operating segment AUM is provided in Table 4f and the related discussion


7


in the "Operating Segment Results – Wealth and Investment Management – Trust and Investment Client Assets Under Management" section in this Report. In addition to AUM we have client assets under administration (AUA) that earn various administrative fees which are generally based on the extent of the services provided to administer the account. Our AUA totaled $1.3 trillion at March 31, 2016, compared with $1.5 trillion at March 31, 2015. Trust and investment management fees decreased to $815 million in first quarter 2016 from $852 million for the same period in 2015, due to lower AUM reflecting lower market values.
We earn investment banking fees from underwriting debt and equity securities, arranging loan syndications, and performing other related advisory services. Investment banking fees decreased to $331 million in first quarter 2016 from $445 million for the same period in 2015, driven by declines in equity origination due to market volatility.
Card fees were $941 million in first quarter 2016, compared with $871 million for the same period a year ago. The increase was primarily due to account growth and increased purchase activity.
Other fees decreased to $933 million in first quarter 2016, from $1.1 billion for the same period in 2015, predominantly driven by lower all other fees. In first quarter 2016, all other fees decreased to $202 million from $340 million for the same period in 2015, mainly due to the deconsolidation of our merchant services joint venture in fourth quarter 2015, which resulted in a proportionate share of that income now being reported in all other income.
Mortgage banking noninterest income, consisting of net servicing income and net gains on loan origination/sales activities, totaled $1.6 billion in first quarter 2016, compared with $1.5 billion for the same period a year ago.
In addition to servicing fees, net mortgage loan servicing income includes amortization of commercial mortgage servicing rights (MSRs), changes in the fair value of residential MSRs during the period, as well as changes in the value of derivatives (economic hedges) used to hedge the residential MSRs. Net servicing income of $850 million for first quarter 2016 included a $498 million net MSR valuation gain ($957 million decrease in the fair value of the MSRs and a $1.5 billion hedge gain). Net servicing income of $523 million for first quarter 2015 included a $108 million net MSR valuation gain ($773 million decrease in the fair value of the MSRs and an $881 million hedge gain). The increase in net MSR valuation gains in first quarter 2016, compared with the same period in 2015, was primarily attributable to MSR valuation adjustments in first quarter 2015 that reflected higher prepayment expectations due to the reduction in FHA mortgage insurance premiums as well as a reduction in forecasted prepayments in first quarter 2016 due to updated economic and mortgage market rate inputs.
Our portfolio of loans serviced for others was $1.77 trillion at March 31, 2016, and $1.78 trillion at December 31, 2015. At March 31, 2016, the ratio of combined residential and commercial MSRs to related loans serviced for others was 0.72%, compared with 0.77% at December 31, 2015. See the “Risk Management – Asset/Liability Management – Mortgage Banking Interest Rate and Market Risk” section in this Report for additional information regarding our MSRs risks and hedging approach.
Net gains on mortgage loan origination/sale activities was $748 million in first quarter 2016, compared with $1.0 billion for the same period a year ago. The decrease in first quarter 2016 compared with first quarter 2015 was primarily driven by a decrease in mortgage loan originations and production margins.
 
Mortgage loan originations were $44 billion for first quarter 2016, compared with $49 billion for the same period a year ago. The production margin on residential held-for-sale mortgage originations, which represents net gains on residential mortgage loan origination/sales activities divided by total residential held-for-sale mortgage originations, provides a measure of the profitability of our residential mortgage origination activity. Table 2a presents the information used in determining the production margin.

Table 2a: Selected Residential Mortgage Production Data
 
 
Quarter ended Mar 31, 
 
 
 
2016

2015

Net gains on mortgage loan origination/sales activities (in millions):
 
 
 
Residential
(A)
$
532

711

Commercial
 
71

91

Residential pipeline and unsold/repurchased loan management (1)
 
145

222

Total
 
$
748

1,024

Residential real estate originations (in billions):
 
 
 
Held-for-sale
(B)
$
31

37

Held-for-investment
 
13

12

Total
 
$
44

49

Production margin on residential held-for-sale mortgage originations
(A)/(B)
1.68
%
1.93

(1)
Primarily includes the results of GNMA loss mitigation activities, interest rate management activities and changes in estimate to the liability for mortgage loan repurchase losses.

The production margin was 1.68% for first quarter 2016, compared with 1.93% for the same period a year ago primarily due to a higher mix of correspondent production. Mortgage applications were $77 billion in first quarter 2016, compared with $93 billion for the same period a year ago. The 1-4 family first mortgage unclosed pipeline was $39 billion at March 31, 2016, compared with $44 billion at March 31, 2015. For additional information about our mortgage banking activities and results, see the “Risk Management – Asset/Liability Management – Mortgage Banking Interest Rate and Market Risk” section and Note 8 (Mortgage Banking Activities) and Note 13 (Fair Values of Assets and Liabilities) to Financial Statements in this Report.
Net gains on mortgage loan origination/sales activities include adjustments to the mortgage repurchase liability. Mortgage loans are repurchased from third parties based on standard representations and warranties, and early payment default clauses in mortgage sale contracts. For first quarter 2016, we released a net $12 million from the repurchase liability, compared with a net $16 million release for first quarter 2015. For additional information about mortgage loan repurchases, see the “Risk Management – Credit Risk Management – Liability for Mortgage Loan Repurchase Losses” section and Note 8 (Mortgage Banking Activities) to Financial Statements in this Report.
We engage in trading activities primarily to accommodate the investment activities of our customers, and to execute economic hedging to manage certain components of our balance sheet risks. Net gains (losses) from trading activities, which reflect unrealized changes in fair value of our trading positions and realized gains and losses, were $200 million in first quarter 2016, compared with $408 million for the same period a year ago. The decrease was primarily driven by lower economic hedge


8

Earnings Performance (continued)




income, lower customer accommodation trading activity within our capital markets business, and lower deferred compensation gains (offset in employee benefits expense). Net gains from trading activities do not include interest and dividend income and expense on trading securities. Those amounts are reported within interest income from trading assets and other interest expense from trading liabilities. For additional information about our trading activities, see the “Risk Management – Asset/Liability Management – Market Risk – Trading Activities” section in this Report. 
Net gains on debt and equity securities totaled $488 million for first quarter 2016 and $648 million for first quarter 2015, after other-than-temporary impairment (OTTI) write-downs of $198 million and $73 million for first quarter 2016 and 2015, respectively. OTTI write-downs in first quarter 2016 mainly reflected deterioration in energy sector investments and largely drove the decrease in net gains on debt and equity securities in first quarter 2016 compared with the same period a year ago.
Lease income was $373 million in first quarter 2016, compared with $132 million for the same period a year ago, primarily driven by the closing of the GE Capital acquisitions in first quarter 2016.
All other income was $720 million in first quarter 2016, compared with $141 million for the same period a year ago. All
 
other income includes ineffectiveness recognized on derivatives that qualify for hedge accounting, the results of certain economic hedges, losses on low income housing tax credit investments, foreign currency adjustments, and income from investments accounted for under the equity method, any of which can cause decreases and net losses in other income. The increase in other income for first quarter 2016, compared with the same period a year ago, primarily reflected a $381 million gain on sale of our crop insurance business and changes in ineffectiveness recognized on interest rate swaps used to hedge our exposure to interest rate risk on long-term debt and cross-currency swaps, cross-currency interest rate swaps and forward contracts used to hedge our exposure to foreign currency risk and interest rate risk involving non-U.S. dollar denominated long-term debt. A portion of the hedge ineffectiveness recognized was partially offset by the results of certain economic hedges and accordingly we recognized a net hedge benefit of $379 million in first quarter 2016 as compared with $123 million for the same period a year ago. For additional information about derivatives used as part of our asset/liability management, see Note 12 (Derivatives) to Financial Statements in this Report.


Noninterest Expense
Table 3: Noninterest Expense
 
Quarter ended Mar 31,
 
 
%

(in millions)
2016

 
2015

 
Change

Salaries
$
4,036

 
3,851

 
5
 %
Commission and incentive compensation
2,645

 
2,685

 
(1
)
Employee benefits
1,526

 
1,477

 
3

Equipment
528

 
494

 
7

Net occupancy
711

 
723

 
(2
)
Core deposit and other intangibles
293

 
312

 
(6
)
FDIC and other deposit assessments
250

 
248

 
1

Outside professional services
583

 
548

 
6

Operating losses
454

 
295

 
54

Outside data processing
208

 
253

 
(18
)
Contract services
282

 
225

 
25

Postage, stationery and supplies
163

 
171

 
(5
)
Travel and entertainment
172

 
158

 
9

Advertising and promotion
134

 
118

 
14

Insurance
111

 
140

 
(21
)
Telecommunications
92

 
111

 
(17
)
Foreclosed assets
78

 
135

 
(42
)
Operating leases
235

 
62

 
279

All other
527

 
501

 
5

Total
$
13,028

 
12,507

 
4


Noninterest expense was $13.0 billion in first quarter 2016, up 4% from $12.5 billion in the same period a year ago, driven by higher personnel expenses, operating leases, operating losses, and higher contract services, partially offset by lower foreclosed assets expense.
Personnel expenses, which include salaries, commissions, incentive compensation and employee benefits, were up $194 million, or 2%, in first quarter 2016 compared with the same period a year ago, predominantly due to annual salary increases, an extra payroll day in first quarter 2016, and
 
increased staffing in risk management and our non-mortgage businesses.
Operating lease expense was up $173 million in first quarter 2016 compared with the same period a year ago, largely due to the leases acquired from GE Capital.
Operating losses were up $159 million, or 54%, in first quarter 2016 compared with the same period a year ago, predominantly due to litigation expense for various legal matters.
Contract services expense was up $57 million, or 25%, in first quarter 2016 compared with the same period a year ago. Many


9


noninterest expense categories in first quarter 2016, including contract services and outside professional services, reflected continued investments in our products, technology and service delivery, as well as costs for the heightened industry focus on regulatory compliance and evolving cybersecurity risk.
Foreclosed assets expense was down $57 million, or 42%, in first quarter 2016 compared with the same period a year ago, mainly driven by lower operating expenses and lower write-downs.
The efficiency ratio was 58.7% in first quarter 2016, compared with 58.8% in first quarter 2015. The Company expects to operate at the higher end of its targeted efficiency ratio range of 55-59% for full year 2016.

Income Tax Expense
Our effective tax rate was 32.0% and 28.2% for first quarter 2016 and 2015, respectively. The effective tax rate for first quarter 2015 reflected $359 million of discrete tax benefits primarily from
 
reductions in reserves for uncertain tax positions due to audit resolutions of prior period matters with U.S. federal and state taxing authorities.

Operating Segment Results
We are organized for management reporting purposes into three operating segments: Community Banking; Wholesale Banking; and WIM. These segments are defined by product type and customer segment and their results are based on our management accounting process, for which there is no comprehensive, authoritative financial accounting guidance equivalent to generally accepted accounting principles (GAAP). Table 4 and the following discussion present our results by operating segment. For additional description of our operating segments, including additional financial information and the underlying management accounting process, see Note 18 (Operating Segments) to Financial Statements in this Report.

Table 4: Operating Segment Results – Highlights
(income/expense in millions,
 
Community Banking
 
 
Wholesale Banking
 
 
Wealth and Investment Management
 
 
Other (1)
 
 
Consolidated
Company
 
average balances in billions)
 
2016

 
2015

 
2016

 
2015

 
2016

 
2015

 
2016

 
2015

 
2016

 
2015

Quarter ended March 31,
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Revenue
 
$
12,614

 
12,111

 
6,958

 
6,409

 
3,854

 
3,976

 
(1,231
)
 
(1,218
)
 
22,195

 
21,278

Provision (reversal of provision) for credit losses
 
720

 
658

 
363

 
(51
)
 
(14
)
 
(3
)
 
17

 
4

 
1,086

 
608

Noninterest expense
 
6,836

 
6,591

 
3,968

 
3,618

 
3,042

 
3,122

 
(818
)
 
(824
)
 
13,028

 
12,507

Net income (loss)
 
3,296

 
3,547

 
1,921

 
1,974

 
512

 
529

 
(267
)
 
(246
)
 
5,462

 
5,804

Average loans
 
$
484.3

 
472.2

 
429.8

 
380.0

 
64.1

 
56.9

 
(51.0
)
 
(45.8
)
 
927.2

 
863.3

Average deposits
 
683.0

 
643.4

 
428.0

 
431.7

 
184.5

 
170.3

 
(76.1
)
 
(70.6
)
 
1,219.4

 
1,174.8

(1)
Includes items not specific to a business segment and elimination of certain items that are included in more than one business segment, substantially all of which represents products and services for WIM customers served through Community Banking distribution channels.

Cross-sell We aspire to create deep and enduring relationships with our customers by providing them with an exceptional experience and by discovering their needs and delivering the most relevant products, services, advice, and guidance. An outcome of offering customers the products and services they need, want and value is that we earn more opportunities to serve them, or what we call cross-sell. Cross-sell is the result of serving our customers well, understanding their financial needs and goals over their lifetimes, and ensuring we innovate our products, services and channels so that we earn more of their business and help them succeed financially. Our approach to cross-sell is needs-based as some customers will benefit from more products, and some may need fewer. We believe there is continued opportunity to meet our customers' financial needs as we build lifelong relationships with them. One way we track the degree to which we are satisfying our customers' financial needs is through our cross-sell metrics, which are based on whether the customer is a retail bank household or has a wholesale banking relationship. For additional information regarding our cross-sell metrics, see the "Earnings Performance – Operating Segments – Cross-sell" section in our 2015 Form 10-K.
 
Operating Segment Results
The following discussion provides a description of each of our operating segments, including cross-sell metrics and financial results.

Community Banking offers a complete line of diversified financial products and services for consumers and small businesses including checking and savings accounts, credit and debit cards, and auto, student, and small business lending. These products also include investment, insurance and trust services in 39 states and D.C., and mortgage and home equity loans in all 50 states and D.C. The Community Banking segment also includes the results of our Corporate Treasury activities net of allocations in support of the other operating segments and results of investments in our affiliated venture capital partnerships. Our retail bank household cross-sell was 6.09 products per household in February 2016, compared with 6.13 in February 2015. Table 4a provides additional financial information for Community Banking.


10

Earnings Performance (continued)




Table 4a: Community Banking
 
Quarter ended March 31,
 
 
 
(in millions, except average balances which are in billions)
2016

 
2015

 
% Change

Net interest income
$
7,468

 
7,147

 
4
 %
Noninterest income:
 
 
 
 
 
Service charges on deposit accounts
753

 
692

 
9

Trust and investment fees:
 
 
 
 

Brokerage advisory, commissions and other fees (1)
450

 
506

 
(11
)
Trust and investment management (1)
205

 
214

 
(4
)
Investment banking (2)
(19
)
 
(36
)
 
47

Total trust and investment fees
636

 
684

 
(7
)
Card fees
852

 
790

 
8

Other fees
372

 
359

 
4

Mortgage banking
1,508

 
1,435

 
5

Insurance
2

 
31

 
(94
)
Net gains (losses) from trading activities
(27
)
 
83

 
NM

Net gains on debt securities
219

 
206

 
6

Net gains from equity investments (3)
175

 
290

 
(40
)
Other income of the segment
656

 
394

 
66

Total noninterest income
5,146

 
4,964

 
4

 
 
 
 
 

Total revenue
12,614

 
12,111

 
4

 
 
 
 
 

Provision for credit losses
720

 
658

 
9

Noninterest expense:
 
 
 
 

Personnel expense
4,618

 
4,518

 
2

Equipment
493

 
461

 
7

Net occupancy
510

 
527

 
(3
)
Core deposit and other intangibles
128

 
144

 
(11
)
FDIC and other deposit assessments
146

 
130

 
12

Outside professional services
185

 
180

 
3

Operating losses
407

 
226

 
80

Other expense of the segment
349

 
405

 
(14
)
Total noninterest expense
6,836

 
6,591

 
4

Income before income tax expense and noncontrolling interests
5,058

 
4,862

 
4

Income tax expense
1,697

 
1,290

 
32

Net income from noncontrolling interests (4)
65

 
25

 
160

Net income
$
3,296

 
3,547

 
(7
)
Average loans
$
484.3

 
472.2

 
3

Average deposits
683.0

 
643.4

 
6

NM – Not meaningful
(1)
Represents income on products and services for Wealth and Investment Management customers served through Community Banking distribution channels and is eliminated in consolidation.
(2)
Includes syndication and underwriting fees paid to Wells Fargo Securities which are offset in our Wholesale Banking segment.
(3)
Predominantly represents gains resulting from venture capital investments.
(4)
Reflects results attributable to noncontrolling interests primarily associated with the Company’s consolidated venture capital investments.
Community Banking reported net income of $3.3 billion, down $251 million, or 7%, from first quarter 2015. First quarter 2015 results included a discrete tax benefit of $359 million. Revenue of $12.6 billion increased $503 million, or 4%, from a year ago primarily due to higher net interest income, other income driven by positive hedge ineffectiveness related to our long term debt hedging results, mortgage banking fees, deposit service charges, and revenue from debit and credit card volumes, partially offset by lower market sensitive revenue, primarily gains on equity investments and trading activities, and lower trust and investment fees. Average loans of $484.3 billion in first quarter 2016 increased $12.1 billion, or 3%, from first quarter 2015. Average deposits increased $39.6 billion, or 6%, from first quarter 2015. Noninterest expense increased $245 million, or 4%,
 
from first quarter 2015, driven by higher operating losses and personnel expenses, partially offset by lower foreclosed assets expense. The provision for credit losses increased $62 million from a year ago primarily due to an allowance build compared with an allowance release in first quarter 2015.


11


Wholesale Banking provides financial solutions to businesses across the United States and globally with annual sales generally in excess of $5 million. Products and businesses include Business Banking, Middle Market Commercial Banking, Government and Institutional Banking, Corporate Banking, Commercial Real Estate, Treasury Management, Wells Fargo Capital Finance, Insurance, International, Real Estate Capital Markets, Commercial Mortgage Servicing, Corporate Trust, Equipment Finance, Wells Fargo Securities, Principal Investments, and Asset
 
Backed Finance. Wholesale Banking cross-sell is reported on a one-quarter lag and for first quarter 2016 was 7.3 products per relationship, up from 7.2 for first quarter 2015. Wholesale Banking cross-sell does not reflect Business Banking relationships, which were realigned from Community Banking to Wholesale Banking effective fourth quarter 2015. Table 4b provides additional financial information for Wholesale Banking.

Table 4b: Wholesale Banking
 
Quarter ended March 31,
 
 
 
(in millions, except average balances which are in billions)
2016

 
2015

 
% Change

Net interest income
$
3,748

 
3,437

 
9
 %
Noninterest income:
 
 
 
 
 
Service charges on deposit accounts
555

 
523

 
6

Trust and investment fees:
 
 
 
 

Brokerage advisory, commissions and other fees
91

 
66

 
38

Trust and investment management
111

 
100

 
11

Investment banking
350

 
484

 
(28
)
Total trust and investment fees
552

 
650

 
(15
)
Card fees
89

 
81

 
10

Other fees
560

 
718

 
(22
)
Mortgage banking
91

 
113

 
(19
)
Insurance
425

 
398

 
7

Net gains from trading activities
207

 
277

 
(25
)
Net gains on debt securities
25

 
72

 
(65
)
Net gains from equity investments
66

 
75

 
(12
)
Other income of the segment
640

 
65

 
885

Total noninterest income
3,210

 
2,972

 
8

 
 
 
 
 

Total revenue
6,958

 
6,409

 
9

 
 
 
 
 

Provision (reversal of provision) for credit losses
363

 
(51
)
 
812

Noninterest expense:
 
 
 
 

Personnel expense
1,974

 
1,839

 
7

Equipment
21

 
20

 
5

Net occupancy
118

 
114

 
4

Core deposit and other intangibles
90

 
87

 
3

FDIC and other deposit assessments
86

 
96

 
(10
)
Outside professional services
214

 
169

 
27

Operating losses
37

 
9

 
311

Other expense of the segment
1,428

 
1,284

 
11

Total noninterest expense
3,968

 
3,618

 
10

Income before income tax expense and noncontrolling interests
2,627

 
2,842

 
(8
)
Income tax expense
719

 
817

 
(12
)
Net income (loss) from noncontrolling interests
(13
)
 
51

 
NM

Net income
$
1,921

 
1,974

 
(3
)
Average loans
$
429.8

 
380.0

 
13

Average deposits
428.0

 
431.7

 
(1
)
NM – Not meaningful
Wholesale Banking reported net income of $1.9 billion, down $53 million, or 3%, from first quarter 2015. Revenue grew $549 million, or 9%, from first quarter 2015 on both increased net interest income and noninterest income. Net interest income increased $311 million, or 9%, driven by strong loan growth and the GE Capital acquisitions. Noninterest income increased $238 million, or 8%, on the gain related to the sale of our crop
 
insurance business, the GE Capital acquisitions and increased treasury management fees, partially offset by lower gains on debt securities, lower customer accommodation trading, and lower investment banking fees. Average loans of $429.8 billion increased $49.8 billion, or 13%, from first quarter 2015, driven by broad based growth including asset backed finance, commercial real estate, corporate banking, equipment finance and structured


12

Earnings Performance (continued)




real estate as well as the GE Capital acquisitions. Average deposits of $428.0 billion decreased $3.7 billion, or 1%, from first quarter 2015 reflecting lower interest bearing deposits, primarily in the International business, driven by market volatility and the competitive market environment. Noninterest expense increased $350 million, or 10%, from first quarter 2015 primarily due to the GE Capital acquisitions and higher personnel expense related to growth initiatives, compliance and regulatory requirements. The provision for credit losses increased $414 million from first quarter 2015 primarily due to deterioration in the oil and gas portfolio.

Wealth and Investment Management provides a full range of personalized wealth management, investment and retirement products and services to clients across U.S. based businesses
 
including Wells Fargo Advisors, The Private Bank, Abbot Downing, Wells Fargo Institutional Retirement and Trust, and Wells Fargo Asset Management. We deliver financial planning, private banking, credit, investment management and fiduciary services to high-net worth and ultra-high-net worth individuals and families. We also serve clients’ brokerage needs, supply retirement and trust services to institutional clients and provide investment management capabilities delivered to global institutional clients through separate accounts and the Wells Fargo Funds. WIM cross-sell was 10.55 products per retail banking household in February 2016, up from 10.44 in February 2015. Table 4c provides additional financial information for WIM.

Table 4c: Wealth and Investment Management
 
Quarter ended March 31,
 
 
 
(in millions, except average balances which are in billions)
2016

 
2015

 
% Change

Net interest income
$
943

 
826

 
14
 %
Noninterest income:
 
 
 
 
 
Service charges on deposit accounts
5

 
4

 
25

Trust and investment fees:
 
 
 
 
 
Brokerage advisory, commissions and other fees
2,154

 
2,313

 
(7
)
Trust and investment management
712

 
760

 
(6
)
Investment banking (1)

 
(3
)
 
100

Total trust and investment fees
2,866

 
3,070

 
(7
)
Card fees
1

 
1

 

Other fees
4

 
4

 

Mortgage banking
(2
)
 
(2
)
 

Insurance

 
1

 
(100
)
Net gains from trading activities
20

 
48

 
(58
)
Net gains on debt securities

 

 
NM

Net gains from equity investments
3

 
5

 
(40
)
Other income of the segment
14

 
19

 
(26
)
Total noninterest income
2,911

 
3,150

 
(8
)
 
 
 
 
 
 
Total revenue
3,854

 
3,976

 
(3
)
 
 
 
 
 
 
Reversal of provision for credit losses
(14
)
 
(3
)
 
NM

Noninterest expense:
 
 
 
 
 
Personnel expense
2,025

 
2,074

 
(2
)
Equipment
15

 
14

 
7

Net occupancy
112

 
111

 
1

Core deposit and other intangibles
75

 
81

 
(7
)
FDIC and other deposit assessments
31

 
37

 
(16
)
Outside professional services
191

 
206

 
(7
)
Operating losses
12

 
62

 
(81
)
Other expense of the segment
581

 
537

 
8

Total noninterest expense
3,042

 
3,122

 
(3
)
Income before income tax expense and noncontrolling interests
826

 
857

 
(4
)
Income tax expense
314

 
324

 
(3
)
Net income (loss) from noncontrolling interests

 
4

 
(100
)
Net income
$
512

 
529

 
(3
)
Average loans
$
64.1

 
56.9

 
13

Average deposits
184.5

 
170.3

 
8

NM – Not meaningful
(1)
Includes syndication and underwriting fees paid to Wells Fargo Securities which are offset in our Wholesale Banking segment.

13


WIM reported net income of $512 million in first quarter 2016, down $17 million, or 3%, from first quarter 2015 primarily driven by lower noninterest income, partially offset by higher net interest income and lower expenses. Revenue of $3.9 billion in first quarter 2016 was down $122 million, or 3%, from first quarter 2015 driven by lower asset-based fees and lower brokerage transaction revenue, partially offset by growth in net interest income. Net interest income increased 14% from first quarter 2015 due to growth in investment portfolios and loan balances. Average loan balances of $64.1 billion in first quarter 2016 increased 13% from first quarter 2015. Average deposits in first quarter 2016 of $184.5 billion increased 8% from first quarter 2015. Noninterest expense of $3.0 billion in first quarter 2016 was down $80 million, or 3%, from first quarter 2015, primarily driven by decreased broker commissions and lower operating losses reflecting decreased litigation accruals, partially offset by higher other personnel expenses. Total provision for credit losses decreased $11 million from first quarter 2015, driven by lower net charge-offs.
The following discussions provide additional information for client assets we oversee in our retail brokerage advisory and trust and investment management business lines.
 
Retail Brokerage Client Assets Brokerage advisory, commissions and other fees are received for providing full-service and discount brokerage services predominantly to retail brokerage clients. Offering advisory account relationships to our brokerage clients is an important component of our broader strategy of meeting their financial needs. Although most of our retail brokerage client assets are in accounts that earn brokerage commissions, the fees from those accounts generally represent transactional commissions based on the number and size of transactions executed at the client’s direction. Fees earned from advisory accounts are asset-based and depend on changes in the value of the client’s assets as well as the level of assets resulting from inflows and outflows. A major portion of our brokerage advisory, commissions and other fee income is earned from advisory accounts. Table 4d shows advisory account client assets as a percentage of total retail brokerage client assets at March 31, 2016 and 2015.

Table 4d: Retail Brokerage Client Assets
 
Quarter ended March 31,
 
(in billions)
2016

 
2015

Retail brokerage client assets
$
1,415.7

 
1,442.7

Advisory account client assets
428.2

 
434.5

Advisory account client assets as a percentage of total client assets
30
%
 
30


Retail Brokerage advisory accounts include assets that are financial advisor-directed and separately managed by third-party managers, as well as certain client-directed brokerage assets where we earn a fee for advisory and other services, but do not have investment discretion. These advisory accounts generate fees as a percentage of the market value of the assets, which vary across the account types based on the distinct services provided,
 

and are affected by investment performance as well as asset inflows and outflows. For first quarter 2016 and 2015, the average fee rate by account type ranged from 80 to 120 basis points. Table 4e presents retail brokerage advisory account client assets activity by account type for first quarter 2016 and 2015.


Table 4e: Retail Brokerage Advisory Account Client Assets
(in billions)
Client
 directed (1)

 
Financial advisor directed (2)

 
Separate accounts (3)

 
Mutual fund advisory (4)

 
Total advisory client assets

December 31, 2014
$
159.8

 
85.4

 
110.7

 
66.9

 
422.8

Inflows (5)
10.3

 
5.4

 
6.0

 
2.9

 
24.6

Outflows (6)
(8.7
)
 
(3.6
)
 
(4.9
)
 
(2.9
)
 
(20.1
)
Market impact (7)
1.6

 
2.7

 
1.8

 
1.1

 
7.2

March 31, 2015
$
163.0

 
89.9

 
113.6

 
68.0

 
434.5

December 31, 2015
$
154.7

 
91.9

 
110.4

 
62.9

 
419.9

Inflows (5)
8.9

 
7.3

 
5.7

 
1.9

 
23.8

Outflows (6)
(9.2
)
 
(4.0
)
 
(4.8
)
 
(3.0
)
 
(21.0
)
Market impact (7)
0.9

 
2.2

 
2.2

 
0.2

 
5.5

March 31, 2016
$
155.3

 
97.4

 
113.5

 
62.0

 
428.2

(1)
Investment advice and other services are provided to client, but decisions are made by the client and the fees earned are based on a percentage of the advisory account assets, not the number and size of transactions executed by the client.
(2)
Professionally managed portfolios with fees earned based on respective strategies and as a percentage of certain client assets.
(3)
Professional advisory portfolios managed by Wells Fargo asset management advisors or third-party asset managers. Fees are earned based on a percentage of certain client assets.
(4)
Program with portfolios constructed of load-waived, no-load and institutional share class mutual funds. Fees are earned based on a percentage of certain client assets.
(5)
Inflows include new advisory account assets, contributions, dividends and interest.
(6)
Outflows include withdrawals, closed accounts’ assets and client management fees.
(7)
Market impact reflects gains and losses on portfolio investments.



14

Earnings Performance (continued)




Trust and Investment Client Assets Under Management We earn trust and investment management fees from managing and administering assets, including mutual funds, institutional separate accounts, personal trust, employee benefit trust and agency assets through our asset management, wealth and retirement businesses. Our asset management business is conducted by Wells Fargo Asset Management (WFAM), which offers Wells Fargo proprietary mutual funds and manages institutional separate accounts. Our wealth business manages
 
assets for high net worth clients, and our retirement business provides total retirement management, investments, and trust and custody solutions tailored to meet the needs of institutional clients. Substantially all of our trust and investment management fee income is earned from AUM where we have discretionary management authority over the investments and generate fees as a percentage of the market value of the AUM. Table 4f presents AUM activity for first quarter 2016 and 2015.

Table 4f: WIM Trust and Investment – Assets Under Management
 
Assets Managed by WFAM (1)
 
 
 
 
 
(in billions)
Money market funds (2)

 
Other assets managed

 
Assets managed by Wealth and Retirement (3)

 
Total assets under management

December 31, 2014
$
123.1

 
372.6

 
165.3

 
661.0

Inflows (4)

 
26.6

 
8.8

 
35.4

Outflows (5)
(11.8
)
 
(23.2
)
 
(9.2
)
 
(44.2
)
Market impact (6)

 
5.4

 
1.9

 
7.3

March 31, 2015
$
111.3

 
381.4

 
166.8

 
659.5

December 31, 2015
$
123.6

 
366.1

 
162.1

 
651.8

Inflows (4)

 
27.1

 
9.1

 
36.2

Outflows (5)
(9.7
)
 
(28.5
)
 
(8.8
)
 
(47.0
)
Market impact (6)

 
2.4

 
1.0

 
3.4

March 31, 2016
$
113.9

 
367.1

 
163.4

 
644.4

(1)
Assets managed by Wells Fargo Asset Management consist of equity, alternative, balanced, fixed income, money market, and stable value, and include client assets that are managed or sub-advised on behalf of other Wells Fargo lines of business.
(2)
Money Market fund activity is presented on a net inflow or net outflow basis, because the gross flows are not meaningful nor used by management as an indicator of performance.
(3)
Includes $8.2 billion and $8.9 billion as of December 31, 2015 and 2014, and $8.3 billion and $8.4 billion as of March 31, 2016 and 2015, respectively, of client assets invested in proprietary funds managed by WFAM.
(4)
Inflows include new managed account assets, contributions, dividends and interest.
(5)
Outflows include withdrawals, closed accounts’ assets and client management fees.
(6)
Market impact reflects gains and losses on portfolio investments.



15


Balance Sheet Analysis 
At March 31, 2016, our assets totaled $1.8 trillion, up $61.6 billion from December 31, 2015. The predominant areas of asset growth were in federal funds sold and other short-term investments, which increased $30.4 billion, loans, which increased $30.7 billion (including $24.9 billion from the first quarter 2016 GE Capital transactions), and other assets, which increased $18.7 billion (including $5.9 billion in operating leases from the first quarter 2016 GE Capital transactions), partially offset by a decrease in investment securities of $12.7 billion. An increase of $28.4 billion in long-term debt (primarily to fund the GE Capital transactions), deposit growth of $18.2 billion, an
 
increase in short-term borrowings of $10.2 billion, and total equity growth of $4.6 billion from December 31, 2015, were the predominant sources that funded our asset growth in the first three months of 2016. Equity growth benefited from $3.0 billion in earnings net of dividends paid.
The following discussion provides additional information about the major components of our balance sheet. Information regarding our capital and changes in our asset mix is included in the “Earnings Performance – Net Interest Income” and “Capital Management” sections and Note 19 (Regulatory and Agency Capital Requirements) to Financial Statements in this Report.


Investment Securities
Table 5: Investment Securities – Summary
 
March 31, 2016
 
 
December 31, 2015
 
(in millions)
Amortized Cost

 
Net
 unrealized
gain

 
Fair value

 
Amortized Cost

 
Net
unrealized
gain

 
Fair value

Available-for-sale securities:
 
 
 
 
 
 
 
 
 
 
 
Debt securities
$
251,040

 
3,012

 
254,052

 
263,318

 
2,403

 
265,721

Marketable equity securities
1,034

 
465

 
1,499

 
1,058

 
579

 
1,637

Total available-for-sale securities
252,074

 
3,477

 
255,551

 
264,376

 
2,982

 
267,358

Held-to-maturity debt securities
79,348

 
2,377

 
81,725

 
80,197

 
370

 
80,567

Total investment securities (1)
$
331,422

 
5,854

 
337,276

 
344,573

 
3,352

 
347,925

(1)
Available-for-sale securities are carried on the balance sheet at fair value. Held-to-maturity securities are carried on the balance sheet at amortized cost.

Table 5 presents a summary of our investment securities portfolio, which decreased $12.7 billion from December 31, 2015, primarily due to sales and paydowns of Federal agency mortgage-backed securities and lower security purchases due to bond market volatility. The total net unrealized gains on available-for-sale securities were $3.5 billion at March 31, 2016, up from $3.0 billion at December 31, 2015, primarily due to a decline in interest rates, partially offset by wider credit spreads. For a discussion of our investment management objectives and practices, see the "Balance Sheet Analysis" section in our 2015 Form 10-K. Also, see the “Risk Management – Asset/Liability Management” section in this Report for information on our use of investments to manage liquidity and interest rate risk.
We analyze securities for other-than-temporary impairment (OTTI) quarterly or more often if a potential loss-triggering event occurs. Of the $198 million in OTTI write-downs recognized in earnings in first quarter 2016, $65 million related to debt securities and $4 million related to marketable equity securities, which are included in available-for-sale securities. Another $129 million in OTTI write-downs were related to nonmarketable equity investments, which are included in other assets. OTTI write-downs recognized in earnings related to oil and gas investments totaled $124 million in first quarter 2016, of which $46 million related to investment securities and $78 million related to nonmarketable equity investments. For a discussion of our OTTI accounting policies and underlying considerations and analysis see Note 1 (Summary of Significant Accounting Policies) to Financial Statements in our 2015 Form 10-K and Note 4 (Investment Securities) to Financial Statements in this Report.
At March 31, 2016, investment securities included $53.8 billion of municipal bonds, of which 95.1% were rated “A-” or better based predominantly on external and, in some cases, internal ratings. Additionally, some of the securities in our total
 
municipal bond portfolio are guaranteed against loss by bond insurers. These guaranteed bonds are substantially all investment grade and were generally underwritten in accordance with our own investment standards prior to the determination to purchase, without relying on the bond insurer’s guarantee in making the investment decision. The credit quality of our municipal bond holdings are monitored as part of our ongoing impairment analysis.
The weighted-average expected maturity of debt securities available-for-sale was 5.9 years at March 31, 2016. Because 46% of this portfolio is MBS, the expected remaining maturity is shorter than the remaining contractual maturity because borrowers generally have the right to prepay obligations before the underlying mortgages mature. The estimated effects of a 200 basis point increase or decrease in interest rates on the fair value and the expected remaining maturity of the MBS available-for-sale portfolio are shown in Table 6.
Table 6: Mortgage-Backed Securities Available for Sale
(in billions)
Fair value

 
Net unrealized gain (loss)

 
Expected remaining maturity
(in years)

At March 31, 2016
 
 
 
 
 
Actual
$
116.7

 
3.1

 
5.0

Assuming a 200 basis point:
 
 
 
 
 
Increase in interest rates
106.7

 
(6.9
)
 
6.8

Decrease in interest rates
119.2

 
5.6

 
2.6


The weighted-average expected maturity of debt securities held-to-maturity was 5.8 years at March 31, 2016. See Note 4


16

Balance Sheet Analysis (continued)

(Investment Securities) to Financial Statements in this Report for a summary of investment securities by security type.
Loan Portfolios
Table 7 provides a summary of total outstanding loans by portfolio segment. Total loans increased $30.7 billion from
 
December 31, 2015, predominantly due to growth in commercial and industrial, real estate mortgage and lease financing loans within the commercial loan portfolio segment, which included $24.9 billion of commercial and industrial loans and capital leases acquired from GE Capital in first quarter 2016.

Table 7: Loan Portfolios
(in millions)
March 31, 2016

 
December 31, 2015

Commercial
$
488,205

 
456,583

Consumer
459,053

 
459,976

Total loans
$
947,258

 
916,559

Change from prior year-end
$
30,699

 
54,008


A discussion of average loan balances and a comparative detail of average loan balances is included in Table 1 under “Earnings Performance – Net Interest Income” earlier in this Report. Additional information on total loans outstanding by portfolio segment and class of financing receivable is included in the “Risk Management – Credit Risk Management” section in this Report. Period-end balances and other loan related information are in Note 5 (Loans and Allowance for Credit Losses) to Financial Statements in this Report. 
 
Table 8 shows contractual loan maturities for loan categories normally not subject to regular periodic principal reduction and the contractual distribution of loans in those categories to changes in interest rates.
 

Table 8: Maturities for Selected Commercial Loan Categories
 
 
March 31, 2016
 
 
December 31, 2015
 
(in millions)
 
Within
one
 year

 
After one
year
through
five years

 
After
 five
years

 
Total

 
Within
one
year

 
After one
year
through
 five years

 
After
five
years

 
Total

Selected loan maturities:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Commercial and industrial
 
$
100,820

 
196,699

 
24,028

 
321,547

 
91,214

 
184,641

 
24,037

 
299,892

Real estate mortgage
 
19,568

 
69,453

 
35,690

 
124,711

 
18,622

 
68,391

 
35,147

 
122,160

Real estate construction
 
8,498

 
13,037

 
1,409

 
22,944

 
7,455

 
13,284

 
1,425

 
22,164

Total selected loans
 
$
128,886

 
279,189

 
61,127

 
469,202

 
117,291

 
266,316

 
60,609

 
444,216

Distribution of loans to changes in interest
rates:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Loans at fixed interest rates
 
$
18,474

 
30,908

 
24,228

 
73,610

 
16,819

 
27,705

 
23,533

 
68,057

Loans at floating/variable interest rates
 
110,412

 
248,281

 
36,899

 
395,592

 
100,472

 
238,611

 
37,076

 
376,159

Total selected loans
 
$
128,886

 
279,189

 
61,127

 
469,202

 
117,291

 
266,316

 
60,609

 
444,216



17


Deposits
Deposit grew $18.2 billion during first quarter 2016 to $1.24 trillion reflecting continued broad-based growth across our consumer businesses. Table 9 provides additional information regarding deposits. Information regarding the impact of deposits
 
on net interest income and a comparison of average deposit balances is provided in “Earnings Performance – Net Interest Income” and Table 1 earlier in this Report.
 

Table 9: Deposits
($ in millions)
Mar 31,
2016

 
% of
total
deposits

 
Dec 31,
2015

 
% of
total
deposits

 

% Change

Noninterest-bearing
$
348,888

 
28
%
 
$
351,579

 
29
%
 
(1
)
Interest-bearing checking
38,121

 
3

 
40,115

 
3

 
(5
)
Market rate and other savings
668,441

 
54

 
651,563

 
54

 
3

Savings certificates
27,028

 
2

 
28,614

 
2

 
(6
)
Other time and deposits
59,555

 
5

 
49,032

 
4

 
21

Deposits in foreign offices (1)
99,457

 
8

 
102,409

 
8

 
(3
)
Total deposits
$
1,241,490

 
100
%
 
$
1,223,312

 
100
%
 
1

(1)
Includes Eurodollar sweep balances of $62.9 billion and $71.1 billion at March 31, 2016, and December 31, 2015, respectively.

Fair Value of Financial Instruments
We use fair value measurements to record fair value adjustments to certain financial instruments and to determine fair value disclosures. See our 2015 Form 10-K for a description of our critical accounting policy related to fair value of financial instruments and a discussion of our fair value measurement techniques.
Table 10 presents the summary of the fair value of financial instruments recorded at fair value on a recurring basis, and the amounts measured using significant Level 3 inputs (before derivative netting adjustments). The fair value of the remaining assets and liabilities were measured using valuation methodologies involving market-based or market-derived information (collectively Level 1 and 2 measurements).
Table 10: Fair Value Level 3 Summary
 
March 31, 2016
 
 
December 31, 2015
 
($ in billions)
Total
balance

 
Level 3 (1)

 
Total
balance

 
Level 3 (1)

Assets carried
at fair value (2)
$
373.0

 
26.8

 
384.2

 
27.6

As a percentage
of total assets
20
%
 
1

 
21

 
2

Liabilities carried
at fair value
$
32.5

 
1.6

 
29.6

 
1.5

As a percentage of
total liabilities
2
%
 
*

 
2

 

* Less than 1%.
(1)
Before derivative netting adjustments.
(2)
Level 3 assets at December 31, 2015, have been revised in accordance with our adoption of Accounting Standards Update 2015-07 (Disclosures for Investments in Certain Entities that Calculate Net Asset Value per Share (or Its Equivalent)). See Note 13 (Fair Values of Assets and Liabilities) to Financial Statements in this Report for additional information.

See Note 13 (Fair Values of Assets and Liabilities) to Financial Statements in this Report for additional information on fair value measurements and a description of the Level 1, 2 and 3 fair value hierarchy.
 
Equity
Total equity was $198.5 billion at March 31, 2016 compared with $193.9 billion at December 31, 2015. The increase was primarily driven by a $3.0 billion increase in retained earnings from earnings net of dividends paid, and a $1.8 billion increase in preferred stock, partially offset by a net reduction in common stock due to repurchases.




18



Off-Balance Sheet Arrangements
In the ordinary course of business, we engage in financial transactions that are not recorded on the balance sheet, or may be recorded on the balance sheet in amounts that are different from the full contract or notional amount of the transaction. Our off-balance sheet arrangements include commitments to lend and purchase securities, transactions with unconsolidated entities, guarantees, derivatives, and other commitments. These transactions are designed to (1) meet the financial needs of customers, (2) manage our credit, market or liquidity risks, and/or (3) diversify our funding sources.
 
Commitments to Lend and Purchase Securities
We enter into commitments to lend funds to customers, which are usually at a stated interest rate, if funded, and for specific purposes and time periods. When we make commitments, we are exposed to credit risk. However, the maximum credit risk for these commitments will generally be lower than the contractual amount because a portion of these commitments are expected to expire without being used by the customer. For more information on lending commitments, see Note 5 (Loans and Allowance for Credit Losses) to Financial Statements in this Report. We also enter into commitments to purchase securities under resale agreements. For more information on commitments to purchase securities under resale agreements, see Note 3 (Federal Funds Sold, Securities Purchased under Resale Agreements and Other Short-Term Investments) to Financial Statements in this Report.
 
Transactions with Unconsolidated Entities
We routinely enter into various types of on- and off-balance sheet transactions with special purpose entities (SPEs), which are corporations, trusts or partnerships that are established for a limited purpose. Generally, SPEs are formed in connection with securitization transactions. For more information on securitizations, including sales proceeds and cash flows from securitizations, see Note 7 (Securitizations and Variable Interest Entities) to Financial Statements in this Report.
 
Guarantees and Certain Contingent Arrangements
Guarantees are contracts that contingently require us to make payments to a guaranteed party based on an event or a change in an underlying asset, liability, rate or index. Guarantees are generally in the form of standby letters of credit, securities lending and other indemnifications, written put options, recourse obligations and other types of guarantee arrangements.
For more information on guarantees and certain contingent arrangements, see Note 10 (Guarantees, Pledged Assets and Collateral) to Financial Statements in this Report.

Derivatives
We primarily use derivatives to manage exposure to market risk, including interest rate risk, credit risk and foreign currency risk, and to assist customers with their risk management objectives. Derivatives are recorded on the balance sheet at fair value and volume can be measured in terms of the notional amount, which is generally not exchanged, but is used only as the basis on which interest and other payments are determined. The notional amount is not recorded on the balance sheet and is not, when viewed in isolation, a meaningful measure of the risk profile of the instruments.
For more information on derivatives, see Note 12 (Derivatives) to Financial Statements in this Report.
 
Other Commitments
We also have other off-balance sheet transactions, including obligations to make rental payments under noncancelable operating leases and commitments to purchase certain debt and equity securities. Our operating lease obligations are discussed in Note 7 (Premises, Equipment, Lease Commitments and Other Assets) to Financial Statements in our 2015 Form 10-K. For more information on commitments to purchase debt and equity securities, see the “Off-Balance Sheet Arrangements” section in our 2015 Form 10-K.



19


Risk Management
Wells Fargo manages a variety of risks that can significantly affect our financial performance and our ability to meet the expectations of our customers, stockholders, regulators and other stakeholders. Among the risks that we manage are operational risk, credit risk, and asset/liability management risk, which includes interest rate risk, market risk, and liquidity and funding risks. Our risk culture is strongly rooted in our Vision and Values, and in order to succeed in our mission of satisfying our customers’ financial needs and helping them succeed financially, our business practices and operating model must support prudent risk management practices. For more information about how we manage these risks, see the “Risk Management” section in our 2015 Form 10-K. The discussion that follows provides an update regarding these risks.
Operational Risk Management
Operational risk is the risk of loss resulting from inadequate or failed internal controls and processes, people and systems, or resulting from external events. These losses may be caused by events such as fraud, breaches of customer privacy, business disruptions, inappropriate employee behavior, vendors that do not perform their responsibilities, and regulatory fines and penalties.
Information security is a significant operational risk for financial institutions such as Wells Fargo, and includes the risk of losses resulting from cyber attacks. Wells Fargo and other financial institutions continue to be the target of various evolving and adaptive cyber attacks, including malware and denial-of-service, as part of an effort to disrupt the operations of financial institutions, potentially test their cybersecurity capabilities, or obtain confidential, proprietary or other information. Wells Fargo has not experienced any material losses relating to these or other cyber attacks. Addressing cybersecurity risks is a priority for Wells Fargo, and we continue to develop and enhance our controls, processes and systems in order to protect our networks, computers, software and data from attack, damage or unauthorized access. We are also proactively involved in industry cybersecurity efforts and working with other parties, including our third-party service providers and governmental agencies, to continue to enhance defenses and improve resiliency to cybersecurity threats. See the “Risk Factors” section in our 2015 Form 10-K for additional information regarding the risks associated with a failure or breach of our operational or security systems or infrastructure, including as a result of cyber attacks.


Credit Risk Management
We define credit risk as the risk of loss associated with a borrower or counterparty default (failure to meet obligations in accordance with agreed upon terms). Credit risk exists with many of our assets and exposures such as debt security holdings, certain derivatives, and loans. The following discussion focuses on our loan portfolios, which represent the largest component of assets on our balance sheet for which we have credit risk. Table 11 presents our total loans outstanding by portfolio segment and class of financing receivable.
 
Table 11: Total Loans Outstanding by Portfolio Segment and Class of Financing Receivable
(in millions)
Mar 31, 2016

 
Dec 31, 2015

Commercial:
 
 
 
Commercial and industrial
$
321,547

 
299,892

Real estate mortgage
124,711

 
122,160

Real estate construction
22,944

 
22,164

Lease financing
19,003

 
12,367

Total commercial
488,205

 
456,583

Consumer:
 
 
 
Real estate 1-4 family first mortgage
274,734

 
273,869

Real estate 1-4 family junior lien mortgage
51,324

 
53,004

Credit card
33,139

 
34,039

Automobile
60,658

 
59,966

Other revolving credit and installment
39,198

 
39,098

Total consumer
459,053

 
459,976

Total loans
$
947,258

 
916,559


We manage our credit risk by establishing what we believe are sound credit policies for underwriting new business, while monitoring and reviewing the performance of our existing loan portfolios. We employ various credit risk management and monitoring activities to mitigate risks associated with multiple risk factors affecting loans we hold, could acquire or originate including:
Loan concentrations and related credit quality
Counterparty credit risk
Economic and market conditions
Legislative or regulatory mandates
Changes in interest rates
Merger and acquisition activities
Reputation risk

Our credit risk management oversight process is governed centrally, but provides for decentralized management and accountability by our lines of business. Our overall credit process includes comprehensive credit policies, disciplined credit underwriting, frequent and detailed risk measurement and modeling, extensive credit training programs, and a continual loan review and audit process.
A key to our credit risk management is adherence to a well-controlled underwriting process, which we believe is appropriate for the needs of our customers as well as investors who purchase the loans or securities collateralized by the loans.



20

Risk Management - Credit Risk Management (continued)

Credit Quality Overview  Credit quality remained solid in first quarter 2016 due in part to an improving housing market, as well as our proactive credit risk management activities. We continued to benefit from improvements in the performance of our residential real estate portfolio, offset by an increase in our commercial allowance to reflect continued deterioration in the oil and gas portfolio. In particular:
Although commercial nonaccrual loans increased to $4.0 billion at March 31, 2016, compared with $2.4 billion at December 31, 2015, consumer nonaccrual loans declined to $8.3 billion at March 31, 2016, compared with $9.0 billion at December 31, 2015. The increase in commercial nonaccrual loans was primarily driven by continued deterioration in the oil and gas portfolio and was partially offset by a decline in consumer nonaccrual loans, partly due to a sale. Nonaccrual loans represented 1.29% of total loans at March 31, 2016, compared with 1.24% at December 31, 2015.
Net charge-offs (annualized) as a percentage of average total loans increased to 0.38% in first quarter 2016, compared with 0.33% for the same period a year ago. Net charge-offs (annualized) as a percentage of our average commercial and consumer portfolios were 0.20% and 0.57% in first quarter 2016, respectively, compared with 0.04% and 0.60%, respectively, in first quarter 2015.
Loans that are not government insured/guaranteed and 90 days or more past due and still accruing were $34 million and $769 million in our commercial and consumer portfolios, respectively, at March 31, 2016, compared with $114 million and $867 million at December 31, 2015.
Our provision for credit losses was $1.1 billion in first quarter 2016, compared with $608 million for the same period a year ago.
The allowance for credit losses increased to $12.7 billion, or 1.34% of total loans, at March 31, 2016, from $12.5 billion, or 1.37%, at December 31, 2015.
 
Additional information on our loan portfolios and our credit quality trends follows.


 
PURCHASED CREDIT-IMPAIRED (PCI) LOANS Loans acquired with evidence of credit deterioration since their origination and where it is probable that we will not collect all contractually required principal and interest payments are PCI loans. Substantially all of our PCI loans were acquired in the Wachovia acquisition on December 31, 2008. PCI loans are recorded at fair value at the date of acquisition, and the historical allowance for credit losses related to these loans is not carried over. The carrying value of PCI loans at March 31, 2016, which included $1.1 billion from the GE Capital acquisitions, totaled $20.3 billion, compared with $20.0 billion at December 31, 2015, and $58.8 billion at December 31, 2008. Such loans are considered to be accruing due to the existence of the accretable yield and not based on consideration given to contractual interest payments. The accretable yield at March 31, 2016, was $16.0 billion.
A nonaccretable difference is established for PCI loans to absorb losses expected on the contractual amounts of those loans in excess of the fair value recorded at the date of acquisition. Amounts absorbed by the nonaccretable difference do not affect the income statement or the allowance for credit losses. Since December 31, 2008, we have released $11.7 billion in nonaccretable difference, including $9.8 billion transferred from the nonaccretable difference to the accretable yield and $1.9 billion released to income through loan resolutions. Also, we have provided $1.7 billion for losses on certain PCI loans or pools of PCI loans that have had credit-related decreases to cash flows expected to be collected. The net result is a $10.0 billion reduction from December 31, 2008, through March 31, 2016, in our initial projected losses of $41.0 billion on all PCI loans. At March 31, 2016, $2.3 billion in nonaccretable difference, which included $347 million from the GE Capital acquisitions, remained to absorb losses on PCI loans.
For additional information on PCI loans, see Note 1 (Summary of Significant Accounting Policies) to Financial Statements in our 2015 Form 10-K, and Note 5 (Loans and Allowance for Credit Losses) to Financial Statements in this Report.



21


Significant Loan Portfolio Reviews Measuring and monitoring our credit risk is an ongoing process that tracks delinquencies, collateral values, FICO scores, economic trends by geographic areas, loan-level risk grading for certain portfolios (typically commercial) and other indications of credit risk. Our credit risk monitoring process is designed to enable early identification of developing risk and to support our determination of an appropriate allowance for credit losses. The following discussion provides additional characteristics and analysis of our significant portfolios. See Note 5 (Loans and Allowance for Credit Losses) to Financial Statements in this Report for more analysis and credit metric information for each of the following portfolios.

COMMERCIAL AND INDUSTRIAL LOANS AND LEASE FINANCING  For purposes of portfolio risk management, we aggregate commercial and industrial loans and lease financing according to market segmentation and standard industry codes. We generally subject commercial and industrial loans and lease financing to individual risk assessment using our internal borrower and collateral quality ratings. Our ratings are aligned to regulatory definitions of pass and criticized categories with criticized divided between special mention, substandard, doubtful and loss categories.
The commercial and industrial loans and lease financing portfolio totaled $340.6 billion, or 36% of total loans, at March 31, 2016. The annualized net charge-off rate for this portfolio was 0.34% in first quarter 2016, compared with 0.28% in fourth quarter 2015, and 0.09% in first quarter 2015. At March 31, 2016, 0.88% of this portfolio was nonaccruing, compared with 0.44% at December 31, 2015. In addition, $32.7 billion of this portfolio was rated as criticized in accordance with regulatory guidance at March 31, 2016, compared with $19.1 billion at December 31, 2015. The increase in nonaccrual and criticized loans in this portfolio was predominantly in the oil and gas portfolio.
A majority of our commercial and industrial loans and lease financing portfolio is secured by short-term assets, such as accounts receivable, inventory and securities, as well as long-lived assets, such as equipment and other business assets. Generally, the collateral securing this portfolio represents a secondary source of repayment.
Table 12 provides a breakout of commercial and industrial loans and lease financing by industry, and includes $52.9 billion of foreign loans at March 31, 2016. Foreign loans totaled $15.4 billion within the investor category, $16.3 billion within the financial institutions category and $2.0 billion within the oil and gas category.
The investors category includes loans to special purpose vehicles (SPVs) formed by sponsoring entities to invest in financial assets backed predominantly by commercial and residential real estate or corporate cash flow, and are repaid from the asset cash flows or the sale of assets by the SPV. We limit loan amounts to a percentage of the value of the underlying assets, as determined by us, based primarily on analysis of underlying credit risk and other factors such as asset duration and ongoing performance.
 
We provide financial institutions with a variety of relationship focused products and services, including loans supporting short-term trade finance and working capital needs. The $16.3 billion of foreign loans in the financial institutions category were predominantly originated by our Global Financial Institutions (GFI) business.
The oil and gas loan portfolio totaled $17.8 billion, or 2% of total outstanding loans, at March 31, 2016, compared with $17.4 billion, or 2% of total outstanding loans, at December 31, 2015. Unfunded loan commitments in the oil and gas loan portfolio totaled $22.9 billion at March 31, 2016. Approximately half of the increase in oil and gas loans from year-end was due to the GE Capital acquisitions. Slightly more than half of our oil and gas loans were to businesses in the exploration and production (E&P) sector. Most of these E&P loans are secured by oil and/or gas reserves and have underlying borrowing base arrangements which include regular (typically semi-annual) “redeterminations” that consider refinements to borrowing structure and prices used to determine borrowing limits. All other oil and gas loans were to midstream and services and equipment companies. We proactively monitor our oil and gas loan portfolio and work with customers to address any emerging issues. Driven by a drop in energy prices, oil and gas nonaccrual loans increased to $1.9 billion at March 31, 2016, compared with $844 million at December 31, 2015.
Table 12: Commercial and Industrial Loans and Lease Financing by Industry (1)
 
March 31, 2016
 
(in millions)
Nonaccrual
loans

 
Total
portfolio

 
(2)
 
% of
total
loans

Investors
$
31

 
52,944

 
 
 
5
%
Financial institutions
33

 
36,983

 
 
 
4

Cyclical retailers
21

 
25,441

 
 
 
3

Oil and gas
1,899

 
17,841

 
 
 
2

Healthcare
39

 
16,487

 
 
 
2

Real estate lessor

 
15,604

 
 
 
2

Industrial equipment
35

 
15,099

 
 
 
2

Food and beverage
15

 
14,880

 
 
 
1

Technology
69

 
10,377

 
 
 
1

Transportation
28

 
9,969

 
 
 
1

Public administration
8

 
9,309

 
 
 
1

Business services
35

 
8,631

 
 
 
1

Other
797

 
106,985

 
(3)
 
11

Total
$
3,010

 
340,550

 
 
 
36
%
(1)
Industry categories are based on the North American Industry Classification System and the amounts reported include foreign loans. See Note 5 (Loans and Allowance for Credit Losses) to Financial Statements in this Report for a breakout of commercial foreign loans.
(2)
Includes $1.2 billion of PCI loans, which are considered to be accruing due to the existence of the accretable yield and not based on consideration given to contractual interest payments.
(3)
No other single industry had total loans in excess of $7.2 billion


22

Risk Management - Credit Risk Management (continued)

COMMERCIAL REAL ESTATE (CRE) We generally subject CRE loans to individual risk assessment using our internal borrower and collateral quality ratings. Our ratings are aligned to regulatory definitions of pass and criticized categories with criticized divided between special mention, substandard, doubtful and loss categories. The CRE portfolio, which included $8.6 billion of foreign CRE loans, totaled $147.7 billion, or 16% of total loans, at March 31, 2016, and consisted of $124.7 billion of mortgage loans and $23.0 billion of construction loans.
Table 13 summarizes CRE loans by state and property type with the related nonaccrual totals. The portfolio is diversified both geographically and by property type. The largest geographic concentrations of combined CRE loans are in California, Texas, New York and Florida, which combined represented 49% of the
 
total CRE portfolio. By property type, the largest concentrations are office buildings at 29% and apartments at 15% of the portfolio. CRE nonaccrual loans totaled 0.6% of the CRE outstanding balance at March 31, 2016, compared with 0.7% at December 31, 2015. At March 31, 2016, we had $6.3 billion of criticized CRE mortgage loans, compared with $6.8 billion at December 31, 2015, and $562 million of criticized CRE construction loans, compared with $549 million at December 31, 2015.
At March 31, 2016, the recorded investment in PCI CRE loans totaled $571 million, down from $12.3 billion when acquired at December 31, 2008, reflecting principal payments, loan resolutions and write-downs.

Table 13: CRE Loans by State and Property Type
 
March 31, 2016
 
 
Real estate mortgage
 
 
 
 
Real estate construction
 
 
 
 
Total
 
 
 
 
 
(in millions)
Nonaccrual
loans

 
Total
portfolio

 
(1)
 
Nonaccrual
loans

 
Total
portfolio

 
(1)
 
Nonaccrual
loans

 
Total
portfolio

 
(1)
 
% of
total
loans

By state:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
California
$
206

 
35,581

 
 
 
11

 
4,458

 
 
 
217

 
40,039

 
 
 
4
%
Texas
56

 
8,977

 
 
 
1

 
1,878

 
 
 
57

 
10,855

 
 
 
1

New York
32

 
8,718

 
 
 
1

 
1,944

 
 
 
33

 
10,662

 
 
 
1

Florida
86

 
8,308

 
 
 
1

 
2,174

 
 
 
87

 
10,482

 
 
 
1

North Carolina
61

 
3,687

 
 
 
7

 
847

 
 
 
68

 
4,534

 
 
 
*

Arizona
45

 
3,957

 
 
 
1

 
523

 
 
 
46

 
4,480

 
 
 
*

Washington
28

 
3,540

 
 
 

 
775

 
 
 
28

 
4,315

 
 
 
*

Georgia
58

 
3,596

 
 
 
9

 
447

 
 
 
67

 
4,043

 
 
 
*

Illinois
27

 
3,481

 
 
 

 
374

 
 
 
27

 
3,855

 
 
 
*

Virginia
12

 
2,802

 
 
 

 
977

 
 
 
12

 
3,779

 
 
 
*

Other
285

 
42,064

 
 
 
32

 
8,547

 
 
 
317

 
50,611

 
(2)
 
5

Total
$
896

 
124,711

 
 
 
63

 
22,944

 
 
 
959

 
147,655

 
 
 
16
%
By property:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Office buildings
$
256

 
39,487

 
 
 

 
2,963

 
 
 
256

 
42,450

 
 
 
4
%
Apartments
26

 
13,676

 
 
 

 
7,979

 
 
 
26

 
21,655

 
 
 
2

Industrial/warehouse
131

 
14,376

 
 
 

 
1,304

 
 
 
131

 
15,680

 
 
 
2

Retail (excluding shopping center)
118

 
14,600

 
 
 

 
777

 
 
 
118

 
15,377

 
 
 
2

Shopping center
43

 
10,150

 
 
 

 
1,214

 
 
 
43

 
11,364

 
 
 
1

Hotel/motel
22

 
9,351

 
 
 

 
1,445

 
 
 
22

 
10,796

 
 
 
1

Real estate - other
112

 
9,067

 
 
 

 
211

 
 
 
112

 
9,278

 
 
 
1

Institutional
33

 
3,049

 
 
 

 
722

 
 
 
33

 
3,771

 
 
 
*

Land (excluding 1-4 family)
1

 
345

 
 
 
10

 
2,599

 
 
 
11

 
2,944

 
 
 
*

Agriculture
52

 
2,550

 
 
 

 
22

 
 
 
52

 
2,572

 
 
 
*

Other
102

 
8,060

 
 
 
53

 
3,708

 
 
 
155

 
11,768

 
 
 
1

Total
$
896

 
124,711

 
 
 
63

 
22,944

 
 
 
959

 
147,655

 
 
 
16
%
*
Less than 1%.
(1)
Includes a total of $571 million PCI loans, consisting of $483 million of real estate mortgage and $88 million of real estate construction, which are considered to be accruing due to the existence of the accretable yield and not based on consideration given to contractual interest payments.
(2)
Includes 40 states; no state had loans in excess of $3.6 billion.



23


FOREIGN LOANS AND COUNTRY RISK EXPOSURE We classify loans for financial statement and certain regulatory purposes as foreign primarily based on whether the borrower’s primary address is outside of the United States. At March 31, 2016, foreign loans totaled $62.1 billion, representing approximately 7% of our total consolidated loans outstanding, compared with $58.6 billion, or approximately 6% of total consolidated loans outstanding, at December 31, 2015. Foreign loans were approximately 3% of our consolidated total assets at March 31, 2016 and at December 31, 2015.
Our foreign country risk monitoring process incorporates frequent dialogue with our financial institution customers, counterparties and regulatory agencies, enhanced by centralized monitoring of macroeconomic and capital markets conditions in the respective countries. We establish exposure limits for each country through a centralized oversight process based on customer needs, and in consideration of relevant economic, political, social, legal, and transfer risks. We monitor exposures closely and adjust our country limits in response to changing conditions.
We evaluate our individual country risk exposure on an ultimate country of risk basis, which is normally based on the country of residence of the guarantor or collateral location, and is different from the reporting based on the borrower’s primary address. Our largest single foreign country exposure on an ultimate risk basis at March 31, 2016, was the United Kingdom, which totaled $27.0 billion, or approximately 1% of our total assets, and included $3.6 billion of sovereign claims. Our United Kingdom sovereign claims arise predominantly from deposits we have placed with the Bank of England pursuant to regulatory requirements in support of our London branch. Our exposure to Canada, our second largest foreign country exposure on an ultimate risk basis, totaled $18.2 billion at March 31, 2016, up $3.1 billion from December 31, 2015, predominantly due to the GE Capital acquisitions.
 
We conduct periodic stress tests of our significant country risk exposures, analyzing the direct and indirect impacts on the risk of loss from various macroeconomic and capital markets scenarios. We do not have significant exposure to foreign country risks because our foreign portfolio is relatively small. However, we have identified exposure to increased loss from U.S. borrowers associated with the potential impact of a regional or worldwide economic downturn on the U.S. economy. We mitigate these potential impacts on the risk of loss through our normal risk management processes which include active monitoring and, if necessary, the application of aggressive loss mitigation strategies.
Table 14 provides information regarding our top 20 exposures by country (excluding the U.S.) and our Eurozone exposure, on an ultimate risk basis. Our exposure to Puerto Rico (considered part of U.S. exposure) is primarily through automobile lending and was not material to our consolidated country risk exposure.


24

Risk Management - Credit Risk Management (continued)

Table 14: Select Country Exposures
 
March 31, 2016
 
 
Lending (1)
 
 
Securities (2)
 
 
Derivatives and other (3)
 
 
Total exposure
 
(in millions)
Sovereign

 
Non-
sovereign

 
Sovereign

 
Non-
sovereign

 
Sovereign

 
Non-
sovereign

 
Sovereign

 
Non-
sovereign (4)

 
Total

Top 20 country exposures:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
United Kingdom
$
3,585

 
18,018

 
5

 
3,412

 

 
2,015

 
3,590

 
23,445

 
27,035

Canada
1

 
16,710

 

 
893

 

 
555

 
1

 
18,158

 
18,159

Cayman Islands

 
3,591

 

 

 

 
247

 

 
3,838

 
3,838

Ireland
21

 
3,415

 

 
281

 

 
110

 
21

 
3,806

 
3,827

Germany
1,664

 
1,295

 
(2
)
 
456

 

 
366

 
1,662

 
2,117

 
3,779

Bermuda

 
3,035

 

 
119

 

 
152

 

 
3,306

 
3,306

India

 
2,211

 

 
71

 

 
3

 

 
2,285

 
2,285

Brazil

 
2,210

 

 
(1
)
 

 

 

 
2,209

 
2,209

Netherlands

 
1,622

 

 
435

 

 
33

 

 
2,090

 
2,090

Australia

 
1,053

 

 
755

 

 
51

 

 
1,859

 
1,859

Switzerland

 
1,531

 

 
114

 

 
24

 

 
1,669

 
1,669

France

 
544

 

 
892

 

 
139

 

 
1,575

 
1,575

Mexico

 
1,458

 

 
13

 

 
4

 

 
1,475

 
1,475

Turkey

 
1,454

 

 

 

 
1

 

 
1,455

 
1,455

China

 
1,379

 
(2
)
 
49

 
2

 
1

 

 
1,429

 
1,429

Chile

 
1,293

 

 
3

 
2

 
58

 
2

 
1,354

 
1,356

South Korea

 
1,252

 
(18
)
 
96

 
4

 
1

 
(14
)
 
1,349

 
1,335

Jersey, C.I.

 
799

 

 
242

 

 
21

 

 
1,062

 
1,062

Guernsey

 
997

 

 
(1
)
 

 
2

 

 
998

 
998

Malaysia

 
906

 

 
46

 

 
1

 

 
953

 
953

Total top 20 country exposures
$
5,271

 
64,773

 
(17
)
 
7,875

 
8

 
3,784

 
5,262

 
76,432

 
81,694

Eurozone exposure:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Eurozone countries included in Top 20 above (5)
$
1,685

 
6,876

 
(2
)
 
2,064

 

 
648

 
1,683

 
9,588

 
11,271

Luxembourg
45

 
469

 

 
202

 

 
37

 
45

 
708

 
753

Austria

 
616

 

 
4

 

 
2

 

 
622

 
622

Spain

 
329

 

 
31

 

 
10

 

 
370

 
370

Belgium

 
245

 

 
33

 

 
1

 

 
279

 
279

Italy

 
74

 

 
51

 

 

 

 
125

 
125

Other Eurozone exposure (6)
23

 
31

 

 
7

 

 
6

 
23

 
44

 
67

Total Eurozone exposure
$
1,753

 
8,640

 
(2
)
 
2,392

 

 
704

 
1,751

 
11,736

 
13,487

(1)
Lending exposure includes funded loans and unfunded commitments, leveraged leases, and money market placements presented on a gross basis prior to the deduction of impairment allowance and collateral received under the terms of the credit agreements. For the countries listed above, includes $16 million in PCI loans, predominantly to customers in the Netherlands and Germany, and $1.1 billion in defeased leases secured primarily by U.S. Treasury and government agency securities, or government guaranteed.
(2)
Represents exposure on debt and equity securities of foreign issuers. Long and short positions are netted and net short positions are reflected as negative exposure.
(3)
Represents counterparty exposure on foreign exchange and derivative contracts, and securities resale and lending agreements. This exposure is presented net of counterparty netting adjustments and reduced by the amount of cash collateral. It includes credit default swaps (CDS) predominantly used to manage our U.S. and London-based cash credit trading businesses, which sometimes results in selling and purchasing protection on the identical reference entity. Generally, we do not use market instruments such as CDS to hedge the credit risk of our investment or loan positions, although we do use them to manage risk in our trading businesses. At March 31, 2016, the gross notional amount of our CDS sold that reference assets in the Top 20 or Eurozone countries was $2.3 billion, which was offset by the notional amount of CDS purchased of $2.3 billion. We did not have any CDS purchased or sold that reference pools of assets that contain sovereign debt or where the reference asset was solely the sovereign debt of a foreign country.
(4)
For countries presented in the table, total non-sovereign exposure comprises $40.3 billion exposure to financial institutions and $38.3 billion to non-financial corporations at March 31, 2016.
(5)
Consists of exposure to Ireland, Germany, Netherlands and France included in Top 20.
(6)
Includes non-sovereign exposure to Portugal in the amount of $27 million and less than $1 million to Greece. We had no sovereign debt exposure to these countries at March 31, 2016.

25


REAL ESTATE 1-4 FAMILY FIRST AND JUNIOR LIEN MORTGAGE LOANS  Our real estate 1-4 family first and junior lien mortgage loans primarily include loans we have made to customers and retained as part of our asset/liability management strategy. These loans, as presented in Table 15, include the Pick-
 
a-Pay portfolio acquired from Wachovia which is discussed later in this Report. These loans also include other purchased loans and loans included on our balance sheet as a result of consolidation of variable interest entities (VIEs). 

Table 15: Real Estate 1-4 Family First and Junior Lien Mortgage Loans
 
March 31, 2016
 
 
December 31, 2015
 
(in millions)
Balance

 
% of
portfolio

 
Balance

 
% of
portfolio

Real estate 1-4 family first mortgage
$
274,734

 
84
%
 
$
273,869

 
84
%
Real estate 1-4 family junior lien mortgage
51,324

 
16

 
53,004

 
16

Total real estate 1-4 family mortgage loans
$
326,058

 
100
%
 
$
326,873

 
100
%

The real estate 1-4 family mortgage loan portfolio includes some loans with adjustable-rate features and some with an interest-only feature as part of the loan terms. Interest-only loans were approximately 8% and 9% of total loans at March 31, 2016, and December 31, 2015, respectively. We believe we have manageable adjustable-rate mortgage (ARM) reset risk across our owned mortgage loan portfolios. We do not offer option ARM products, nor do we offer variable-rate mortgage products with fixed payment amounts, commonly referred to within the financial services industry as negative amortizing mortgage loans. The option ARMs we do have are included in the Pick-a-Pay portfolio which was acquired from Wachovia. Since our acquisition of the Pick-a-Pay loan portfolio at the end of 2008, the option payment portion of the portfolio has reduced from 86% to 38% at March 31, 2016, as a result of our modification activities and customers exercising their option to convert to fixed payments. For more information, see the “Pick-a-Pay Portfolio” section in this Report.
We continue to modify real estate 1-4 family mortgage loans to assist homeowners and other borrowers experiencing financial difficulties. For more information on our participation in the U.S. Treasury’s Making Home Affordable (MHA) programs, see the “Risk Management – Credit Risk Management – Real Estate 1-4 Family First and Junior Lien Mortgage Loans” section in our 2015 Form 10-K.
Part of our credit monitoring includes tracking delinquency, FICO scores and loan/combined loan to collateral values (LTV/CLTV) on the entire real estate 1-4 family mortgage loan portfolio. These credit risk indicators, which exclude government insured/guaranteed loans, continued to improve in first quarter 2016 on the non-PCI mortgage portfolio. Loans 30 days or more delinquent at March 31, 2016, totaled $7.3 billion, or 2% of total non-PCI mortgages, compared with $8.3 billion, or 3%, at December 31, 2015. Loans with FICO scores lower than 640 totaled $21.1 billion, or 7% of total non-PCI mortgages, for both March 31, 2016 and December 31, 2015. Mortgages with a LTV/CLTV greater than 100% totaled $14.4 billion at March 31, 2016, or 5% of total non-PCI mortgages, compared with $15.1 billion, or 5%, at December 31, 2015. Information regarding credit quality indicators, including PCI credit quality indicators, can be found in Note 5 (Loans and Allowance for Credit Losses) to Financial Statements in this Report.
Real estate 1-4 family first and junior lien mortgage loans by state are presented in Table 16. Our real estate 1-4 family mortgage loans to borrowers in California represented approximately 12% of total loans at March 31, 2016, located mostly within the larger metropolitan areas, with no single California metropolitan area consisting of more than 5% of total loans. We monitor changes in real estate values and underlying economic or market conditions for all geographic areas of our
 
real estate 1-4 family mortgage portfolio as part of our credit risk management process. Our underwriting and periodic review of loans secured by residential real estate collateral includes appraisals or estimates from automated valuation models (AVMs) to support property values. Additional information about AVMs and our policy for their use can be found in Note 5 (Loans and Allowance for Credit Losses) to Financial Statements in this Report and the “Risk Management – Credit Risk Management – Real Estate 1-4 Family First and Junior Lien Mortgage Loans” section in our 2015 Form 10-K.
Table 16: Real Estate 1-4 Family First and Junior Lien Mortgage Loans by State
 
March 31, 2016
 
(in millions)
Real estate
1-4 family
first
mortgage

 
Real estate
1-4 family
junior lien
mortgage

 
Total real
estate 1-4
family
mortgage

 
% of
total
loans

Real estate 1-4 family loans (excluding PCI):
 
 
 
 
 
 
 
California
$
89,491

 
14,039

 
103,530

 
11
%
New York
21,731

 
2,352

 
24,083

 
2

Florida
14,041

 
4,659

 
18,700

 
2

New Jersey
11,931

 
4,325

 
16,256

 
2

Virginia
7,269

 
2,927

 
10,196

 
1

Texas
8,196

 
816

 
9,012

 
1

Pennsylvania
5,691

 
2,679

 
8,370

 
1

North Carolina
5,970

 
2,325

 
8,295

 
1

Washington
6,938

 
1,196

 
8,134

 
1

Other (1)
63,369

 
15,946

 
79,315

 
8

Government insured/
guaranteed loans (2)
21,573

 

 
21,573

 
2

Real estate 1-4 family loans (excluding PCI)
256,200

 
51,264

 
307,464

 
32

Real estate 1-4 family PCI loans (3)
18,534

 
60

 
18,594

 
2

Total
$
274,734

 
51,324

 
326,058

 
34
%
(1)
Consists of 41 states; no state had loans in excess of $7.2 billion.
(2)
Represents loans whose repayments are predominantly insured by the Federal Housing Administration (FHA) or guaranteed by the Department of Veterans Affairs (VA).
(3)
Includes $12.9 billion in real estate 1-4 family mortgage PCI loans in California.

First Lien Mortgage Portfolio  Our total real estate 1-4 family first lien mortgage portfolio increased $865 million in first quarter 2016, as we retained $11.8 billion in non-conforming originations, primarily consisting of loans that exceed


26

Risk Management - Credit Risk Management (continued)

conventional conforming loan amount limits established by federal government-sponsored entities (GSEs).
The credit performance associated with our real estate 1-4 family first lien mortgage portfolio continued to improve in first quarter 2016, as measured through net charge-offs and nonaccrual loans. Net charge-offs (annualized) as a percentage of average real estate 1-4 family first lien mortgage loans improved to 0.07% in first quarter 2016, compared with 0.13%, for the same period a year ago. Nonaccrual loans were $6.7 billion at March 31, 2016, compared with $7.3 billion at December 31,
 
2015. Improvement in the credit performance was driven by an improving housing environment. Real estate 1-4 family first lien mortgage loans originated after 2008, which generally utilized tighter underwriting standards, have resulted in minimal losses to date and were approximately 68% of our total real estate 1-4 family first lien mortgage portfolio as of March 31, 2016.
Table 17 shows the credit attributes of the first lien mortgage portfolio and lists the top five states by outstanding balance.

Table 17: First Lien Mortgage Portfolio Performance
 
Outstanding balance
 
 
% of loans 30 days or more past due
 
Loss (recovery) rate (annualized) quarter ended
(in millions)
Mar 31,
2016

Dec 31,
2015

 
Mar 31,
2016

Dec 31,
2015
 
Mar 31,
2016

Dec 31,
2015

Sep 30,
2015

Jun 30,
2015

Mar 31,
2015
California
$
89,491

88,367

 
1.64
%
1.87
 
(0.07
)
(0.05
)
(0.05
)
(0.02
)
New York
21,731

20,962

 
2.71

3.07
 
0.12

0.08

0.13

0.14

0.10
Florida
14,041

14,068

 
4.60

5.14
 
0.03

0.02

0.16

0.23

0.17
New Jersey
11,931

11,825

 
5.10

5.68
 
0.44

0.33

0.38

0.27

0.24
Texas
8,196

8,153

 
2.50

2.80
 
0.10

0.02


0.02

0.03
Other
89,237

88,951

 
3.16

3.72
 
0.18

0.21

0.23

0.22

0.31
Total
234,627

232,326

 
2.70
%
3.11
 
0.08

0.09

0.11

0.12

0.16
Government insured/guaranteed loans
21,573

22,353

 
 
 
 
 
 
 
 
 
PCI
18,534

19,190

 
 
 
 
 
 
 
 
 
Total first lien mortgages
$
274,734

273,869

 
 
 
 
 
 
 
 
 

Pick‑a‑Pay Portfolio  The Pick-a-Pay portfolio was one of the consumer residential first lien mortgage portfolios we acquired from Wachovia and a majority of the portfolio was identified as PCI loans.
The Pick-a-Pay portfolio includes loans that offer payment options (Pick-a-Pay option payment loans), and also includes loans that were originated without the option payment feature, loans that no longer offer the option feature as a result of our modification efforts since the acquisition, and loans where the customer voluntarily converted to a fixed-rate product. The Pick-
 
a-Pay portfolio is included in the consumer real estate 1-4 family first mortgage class of loans throughout this Report. Table 18 provides balances by types of loans as of March 31, 2016, as a result of modification efforts, compared to the types of loans included in the portfolio at acquisition. Total adjusted unpaid principal balance of PCI Pick-a-Pay loans was $23.1 billion at March 31, 2016, compared with $61.0 billion at acquisition. Primarily due to modification efforts, the adjusted unpaid principal balance of option payment PCI loans has declined to 15% of the total Pick-a-Pay portfolio at March 31, 2016, compared with 51% at acquisition.

Table 18: Pick-a-Pay Portfolio – Comparison to Acquisition Date
 
 
 
December 31,
 
 
March 31, 2016
 
 
2015
 
 
2008
 
(in millions)
Adjusted
unpaid
principal
balance (1)

 
% of
total

 
Adjusted
unpaid
principal
balance (1)

 
% of
total

 
Adjusted
unpaid
principal
balance (1)

 
% of
total

Option payment loans
$
16,089

 
38
%
 
$
16,828

 
39
%
 
$
99,937

 
86
%
Non-option payment adjustable-rate
and fixed-rate loans
5,473

 
13

 
5,706

 
13

 
15,763

 
14

Full-term loan modifications
20,738

 
49

 
21,193

 
48

 

 

Total adjusted unpaid principal balance
$
42,300

 
100
%
 
$
43,727

 
100
%
 
$
115,700

 
100
%
Total carrying value
$
37,676

 
 
 
39,065

 
 
 
95,315

 
 
(1)
Adjusted unpaid principal balance includes write-downs taken on loans where severe delinquency (normally 180 days) or other indications of severe borrower financial stress exist that indicate there will be a loss of contractually due amounts upon final resolution of the loan.

 Table 19 reflects the geographic distribution of the Pick-a-Pay portfolio broken out between PCI loans and all other loans. The LTV ratio is a useful metric in evaluating future real estate 1-4 family first mortgage loan performance, including potential charge-offs. Because PCI loans were initially recorded at fair
 
value, including write-downs for expected credit losses, the ratio of the carrying value to the current collateral value will be lower compared with the LTV based on the adjusted unpaid principal balance. For informational purposes, we have included both ratios for PCI loans in the following table.


27


Table 19: Pick-a-Pay Portfolio (1)
 
March 31, 2016
 
 
PCI loans
 
 
All other loans
 
(in millions)
Adjusted
unpaid
principal
balance (2)

 
Current
LTV
ratio (3)

 
Carrying
value (4)

 
Ratio of
carrying
value to
current
value (5)

 
Carrying
value (4)

 
Ratio of
carrying
value to
current
value (5)

California
$
16,079

 
72
%
 
$
12,838

 
57
%
 
$
9,311

 
52
%
Florida
1,819

 
81

 
1,392

 
60

 
1,932

 
65

New Jersey
751

 
81

 
578

 
60

 
1,272

 
68

New York
518

 
77

 
440

 
59

 
624

 
67

Texas
196

 
55

 
176

 
49

 
753

 
43

Other states
3,724

 
78

 
2,972

 
61

 
5,388

 
64

Total Pick-a-Pay loans
$
23,087

 
74

 
$
18,396

 
58

 
$
19,280

 
58

 
 
 
 
 
 
 
 
 
 
 
 
(1)
The individual states shown in this table represent the top five states based on the total net carrying value of the Pick-a-Pay loans at the beginning of 2016.
(2)
Adjusted unpaid principal balance includes write-downs taken on loans where severe delinquency (normally 180 days) or other indications of severe borrower financial stress exist that indicate there will be a loss of contractually due amounts upon final resolution of the loan.
(3)
The current LTV ratio is calculated as the adjusted unpaid principal balance divided by the collateral value. Collateral values are generally determined using automated valuation models (AVM) and are updated quarterly. AVMs are computer-based tools used to estimate market values of homes based on processing large volumes of market data including market comparables and price trends for local market areas.
(4)
Carrying value, which does not reflect the allowance for loan losses, includes remaining purchase accounting adjustments, which, for PCI loans may include the nonaccretable difference and the accretable yield and, for all other loans, an adjustment to mark the loans to a market yield at date of merger less any subsequent charge-offs.
(5)
The ratio of carrying value to current value is calculated as the carrying value divided by the collateral value.

In first quarter 2016, we completed over 600 proprietary and Home Affordability Modification Program (HAMP) Pick-a-Pay loan modifications. We have completed over 133,000 modifications since the Wachovia acquisition, resulting in over $6.1 billion of principal forgiveness to our Pick-a-Pay customers. There remains $8.7 million of conditional forgiveness that can be earned by borrowers through performance over a three-year period.
Due to better than expected performance observed on the PCI portion of the Pick-a-Pay portfolio compared with the original acquisition estimates, we have reclassified $7.1 billion from the nonaccretable difference to the accretable yield since acquisition. Our cash flows expected to be collected have been favorably affected by lower expected defaults and losses as a result of observed and forecasted economic strengthening, particularly in housing prices, and our loan modification efforts. These factors are expected to reduce the frequency and severity of defaults and keep these loans performing for a longer period, thus increasing future principal and interest cash flows. The resulting increase in the accretable yield will be realized over the remaining life of the portfolio, which is estimated to have a weighted-average remaining life of approximately 11.7 years at March 31, 2016. The weighted average remaining life decreased slightly from December 31, 2015 due to the passage of time. The accretable yield percentage at March 31, 2016, was 6.68%, up from 6.21% at the end of 2015 due to favorable changes in the expected timing and composition of cash flows resulting from improving credit and prepayment expectations. Fluctuations in the accretable yield are driven by changes in interest rate indices for variable rate PCI loans, prepayment assumptions, and expected principal and interest payments over the estimated life of the portfolio, which will be affected by the pace and degree of improvements in the U.S. economy and housing markets and projected lifetime performance resulting from loan modification activity. Changes in the projected timing of cash flow events, including loan liquidations, modifications and short sales, can also affect the accretable yield and the estimated weighted-average life of the portfolio.
The predominant portion of our PCI loans is included in the Pick-a-Pay portfolio. For further information on the judgment involved in estimating expected cash flows for PCI loans, see the
 
“Critical Accounting Policies – Purchased Credit-Impaired Loans” section and Note 1 (Summary of Significant Accounting Policies) to Financial Statements in our 2015 Form 10-K.
For further information on the Pick-a-Pay portfolio, including recast risk, deferral of interest and loan modifications, see the "Risk Management – Credit Risk Management – Pick-a-Pay Portfolio" section in our 2015 Form 10-K.


28

Risk Management - Credit Risk Management (continued)

Junior Lien Mortgage Portfolio  The junior lien mortgage portfolio consists of residential mortgage lines and loans that are subordinate in rights to an existing lien on the same property. It is not unusual for these lines and loans to have draw periods, interest only payments, balloon payments, adjustable rates and similar features. The majority of our junior lien loan products are amortizing payment loans with fixed interest rates and repayment periods between five to 30 years. 
We continuously monitor the credit performance of our junior lien mortgage portfolio for trends and factors that influence the frequency and severity of loss. We have observed that the severity of loss for junior lien mortgages is high and generally not affected by whether we or a third party own or service the related first lien mortgage, but the frequency of delinquency is typically lower when we own or service the first lien mortgage. In general, we have limited information available on the delinquency status of the third party owned or serviced senior lien where we also hold a junior lien. To capture this inherent loss content, our allowance process for junior lien mortgages considers the relative difference in loss experience for junior lien mortgages behind first lien mortgage loans we own or
 
service, compared with those behind first lien mortgage loans owned or serviced by third parties. In addition, our allowance process for junior lien mortgages that are current, but are in their revolving period, considers the inherent loss where the borrower is delinquent on the corresponding first lien mortgage loans.
Table 20 shows the credit attributes of the junior lien mortgage portfolio and lists the top five states by outstanding balance. The decrease in outstanding balances since December 31, 2015, predominantly reflects loan paydowns. As of March 31, 2016, 16% of the outstanding balance of the junior lien mortgage portfolio was associated with loans that had a combined loan to value (CLTV) ratio in excess of 100%. Of those junior lien mortgages with a CLTV ratio in excess of 100%, 2.58% were 30 days or more past due. CLTV means the ratio of the total loan balance of first lien mortgages and junior lien mortgages (including unused line amounts for credit line products) to property collateral value. The unsecured portion (the outstanding amount that was in excess of the most recent property collateral value) of the outstanding balances of these loans totaled 7% of the junior lien mortgage portfolio at March 31, 2016.

Table 20: Junior Lien Mortgage Portfolio Performance
 
Outstanding balance
 
 
% of loans 30 days or more past due
 
Loss rate (annualized) quarter ended
 
(in millions)
Mar 31,
2016

 
Dec 31,
2015

 
Mar 31,
2016

 
Dec 31,
2015
 
Mar 31,
2016

 
Dec 31,
2015

 
Sep 30,
2015

 
Jun 30,
2015

 
Mar 31,
2015

California
$
14,039

 
14,554

 
1.92
%
 
2.03
 
0.27

 
0.12

 
0.21

 
0.27

 
0.41

Florida
4,659

 
4,823

 
2.31

 
2.45
 
0.79

 
0.51

 
1.02

 
0.82

 
1.15

New Jersey
4,325

 
4,462

 
3.07

 
3.06
 
0.84

 
0.77

 
1.23

 
1.02

 
1.20

Virginia
2,927

 
2,991

 
1.81

 
2.05
 
0.80

 
0.77

 
0.73

 
0.75

 
1.22

Pennsylvania
2,679

 
2,748

 
2.27

 
2.35
 
0.55

 
0.66

 
0.79

 
0.97

 
1.21

Other
22,635

 
23,357

 
2.12

 
2.24
 
0.63

 
0.68

 
0.70

 
0.76

 
0.92

 Total
51,264


52,935

 
2.15
%
 
2.27
 
0.57

 
0.52

 
0.64

 
0.66

 
0.85

PCI
60

 
69

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total junior lien mortgages
$
51,324

 
53,004

 
 
 
 
 
 
 
 
 
 
 
 
 
 


29


Our junior lien, as well as first lien, lines of credit products generally have a draw period of 10 years (with some up to 15 or 20 years) with variable interest rate and payment options during the draw period of (1) interest only or (2) 1.5% of outstanding principal balance plus accrued interest. During the draw period, the borrower has the option of converting all or a portion of the line from a variable interest rate to a fixed rate with terms including interest-only payments for a fixed period between three to seven years or a fully amortizing payment with a fixed period between five to 30 years. At the end of the draw period, a line of credit generally converts to an amortizing payment schedule with repayment terms of up to 30 years based on the balance at time of conversion. Certain lines and loans have been structured with a balloon payment, which requires full repayment of the outstanding balance at the end of the term period. The conversion of lines or loans to fully amortizing or balloon payoff may result in a significant payment increase, which can affect some borrowers’ ability to repay the outstanding balance.
On a monthly basis, we monitor the payment characteristics of borrowers in our junior lien portfolio. In March 2016, approximately 46% of these borrowers paid only the minimum amount due and approximately 49% paid more than the minimum amount due. The rest were either delinquent or paid less than the minimum amount due. For the borrowers with an interest only payment feature, approximately 34% paid only the
 
minimum amount due and approximately 61% paid more than the minimum amount due.
The lines that enter their amortization period may experience higher delinquencies and higher loss rates than the ones in their draw or term period. We have considered this increased inherent risk in our allowance for credit loss estimate.
In anticipation of our borrowers reaching the end of their contractual commitment, we have created a program to inform, educate and help these borrowers transition from interest-only to fully-amortizing payments or full repayment. We monitor the performance of the borrowers moving through the program in an effort to refine our ongoing program strategy.
Table 21 reflects the outstanding balance of our portfolio of junior lien mortgages, including lines and loans, and senior lien lines segregated into scheduled end of draw or end of term periods and products that are currently amortizing, or in balloon repayment status. It excludes real estate 1-4 family first lien line reverse mortgages, which total $2.1 billion, because they are predominantly insured by the FHA, and it excludes PCI loans, which total $86 million, because their losses were generally reflected in our nonaccretable difference established at the date of acquisition.


Table 21: Junior Lien Mortgage Line and Loan and Senior Lien Mortgage Line Portfolios Payment Schedule
 
 
 
 
 
Scheduled end of draw / term
 
 
 
(in millions)
Outstanding balance
March 31, 2016

 
Remainder
of 2016

 
2017

 
2018

 
2019

 
2020

 
2021 and
thereafter (1)

 
Amortizing

Junior lien lines and loans
$
51,264

 
3,345

 
4,988

 
2,845

 
1,128

 
1,014

 
25,291

 
12,653

First lien lines
15,973

 
450

 
737

 
872

 
388

 
358

 
11,248

 
1,920

Total (2)(3)
$
67,237

 
3,795

 
5,725

 
3,717

 
1,516

 
1,372

 
36,539

 
14,573

% of portfolios
100
%
 
6

 
9

 
6

 
2

 
2

 
54

 
21

(1)
Substantially all lines and loans are scheduled to convert to amortizing loans by the end of 2026, with annual scheduled amounts through that date ranging from $2.7 billion to $8.6 billion and averaging $6.1 billion per year.
(2)
Junior and first lien lines are predominantly interest-only during their draw period. The unfunded credit commitments for junior and first lien lines totaled $67.8 billion at March 31, 2016.
(3)
Includes scheduled end-of-term balloon payments for lines and loans totaling $151 million, $337 million, $407 million, $380 million, $411 million and $1.1 billion for 2016 2017, 2018, 2019, 2020, and 2021 and thereafter, respectively. Amortizing lines and loans include $159 million of end-of-term balloon payments, which are past due. At March 31, 2016, $504 million, or 5% of outstanding lines of credit that are amortizing, are 30 days or more past due compared to $845 million or 2% for lines in their draw period.
CREDIT CARDS  Our credit card portfolio totaled $33.1 billion at March 31, 2016, which represented 3% of our total outstanding loans. The net charge-off rate (annualized) for our credit card portfolio was 3.16% for first quarter 2016, compared with 3.19% for first quarter 2015.
 
AUTOMOBILE  Our automobile portfolio, predominantly composed of indirect loans, totaled $60.7 billion at March 31, 2016. The net charge-off rate (annualized) for our automobile portfolio was 0.85% for first quarter 2016, compared with 0.73% for first quarter 2015.

 
OTHER REVOLVING CREDIT AND INSTALLMENT Other revolving credit and installment loans totaled $39.2 billion at March 31, 2016, and primarily included student and security-based loans. Student loans totaled $12.5 billion at March 31, 2016. The net charge-off rate (annualized) for other revolving credit and installment loans was 1.42% for first quarter 2016, compared with 1.32% for first quarter 2015.



30

Risk Management - Credit Risk Management (continued)

NONPERFORMING ASSETS (NONACCRUAL LOANS AND FORECLOSED ASSETS) Table 22 summarizes nonperforming assets (NPAs) for each of the last four quarters. Total NPAs increased in first quarter 2016, primarily driven by a $1.1 billion increase in nonaccrual loans in the oil and gas portfolio and the addition of $343 million of nonaccrual loans from the GE Capital acquisitions. The increase in nonaccrual loans was partially offset by a $684 million decline in consumer real estate nonaccrual loans, partly due to a sale, as well as a $76 million decline in commercial real estate nonaccrual loans.

We generally place loans on nonaccrual status when:
the full and timely collection of interest or principal becomes uncertain (generally based on an assessment of the borrower’s financial condition and the adequacy of collateral, if any);
 
they are 90 days (120 days with respect to real estate 1-4 family first and junior lien mortgages) past due for interest or principal, unless both well-secured and in the process of collection;
part of the principal balance has been charged off;
for junior lien mortgages, we have evidence that the related first lien mortgage may be 120 days past due or in the process of foreclosure regardless of the junior lien delinquency status; or
consumer real estate and auto loans are discharged in bankruptcy, regardless of their delinquency status.



Table 22: Nonperforming Assets (Nonaccrual Loans and Foreclosed Assets)
 
 
March 31, 2016
 
 
December 31, 2015
 
 
September 30, 2015
 
 
June 30, 2015
 
($ in millions)
 
Balance

 
% of
total
loans

 
Balance

 
% of
total
loans

 
Balance

 
% of
total
loans

 
Balance

 
% of
total
loans

Nonaccrual loans:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Commercial:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Commercial and industrial
 
$
2,911

 
0.91
%
 
$
1,363

 
0.45
%
 
$
1,031

 
0.35
%
 
$
1,079

 
0.38
%
Real estate mortgage
 
896

 
0.72

 
969

 
0.79

 
1,125

 
0.93

 
1,250

 
1.04

Real estate construction
 
63

 
0.27

 
66

 
0.30

 
151

 
0.70

 
165

 
0.77

Lease financing
 
99

 
0.52

 
26

 
0.21

 
29

 
0.24

 
28

 
0.23

Total commercial
 
3,969

 
0.81

 
2,424

 
0.53

 
2,336

 
0.52

 
2,522

 
0.58

Consumer:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Real estate 1-4 family first mortgage (1)
 
6,683

 
2.43

 
7,293

 
2.66

 
7,425

 
2.74

 
8,045

 
3.00

Real estate 1-4 family junior lien mortgage
 
1,421

 
2.77

 
1,495

 
2.82

 
1,612

 
2.95

 
1,710

 
3.04

Automobile
 
114

 
0.19

 
121

 
0.20

 
123

 
0.21

 
126

 
0.22

Other revolving credit and installment
 
47

 
0.12

 
49

 
0.13

 
41

 
0.11

 
40

 
0.11

Total consumer
 
8,265

 
1.80

 
8,958

 
1.95

 
9,201

 
2.02

 
9,921

 
2.20

Total nonaccrual loans (2)(3)(4)
 
12,234

 
1.29

 
11,382

 
1.24

 
11,537

 
1.28

 
12,443

 
1.40

Foreclosed assets:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Government insured/guaranteed (5)
 
386

 
 
 
446

 
 
 
502

 
 
 
588

 
 
Non-government insured/guaranteed
 
893

 
 
 
979

 
 
 
1,265

 
 
 
1,370

 
 
Total foreclosed assets
 
1,279

 
 
 
1,425

 
 
 
1,767

 
 
 
1,958

 
 
Total nonperforming assets
 
$
13,513

 
1.43
%
 
$
12,807

 
1.40
%
 
$
13,304

 
1.47
%
 
$
14,401

 
1.62
%
Change in NPAs from prior quarter
 
$
706

 
 
 
(497
)
 
 
 
(1,097
)
 
 
 
(438
)
 
 

(1)
Includes MHFS of $157 million, $177 million, $96 million, and $144 million at March 31, 2016 and December 31, September 30, and June 30, 2015, respectively.
(2)
Excludes PCI loans because they continue to earn interest income from accretable yield, independent of performance in accordance with their contractual terms.
(3)
Real estate 1-4 family mortgage loans predominantly insured by the FHA or guaranteed by the VA and student loans predominantly guaranteed by agencies on behalf of the U.S. Department of Education under the Federal Family Education Loan Program are not placed on nonaccrual status because they are insured or guaranteed.
(4)
See Note 5 (Loans and Allowance for Credit Losses) to Financial Statements in this Report for further information on impaired loans.
(5)
Consistent with regulatory reporting requirements, foreclosed real estate resulting from government insured/guaranteed loans are classified as nonperforming. Both principal and interest related to these foreclosed real estate assets are collectible because the loans were predominantly insured by the FHA or guaranteed by the VA. Foreclosure of certain government guaranteed residential real estate mortgage loans that meet criteria specified by Accounting Standards Update (ASU) 2014-14, Classification of Certain Government-Guaranteed Mortgage Loans Upon Foreclosure, effective as of January 1, 2014 are excluded from this table and included in Accounts Receivable in Other Assets. For more information on the changes in foreclosures for government guaranteed residential real estate mortgage loans, see Note 1 (Summary of Significant Accounting Policies) to Financial Statements in our 2015 Form 10-K.



31


Table 23 provides an analysis of the changes in nonaccrual loans.


Table 23: Analysis of Changes in Nonaccrual Loans
 
Quarter ended
 
(in millions)
Mar 31,
2016

 
Dec 31,
2015

 
Sep 30,
2015

 
Jun 30,
2015

 
Mar 31,
2015

Commercial nonaccrual loans
 
 
 
 
 
 
 
 
 
Balance, beginning of period
$
2,424

 
2,336

 
2,522

 
2,192

 
2,239

Inflows
2,291

 
793

 
382

 
840

 
496

Outflows:
 
 
 
 
 
 
 
 
 
Returned to accruing
(34
)
 
(44
)
 
(26
)
 
(20
)
 
(67
)
Foreclosures
(4
)
 
(72
)
 
(32
)
 
(11
)
 
(24
)
Charge-offs
(317
)
 
(243
)
 
(135
)
 
(117
)
 
(107
)
Payments, sales and other (1)
(391
)
 
(346
)
 
(375
)
 
(362
)
 
(345
)
Total outflows
(746
)
 
(705
)
 
(568
)
 
(510
)
 
(543
)
Balance, end of period
3,969


2,424


2,336


2,522


2,192

Consumer nonaccrual loans
 
 
 
 
 
 
 
 
 
Balance, beginning of period
8,958

 
9,201

 
9,921

 
10,318

 
10,609

Inflows
964

 
1,226

 
1,019

 
1,098

 
1,341

Outflows:
 
 
 
 
 
 
 
 
 
Returned to accruing
(584
)
 
(646
)
 
(676
)
 
(668
)
 
(686
)
Foreclosures
(98
)
 
(89
)
 
(99
)
 
(108
)
 
(111
)
Charge-offs
(203
)
 
(204
)
 
(228
)
 
(229
)
 
(265
)
Payments, sales and other (1)
(772
)
 
(530
)
 
(736
)
 
(490
)
 
(570
)
Total outflows
(1,657
)
 
(1,469
)
 
(1,739
)
 
(1,495
)
 
(1,632
)
Balance, end of period
8,265


8,958


9,201


9,921


10,318

Total nonaccrual loans
$
12,234

 
11,382

 
11,537

 
12,443

 
12,510

(1)
Other outflows include the effects of VIE deconsolidations and adjustments for loans carried at fair value.

Typically, changes to nonaccrual loans period-over-period represent inflows for loans that are placed on nonaccrual status in accordance with our policy, offset by reductions for loans that are paid down, charged off, sold, foreclosed, or are no longer classified as nonaccrual as a result of continued performance and an improvement in the borrower’s financial condition and loan repayment capabilities. Also, reductions can come from borrower repayments even if the loan remains on nonaccrual.
While nonaccrual loans are not free of loss content, we believe exposure to loss is significantly mitigated by the following factors at March 31, 2016:
97% of total commercial nonaccrual loans and over 99% of total consumer nonaccrual loans are secured. Of the consumer nonaccrual loans, 98% are secured by real estate and 76% have a combined LTV (CLTV) ratio of 80% or less.
losses of $495 million and $2.9 billion have already been recognized on 17% of commercial nonaccrual loans and 51% of consumer nonaccrual loans, respectively. Generally, when a consumer real estate loan is 120 days past due (except when required earlier by guidance issued by bank regulatory agencies), we transfer it to nonaccrual status. When the loan reaches 180 days past due, or is discharged in bankruptcy, it is our policy to write these loans down to net realizable value (fair value of collateral less estimated costs to sell), except for modifications in their trial period that are not written down as long as trial payments are made on time. Thereafter, we reevaluate each loan regularly and record additional write-downs if needed.
 
78% of commercial nonaccrual loans were current on interest, but were on nonaccrual status because the full or timely collection of interest or principal had become uncertain.
the risk of loss of all nonaccrual loans has been considered and we believe is adequately covered by the allowance for loan losses.
$1.9 billion of consumer loans discharged in bankruptcy and classified as nonaccrual were 60 days or less past due, of which $1.7 billion were current.

We continue to work with our customers experiencing financial difficulty to determine if they can qualify for a loan modification so that they can stay in their homes. Under both our proprietary modification programs and the MHA programs, customers may be required to provide updated documentation, and some programs require completion of payment during trial periods to demonstrate sustained performance before the loan can be removed from nonaccrual status. In addition, for loans in foreclosure in certain states, including New York and New Jersey, the foreclosure timeline has significantly increased due to backlogs in an already complex process. Therefore, some loans may remain on nonaccrual status for a long period.
Table 24 provides a summary of foreclosed assets and an analysis of changes in foreclosed assets.




32

Risk Management - Credit Risk Management (continued)

Table 24: Foreclosed Assets
(in millions)
Mar 31,
2016

 
Dec 31,
2015

 
Sep 30,
2015

 
Jun 30,
2015

 
Mar 31,
2015

Summary by loan segment
 
 
 
 
 
 
 
 
 
Government insured/guaranteed
$
386

 
446

 
502

 
588

 
772

PCI loans:
 
 
 
 
 
 
 
 
 
Commercial
142

 
152

 
297

 
305

 
329

Consumer
97

 
103

 
126

 
160

 
197

Total PCI loans
239

 
255

 
423

 
465

 
526

All other loans:
 
 
 
 
 
 
 
 
 
Commercial
357

 
384

 
437

 
458

 
548

Consumer
297

 
340

 
405

 
447

 
483

Total all other loans
654

 
724

 
842

 
905

 
1,031

Total foreclosed assets
$
1,279

 
1,425

 
1,767

 
1,958

 
2,329

Analysis of changes in foreclosed assets
 
 
 
 
 
 
 
 
 
Balance, beginning of period
$
1,425

 
1,767

 
1,958

 
2,329

 
2,609

Net change in government insured/guaranteed (1)
(60
)
 
(56
)
 
(86
)
 
(184
)
 
(210
)
Additions to foreclosed assets (2)
290

 
327

 
325

 
300

 
356

Reductions:
 
 
 
 
 
 
 
 
 
Sales
(390
)
 
(719
)
 
(468
)
 
(531
)
 
(451
)
Write-downs and gains (losses) on sales
14

 
106

 
38

 
44

 
25

Total reductions
(376
)
 
(613
)
 
(430
)
 
(487
)
 
(426
)
Balance, end of period
$
1,279

 
1,425

 
1,767

 
1,958

 
2,329

(1)
Foreclosed government insured/guaranteed loans are temporarily transferred to and held by us as servicer, until reimbursement is received from FHA or VA. The net change in government insured/guaranteed foreclosed assets is made up of inflows from mortgages held for investment and MHFS, and outflows when we are reimbursed by FHA/VA. Transfers from government insured/guaranteed loans to foreclosed assets amounted to $61 million, $46 million, $38 million, $24 million and $49 million for the quarters ended March 31, 2016 and December 31, September 30, June 30, and March 31, 2015, respectively.
(2)
Predominantly include loans moved into foreclosure from nonaccrual status, PCI loans transitioned directly to foreclosed assets and repossessed automobiles.
Foreclosed assets at March 31, 2016, included $754 million of foreclosed residential real estate that had collateralized commercial and consumer loans, of which 51% is predominantly FHA insured or VA guaranteed and expected to have minimal or no loss content. The remaining foreclosed assets balance of $525 million has been written down to estimated net realizable value. Foreclosed assets at March 31, 2016 decreased compared with December 31, 2015. Of the $1.3 billion in foreclosed assets at March 31, 2016, 45% have been in the foreclosed assets portfolio one year or less.



33


TROUBLED DEBT RESTRUCTURINGS (TDRs)


Table 25: Troubled Debt Restructurings (TDRs)
(in millions)
Mar 31,
2016


Dec 31,
2015


Sep 30,
2015


Jun 30,
2015


Mar 31,
2015

Commercial:
 
 
 
 
 
 
 
 
 
Commercial and industrial
$
1,606

 
1,123

 
999

 
808

 
779

Real estate mortgage
1,364

 
1,456

 
1,623

 
1,740

 
1,838

Real estate construction
116

 
125

 
207

 
236

 
247

Lease financing
6

 
1

 
1

 
2

 
2

Total commercial TDRs
3,092

 
2,705

 
2,830

 
2,786

 
2,866

Consumer:
 
 
 
 
 
 
 
 
 
Real estate 1-4 family first mortgage
16,299

 
16,812

 
17,193

 
17,692

 
18,003

Real estate 1-4 family junior lien mortgage
2,261

 
2,306

 
2,336

 
2,381

 
2,424

Credit Card
295

 
299

 
307

 
315

 
326

Automobile
97

 
105

 
109

 
112

 
124

Other revolving credit and installment
81

 
73

 
63

 
58

 
54

Trial modifications
380

 
402

 
421

 
450

 
432

Total consumer TDRs (1)
19,413

 
19,997

 
20,429

 
21,008

 
21,363

Total TDRs
$
22,505

 
22,702

 
23,259

 
23,794

 
24,229

TDRs on nonaccrual status
$
6,484

 
6,506

 
6,709

 
6,889

 
6,982

TDRs on accrual status (1)
16,021

 
16,196

 
16,550

 
16,905

 
17,247

Total TDRs
$
22,505

 
22,702

 
23,259

 
23,794

 
24,229

(1)
TDR loans include $1.8 billion, $1.8 billion, $1.8 billion, $1.9 billion, and $2.1 billion at March 31, 2016, and December 31, September 30, June 30, and March 31, 2015, respectively, of government insured/guaranteed loans that are predominantly insured by the FHA or guaranteed by the VA and accruing.
 
Table 25 provides information regarding the recorded investment of loans modified in TDRs. The allowance for loan losses for TDRs was $2.5 billion and $2.7 billion at March 31, 2016, and December 31, 2015, respectively. See Note 5 (Loans and Allowance for Credit Losses) to Financial Statements in this Report for additional information regarding TDRs. In those situations where principal is forgiven, the entire amount of such forgiveness is immediately charged off to the extent not done so prior to the modification. We sometimes delay the timing on the repayment of a portion of principal (principal forbearance) and charge off the amount of forbearance if that amount is not considered fully collectible.
For more information on our nonaccrual policies when a restructuring is involved, see the "Risk Management – Credit Risk Management – Troubled Debt Restructurings (TDRs)" section in our 2015 Form 10-K.
 
Table 26 provides an analysis of the changes in TDRs. Loans modified more than once are reported as TDR inflows only in the period they are first modified. Other than resolutions such as foreclosures, sales and transfers to held for sale, we may remove loans held for investment from TDR classification, but only if they have been refinanced or restructured at market terms and qualify as a new loan.


34

Risk Management - Credit Risk Management (continued)

Table 26: Analysis of Changes in TDRs
 
 
 
 
 
Quarter ended
 
(in millions)
Mar 31,
2016

 
Dec 31,
2015

 
Sep 30,
2015

 
Jun 30,
2015

 
Mar 31,
2015

Commercial:
 
 
 
 
 
 
 
 
 
Balance, beginning of quarter
$
2,705

 
2,830

 
2,786

 
2,866

 
2,920

Inflows (1)
866

 
474

 
573

 
372

 
310

Outflows
 
 
 
 
 
 
 
 
 
Charge-offs
(124
)
 
(109
)
 
(86
)
 
(20
)
 
(26
)
Foreclosures
(1
)
 
(64
)
 
(30
)
 
(5
)
 
(11
)
Payments, sales and other (2)
(354
)
 
(426
)
 
(413
)
 
(427
)
 
(327
)
Balance, end of quarter
3,092

 
2,705

 
2,830

 
2,786

 
2,866

Consumer:
 
 
 
 
 
 
 
 
 
Balance, beginning of quarter
19,997

 
20,429

 
21,008

 
21,363

 
21,629

Inflows (1)
661

 
672

 
753

 
747

 
755

Outflows
 
 
 
 
 
 
 
 
 
Charge-offs
(67
)
 
(73
)
 
(79
)
 
(71
)
 
(88
)
Foreclosures
(238
)
 
(226
)
 
(226
)
 
(242
)
 
(245
)
Payments, sales and other (2)
(917
)
 
(786
)
 
(998
)
 
(807
)
 
(668
)
Net change in trial modifications (3)
(23
)
 
(19
)
 
(29
)
 
18

 
(20
)
Balance, end of quarter
19,413

 
19,997

 
20,429

 
21,008

 
21,363

Total TDRs
$
22,505

 
22,702

 
23,259

 
23,794

 
24,229

(1)
Inflows include loans that both modify and resolve within the period as well as advances on loans that modified in a prior period.
(2)
Other outflows include normal amortization/accretion of loan basis adjustments and loans transferred to held-for-sale. It also includes $6 million of loans refinanced or restructured at market terms and qualifying as new loans and removed from TDR classification for the quarter ended December 31, 2015, while no loans were removed from TDR classification for the quarters ended March 31, 2016, and September 30, June 30, and March 31, 2015.
(3)
Net change in trial modifications includes: inflows of new TDRs entering the trial payment period, net of outflows for modifications that either (i) successfully perform and enter into a permanent modification, or (ii) did not successfully perform according to the terms of the trial period plan and are subsequently charged-off, foreclosed upon or otherwise resolved. Our experience is that substantially all of the mortgages that enter a trial payment period program are successful in completing the program requirements.


35


LOANS 90 DAYS OR MORE PAST DUE AND STILL ACCRUING
Loans 90 days or more past due as to interest or principal are still accruing if they are (1) well-secured and in the process of collection or (2) real estate 1-4 family mortgage loans or consumer loans exempt under regulatory rules from being classified as nonaccrual until later delinquency, usually 120 days past due. PCI loans are not included in past due and still accruing loans even though they are 90 days or more contractually past due. These PCI loans are considered to be accruing because they continue to earn interest from accretable yield, independent of performance in accordance with their contractual terms.
Excluding insured/guaranteed loans, loans 90 days or more past due and still accruing at March 31, 2016, were down $178 million, or 18%, from December 31, 2015, due to payoffs, modifications and other loss mitigation activities and credit
 
stabilization. Also, fluctuations from quarter to quarter are influenced by seasonality.
Loans 90 days or more past due and still accruing whose repayments are predominantly insured by the FHA or guaranteed by the VA for mortgages and the U.S. Department of Education for student loans under the Federal Family Education Loan Program (FFELP) were $12.3 billion at March 31, 2016, down from $13.4 billion at December 31, 2015, due to seasonally lower delinquencies.
Table 27 reflects non-PCI loans 90 days or more past due and still accruing by class for loans not government insured/guaranteed. For additional information on delinquencies by loan class, see Note 5 (Loans and Allowance for Credit Losses) to Financial Statements in this Report.

Table 27: Loans 90 Days or More Past Due and Still Accruing
(in millions)
Mar 31, 2016

 
Dec 31, 2015

 
Sep 30, 2015

 
Jun 30, 2015

 
Mar 31, 2015

Loans 90 days or more past due and still accruing:
 
 
 
 
 
 
 
 
 
Total (excluding PCI (1)):
$
13,060

 
14,380

 
14,405

 
15,161

 
16,344

Less: FHA insured/VA guaranteed (2)(3)
12,233

 
13,373

 
13,500

 
14,359

 
15,453

Less: Student loans guaranteed under the FFELP (4)
24

 
26

 
33

 
46

 
50

Total, not government insured/guaranteed
$
803

 
981

 
872

 
756

 
841

By segment and class, not government insured/guaranteed:
Commercial:
 
 
 
 
 
 
 
 
 
Commercial and industrial
$
24

 
97

 
53

 
17

 
31

Real estate mortgage
8

 
13

 
24

 
10

 
43

Real estate construction
2

 
4

 

 

 

Total commercial
34


114


77


27


74

Consumer:
 
 
 
 
 
 
 
 
 
Real estate 1-4 family first mortgage (3)
167

 
224

 
216

 
220

 
221

Real estate 1-4 family junior lien mortgage (3)
55

 
65

 
61

 
65

 
55

Credit card
389

 
397

 
353

 
304

 
352

Automobile
55

 
79

 
66

 
51

 
47

Other revolving credit and installment
103

 
102

 
99

 
89

 
92

Total consumer
769

 
867


795


729


767

Total, not government insured/guaranteed
$
803

 
981


872


756


841

(1)
PCI loans totaled $2.7 billion, $2.9 billion, $3.2 billion, $3.4 billion, and $3.6 billion at March 31, 2016, and December 31, September 30, June 30, and March 31, 2015, respectively.
(2)
Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA.
(3)
Includes mortgage loans held for sale 90 days or more past due and still accruing.
(4)
Represents loans whose repayments are predominantly guaranteed by agencies on behalf of the U.S. Department of Education under the FFELP.



36

Risk Management - Credit Risk Management (continued)

NET CHARGE-OFFS

Table 28: Net Charge-offs
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Quarter ended 
 
 
Mar 31, 2016
 
 
Dec 31, 2015
 
 
Sep 30, 2015
 
 
Jun 30, 2015
 
 
Mar 31, 2015
 
($ in millions)
Net loan
charge-
offs

 
% of 
avg. 
loans(1) 

 
Net loan
charge-
offs

 
% of avg. loans (1)

 
Net loan
charge-
offs

 
% of avg. loans (1)

 
Net loan
charge-offs

 
% of
avg. loans (1)

 
Net loan
charge-offs

 
% of
avg.
loans (1)

Commercial:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Commercial and industrial
$
273

 
0.36
 %
 
$
215

 
0.29
 %
 
$
122

 
0.17
 %
 
$
81

 
0.12
 %
 
$
64

 
0.10
 %
Real estate mortgage
(29
)
 
(0.10
)
 
(19
)
 
(0.06
)
 
(23
)
 
(0.08
)
 
(15
)
 
(0.05
)
 
(11
)
 
(0.04
)
Real estate construction
(8
)
 
(0.13
)
 
(10
)
 
(0.18
)
 
(8
)
 
(0.15
)
 
(6
)
 
(0.11
)
 
(9
)
 
(0.19
)
Lease financing
1

 
0.01

 
1

 
0.01

 
3

 
0.11

 
2

 
0.06

 

 

Total commercial
237

 
0.20

 
187

 
0.16

 
94

 
0.08

 
62

 
0.06

 
44

 
0.04

Consumer:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Real estate 1-4 family
first mortgage
48

 
0.07

 
50

 
0.07

 
62

 
0.09

 
67

 
0.10

 
83

 
0.13

Real estate 1-4 family
junior lien mortgage
74

 
0.57

 
70

 
0.52

 
89

 
0.64

 
94

 
0.66

 
123

 
0.85

Credit card
262

 
3.16

 
243

 
2.93

 
216

 
2.71

 
243

 
3.21

 
239

 
3.19

Automobile
127

 
0.85

 
135

 
0.90

 
113

 
0.76

 
68

 
0.48

 
101

 
0.73

Other revolving credit and
installment
138

 
1.42

 
146

 
1.49

 
129

 
1.35

 
116

 
1.26

 
118

 
1.32

Total consumer
649

 
0.57

 
644

 
0.56

 
609

 
0.53

 
588

 
0.53

 
664

 
0.60

Total
$
886

 
0.38
 %
 
$
831

 
0.36
 %
 
$
703

 
0.31
 %
 
$
650

 
0.30
 %
 
$
708

 
0.33
 %
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(1)
Quarterly net charge-offs (recoveries) as a percentage of average respective loans are annualized.

Table 28 presents net charge-offs for first quarter 2016 and the previous four quarters. Net charge-offs in first quarter 2016 were $886 million (0.38% of average total loans outstanding) compared with $708 million (0.33%) in first quarter 2015.
The increase in commercial and industrial net charge-offs reflected continued deterioration within the oil and gas portfolio. Our commercial real estate portfolios were in a net recovery position. Total consumer net charge-offs increased slightly from the prior quarter.

ALLOWANCE FOR CREDIT LOSSES  The allowance for credit losses, which consists of the allowance for loan losses and the allowance for unfunded credit commitments, is management’s estimate of credit losses inherent in the loan portfolio and unfunded credit commitments at the balance sheet date, excluding loans carried at fair value. The detail of the changes in the allowance for credit losses by portfolio segment (including charge-offs and recoveries by loan class) is in Note 5 (Loans and Allowance for Credit Losses) to Financial Statements in this Report.
 
We apply a disciplined process and methodology to establish our allowance for credit losses each quarter. This process takes into consideration many factors, including historical and forecasted loss trends, loan-level credit quality ratings and loan grade-specific characteristics. The process involves subjective and complex judgments. In addition, we review a variety of credit metrics and trends. These credit metrics and trends, however, do not solely determine the amount of the allowance as we use several analytical tools. Our estimation approach for the commercial portfolio reflects the estimated probability of default in accordance with the borrower’s financial strength, and the severity of loss in the event of default, considering the quality of any underlying collateral. Probability of default and severity at the time of default are statistically derived through historical observations of defaults and losses after default within each credit risk rating. Our estimation approach for the consumer portfolio uses forecasted losses that represent our best estimate of inherent loss based on historical experience, quantitative and other mathematical techniques. For additional information on our allowance for credit losses, see the “Critical Accounting Policies – Allowance for Credit Losses” section in our 2015 Form 10-K and Note 5 (Loans and Allowance for Credit Losses) to Financial Statements in this Report.
Table 29 presents the allocation of the allowance for credit losses by loan segment and class for the most recent quarter end and last four year ends.


37


Table 29: Allocation of the Allowance for Credit Losses (ACL)
 
Mar 31, 2016
 
 
Dec 31, 2015
 
 
Dec 31, 2014
 
 
Dec 31, 2013
 
 
Dec 31, 2012
 
(in millions)
ACL

 
Loans
as %
of total
loans

 
ACL

 
Loans
as %
of total
loans

 
ACL

 
Loans
as %
of total
loans

 
ACL

 
Loans
as %
of total
loans

 
ACL

 
Loans
as %
of total
loans

Commercial:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Commercial and industrial
$
4,723

 
34
%
 
$
4,231

 
33
%
 
$
3,506

 
32
%
 
$
3,040

 
29
%
 
$
2,789

 
28
%
Real estate mortgage
1,221

 
13

 
1,264

 
13

 
1,576

 
13

 
2,157

 
14

 
2,284

 
13

Real estate construction
1,230

 
3

 
1,210

 
3

 
1,097

 
2

 
775

 
2

 
552

 
2

Lease financing
174

 
2

 
167

 
1

 
198

 
1

 
131

 
1

 
89

 
2

Total commercial
7,348

 
52

 
6,872

 
50

 
6,377

 
48

 
6,103

 
46

 
5,714

 
45

Consumer:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Real estate 1-4 family first mortgage
1,661

 
29

 
1,895

 
30

 
2,878

 
31

 
4,087

 
32

 
6,100

 
31

Real estate 1-4 family
junior lien mortgage
1,057

 
6

 
1,223

 
6

 
1,566

 
7

 
2,534

 
8

 
3,462

 
10

Credit card
1,392

 
3

 
1,412

 
4

 
1,271

 
4

 
1,224

 
3

 
1,234

 
3

Automobile
589

 
6

 
529

 
6

 
516

 
6

 
475

 
6

 
417

 
6

Other revolving credit and installment
621

 
4

 
581

 
4

 
561

 
4

 
548

 
5

 
550

 
5

Total consumer
5,320

 
48

 
5,640

 
50

 
6,792

 
52

 
8,868

 
54

 
11,763

 
55

Total
$
12,668

 
100
%
 
$
12,512

 
100
%
 
$
13,169

 
100
%
 
$
14,971

 
100
%
 
$
17,477

 
100
%
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Mar 31, 2016
 
 
Dec 31, 2015
 
 
Dec 31, 2014
 
 
Dec 31, 2013
 
 
Dec 31, 2012
 
Components:
 
 
 
 
 
 
 
 
 
Allowance for loan losses
$
11,621
 
 
11,545
 
 
12,319
 
 
14,502
 
 
17,060
 
Allowance for unfunded
credit commitments
1,047
 
 
967
 
 
850
 
 
469
 
 
417
 
Allowance for credit losses
$
12,668
 
 
12,512
 
 
13,169
 
 
14,971
 
 
17,477
 
Allowance for loan losses as a percentage of total loans
1.23
%
 
1.26
 
 
1.43
 
 
1.76
 
 
2.13
 
Allowance for loan losses as a percentage of total net charge-offs (1)
326
 
 
399
 
 
418
 
 
322
 
 
189
 
Allowance for credit losses as a percentage of total loans
1.34
 
 
1.37
 
 
1.53
 
 
1.82
 
 
2.19
 
Allowance for credit losses as a percentage of total nonaccrual loans
104
 
 
110
 
 
103
 
 
96
 
 
85
 
(1)
Total net charge-offs are annualized for quarter ended March 31, 2016.

In addition to the allowance for credit losses, there was $2.3 billion at March 31, 2016, and $1.9 billion at December 31, 2015, of nonaccretable difference to absorb losses for PCI loans. The allowance for credit losses is lower than otherwise would have been required without PCI loan accounting. As a result of PCI loans, certain ratios of the Company may not be directly comparable with credit-related metrics for other financial institutions. Additionally, loans purchased at fair value, including loans from the GE Capital acquisitions, generally reflect a lifetime credit loss adjustment and therefore do not initially require additions to the allowance as is typically associated with loan growth. For additional information on PCI loans, see the “Risk Management – Credit Risk Management – Purchased Credit-Impaired Loans” section and Note 5 (Loans and Allowance for Credit Losses) to Financial Statements in this Report.
The ratio of the allowance for credit losses to total nonaccrual loans may fluctuate significantly from period to period due to such factors as the mix of loan types in the portfolio, borrower credit strength and the value and marketability of collateral. Over one-half of our nonaccrual loans were real estate 1-4 family first and junior lien mortgage loans at March 31, 2016.
 
The allowance for credit losses increased from December 31, 2015, due to an increase in our commercial allowance reflecting deterioration in the oil and gas portfolio, partially offset by continued credit improvement in our residential real estate portfolios, primarily associated with continued improvement in the housing market. Total provision for credit losses was $1.1 billion in first quarter 2016, compared with $608 million in first quarter 2015.
We believe the allowance for credit losses of $12.7 billion at March 31, 2016, was appropriate to cover credit losses inherent in the loan portfolio, including unfunded credit commitments, at that date. Approximately $1.7 billion of the allowance at March 31, 2016 was allocated to our oil and gas portfolio, compared with $1.2 billion at December 31, 2015. However, the entire allowance is available to absorb credit losses inherent in the total loan portfolio. The allowance for credit losses is subject to change and reflects existing factors as of the date of determination, including economic or market conditions and ongoing internal and external examination processes. Due to the sensitivity of the allowance for credit losses to changes in the economic and business environment, it is possible that we will incur incremental credit losses not anticipated as of the balance


38

Risk Management - Credit Risk Management (continued)

sheet date. Future allowance levels will be based on a variety of factors, including loan growth, portfolio performance and general economic conditions. Our process for determining the allowance for credit losses is discussed in the “Critical Accounting Policies – Allowance for Credit Losses” section and Note 1 (Summary of Significant Accounting Policies) to Financial Statements in our 2015 Form 10-K.
LIABILITY FOR MORTGAGE LOAN REPURCHASE LOSSES 
In connection with our sales and securitization of residential mortgage loans to various parties, we have established a mortgage repurchase liability, initially at fair value, related to various representations and warranties that reflect management’s estimate of losses for loans for which we could have a repurchase obligation, whether or not we currently service those loans, based on a combination of factors. Our mortgage repurchase liability estimation process also incorporates a forecast of repurchase demands associated with mortgage insurance rescission activity.
Because we retain the servicing for most of the mortgage loans we sell or securitize, we believe the quality of our residential mortgage loan servicing portfolio provides helpful information in evaluating our repurchase liability. Of the $1.6 trillion in the residential mortgage loan servicing portfolio at March 31, 2016, 95% was current and less than 2% was subprime at origination. Our combined delinquency and foreclosure rate on this portfolio was 4.50% at March 31, 2016, compared with 5.18% at December 31, 2015. Two percent of this portfolio is private label securitizations for which we originated the loans and, therefore have some repurchase risk.
The overall level of unresolved repurchase demands and mortgage insurance rescissions outstanding at March 31, 2016, was $47 million, representing 215 loans, down from a year ago both in number of outstanding loans and in total dollar balances as we observed a decline in new demands and continued to work through the outstanding demands and mortgage insurance rescissions.
Our liability for mortgage repurchases, included in “Accrued expenses and other liabilities” in our consolidated balance sheet, represents our best estimate of the probable loss that we expect to incur for various representations and warranties in the contractual provisions of our sales of mortgage loans. The liability was $355 million at March 31, 2016, $378 million at December 31, 2015, and $586 million at March 31, 2015. In first quarter 2016, we released $12 million, which increased net gains on mortgage loan origination/sales activities, compared with a release of $16 million in first quarter 2015. The release in first quarter 2016 was primarily due to a re-estimation of our liability based on recently observed trends. We incurred net losses on repurchased loans and investor reimbursements totaling $11 million in first quarter 2016, compared with $13 million in first quarter 2015.
Because of the uncertainty in the various estimates underlying the mortgage repurchase liability, there is a range of losses in excess of the recorded mortgage repurchase liability that are reasonably possible. The estimate of the range of possible loss for representations and warranties does not represent a probable loss, and is based on currently available information, significant judgment, and a number of assumptions that are subject to change. The high end of this range of reasonably possible losses exceeded our recorded liability by $274 million at March 31, 2016, and was determined based upon modifying the assumptions (particularly to assume significant changes in investor repurchase demand practices) used in our best estimate of probable loss to reflect what we
 
believe to be the high end of reasonably possible adverse assumptions.
For additional information on our repurchase liability, see the “Risk Management – Credit Risk Management – Liability For Mortgage Loan Repurchase Losses” section in our 2015 Form 10-K and Note 8 (Mortgage Banking Activities) to Financial Statements in this Report.

RISKS RELATING TO SERVICING ACTIVITIES In addition to servicing loans in our portfolio, we act as servicer and/or master servicer of residential mortgage loans included in GSE-guaranteed mortgage securitizations, GNMA-guaranteed mortgage securitizations of FHA-insured/VA-guaranteed mortgages and private label mortgage securitizations, as well as for unsecuritized loans owned by institutional investors. In connection with our servicing activities we have entered into various settlements with federal and state regulators to resolve certain alleged servicing issues and practices. In general, these settlements required us to provide customers with loan modification relief, refinancing relief, and foreclosure prevention and assistance, as well as imposed certain monetary penalties on us.
In particular, in June 2015, we entered into an amendment to an April 2011 Consent Order with the Office of the Comptroller of the Currency (OCC) to address 15 of the 98 actionable items contained in the April 2011 Consent Order that were still considered open. This amendment requires that we remediate certain activities associated with our mortgage loan servicing practices and allows for the OCC to take additional supervisory action, including possible civil money penalties, if we do not comply with the terms of this amended Consent Order. In addition, this amendment prohibits us from acquiring new mortgage servicing rights or entering into new mortgage servicing contracts, other than mortgage servicing associated with originating mortgage loans or purchasing loans from correspondent clients in our normal course of business. Additionally, this amendment prohibits any new off-shoring of new mortgage servicing activities and requires OCC approval to outsource or sub-service any new mortgage servicing activities.
For additional information about the risks and various settlements related to our servicing activities, see the “Risk Management – Credit Risk Management – Risks Relating to Servicing Activities” section in our 2015 Form 10-K.




39


Asset/Liability Management
Asset/liability management involves evaluating, monitoring and managing interest rate risk, market risk, liquidity and funding. Primary oversight of interest rate risk and market risk resides with the Finance Committee of our Board of Directors (Board), which oversees the administration and effectiveness of financial risk management policies and processes used to assess and manage these risks. Primary oversight of liquidity and funding resides with the Risk Committee of the Board. At the management level we utilize a Corporate Asset/Liability Management Committee (Corporate ALCO), which consists of senior financial, risk, and business executives, to oversee these risks and report on them periodically to the Board’s Finance Committee and Risk Committee as appropriate. Each of our principal lines of business has its own asset/liability management committee and process linked to the Corporate ALCO process. As discussed in more detail for trading activities below, we employ separate management level oversight specific to market risk. Market risk, in its broadest sense, refers to the possibility that losses will result from the impact of adverse changes in market rates and prices on our trading and non-trading portfolios and financial instruments.
 
INTEREST RATE RISK Interest rate risk, which potentially can have a significant earnings impact, is an integral part of being a financial intermediary.  
We assess interest rate risk by comparing outcomes under various earnings simulations using many interest rate scenarios that differ in the direction of interest rate changes, the degree of change over time, the speed of change and the projected shape of the yield curve. These simulations require assumptions regarding how changes in interest rates and related market conditions could influence drivers of earnings and balance sheet composition such as loan origination demand, prepayment speeds, deposit balances and mix, as well as pricing strategies.
Our risk measures include both net interest income sensitivity and interest rate sensitive noninterest income and expense impacts. We refer to the combination of these exposures as interest rate sensitive earnings. In general, the Company is positioned to benefit from higher interest rates. Currently, our profile is such that net interest income will benefit from higher interest rates as our assets reprice faster and to a greater degree than our liabilities, and, in response to lower market rates, our assets will reprice downward and to a greater degree than our liabilities. Our interest rate sensitive noninterest income and expense is largely driven by mortgage activity, and tends to move in the opposite direction of our net interest income. So, in response to higher interest rates, mortgage activity, primarily refinancing activity, generally declines. And in response to lower rates, mortgage activity generally increases. Mortgage results in our simulations are also impacted by the valuation of MSRs and related hedge positions. See the “Risk Management–Mortgage Banking Interest Rate and Market Risk” section in this Report for more information.
The degree to which these sensitivities offset each other is dependent upon the timing and magnitude of changes in interest rates, and the slope of the yield curve. During a transition to a higher or lower interest rate environment, a reduction or increase in interest-sensitive earnings from the mortgage banking business could occur quickly, while the benefit or detriment from balance sheet repricing could take more time to develop. For example, our lower rate scenarios (scenario 1 and scenario 2) in the following table measure a decline in interest rates versus our most likely scenario. Although the performance in these rate scenarios contain benefits from increased mortgage banking
 
activity, the result is lower earnings relative to the most likely scenario over time given pressure on net interest income. The higher rate scenarios (scenario 3 and scenario 4) measure the impact of varying degrees of rising short-term and long-term interest rates over the course of the forecast horizon relative to the most likely scenario, both resulting in positive earnings sensitivity.
For more information about the various causes of interest rate risk, see the "Risk Management–Asset/Liability Management–Interest Rate Risk" section in our 2015 Form 10-K.
As of March 31, 2016, our most recent simulations estimate earnings at risk over the next 24 months under a range of both lower and higher interest rates. The results of the simulations are summarized in Table 30, indicating cumulative net income after tax earnings sensitivity relative to the most likely earnings plan over the 24 month horizon (a positive range indicates a beneficial earnings sensitivity measurement relative to the most likely earnings plan and a negative range indicates a detrimental earnings sensitivity relative to the most likely earnings plan). 
Table 30: Earnings Sensitivity Over 24 Month Horizon Relative to Most Likely Earnings Plan
 
Most

Lower rates
 
Higher rates
 
likely

Scenario 1
Scenario 2
 
Scenario 3
 
Scenario 4
Ending rates:
 
 
 
 
 
 
 
Federal funds
2.14
%
0.25
1.90
 
2.36
 
5.25
10-year treasury (1)
3.44

1.80
2.94
 
3.94
 
6.30
Earnings relative to most likely
N/A

(4)-(5)
(1)-(2)
 
0-5
 
0-5
(1)
U.S. Constant Maturity Treasury Rate

We use the investment securities portfolio and exchange-traded and over-the-counter (OTC) interest rate derivatives to hedge our interest rate exposures. See the “Balance Sheet Analysis – Investment Securities” section in this Report for more information on the use of the available-for-sale and held-to-maturity securities portfolios. The notional or contractual amount, credit risk amount and fair value of the derivatives used to hedge our interest rate risk exposures as of March 31, 2016, and December 31, 2015, are presented in Note 12 (Derivatives) to Financial Statements in this Report. We use derivatives for asset/liability management in two main ways:
to convert the cash flows from selected asset and/or liability instruments/portfolios including investments, commercial loans and long-term debt, from fixed-rate payments to floating-rate payments, or vice versa; and
to economically hedge our mortgage origination pipeline, funded mortgage loans and MSRs using interest rate swaps, swaptions, futures, forwards and options.
 
MORTGAGE BANKING INTEREST RATE AND MARKET RISK  We originate, fund and service mortgage loans, which subjects us to various risks, including credit, liquidity and interest rate risks. For more information on mortgage banking interest rate and market risk, see the "Risk Management – Asset/Liability Management – Mortgage Banking Interest Rate and Market Risk" section in our 2015 Form 10-K.
While our hedging activities are designed to balance our mortgage banking interest rate risks, the financial instruments we use may not perfectly correlate with the values and income being hedged. For example, the change in the value of ARM production held for sale from changes in mortgage interest rates may or may not be fully offset by Treasury and LIBOR index-based financial instruments used as economic hedges for such


40

Asset/Liability Management (continued)

ARMs. Additionally, hedge-carry income on our economic hedges for the MSRs may not continue at recent levels if the spread between short-term and long-term rates decreases or there are other changes in the market for mortgage forwards that affect the implied carry.
The total carrying value of our residential and commercial MSRs was $12.7 billion at March 31, 2016, and $13.7 billion at December 31, 2015. The weighted-average note rate on our portfolio of loans serviced for others was 4.34% at March 31, 2016, and 4.37% at December 31, 2015. The carrying value of our total MSRs represented 0.72% of mortgage loans serviced for others at March 31, 2016, and 0.77% at December 31, 2015.
 
MARKET RISK – TRADING ACTIVITIES  The Finance Committee of our Board of Directors reviews the acceptable market risk appetite for our trading activities. We engage in trading activities primarily to accommodate the investment and risk management activities of our customers (which involves transactions that are recorded as trading assets and liabilities on our balance sheet), to execute economic hedging to manage certain balance sheet risks and, to a very limited degree, for proprietary trading for our own account. These activities primarily occur within our Wholesale Banking businesses and to a lesser extent other divisions of the Company. All of our trading assets and liabilities, including securities, foreign exchange transactions, commodity transactions, and derivatives are carried at fair value. Income earned related to these trading activities include net interest income and changes in fair value related to trading assets and liabilities. Net interest income earned on trading assets and liabilities is reflected in the interest income and interest expense components of our income statement. Changes in fair value of trading assets and liabilities are reflected in net gains on trading activities, a component of noninterest income in our income statement.
Table 31 presents total revenue from trading activities.

Table 31: Net gains (losses) from Trading Activities
 
Quarter ended Mar 31,
 
(in millions)
 
2016

 
2015

Interest income (1)
 
$
596

 
445

Less: Interest expense (2)
 
89

 
97

Net interest income
 
507

 
348

Noninterest income:
 
 
 
 
Net gains (losses) from trading activities (3):
 
 
 
 
Customer accommodation
 
219

 
297

Economic hedges and other (4)
 
(19
)
 
111

Total net gains (losses) from trading activities
 
200

 
408

Total trading-related net interest and noninterest income
 
$
707

 
756

(1)
Represents interest and dividend income earned on trading securities.
(2)
Represents interest and dividend expense incurred on trading securities we have sold but have not yet purchased.
(3)
Represents realized gains (losses) from our trading activity and unrealized gains (losses) due to changes in fair value of our trading positions, attributable to the type of business activity.
(4)
Excludes economic hedging of mortgage banking and asset/liability management activities, for which hedge results (realized and unrealized) are reported with the respective hedged activities.
Customer accommodation  Customer accommodation activities are conducted to help customers manage their investment and risk management needs. We engage in market-making activities or act as an intermediary to purchase or sell financial instruments in anticipation of or in response to customer needs.
 
This category also includes positions we use to manage our exposure to customer transactions.
For the majority of our customer accommodation trading, we serve as intermediary between buyer and seller. For example, we may purchase or sell a derivative to a customer who wants to manage interest rate risk exposure. We typically enter into offsetting derivative or security positions with a separate counterparty or exchange to manage our exposure to the derivative with our customer. We earn income on this activity based on the transaction price difference between the customer and offsetting derivative or security positions, which is reflected in the fair value changes of the positions recorded in net gains on trading activities.
Customer accommodation trading also includes net gains related to market-making activities in which we take positions to facilitate customer order flow. For example, we may own securities recorded as trading assets (long positions) or sold securities we have not yet purchased, recorded as trading liabilities (short positions), typically on a short-term basis, to facilitate support of buying and selling demand from our customers. As a market maker in these securities, we earn income due to: (1) the difference between the price paid or received for the purchase and sale of the security (bid-ask spread), (2) the net interest income, and (3) the change in fair value of the long or short positions during the short-term period held on our balance sheet. Additionally, we may enter into separate derivative or security positions to manage our exposure related to our long or short security positions. Income earned on this type of market-making activity is reflected in the fair value changes of these positions recorded in net gains on trading activities.

Economic hedges and other  Economic hedges in trading are not designated in a hedge accounting relationship and exclude economic hedging related to our asset/liability risk management and substantially all mortgage banking risk management activities. Economic hedging activities include the use of trading securities to economically hedge risk exposures related to non-trading activities or derivatives to hedge risk exposures related to trading assets or trading liabilities. Economic hedges are unrelated to our customer accommodation activities. Other activities include financial assets held for investment purposes that we elected to carry at fair value with changes in fair value recorded to earnings in order to mitigate accounting measurement mismatches or avoid embedded derivative accounting complexities.

Proprietary trading  Proprietary trading consists of security or derivative positions executed for our own account based upon market expectations or to benefit from price differences between financial instruments and markets. Proprietary trading activity has been substantially restricted by the Dodd-Frank Act provisions known as the “Volcker Rule.” Accordingly, we reduced and have exited certain business activities as a result of the rule. As discussed within this section and the noninterest income section of our financial results, proprietary trading activity is insignificant to our business and financial results. For more details on the Volcker Rule, see the “Regulatory Reform” section in our 2015 Form 10-K.
 
Daily Trading-Related Revenue  Table 32 provides information on the distribution of daily trading-related revenues for the Company’s trading portfolio. This trading-related revenue is defined as the change in value of the trading assets and trading liabilities, trading-related net interest income, and trading-related intra-day gains and losses. Net trading-related revenue


41


does not include activity related to long-term positions held for economic hedging purposes, period-end adjustments, and other activity not representative of daily price changes driven by market factors.

Table 32: Distribution of Daily Trading-Related Revenues
    
Market risk is the risk of possible economic loss from adverse changes in market risk factors such as interest rates, credit spreads, foreign exchange rates, equity, commodity prices, mortgage rates, and market liquidity. Market risk is intrinsic to the Company’s sales and trading, market making, investing, and risk management activities.
The Company uses value-at-risk (VaR) metrics complemented with sensitivity analysis and stress testing in measuring and monitoring market risk. VaR is a statistical risk measure used to estimate the potential loss from adverse moves in the financial markets.
Trading VaR is the measure used to provide insight into the market risk exhibited by the Company’s trading positions. The
 
Company calculates Trading VaR for risk management purposes to establish line of business and Company-wide risk limits. Trading VaR is calculated based on all trading positions classified as trading assets or trading liabilities on our balance sheet.
Table 33 shows the results of the Company’s Trading General VaR by risk category. As presented in the table, average Trading General VaR was $18 million for the quarter ended March 31, 2016, compared with $19 million for the quarter ended December 31, 2015. The decrease was primarily driven by changes in portfolio composition.


Table 33: Trading 1-Day 99% General VaR by Risk Category
 
 
 
Quarter ended
 
 
March 31, 2016
 
 
December 31, 2015
 
(in millions)
Period
end

 
Average

 
Low

 
High

 
Period
end

 
Average

 
Low

 
High

Company Trading General VaR Risk Categories
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Credit
$
16

 
16

 
14

 
18

 
14

 
18

 
14

 
25

Interest rate
11

 
11

 
6

 
19

 
8

 
9

 
5

 
13

Equity
14

 
14

 
11

 
16

 
13

 
14

 
12

 
16

Commodity
1

 
1

 
1

 
2

 
1

 
1

 
1

 
1

Foreign exchange
1

 
2

 
1

 
2

 
2

 
1

 
1

 
2

Diversification benefit (1)
(23
)
 
(26
)
 
 
 
 
 
(20
)
 
(24
)
 
 
 
 
Company Trading General VaR
$
20

 
18

 
 
 
 
 
18

 
19

 
 
 
 
(1)
The period-end VaR was less than the sum of the VaR components described above, which is due to portfolio diversification. The diversification effect arises because the risks are not perfectly correlated causing a portfolio of positions to usually be less risky than the sum of the risks of the positions alone. The diversification benefit is not meaningful for low and high metrics since they may occur on different days.

Regulatory Market Risk Capital  is based on U.S. regulatory agency risk-based capital regulations that are based on the Basel Committee Capital Accord of the Basel Committee on Banking
 
Supervision. The Company must calculate regulatory capital based on the Basel III market risk capital rule, which requires banking organizations with significant trading activities to adjust


42

Asset/Liability Management (continued)

their capital requirements to better account for the market risks of those activities based on comprehensive and risk sensitive methods and models. The market risk capital rule is intended to cover the risk of loss in value of covered positions due to changes in market conditions.
 
Composition of Material Portfolio of Covered Positions  The positions that are “covered” by the market risk capital rule are generally a subset of our trading assets and trading liabilities, specifically those held by the Company for the purpose of short-term resale or with the intent of benefiting from actual or expected short-term price movements, or to lock in arbitrage profits. Positions excluded from market risk regulatory capital treatment are subject to the credit risk capital rules applicable to the “non-covered” trading positions.
The material portfolio of the Company’s “covered” positions is predominantly concentrated in the trading assets and trading liabilities managed within Wholesale Banking where the substantial portion of market risk capital resides. Wholesale Banking engages in the fixed income, traded credit, foreign exchange, equities, and commodities markets businesses. Other business segments hold small additional trading positions covered under the market risk capital rule.

Regulatory Market Risk Capital Components  The capital required for market risk on the Company’s “covered” positions is determined by internally developed models or standardized specific risk charges. The market risk regulatory capital models
 
are subject to internal model risk management and validation. The models are continuously monitored and enhanced in response to changes in market conditions, improvements in system capabilities, and changes in the Company’s market risk exposure. The Company is required to obtain and has received prior written approval from its regulators before using its internally developed models to calculate the market risk capital charge.
Basel III prescribes various VaR measures in the determination of regulatory capital and RWAs. The Company uses the same VaR models for both market risk management purposes as well as regulatory capital calculations. For regulatory purposes, we use the following metrics to determine the Company’s market risk capital requirements:
 
General VaR measures the risk of broad market movements such as changes in the level of credit spreads, interest rates, equity prices, commodity prices, and foreign exchange rates. General VaR uses historical simulation analysis based on 99% confidence level and a 10-day time horizon.
Table 34 shows the General VaR measure categorized by major risk categories. Average 10-day Company Regulatory General VaR was $36 million for the quarter ended March 31, 2016, compared with $40 million for the quarter ended December 31, 2015. The decrease was primarily driven by changes in portfolio composition.

Table 34: Regulatory 10-Day 99% General VaR by Risk Category
 
 
 
Quarter ended
 
 
March 31, 2016
 
 
December 31, 2015
 
(in millions)
Period
end

 
Average

 
Low

 
High

 
Period
end

 
Average

 
Low

 
High

Wholesale Regulatory General VaR Risk Categories
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Credit
$
19

 
31

 
19

 
44

 
29

 
38

 
26

 
54

Interest rate
21

 
29

 
17

 
48

 
25

 
29

 
21

 
40

Equity
4

 
7

 
4

 
12

 
9

 
7

 
4

 
11

Commodity
3

 
2

 
1

 
4

 
2

 
3

 
1

 
5

Foreign exchange
2

 
2

 
1

 
5

 
2

 
2

 
1

 
5

Diversification benefit (1)
(24
)
 
(37
)
 
 
 
 
 
(22
)
 
(41
)
 
 
 
 
Wholesale Regulatory General VaR
$
25

 
34

 
20

 
54

 
45

 
38

 
26

 
54

Company Regulatory General VaR
27

 
36

 
19

 
56

 
47

 
40

 
28

 
56

(1)
The period-end VaR was less than the sum of the VaR components described above, which is due to portfolio diversification. The diversification benefit arises because the risks are not perfectly correlated causing a portfolio of positions to usually be less risky than the sum of the risks of the positions alone. The diversification benefit is not meaningful for low and high metrics since they may occur on different days.

Specific Risk measures the risk of loss that could result from factors other than broad market movements, or name-specific market risk. Specific Risk uses Monte Carlo simulation analysis based on a 99% confidence level and a 10-day time horizon.
 
Total VaR (as presented in Table 35) is composed of General VaR and Specific Risk and uses the previous 12 months of historical market data in compliance with regulatory requirements.

Total Stressed VaR (as presented in Table 35) uses a historical period of significant financial stress over a continuous 12 month period using historically available market data and is composed of Stressed General VaR and Stressed Specific Risk. Total Stressed VaR uses the same methodology and models as Total VaR. 

 
Incremental Risk Charge (as presented in Table 35) captures losses due to both issuer default and migration risk at the 99.9% confidence level over the one-year capital horizon under the assumption of constant level of risk or a constant position assumption. The model covers all non-securitized credit-sensitive trading products.
The Company calculates Incremental Risk by generating a portfolio loss distribution using Monte Carlo simulation, which assumes numerous scenarios, where an assumption is made that the portfolio’s composition remains constant for a one-year time horizon. Individual issuer credit grade migration and issuer default risk is modeled through generation of the issuer’s credit rating transition based upon statistical modeling. Correlation between credit grade migration and default is captured by a multifactor proprietary model which takes into account industry classifications as well as regional effects. Additionally, the impact


43


of market and issuer specific concentrations is reflected in the modeling framework by assignment of a higher charge for portfolios that have increasing concentrations in particular issuers or sectors. Lastly, the model captures product basis risk; that is, it reflects the material disparity between a position and its hedge.
 
Table 35 provides information on Total VaR, Total Stressed VaR and the Incremental Risk Charge results for the quarter ended March 31, 2016. For the Incremental Risk Charge, the required capital for market risk at quarter end equals the average for the quarter. 


Table 35: Market Risk Regulatory Capital Modeled Components
 
Quarter ended March 31, 2016
 
 
March 31, 2016
 
(in millions)
Average

 
Low

 
High

 
Quarter end

 
Risk-
based
capital (1)

 
Risk-
weighted
assets (1)

Total VaR
$
63

 
55

 
73

 
65

 
190

 
2,374

Total Stressed VaR
231

 
160

 
291

 
191

 
693

 
8,668

Incremental Risk Charge
287

 
245

 
326

 
257

 
287

 
3,587

(1)
Results represent the risk-based capital and RWAs based on the VaR and Incremental Risk Charge models.

Securitized Products Charge  Basel III requires a separate market risk capital charge for positions classified as a securitization or re-securitization. The primary criteria for classification as a securitization are whether there is a transfer of risk and whether the credit risk associated with the underlying exposures has been separated into at least two tranches reflecting different levels of seniority. Covered trading securitizations positions include consumer and commercial asset-backed securities (ABS), commercial mortgage-backed securities (CMBS), residential mortgage-backed securities (RMBS), and collateralized loan and other debt obligations (CLO/CDO) positions. The securitization capital requirements are the greater of the capital requirements of the net long or short exposure, and are capped at the maximum loss that could be incurred on any given transaction.
Table 36 shows the aggregate net fair market value of securities and derivative securitization positions by exposure type that meet the regulatory definition of a covered trading securitization position at March 31, 2016, and December 31, 2015.
Table 36: Covered Securitization Positions by Exposure Type (Net Market Value)
(in millions)
ABS

 
CMBS

 
RMBS

 
CLO/CDO

March 31, 2016
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Securitization exposure:
 
 
 
 
 
 
 
Securities
$
815

 
327

 
665

 
336

Derivatives
12

 
4

 
2

 
(12
)
Total
$
827

 
331

 
667

 
324

December 31, 2015
 
 
 
 
 
 
 
Securitization exposure:
 
 
 
 
 
 
 
Securities
$
962

 
402

 
571

 
667

Derivatives
15

 
6

 
2

 
(21
)
Total
$
977

 
408

 
573

 
646

 
SECURITIZATION DUE DILIGENCE AND RISK MONITORING The market risk capital rule requires that the Company conduct due diligence on the risk of each position within three days of the purchase of a securitization position. The Company’s due diligence seeks to provide an understanding of the features that would materially affect the performance of a securitization or re-securitization. The due diligence analysis is re-performed on a quarterly basis for each securitization and re-securitization position. The Company uses an automated solution to track the due diligence associated with securitization activity. The Company aims to manage the risks associated with securitization and re-securitization positions through the use of offsetting positions and portfolio diversification.

Standardized Specific Risk Charge  For debt and equity positions that are not evaluated by the approved internal specific risk models, a regulatory prescribed standard specific risk charge is applied. The standard specific risk add-on for sovereign entities, public sector entities, and depository institutions is based on the Organization for Economic Co-operation and Development (OECD) country risk classifications (CRC) and the remaining contractual maturity of the position. These risk add-ons for debt positions range from 0.25% to 12%. The add-on for corporate debt is based on creditworthiness and the remaining contractual maturity of the position. All other types of debt positions are subject to an 8% add-on. The standard specific risk add-on for equity positions is generally 8%.
 
Comprehensive Risk Charge / Correlation Trading  The market risk capital rule requires capital for correlation trading positions. The Company's remaining correlation trading exposure covered under the market risk capital rule matured in fourth quarter 2014.
Table 37 summarizes the market risk-based capital requirements charge and market RWAs in accordance with the Basel III market risk capital rule as of March 31, 2016, and as of December 31, 2015. The market RWAs are calculated as the sum of the components in the table below.



44

Asset/Liability Management (continued)

Table 37: Market Risk Regulatory Capital and RWAs
 
March 31, 2016
 
 
December 31, 2015
 
(in millions)
Risk-
based
capital

 
Risk-
weighted
assets

 
Risk-
based
capital

 
Risk-
weighted
assets

Total VaR
$
190

 
2,374

 
188

 
2,350

Total Stressed VaR
693

 
8,668

 
773

 
9,661

Incremental Risk Charge
287

 
3,587

 
309

 
3,864

Securitized Products Charge
564

 
7,049

 
616

 
7,695

Standardized Specific Risk Charge
1,055

 
13,185

 
1,048

 
13,097

De minimis Charges (positions not included in models)
28

 
350

 
19

 
243

Total
$
2,817

 
35,213

 
2,953

 
36,910


RWA Rollforward  Table 38 depicts the changes in the market risk regulatory capital and RWAs under Basel III for the first quarter of 2016.
Table 38: Analysis of Changes in Market Risk Regulatory Capital and RWAs
(in millions)
Risk-
based
capital

 
Risk-
weighted
assets

Balance, December 31, 2015
$
2,953

 
36,910

Total VaR
2

 
24

Total Stressed VaR
(79
)
 
(992
)
Incremental Risk Charge
(22
)
 
(277
)
Securitized Products Charge
(52
)
 
(646
)
Standardized Specific Risk Charge
7

 
87

De minimis Charges
8

 
107

Balance, March 31, 2016
$
2,817

 
35,213


All changes to market risk regulatory capital and RWAs in first quarter 2016 were associated with changes in positions due to normal trading activity.

VaR Backtesting  The market risk capital rule requires backtesting as one form of validation of the VaR model. Backtesting is a comparison of the daily VaR estimate with the actual clean profit and loss (clean P&L) as defined by the market risk capital rule. Clean P&L is the change in the value of the Company’s covered trading positions that would have occurred
 
had previous end-of-day covered trading positions remained unchanged (therefore, excluding fees, commissions, net interest income, and intraday trading gains and losses). The backtesting analysis compares the daily Total VaR for each of the trading days in the preceding 12 months with the net clean P&L. Clean P&L does not include credit adjustments and other activity not representative of daily price changes driven by market risk factors. The clean P&L measure of revenue is used to evaluate the performance of the Total VaR and is not comparable to our actual daily trading net revenues, as reported elsewhere in this Report.
Any observed clean P&L loss in excess of the Total VaR is considered a market risk regulatory capital backtesting exception. The actual number of exceptions (that is, the number of business days for which the clean P&L losses exceed the corresponding 1-day, 99% Total VaR measure) over the preceding 12 months is used to determine the capital multiplier for the capital calculation. The number of actual backtesting exceptions is dependent on current market performance relative to historic market volatility in addition to model performance and assumptions. This capital multiplier increases from a minimum of three to a maximum of four, depending on the number of exceptions. No backtesting exceptions occurred over the preceding 12 months. Backtesting is also performed at granular levels within the Company.
Table 39 shows daily Total VaR (1-day, 99%) used for regulatory market risk capital backtesting for the 12 months ended March 31, 2016. The Company’s average Total VaR for first quarter 2016 was $21 million with a low of $19 million and a high of $24 million.



45


Table 39: Daily Total 1-Day 99% VaR Measure (Rolling 12 Months)
Market Risk Governance, Measurement, Monitoring and Model Risk Management We employ a well-defined and structured market risk governance process and market risk measurement process, which incorporates value-at-risk (VaR) measurements combined with sensitivity analysis and stress testing to help us monitor our market risk. These monitoring measurements require the use of market risk models, which we govern by our Corporate Model Risk policies and procedures. For more information on our governance, measurement, monitoring, and model management practices, see the "Risk Management – Asset/Liability Management – Market Risk – Trading Activities" section in our 2015 Form 10-K.

MARKET RISK – EQUITY INVESTMENTS  We are directly and indirectly affected by changes in the equity markets. We make and manage direct equity investments in start-up businesses, emerging growth companies, management buy-outs, acquisitions and corporate recapitalizations. We also invest in non-affiliated funds that make similar private equity investments. These private equity investments are made within capital allocations approved by management and the Board. The Board’s policy is to review business developments, key risks and historical returns for the private equity investment portfolio at least annually. Management reviews these investments at least quarterly and assesses them for possible OTTI. For nonmarketable investments, the analysis is based on facts and circumstances of each individual investment and the expectations for that investment’s cash flows and capital needs, the viability of its business model and our exit strategy. Nonmarketable investments include private equity investments accounted for under the cost method, equity method and fair value option.
As part of our business to support our customers, we trade public equities, listed/OTC equity derivatives and convertible bonds. We have parameters that govern these activities. We also have marketable equity securities in the available-for-sale securities portfolio, including securities relating to our venture capital activities. We manage these investments within capital
 
risk limits approved by management and the Board and monitored by Corporate ALCO and the Corporate Market Risk Committee. Gains and losses on these securities are recognized in net income when realized and periodically include OTTI charges.
Changes in equity market prices may also indirectly affect our net income by (1) the value of third party assets under management and, hence, fee income, (2) borrowers whose ability to repay principal and/or interest may be affected by the stock market, or (3) brokerage activity, related commission income and other business activities. Each business line monitors and manages these indirect risks.
Table 40 provides information regarding our marketable and nonmarketable equity investments as of March 31, 2016, and December 31, 2015.


46

Asset/Liability Management (continued)

Table 40: Nonmarketable and Marketable Equity Investments
(in millions)
Mar 31,
2016

 
Dec 31,
2015

Nonmarketable equity investments:
 
 
 
Cost method:
 
 
 
Federal bank stock
5,312

 
4,814

Private equity
1,491

 
1,626

Auction rate securities
566

 
595

Total cost method
7,369

 
7,035

Equity method:
 
 
 
LIHTC (1)
8,598

 
8,314

Private equity
3,489

 
3,300

Tax-advantaged renewable energy
1,630

 
1,625

New market tax credit and other
328

 
408

Total equity method
14,045

 
13,647

Fair value (2)
3,098

 
3,065

Total nonmarketable equity investments (3)
$
24,512

 
23,747

Marketable equity securities:
 
 
 
Cost
$
1,034

 
1,058

Net unrealized gains
465

 
579

Total marketable equity securities (4)
$
1,499

 
1,637

(1)
Represents low income housing tax credit investments.
(2)
Represents nonmarketable equity investments for which we have elected the fair value option. See Note 6 (Other Assets) and Note 13 (Fair Values of Assets and Liabilities) to Financial Statements in this Report for additional information.
(3)
Included in other assets on the balance sheet. See Note 6 (Other Assets) to Financial Statements in this Report for additional information.
(4)
Included in available-for-sale securities. See Note 4 (Investment Securities) to Financial Statements in this Report for additional information.



47


LIQUIDITY AND FUNDING  The objective of effective liquidity management is to ensure that we can meet customer loan requests, customer deposit maturities/withdrawals and other cash commitments efficiently under both normal operating conditions and under periods of Wells Fargo-specific and/or market stress. To achieve this objective, the Board of Directors establishes liquidity guidelines that require sufficient asset-based liquidity to cover potential funding requirements and to avoid over-dependence on volatile, less reliable funding markets. These guidelines are monitored on a monthly basis by the Corporate ALCO and on a quarterly basis by the Board of Directors. These guidelines are established and monitored for both the consolidated company and for the Parent on a stand-alone basis to ensure that the Parent is a source of strength for its regulated, deposit-taking banking subsidiaries.

Liquidity Standards On September 3, 2014, the FRB, OCC and FDIC issued a final rule that implements a quantitative liquidity requirement consistent with the liquidity coverage ratio (LCR) established by the Basel Committee on Banking Supervision (BCBS). The rule requires banking institutions, such as Wells Fargo, to hold high-quality liquid assets, such as central bank reserves and government and corporate debt that can be converted easily and quickly into cash, in an amount equal to or greater than its projected net cash outflows during a 30-day stress period. The final LCR rule began its phase-in period on January 1, 2015, and requires full compliance with a minimum 100% LCR by January 1, 2017. The FRB also finalized rules imposing enhanced liquidity management standards on large bank holding companies (BHC) such as Wells Fargo. In addition, the FRB recently proposed a rule that would require large bank holding companies, such as Wells Fargo, to publicly disclose on a quarterly basis certain quantitative and qualitative information regarding their LCR calculations.
 
The FRB, OCC and FDIC recently proposed a rule that would implement a stable funding requirement, the net stable funding ratio (NSFR), which would require large banking organizations, such as Wells Fargo, to maintain a sufficient amount of stable funding in relation to their assets, derivative exposures and commitments over a one-year horizon period. As proposed, the rule would become effective on January 1, 2018. The proposed rule is open for comments until August 5, 2016.
We continue to analyze these rules and other regulatory proposals that may affect liquidity risk management to determine the level of operational or compliance impact to Wells Fargo. For additional information see the “Capital Management” and “Regulatory Reform” sections in this Report and in our 2015 Form 10-K.

Liquidity Sources We maintain liquidity in the form of cash, cash equivalents and unencumbered high-quality, liquid securities. These assets make up our primary sources of liquidity which are presented in Table 41. Our cash is primarily on deposit with the Federal Reserve. Securities included as part of our primary sources of liquidity are comprised of U.S. Treasury and federal agency debt, and mortgage-backed securities issued by federal agencies within our investment securities portfolio. We believe these securities provide quick sources of liquidity through sales or by pledging to obtain financing, regardless of market conditions. Some of these securities are within the held-to-maturity portion of our investment securities portfolio and as such are not intended for sale but may be pledged to obtain financing. Some of the legal entities within our consolidated group of companies are subject to various regulatory, tax, legal and other restrictions that can limit the transferability of their funds. We believe we maintain adequate liquidity for these entities in consideration of such funds transfer restrictions.

Table 41: Primary Sources of Liquidity
 
March 31, 2016
 
 
December 31, 2015
 
(in millions)
Total

 
Encumbered

 
Unencumbered

 
Total

 
Encumbered

 
Unencumbered

Interest-earning deposits
$
242,754

 

 
242,754

 
$
220,409

 

 
220,409

Securities of U.S. Treasury and federal agencies
80,466

 
5,139

 
75,327

 
81,417

 
6,462

 
74,955

Mortgage-backed securities of federal agencies (1)
123,807

 
59,787

 
64,020

 
132,967

 
74,778

 
58,189

Total
$
447,027

 
64,926

 
382,101

 
$
434,793

 
81,240

 
353,553

(1)
Included in encumbered securities at March 31, 2016, were securities with a fair value of $202 million which were purchased in March 2016, but settled in April 2016.

In addition to our primary sources of liquidity shown in Table 41, liquidity is also available through the sale or financing of other securities including trading and/or available-for-sale securities, as well as through the sale, securitization or financing of loans, to the extent such securities and loans are not encumbered. In addition, other securities in our held-to-maturity portfolio, to the extent not encumbered, may be pledged to obtain financing.
Deposits have historically provided a sizeable source of relatively low-cost funds. At March 31, 2016, deposits were 131% of total loans compared with 133% at December 31, 2015. Additional funding is provided by long-term debt and short-term borrowings.


48

Asset/Liability Management (continued)

Table 42 shows selected information for short-term borrowings, which generally mature in less than 30 days.
 


Table 42: Short-Term Borrowings
 
Quarter ended
 
(in millions)
Mar 31
2016

 
Dec 31,
2015

 
Sep 30,
2015

 
Jun 30,
2015

 
Mar 31,
2015

Balance, period end
 
 
 
 
 
 
 
 
 
Federal funds purchased and securities sold under agreements to repurchase
$
92,875

 
82,948

 
74,652

 
71,439

 
64,400

Commercial paper
519

 
334

 
393

 
621

 
3,552

Other short-term borrowings
14,309

 
14,246

 
13,024

 
10,903

 
9,745

Total
$
107,703

 
97,528

 
88,069

 
82,963

 
77,697

Average daily balance for period
 
 
 
 
 
 
 
 
 
Federal funds purchased and securities sold under agreements to repurchase
$
93,502

 
88,949

 
79,445

 
72,429

 
58,881

Commercial paper
442

 
414

 
484

 
2,433

 
3,040

Other short-term borrowings
13,913

 
13,552

 
10,428

 
9,637

 
9,791

Total
$
107,857

 
102,915

 
90,357

 
84,499

 
71,712

Maximum month-end balance for period
 
 
 
 
 
 
 
 
 
Federal funds purchased and securities sold under agreements to repurchase (1)
$
98,718

 
89,800

 
80,961

 
71,811

 
66,943

Commercial paper (2)
519

 
461

 
510

 
2,713

 
3,552

Other short-term borrowings (3)
14,593

 
14,246

 
13,024

 
10,903

 
10,068

(1)
Highest month-end balance in each of the last five quarters was in February 2016 and October, August, May and February 2015.
(2)
Highest month-end balance in each of the last five quarters was in March 2016 and November, July, April and March 2015.
(3)
Highest month-end balance in each of the last five quarters was in February 2016 and December, September, June and February 2015.
We access domestic and international capital markets for long-term funding (generally greater than one year) through issuances of registered debt securities, private placements and asset-backed secured funding.

Parent Under SEC rules, our Parent is classified as a “well-known seasoned issuer,” which allows it to file a registration statement that does not have a limit on issuance capacity. In May 2014, the Parent filed a registration statement with the SEC for the issuance of senior and subordinated notes, preferred stock and other securities. The Parent’s ability to issue debt and other securities under this registration statement is limited by the debt issuance authority granted by the Board. The Parent is currently authorized by the Board to issue $60 billion in outstanding short-term debt and $170 billion in outstanding long-term debt. At March 31, 2016, the Parent had available $39.3 billion in short-term debt issuance authority and $41.0 billion in long-term debt issuance authority. The Parent’s debt issuance authority granted by the Board includes short-term and long-term debt issued to affiliates. During first quarter 2016, the Parent issued $5.1 billion of senior notes, of which $4.1 billion were registered with the SEC. In addition, in April 2016, the Parent issued $7.46 billion of senior notes, of which $3.5 billion were registered with the SEC.
The Parent’s proceeds from securities issued were used for general corporate purposes, and, unless otherwise specified in the applicable prospectus or prospectus supplement, we expect the proceeds from securities issued in the future will be used for the same purposes. Depending on market conditions, we may purchase our outstanding debt securities from time to time in privately negotiated or open market transactions, by tender offer, or otherwise.
Table 43 provides information regarding the Parent’s medium-term note (MTN) programs, which are covered by the long-term debt issuance authority granted by the Board. The Parent may issue senior and subordinated debt securities under Series N & O, and the European and Australian programmes. Under Series K, the Parent may issue senior debt securities linked
 
to one or more indices or bearing interest at a fixed or floating rate.
Table 43: Medium-Term Note (MTN) Programs
 
 
 
 
 
 
March 31, 2016
 
(in billions)
 
Date
established
 
 
 
Debt
issuance
authority

 
Available
for
issuance

MTN program:
 
 
 
 
 
 
 
 
Series N & O (1)(2)
 
May 2014
 
 
 
$

 
$

Series K (1)(3)
 
April 2010
 
 
 
25.0

 
20.4

European (4)(5)
 
December 2009
 
 
 
35.0

 
13.9

European (4)(6)
 
August 2013
 
 
 
10.0

 
7.6

Australian (4)(7)
 
June 2005
 
AUD
 
10.0

 
7.8

(1)
SEC registered.
(2)
The Parent can issue an indeterminate amount of debt securities, subject to the long-term debt issuance authority granted by the Board.
(3)
As amended in April 2012 and March 2015.
(4)
Not registered with the SEC. May not be offered in the United States without applicable exemptions from registration.
(5)
As amended in April 2012, April 2013, April 2014, March 2015 and March 2016. For securities to be admitted to listing on the Official List of the United Kingdom Financial Conduct Authority and to trade on the Regulated Market of the London Stock Exchange.
(6)
As amended in May 2014, April 2015 and April 2016, for securities that will not be admitted to listing, trading and/or quotation by any stock exchange or quotation system, or will be admitted to listing, trading and/or quotation by a stock exchange or quotation system that is not considered to be a regulated market.
(7)
As amended in October 2005, March 2010 and September 2013.

Wells Fargo Bank, N.A. Wells Fargo Bank, N.A. is authorized by its board of directors to issue $100 billion in outstanding short-term debt and $125 billion in outstanding long-term debt. At March 31, 2016, Wells Fargo Bank, N.A. had available $100 billion in short-term debt issuance authority and $48.4 billion in long-term debt issuance authority. In April 2015, Wells Fargo Bank, N.A. established a $100 billion bank note program under which, subject to any other debt outstanding under the limits described above, it may issue $50 billion in outstanding short-term senior notes and $50 billion in outstanding long-term


49


senior or subordinated notes. At March 31, 2016, Wells Fargo Bank, N.A. had remaining issuance capacity under the bank note program of $50.0 billion in short-term senior notes and $44.0 billion in long-term senior or subordinated notes. In first quarter 2016, Wells Fargo Bank, N.A. issued $6.0 billion of unregistered senior notes under the bank note program. In addition, in first quarter 2016, Wells Fargo Bank, N.A. executed advances of $12.5 billion with the Federal Home Loan Bank of Des Moines, and as of March 31, 2016, Wells Fargo Bank, N.A. had outstanding advances of $49.6 billion across the Federal Home Loan Bank System. In April 2016, Wells Fargo Bank, N.A. executed an additional $1.0 billion in Federal Home Loan Bank advances.

Credit Ratings Investors in the long-term capital markets, as well as other market participants, generally will consider, among other factors, a company’s debt rating in making investment decisions. Rating agencies base their ratings on many quantitative and qualitative factors, including capital adequacy, liquidity, asset quality, business mix, the level and quality of earnings, and rating agency assumptions regarding the
 
probability and extent of federal financial assistance or support for certain large financial institutions. Adverse changes in these factors could result in a reduction of our credit rating; however, our debt securities do not contain credit rating covenants.
There were no significant actions undertaken by any of the rating agencies with regard to our ratings during first quarter 2016. Both the Parent and Wells Fargo Bank, N.A. remain among the top-rated financial firms in the U.S.
See the “Risk Management – Asset/Liability Management” section in this Report and the "Risk Factors" section in our 2015 Form 10-K for additional information regarding our credit ratings and the potential impact a credit rating downgrade would have on our liquidity and operations, as well as Note 12 (Derivatives) to Financial Statements in this Report for information regarding additional collateral and funding obligations required for certain derivative instruments in the event our credit ratings were to fall below investment grade.
The credit ratings of the Parent and Wells Fargo Bank, N.A. as of March 31, 2016, are presented in Table 44.

Table 44: Credit Ratings as of March 31, 2016
 
Wells Fargo & Company
 
Wells Fargo Bank, N.A.
 
Senior debt
 
Short-term
borrowings 
 
Long-term
deposits 
 
Short-term
borrowings 
Moody's
 A2
 
 P-1
 
 Aa1
 
 P-1
S&P
 A
 
 A-1
 
 AA-
 
 A-1+
Fitch Ratings, Inc.
 AA-
 
 F1+
 
 AA+
 
 F1+
DBRS
 AA
 
 R-1*
 
 AA**
 
 R-1**
* middle ** high
 
 
 
 
 
 
 
FEDERAL HOME LOAN BANK MEMBERSHIP The Federal Home Loan Banks (the FHLBs) are a group of cooperatives that lending institutions use to finance housing and economic development in local communities. We are a member of the FHLBs based in Dallas, Des Moines and San Francisco. Each member of the FHLBs is required to maintain a minimum investment in capital stock of the applicable FHLB. The board of directors of each FHLB can increase the minimum investment requirements in the event it has concluded that additional capital is required to allow it to meet its own regulatory capital requirements. Any increase in the minimum investment requirements outside of specified ranges requires the approval of the Federal Housing Finance Board. Because the extent of any obligation to increase our investment in any of the FHLBs depends entirely upon the occurrence of a future event, potential future payments to the FHLBs are not determinable.



50

Capital Management (continued)

Capital Management

We have an active program for managing capital through a comprehensive process for assessing the Company’s overall capital adequacy. Our objective is to maintain capital at an amount commensurate with our risk profile and risk tolerance objectives, and to meet both regulatory and market expectations. We primarily fund our capital needs through the retention of earnings net of dividends as well as the issuance of preferred stock and long and short-term debt. Retained earnings increased $3.0 billion from December 31, 2015, predominantly from Wells Fargo net income of $5.5 billion, less common and preferred stock dividends of $2.3 billion. During first quarter 2016, we issued 35.5 million shares of common stock. We also issued 40 million Depositary Shares, each representing 1/1,000th interest in a share of the Company’s newly issued Non-Cumulative Perpetual Class A Preferred Stock, Series W, for an aggregate public offering price of $1.0 billion. During first quarter 2016, we repurchased 51.7 million shares of common stock in open market transactions, private transactions and from employee benefit plans, at a cost of $2.5 billion, which included $500 million paid in a prior quarter under a forward repurchase agreement that settled in first quarter 2016. We also entered into a $750 million forward repurchase contract with an unrelated third party in April 2016 that is expected to settle in second quarter 2016 for approximately 15 million shares. For additional information about our forward repurchase agreements, see Note 1 (Summary of Significant Accounting Policies) to Financial Statements in this Report.
 
Regulatory Capital Guidelines
The Company and each of our insured depository institutions are subject to various regulatory capital adequacy requirements administered by the FRB and the OCC. Risk-based capital (RBC) guidelines establish a risk-adjusted ratio relating capital to different categories of assets and off-balance sheet exposures. See Note 19 (Regulatory and Agency Capital Requirements) to Financial Statements in this Report for additional information.

RISK-BASED CAPITAL AND RISK-WEIGHTED ASSETS The Company is subject to final and interim final rules issued by federal banking regulators to implement Basel III capital requirements for U.S. banking organizations. These rules are based on international guidelines for determining regulatory capital issued by the Basel Committee on Banking Supervision (BCBS). The federal banking regulators’ capital rules, among other things, require on a fully phased-in basis:
a minimum Common Equity Tier 1 (CET1) ratio of 9.0%, comprised of a 4.5% minimum requirement plus a capital conservation buffer of 2.5% and for us, as a global systemically important bank (G-SIB), a capital surcharge to be calculated annually, which is 2.0% based on our year-end 2014 data;
a minimum tier 1 capital ratio of 10.5%, comprised of a 6.0% minimum requirement plus the capital conservation buffer of 2.5% and the G-SIB capital surcharge of 2.0%;
a minimum total capital ratio of 12.5%, comprised of a 8.0% minimum requirement plus the capital conservation buffer of 2.5% and the G-SIB capital surcharge of 2.0%;
a potential countercyclical buffer of up to 2.5% to be added to the minimum capital ratios, which is currently not in effect but could be imposed by regulators at their discretion if it is determined that a period of excessive
 
credit growth is contributing to an increase in systemic risk;
a minimum tier 1 leverage ratio of 4.0%; and
a minimum supplementary leverage ratio (SLR) of 5.0% (comprised of a 3.0% minimum requirement plus a supplementary leverage buffer of 2.0%) for large and internationally active bank holding companies (BHCs).

We were required to comply with the final Basel III capital rules beginning January 2014, with certain provisions subject to phase-in periods. The Basel III capital rules are scheduled to be fully phased in by the end of 2021. The Basel III capital rules contain two frameworks for calculating capital requirements, a Standardized Approach, which replaced Basel I, and an Advanced Approach applicable to certain institutions.
In March 2015, the FRB and OCC directed the Company and its subsidiary national banks to exit the parallel run phase and begin using the Basel III Advanced Approaches capital framework, in addition to the Standardized Approach, to determine our compliance with risk-based capital requirements starting in second quarter 2015. Accordingly, in the assessment of our capital adequacy, we must report the lower of our CET1, tier 1 and total capital ratios calculated under the Standardized Approach and under the Advanced Approach.
Because the Company has been designated as a G-SIB, we will also be subject to the FRB’s rule implementing the additional capital surcharge of between 1.0-4.5% on G-SIBs. Under the rule, we must annually calculate our surcharge under two methods and use the higher of the two surcharges. The first method (method one) will consider our size, interconnectedness, cross-jurisdictional activity, substitutability, and complexity, consistent with a methodology developed by the BCBS and the Financial Stability Board (FSB). The second (method two) will use similar inputs, but will replace substitutability with use of short-term wholesale funding and will generally result in higher surcharges than the BCBS methodology. The phase-in period for the G-SIB surcharge began on January 1, 2016 and will become fully effective on January 1, 2019. Based on year-end 2014 data, our 2016 G-SIB surcharge under method two is 2.0% of the Company’s RWAs, which is the higher of method one and method two. Because the G-SIB surcharge is calculated annually based on data that can differ over time, the amount of the surcharge is subject to change in future years. Under the Standardized Approach (fully phased-in), our CET1 ratio of 10.61% exceeded the minimum of 9.0% by 161 basis points at March 31, 2016.
The tables that follow provide information about our risk- based capital and related ratios as calculated under Basel III capital guidelines. For banking industry regulatory reporting purposes, we report our capital in accordance with Transition Requirements but are managing our capital based on a fully phased-in calculation. For information about our capital requirements calculated in accordance with Transition Requirements, see Note 19 (Regulatory and Agency Capital Requirements) to Financial Statements in this Report.


51


Table 45 summarizes our CET1, tier 1 capital, total capital, risk-weighted assets and capital ratios on a fully phased-in basis at March 31, 2016 and December 31, 2015. As of March 31, 2016, our CET1 ratio was lower using RWAs calculated under the Standardized Approach.
 



Table 45: Capital Components and Ratios (Fully Phased-In) (1)
 
 
March 31, 2016
 
 
 
December 31, 2015
 
 
(in billions)
 
Advanced Approach

 
Standardized Approach

 
 
Advanced Approach

 
Standardized Approach

 
Common Equity Tier 1
(A)
$
142.7

 
142.7

 
 
142.4

 
142.4

 
Tier 1 Capital
(B)
164.2

 
164.2

 
 
162.8

 
162.8

 
Total Capital
(C)
190.9

 
202.4

 
 
190.4

 
200.8

 
Risk-Weighted Assets
(D)
1,323.7

 
1,345.1

 
 
1,282.8

 
1,321.7

 
Common Equity Tier 1 Capital Ratio
(A)/(D)
10.78
%
 
10.61

*
 
11.10

 
10.77

*
Tier 1 Capital Ratio
(B)/(D)
12.40

 
12.21

*
 
12.69

 
12.32

*
Total Capital Ratio
(C)/(D)
14.43

*
15.06

 
 
14.84

*
15.19

 
*Denotes the lowest capital ratio as determined under the Advanced and Standardized Approaches.
(1)
Fully phased-in regulatory capital amounts, ratios and RWAs are considered non-GAAP financial measures that are used by management, bank regulatory agencies, investors and analysts to assess and monitor the Company’s capital position. See Table 46 for information regarding the calculation and components of CET1, Tier 1 capital, total capital and RWAs, as well as the corresponding reconciliation of our regulatory capital amounts to total equity.


52

Capital Management (continued)

Table 46 provides information regarding the calculation and composition of our risk-based capital under the Advanced and Standardized Approaches at March 31, 2016 and December 31, 2015.
 



Table 46: Risk-Based Capital Calculation and Components
 
 
March 31, 2016
 
 
December 31, 2015
 
(in billions)
 
Advanced Approach

 
Standardized Approach

 
Advanced Approach

 
Standardized Approach

Total equity
 
$
198.5

 
198.5

 
193.9

 
193.9

Noncontrolling interests
 
(1.0
)
 
(1.0
)
 
(0.9
)
 
(0.9
)
Total Wells Fargo stockholders' equity
 
197.5

 
197.5

 
193.0

 
193.0

Adjustments:
 
 
 
 
 
 
 
 
Preferred stock
 
(22.0
)
 
(22.0
)
 
(21.0
)
 
(21.0
)
Cumulative other comprehensive income
 

 

 

 

Goodwill and other intangible assets (1)
 
(30.9
)
 
(30.9
)
 
(28.7
)
 
(28.7
)
Investment in certain subsidiaries and other
 
(1.9
)
 
(1.9
)
 
(0.9
)
 
(0.9
)
Common Equity Tier 1 (Fully Phased-In)
 
142.7

 
142.7

 
142.4

 
142.4

Effect of Transition Requirements
 
1.4

 
1.4

 
1.8

 
1.8

Common Equity Tier 1 (Transition Requirements)
 
$
144.1

 
144.1

 
144.2

 
144.2

 
 
 
 
 
 
 
 
 
Common Equity Tier 1 (Fully Phased-In)
 
$
142.7

 
142.7

 
142.4

 
142.4

Preferred stock
 
22.0

 
22.0

 
21.0

 
21.0

Other
 
(0.5
)
 
(0.5
)
 
(0.6
)
 
(0.6
)
Total Tier 1 capital (Fully Phased-In)
(A)
164.2

 
164.2

 
162.8

 
162.8

Effect of Transition Requirements
 
1.4

 
1.4

 
1.8

 
1.8

Total Tier 1 capital (Transition Requirements)
 
$
165.6

 
165.6

 
164.6

 
164.6

 
 
 
 
 
 
 
 
 
Total Tier 1 capital (Fully Phased-In)
 
$
164.2

 
164.2

 
162.8

 
162.8

Long-term debt and other instruments qualifying as Tier 2
 
25.8

 
25.8

 
25.8

 
25.8

Qualifying allowance for credit losses (2)
 
1.2

 
12.7

 
2.1

 
12.5

Other
 
(0.3
)
 
(0.3
)
 
(0.3
)
 
(0.3
)
Total Tier 2 capital (Fully Phased-In)
(B)
26.7

 
38.2

 
27.6

 
38.0

Effect of Transition Requirements
 
2.0

 
2.0

 
3.0

 
3.0

Total Tier 2 capital (Transition Requirements)
 
$
28.7

 
40.2

 
30.6

 
41.0

 
 
 
 
 
 
 
 
 
Total qualifying capital (Fully Phased-In)
(A+B)
$
190.9

 
202.4

 
190.4

 
200.8

Total Effect of Transition Requirements
 
3.4

 
3.4

 
4.8

 
4.8

Total qualifying capital (Transition Requirements)
 
$
194.3

 
205.8

 
195.2

 
205.6

 
 
 
 
 
 
 
 
 
Risk-Weighted Assets (RWAs) (3)(4):
 
 
 
 
 
 
 
 
Credit risk
 
$
1,021.3

 
1,309.9

 
989.6

 
1,284.8

Market risk
 
35.2

 
35.2

 
36.9

 
36.9

Operational risk
 
267.2

 
 N/A

 
256.3

 
 N/A

Total RWAs (Fully Phased-In)
 
$
1,323.7

 
1,345.1

 
1,282.8

 
1,321.7

Credit risk
 
$
1,000.7

 
1,290.4

 
970.0

 
1,266.2

Market risk
 
35.2

 
35.2

 
36.9

 
36.9

Operational risk
 
267.2

 
 N/A

 
256.3

 
 N/A

Total RWAs (Transition Requirements)
 
$
1,303.1

 
1,325.6

 
1,263.2

 
1,303.1

(1)
Goodwill and other intangible assets are net of any associated deferred tax liabilities.
(2)
Under the Advanced Approach the allowance for credit losses that exceeds expected credit losses is eligible for inclusion in Tier 2 Capital, to the extent the excess allowance does not exceed 0.6% of Advanced credit RWAs, and under the Standardized Approach, the allowance for credit losses is includable in Tier 2 Capital up to 1.25% of Standardized credit RWAs, with any excess allowance for credit losses being deducted from total RWAs.
(3)
RWAs calculated under the Advanced Approach utilize a risk-sensitive methodology, which relies upon the use of internal credit models based upon our experience with internal rating grades. Advanced Approach also includes an operational risk component, which reflects the risk of operating loss resulting from inadequate or failed internal processes or systems.
(4)
Under the regulatory guidelines for risk-based capital, on-balance sheet assets and credit equivalent amounts of derivatives and off-balance sheet items are assigned to one of several broad risk categories according to the obligor, or, if relevant, the guarantor or the nature of any collateral. The aggregate dollar amount in each risk category is then multiplied by the risk weight associated with that category. The resulting weighted values from each of the risk categories are aggregated for determining total RWAs.

53


Table 47 presents the changes in Common Equity Tier 1 under the Advanced Approach for the three months ended March 31, 2016.

Table 47: Analysis of Changes in Common Equity Tier 1
(in billions)
 
 
Common Equity Tier 1 (Fully Phased-In) at December 31, 2015
 
$
142.4

Net income
 
5.1

Common stock dividends
 
(1.9
)
Common stock issued, repurchased, and stock compensation-related items
 
(1.1
)
Goodwill and other intangible assets (net of any associated deferred tax liabilities)
 
(2.2
)
Other
 
0.4

Change in Common Equity Tier 1
 
0.3

Common Equity Tier 1 (Fully Phased-In) at March 31, 2016
 
$
142.7


Table 48 presents net changes in the components of RWAs under the Advanced and Standardized Approaches for the three months ended March 31, 2016.

Table 48: Analysis of Changes in RWAs
(in billions)
Advanced Approach

Standardized Approach

RWAs (Fully Phased-In) at December 31, 2015
$
1,282.8

1,321.7

Net change in credit risk RWAs
31.7

25.1

Net change in market risk RWAs
(1.7
)
(1.7
)
Net change in operational risk RWAs
10.9

  N/A

Total change in RWAs
40.9

23.4

RWAs (Fully Phased-In) at March 31, 2016
1,323.7

1,345.1

Effect of Transition Requirements
(20.6
)
(19.5
)
RWAs (Transition Requirements) at March 31, 2016
$
1,303.1

1,325.6


54

Capital Management (continued)

SUPPLEMENTARY LEVERAGE RATIO In April 2014, federal banking regulators finalized a rule that enhances the SLR requirements for BHCs, like Wells Fargo, and their insured depository institutions. The SLR consists of Tier 1 capital divided by the Company’s total leverage exposure. Total leverage exposure consists of the total average on-balance sheet assets, plus off-balance sheet exposures, such as undrawn commitments and derivative exposures, less amounts permitted to be deducted from Tier 1 capital. The rule, which becomes effective on January 1, 2018, will require a covered BHC to maintain a SLR of at least 5.0% (comprised of the 3.0% minimum requirement plus a supplementary leverage buffer of 2.0%) to avoid restrictions on capital distributions and discretionary bonus payments. The rule will also require that all of our insured depository institutions maintain a SLR of 6.0% under applicable regulatory capital adequacy guidelines. In September 2014, federal banking regulators finalized additional changes to the SLR requirements to implement revisions to the Basel III leverage framework finalized by the BCBS in January 2014. These additional changes, among other things, modify the methodology for including off- balance sheet items, including credit derivatives, repo-style transactions and lines of credit, in the denominator of the SLR, and will become effective on January 1, 2018. At March 31, 2016, our SLR for the Company was 7.6% assuming full phase-in of the Advanced Approach capital framework. Based on our review, our current leverage levels would exceed the applicable requirements for each of our insured depository institutions as well. The fully phased-in SLR is considered a non-GAAP financial measure that is used by management, bank regulatory agencies, investors and analysts to assess and monitor the Company’s leverage exposure. See Table 49 for information regarding the calculation and components of the SLR.
Table 49: Fully Phased-In SLR
(in billions)
March 31, 2016

Tier 1 capital
$
164.2

Total average assets
1,819.9

Less: deductions from Tier 1 capital
31.6

Total adjusted average assets
1,788.3

Adjustments:
 
Derivative exposures
70.9

Repo-style transactions
5.8

Other off-balance sheet exposures
295.2

Total adjustments
371.9

Total leverage exposure
$
2,160.2

Supplementary leverage ratio
7.6
%
OTHER REGULATORY CAPITAL MATTERS In October 2015, the FRB proposed rules to address the amount of equity and unsecured long-term debt a U.S. G-SIB must hold to improve its resolvability and resiliency, often referred to as Total Loss Absorbing Capacity (TLAC). Under the proposed rules, U.S. G-SIBs would be required to have a minimum TLAC amount (consisting of CET1 capital and additional tier 1 capital issued directly by the top-tier or covered BHC plus eligible external long-term debt) equal to the greater of (i) 18% of RWAs and (ii) 9.5% of total leverage exposure (the denominator of the SLR calculation). Additionally, U.S. G-SIBs would be required to maintain a TLAC buffer equal to 2.5% of RWAs plus the firm’s applicable G-SIB capital surcharge calculated under method one plus any applicable countercyclical buffer that would be added to the 18% minimum in order to avoid restrictions on capital
 
distributions and discretionary bonus payments. The proposed rules would also require U.S. G-SIBs to have a minimum amount of eligible unsecured long-term debt equal to the greater of (i) 6.0% of RWAs plus the firm’s applicable G-SIB capital surcharge calculated under method two and (ii) 4.5% of the total leverage exposure. In addition, the proposed rules would impose certain restrictions on the operations and liabilities of the top-tier or covered BHC in order to further facilitate an orderly resolution, including prohibitions on the issuance of short-term debt to external investors and on entering into derivatives and certain other types of financial contracts with external counterparties. The proposed rules were open for comments until February 1, 2016. If the proposed rules are finalized as proposed, we may be required to issue additional long-term debt. We continue to evaluate the impact this proposal will have on our consolidated financial statements.
In addition, as discussed in the “Risk Management – Asset/ Liability Management – Liquidity and Funding – Liquidity Standards” section in this Report, federal banking regulators have issued a final rule regarding the U.S. implementation of the Basel III LCR and a proposed rule regarding the NSFR.

Capital Planning and Stress Testing
Our planned long-term capital structure is designed to meet regulatory and market expectations. We believe that our long-term targeted capital structure enables us to invest in and grow our business, satisfy our customers' financial needs in varying environments, access markets, and maintain flexibility to return capital to our shareholders. Our long-term targeted capital structure also considers capital levels sufficient to exceed capital requirements including the G-SIB surcharge. Accordingly, based on the final Basel III capital rules under the lower of the Standardized or Advanced Approaches CET1 capital ratios, we currently target a long-term CET1 capital ratio at or in excess of 10%, which includes a 2% G-SIB surcharge. Our capital targets are subject to change based on various factors, including changes to the regulatory capital framework and expectations for large banks promulgated by bank regulatory agencies, planned capital actions, changes in our risk profile and other factors.
Under the FRB’s capital plan rule, large BHCs are required to submit capital plans annually for review to determine if the FRB has any objections before making any capital distributions. The rule requires updates to capital plans in the event of material changes in a BHC’s risk profile, including as a result of any significant acquisitions. The FRB assesses the overall financial condition, risk profile, and capital adequacy of BHCs while considering both quantitative and qualitative factors when evaluating capital plans. On March 11, 2015, the FRB notified us that it did not object to our capital plan included in the 2015 CCAR.
Our 2016 CCAR, which was submitted on April 4, 2016, included a comprehensive capital plan supported by an assessment of expected sources and uses of capital over a given planning horizon under a range of expected and stress scenarios, similar to the process the FRB used to conduct the 2015 CCAR. As part of the 2016 CCAR, the FRB also generated a supervisory stress test, which assumed a sharp decline in the economy and significant decline in asset pricing using the information provided by the Company to estimate performance. The FRB is expected to review the supervisory stress results both as required under the Dodd-Frank Act using a common set of capital actions for all large BHCs and by taking into account the Company’s proposed capital actions. The FRB has indicated that it will publish its supervisory stress test results as required under the Dodd-Frank


55


Act, and the related CCAR results taking into account the Company’s proposed capital actions, by June 30, 2016.
In addition to CCAR, federal banking regulators also require stress tests to evaluate whether an institution has sufficient capital to continue to operate during periods of adverse economic and financial conditions. These stress testing requirements set forth the timing and type of stress test activities large BHCs and banks must undertake as well as rules governing stress testing controls, oversight and disclosure requirements. The rules also limit a large BHC’s ability to make capital distributions to the extent its actual capital issuances were less than amounts indicated in its capital plan. As required under the FRB’s stress testing rule, we completed a mid-cycle stress test based on data and scenarios developed by the Company. We submitted the results of the mid-cycle stress test to the FRB and disclosed a summary of the results in July 2015.

Securities Repurchases
From time to time the Board authorizes the Company to repurchase shares of our common stock. Although we announce when the Board authorizes share repurchases, we typically do not give any public notice before we repurchase our shares. Future stock repurchases may be private or open-market repurchases, including block transactions, accelerated or delayed block transactions, forward transactions, and similar transactions. Additionally, we may enter into plans to purchase stock that satisfy the conditions of Rule 10b5-1 of the Securities Exchange Act of 1934. Various factors determine the amount and timing of our share repurchases, including our capital requirements, the number of shares we expect to issue for employee benefit plans and acquisitions, market conditions (including the trading price of our stock), and regulatory and legal considerations, including the FRB’s response to our capital plan and to changes in our risk profile.
In March 2014, the Board authorized the repurchase of 350 million shares of our common stock. In January 2016, the Board authorized the repurchase of an additional 350 million shares of our common stock. At March 31, 2016, we had a combined remaining authority to repurchase approximately 375 million shares, subject to regulatory and legal conditions. For more information about share repurchases during first quarter 2016, see Part II, Item 2 in this Report.
 
Historically, our policy has been to repurchase shares under the “safe harbor” conditions of Rule 10b-18 of the Securities Exchange Act of 1934 including a limitation on the daily volume of repurchases. Rule 10b-18 imposes an additional daily volume limitation on share repurchases during a pending merger or acquisition in which shares of our stock will constitute some or all of the consideration. Our management may determine that during a pending stock merger or acquisition when the safe harbor would otherwise be available, it is in our best interest to repurchase shares in excess of this additional daily volume limitation. In such cases, we intend to repurchase shares in compliance with the other conditions of the safe harbor, including the standing daily volume limitation that applies whether or not there is a pending stock merger or acquisition.
In connection with our participation in the Capital Purchase Program (CPP), a part of the Troubled Asset Relief Program (TARP), we issued to the U.S. Treasury Department warrants to purchase 110,261,688 shares of our common stock with an original exercise price of $34.01 per share expiring on October 28, 2018. The terms of the warrants require the exercise price to be adjusted under certain circumstances when the Company’s quarterly common stock dividend exceeds $0.34 per share, which began occurring in second quarter 2014. Accordingly, with each quarterly common stock dividend above $0.34 per share, we must calculate whether an adjustment to the exercise price is required by the terms of the warrants, including whether certain minimum thresholds have been met to trigger an adjustment, and notify the holders of any such change. The Board authorized the repurchase by the Company of up to $1 billion of the warrants. At March 31, 2016, there were 34,816,632 warrants outstanding, exercisable at $33.896 per share, and $452 million of unused warrant repurchase authority. Depending on market conditions, we may purchase from time to time additional warrants in privately negotiated or open market transactions, by tender offer or otherwise.


56


Regulatory Reform 
Since the enactment of the Dodd-Frank Act in 2010, the U.S. financial services industry has been subject to a significant increase in regulation and regulatory oversight initiatives. This increased regulation and oversight has substantially changed how most U.S. financial services companies conduct business and has increased their regulatory compliance costs.
The following supplements our discussion of the significant regulations and regulatory oversight initiatives that have affected or may affect our business contained in the "Regulatory Reform" and "Risk Factors" sections in our 2015 Form 10-K.

DEPOSIT INSURANCE ASSESSMENTS Our subsidiary banks, including Wells Fargo Bank, N.A., are members of the Deposit Insurance Fund (DIF) maintained by the FDIC. Through the DIF, the FDIC insures the deposits of our banks up to prescribed limits for each depositor and funds the DIF through assessments on member banks. To maintain the DIF, member institutions are assessed an insurance premium based on an assessment base and an assessment rate.
The Dodd-Frank Act gave the FDIC greater discretion to manage the DIF, changed the assessment base from domestic deposits to consolidated average assets less average tangible equity, and mandated a minimum Designated Reserve Ratio (reserve ratio or DRR) of 1.35%. The FDIC Board adopted a Restoration Plan to ensure that the DIF reserve ratio reaches 1.35% by September 30, 2020, as required by the Dodd-Frank Act, and, in March 2016, issued a final rule to meet this DRR level. The final rule imposes on insured depository institutions with $10 billion or more in assets, such as Wells Fargo, a surcharge of 4.5 cents per $100 of their assessment base, after making certain adjustments. The final rule is effective July 1, 2016, and the surcharge would be effective at that date or the first day of the calendar quarter after the DIF reserve ratio reaches 1.15% if the DIF reserve ratio has not reached 1.15% prior to July 1, 2016. The surcharge is in addition to the base assessments paid by the affected institutions and could significantly increase the overall amount of their deposit insurance assessments. When this new surcharge becomes effective, based on our assessment base as of March 31, 2016, we estimate that, combined with the benefit of lower base assessment rates previously adopted by the FDIC, our overall deposit insurance assessment expense will increase by approximately $100 million per quarter. The FDIC expects the surcharge to be in effect for approximately two years, however, if the DIF reserve ratio does not reach 1.35% by December 31, 2018 (provided it is at least 1.15%), the final rule provides that the FDIC will impose a shortfall assessment on any bank that was subject to the surcharge. In addition to ensuring that the DIF reserve ratio reaches the statutory minimum of 1.35% by September 30, 2020, the FDIC Board has also finalized a comprehensive, long-range plan for DIF management, whereby the DRR has been targeted at 2%.

"LIVING WILL" REQUIREMENTS AND RELATED MATTERS Rules adopted by the FRB and the FDIC under the Dodd-Frank Act require large financial institutions, including Wells Fargo, to prepare and periodically revise resolution plans, so-called “living-wills”, that would facilitate their resolution in the event of material distress or failure. Under the rules, resolution plans are required to provide strategies for resolution under the Bankruptcy Code and other applicable insolvency regimes that can be accomplished in a reasonable period of time and in a manner that mitigates the risk that failure would have serious
 
adverse effects on the financial stability of the United States. On April 12, 2016, the FRB and FDIC notified us that they had jointly determined that our 2015 resolution plan is not credible or would not facilitate an orderly resolution under the Bankruptcy Code. We are required to remedy the deficiencies in a submission to be provided to the FRB and FDIC by October 1, 2016. In the event that our submission does not adequately remedy the deficiencies, the FRB and FDIC may impose more stringent capital, leverage or liquidity requirements on us or restrict our growth, activities or operations until we submit a plan remedying the deficiencies. If the FRB and FDIC ultimately determine that we have been unable to remedy the deficiencies, they could order us to divest assets or operations in order to facilitate our orderly resolution in the event of our material distress or failure.

DEPARTMENT OF LABOR ERISA FIDUCIARY STANDARD In April 2016, the U.S. Department of Labor adopted a rule under the Employee Retirement Income Security Act of 1974 (ERISA) that, among other changes and subject to certain exceptions, will as of the applicability date of April 10, 2017 make anyone, including broker-dealers, providing investment advice to retirement investors a fiduciary who must act in the best interest of clients when providing investment advice for direct or indirect compensation to a retirement plan, to a plan fiduciary, participant or beneficiary, or to an investment retirement account (IRA) or IRA holder. The rule is still being reviewed by us but may impact the manner in which business is conducted with retirement investors and affect product offerings with respect to retirement plans and IRAs.








57


Critical Accounting Policies
Our significant accounting policies (see Note 1 (Summary of Significant Accounting Policies) to Financial Statements in our 2015 Form 10-K) are fundamental to understanding our results of operations and financial condition because they require that we use estimates and assumptions that may affect the value of our assets or liabilities and financial results. Five of these policies are critical because they require management to make difficult, subjective and complex judgments about matters that are inherently uncertain and because it is likely that materially different amounts would be reported under different conditions or using different assumptions. These policies govern:
the allowance for credit losses;
PCI loans;
the valuation of residential MSRs;
the fair value of financial instruments; and
income taxes.

Management and the Board's Audit and Examination Committee have reviewed and approved these critical accounting policies. These policies are described further in the “Financial Review – Critical Accounting Policies” section and Note 1 (Summary of Significant Accounting Policies) to Financial Statements in our 2015 Form 10-K.


58

Current Accounting Developments (continued)

Current Accounting Developments
Table 50 provides accounting pronouncements applicable to us that have been issued by the FASB but are not yet effective.


Table 50: Current Accounting Developments – Issued Standards
Standard
 
Description
 
Effective date and financial statement impact
Accounting Standards Update (ASU or Update) 2016-09 – Compensation – Stock Compensation (Topic 718): Improvements to Employee Share-Based Payment Accounting

 
The Update simplifies the accounting for share-based payment awards issued to employees, including recognition and classification of excess tax benefits and tax deficiencies in the statement of income and the statement of cash flows. The guidance also allows entities to elect an accounting policy to either estimate the number of award forfeitures or account for forfeitures as they occur.
 
The guidance is effective for us in first quarter 2017 with application varying by provision within the Update. Early adoption is permitted. We are evaluating the impact the Update will have on our consolidated financial statements.
ASU 2016-07 – Investments – Equity Method and Joint Ventures (Topic 323): Simplifying the Transition to the Equity Method of Accounting
 
The Update eliminates the requirement for companies to retroactively apply the equity method of accounting for investments when increases in ownership interests or degree of influence result in the adoption of the equity method. Under the new guidance, the equity method should be applied prospectively in the period in which the ownership changes occur.
 
The guidance is effective for us in first quarter 2017 with prospective application. Early adoption is permitted. We are evaluating the impact the Update will have on our consolidated financial statements.
ASU 2016-06 – Derivatives and Hedging (Topic 815): Contingent Put and Call Options in Debt Instruments
 
The Update clarifies the criteria entities should use when evaluating whether embedded contingent put and call options in debt instruments should be separated from the debt instrument and accounted for separately as derivatives. Companies should not consider whether the event that triggers the ability to exercise put or call options is related to interest rates or credit risk.
 
The guidance is effective for us in first quarter 2017 with modified retrospective application to debt instruments existing as of the beginning of the adoption period. Early adoption is permitted. We are evaluating the impact the Update will have on our consolidated financial statements.
ASU 2016-05 – Derivatives and Hedging (Topic 815): Effect of Derivative Contract Novations on Existing Hedge Accounting Relationships
 
The Update clarifies that a change in the counterparty to a derivative instrument that has been designated as an accounting hedge does not require the hedging relationship to be dedesignated as long as all other hedge accounting criteria continue to be met.
 
The guidance is effective for us in first quarter 2017 with prospective or modified retrospective application. Early adoption is permitted. We are evaluating the impact the Update will have on our consolidated financial statements.
ASU 2016-04 – Liabilities – Extinguishments of Liabilities (Subtopic 405-20): Recognition of Breakage for Certain Prepaid Stored-Value Products
 
The Update requires entities to recognize breakage for prepaid stored-value card liabilities (e.g. gift cards) provided the liabilities meet certain criteria.
 
The guidance is effective for us in first quarter 2018 with early adoption permitted. The guidance allows us to elect the transition method, permitting either a modified retrospective application with a cumulative-effect adjustment to the balance sheet as of the beginning of the adoption period or retrospective application to each period presented. We are evaluating the impact the Update will have on our consolidated financial statements.

ASU 2016-02 – Leases (Topic 842)
 
The Update requires lessees to recognize leases on the balance sheet with lease liabilities and corresponding right-of-use assets based on the present value of lease payments. Lessor accounting is largely unchanged with lease financings and operating lease assets depending on the nature of the leases. The Update also eliminates leveraged lease accounting but allows existing leveraged leases to continue their current accounting until maturity or termination.
 
The guidance is effective for us in first quarter 2019 with modified retrospective application. Early adoption is permitted. We are evaluating the impact the Update will have on our consolidated financial statements.

59


Standard
 
Description
 
Effective date and financial statement impact
ASU 2016-01 – Financial Instruments – Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities
 
The Update amends the presentation and accounting for certain financial instruments, including liabilities measured at fair value under the fair value option and equity investments. The guidance also updates fair value presentation and disclosure requirements for financial instruments measured at amortized cost.
 
The Update is effective for us in first quarter 2018 with prospective application to changes in guidance related to nonmarketable equity investments. The remaining amendments should be applied with a cumulative-effect adjustment to the balance sheet as of the beginning of the adoption period. Early application is only permitted for changes related to liabilities measured at fair value under the fair value option. Early adoption is prohibited for the remaining amendments. We are evaluating the impact of the Update on our consolidated financial statements.
ASU 2014-09 – Revenue from Contracts With Customers (Topic 606) and subsequent related Updates
 
The Update modifies the guidance companies use to recognize revenue from contracts with customers for transfers of goods or services and transfers of nonfinancial assets, unless those contracts are within the scope of other standards. The guidance also requires new qualitative and quantitative disclosures, including information about contract balances and performance obligations.
 
In August 2015, the FASB issued ASU 2015-14 (Deferral of the Effective Date), which defers the effective date of ASU 2014-09 to first quarter 2018. Early adoption is permitted in first quarter 2017. Our revenue is balanced between net interest income on financial assets and liabilities, which is explicitly excluded from the scope of the new guidance, and noninterest income. We continue to evaluate the impact of the Update to our noninterest income and on our presentation and disclosures. We expect to adopt the Update in first quarter 2018 with a cumulative-effect adjustment to opening retained earnings.

Table 51 provides proposed accounting pronouncements that could materially affect our consolidated financial statements when finalized by the FASB.


Table 51: Current Accounting Developments – Proposed Standards
Proposed Standard
 
Description
 
Expected Issuance
Financial Instruments – Credit Losses (Subtopic 825-15)
 
The proposed Update would change the accounting for credit losses on loans and debt securities. For loans, the proposal would require an expected credit loss model rather than the current incurred loss model to determine the allowance for credit losses. The expected credit loss model would estimate losses for the estimated life of the financial asset. In addition, the proposed guidance would modify the other-than-temporary impairment model for available-for-sale debt securities to require an allowance for credit impairment instead of a direct write-down, which would allow for reversal of credit impairments in future periods.
 
The FASB expects to issue a final standard in 2016.


60

Forward-Looking Statements (continued)

Forward-Looking Statements
This document contains “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. In addition, we may make forward-looking statements in our other documents filed or furnished with the SEC, and our management may make forward-looking statements orally to analysts, investors, representatives of the media and others. Forward-looking statements can be identified by words such as “anticipates,” “intends,” “plans,” “seeks,” “believes,” “estimates,” “expects,” “target,” “projects,” “outlook,” “forecast,” “will,” “may,” “could,” “should,” “can” and similar references to future periods. In particular, forward-looking statements include, but are not limited to, statements we make about: (i) the future operating or financial performance of the Company, including our outlook for future growth; (ii) our noninterest expense and efficiency ratio; (iii) future credit quality and performance, including our expectations regarding future loan losses and allowance levels; (iv) the appropriateness of the allowance for credit losses; (v) our expectations regarding net interest income and net interest margin; (vi) loan growth or the reduction or mitigation of risk in our loan portfolios; (vii) future capital levels or targets and our estimated Common Equity Tier 1 ratio under Basel III capital standards; (viii) the performance of our mortgage business and any related exposures; (ix) the expected outcome and impact of legal, regulatory and legislative developments, as well as our expectations regarding compliance therewith; (x) future common stock dividends, common share repurchases and other uses of capital; (xi) our targeted range for return on assets and return on equity; (xii) the outcome of contingencies, such as legal proceedings; and (xiii) the Company’s plans, objectives and strategies.
Forward-looking statements are not based on historical facts but instead represent our current expectations and assumptions regarding our business, the economy and other future conditions. Because forward-looking statements relate to the future, they are subject to inherent uncertainties, risks and changes in circumstances that are difficult to predict. Our actual results may differ materially from those contemplated by the forward-looking statements. We caution you, therefore, against relying on any of these forward-looking statements. They are neither statements of historical fact nor guarantees or assurances of future performance. While there is no assurance that any list of risks and uncertainties or risk factors is complete, important factors that could cause actual results to differ materially from those in the forward-looking statements include the following, without limitation:
current and future economic and market conditions, including the effects of declines in housing prices, high unemployment rates, U.S. fiscal debt, budget and tax matters, geopolitical matters, and the overall slowdown in global economic growth;
our capital and liquidity requirements (including under regulatory capital standards, such as the Basel III capital standards) and our ability to generate capital internally or raise capital on favorable terms;
financial services reform and other current, pending or future legislation or regulation that could have a negative effect on our revenue and businesses, including the Dodd-Frank Act and other legislation and regulation relating to bank products and services;
the extent of our success in our loan modification efforts, as well as the effects of regulatory requirements or guidance regarding loan modifications;
 
the amount of mortgage loan repurchase demands that we receive and our ability to satisfy any such demands without having to repurchase loans related thereto or otherwise indemnify or reimburse third parties, and the credit quality of or losses on such repurchased mortgage loans;
negative effects relating to our mortgage servicing and foreclosure practices, as well as changes in industry standards or practices, regulatory or judicial requirements, penalties or fines, increased servicing and other costs or obligations, including loan modification requirements, or delays or moratoriums on foreclosures;
our ability to realize our efficiency ratio target as part of our expense management initiatives, including as a result of business and economic cyclicality, seasonality, changes in our business composition and operating environment, growth in our businesses and/or acquisitions, and unexpected expenses relating to, among other things, litigation and regulatory matters;
the effect of the current low interest rate environment or changes in interest rates on our net interest income, net interest margin and our mortgage originations, mortgage servicing rights and mortgages held for sale;
significant turbulence or a disruption in the capital or financial markets, which could result in, among other things, reduced investor demand for mortgage loans, a reduction in the availability of funding or increased funding costs, and declines in asset values and/or recognition of other-than-temporary impairment on securities held in our investment securities portfolio;
the effect of a fall in stock market prices on our investment banking business and our fee income from our brokerage, asset and wealth management businesses;
reputational damage from negative publicity, protests, fines, penalties and other negative consequences from regulatory violations and legal actions;
a failure in or breach of our operational or security systems or infrastructure, or those of our third party vendors or other service providers, including as a result of cyber attacks;
the effect of changes in the level of checking or savings account deposits on our funding costs and net interest margin;
fiscal and monetary policies of the Federal Reserve Board; and
the other risk factors and uncertainties described under “Risk Factors” in our Annual Report on Form 10-K for the year ended December 31, 2015.
 
In addition to the above factors, we also caution that the amount and timing of any future common stock dividends or repurchases will depend on the earnings, cash requirements and financial condition of the Company, market conditions, capital requirements (including under Basel capital standards), common stock issuance requirements, applicable law and regulations (including federal securities laws and federal banking regulations), and other factors deemed relevant by the Company’s Board of Directors, and may be subject to regulatory approval or conditions.
For more information about factors that could cause actual results to differ materially from our expectations, refer to our reports filed with the Securities and Exchange Commission, including the discussion under “Risk Factors” in our Annual Report on Form 10-K for the year ended December 31, 2015, as


61


filed with the Securities and Exchange Commission and available on its website at www.sec.gov. 
Any forward-looking statement made by us speaks only as of the date on which it is made. Factors or events that could cause our actual results to differ may emerge from time to time, and it
 
is not possible for us to predict all of them. We undertake no obligation to publicly update any forward-looking statement, whether as a result of new information, future developments or otherwise, except as may be required by law.


Risk Factors
An investment in the Company involves risk, including the possibility that the value of the investment could fall substantially and that dividends or other distributions on the investment could be reduced or eliminated. For a discussion of risk factors that
 
could adversely affect our financial results and condition, and the value of, and return on, an investment in the Company, we refer you to the “Risk Factors” section in our 2015 Form 10-K.


Controls and Procedures
Disclosure Controls and Procedures
The Company’s management evaluated the effectiveness, as of March 31, 2016, of the Company’s disclosure controls and procedures. The Company’s chief executive officer and chief financial officer participated in the evaluation. Based on this evaluation, the Company’s chief executive officer and chief financial officer concluded that the Company’s disclosure controls and procedures were effective as of March 31, 2016.

Internal Control Over Financial Reporting
Internal control over financial reporting is defined in Rule 13a-15(f) promulgated under the Securities Exchange Act of 1934 as a process designed by, or under the supervision of, the Company’s principal executive and principal financial officers and effected by the Company’s Board, management and other personnel, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with U.S. generally accepted accounting principles (GAAP) and includes those policies and procedures that:
pertain to the maintenance of records that in reasonable detail accurately and fairly reflect the transactions and dispositions of assets of the Company;
provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of the Company are being made only in accordance with authorizations of management and directors of the Company; and
provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of the Company’s assets that could have a material effect on the financial statements.
Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate. No change occurred during first quarter 2016 that has materially affected, or is reasonably likely to materially affect, the Company’s internal control over financial reporting.

62


Wells Fargo & Company and Subsidiaries
Consolidated Statement of Income (Unaudited)
 
Quarter ended March 31,
 
(in millions, except per share amounts)
2016

 
2015

Interest income
 
 
 
Trading assets
$
596

 
445

Investment securities
2,262

 
2,144

Mortgages held for sale
161

 
177

Loans held for sale
2

 
5

Loans
9,577

 
8,938

Other interest income
374

 
254

Total interest income
12,972

 
11,963

Interest expense
 
 
 
Deposits
307

 
258

Short-term borrowings
67

 
18

Long-term debt
842

 
604

Other interest expense
89

 
97

Total interest expense
1,305

 
977

Net interest income
11,667


10,986

Provision for credit losses
1,086

 
608

Net interest income after provision for credit losses
10,581

 
10,378

Noninterest income
 
 
 
Service charges on deposit accounts
1,309

 
1,215

Trust and investment fees
3,385

 
3,677

Card fees
941

 
871

Other fees
933

 
1,078

Mortgage banking
1,598

 
1,547

Insurance
427

 
430

Net gains from trading activities
200

 
408

Net gains on debt securities (1)
244

 
278

Net gains from equity investments (2)
244

 
370

Lease income
373

 
132

Other
874

 
286

Total noninterest income
10,528

 
10,292

Noninterest expense
 
 
 
Salaries
4,036

 
3,851

Commission and incentive compensation
2,645

 
2,685

Employee benefits
1,526

 
1,477

Equipment
528

 
494

Net occupancy
711

 
723

Core deposit and other intangibles
293

 
312

FDIC and other deposit assessments
250

 
248

Other
3,039

 
2,717

Total noninterest expense
13,028

 
12,507

Income before income tax expense
8,081


8,163

Income tax expense
2,567

 
2,279

Net income before noncontrolling interests
5,514


5,884

Less: Net income from noncontrolling interests
52

 
80

Wells Fargo net income
$
5,462


5,804

Less: Preferred stock dividends and other
377

 
343

Wells Fargo net income applicable to common stock
$
5,085

 
5,461

Per share information
 
 
 
Earnings per common share
$
1.00

 
1.06

Diluted earnings per common share
0.99

 
1.04

Dividends declared per common share
0.375

 
0.350

Average common shares outstanding
5,075.7

 
5,160.4

Diluted average common shares outstanding
5,139.4

 
5,243.6

(1)
Total other-than-temporary impairment (OTTI) losses (reversal of losses) were $76 million and $(6) million for first quarter 2016 and 2015, respectively. Of total OTTI, losses of $65 million and $31 million were recognized in earnings, and losses (reversal of losses) of $11 million and $(37) million were recognized as non-credit-related OTTI in other comprehensive income for first quarter 2016 and 2015, respectively.
(2)
Includes OTTI losses of $133 million and $42 million for first quarter 2016 and 2015, respectively.

The accompanying notes are an integral part of these statements.

63


Wells Fargo & Company and Subsidiaries
 
 
 
 
Consolidated Statement of Comprehensive Income (Unaudited)
 
 
 
 
 
Quarter ended March 31,
 
(in millions)
 
2016

 
2015

Wells Fargo net income
 
$
5,462

 
5,804

Other comprehensive income, before tax:
 
 
 
 
Investment securities:
 
 
 
 
Net unrealized gains arising during the period
 
795

 
393

Reclassification of net gains to net income
 
(304
)
 
(300
)
Derivatives and hedging activities:
 
 
 
 
Net unrealized gains arising during the period
 
1,999

 
952

Reclassification of net gains on cash flow hedges to net income
 
(256
)
 
(234
)
Defined benefit plans adjustments:
 
 
 
 
Net actuarial losses arising during the period
 
(8
)
 
(11
)
Amortization of net actuarial loss, settlements and other to net income
 
37

 
43

Foreign currency translation adjustments:
 
 
 
 
Net unrealized gains (losses) arising during the period
 
43

 
(55
)
Other comprehensive income, before tax
 
2,306

 
788

Income tax expense related to other comprehensive income
 
(857
)
 
(228
)
Other comprehensive income, net of tax
 
1,449

 
560

Less: Other comprehensive income (loss) from noncontrolling interests
 
(28
)
 
301

Wells Fargo other comprehensive income, net of tax
 
1,477

 
259

Wells Fargo comprehensive income
 
6,939

 
6,063

Comprehensive income from noncontrolling interests
 
24

 
381

Total comprehensive income
 
$
6,963

 
6,444


The accompanying notes are an integral part of these statements.

64


Wells Fargo & Company and Subsidiaries
 
 
 
Consolidated Balance Sheet
 
 
 
(in millions, except shares)
Mar 31,
2016

 
Dec 31,
2015

Assets
(Unaudited)

 
 
Cash and due from banks
$
19,084

 
19,111

Federal funds sold, securities purchased under resale agreements and other short-term investments
300,547

 
270,130

Trading assets
73,158

 
77,202

Investment securities:
 
 
 
Available-for-sale, at fair value 
255,551

 
267,358

Held-to-maturity, at cost (fair value $81,725 and $80,567) 
79,348

 
80,197

Mortgages held for sale (includes $15,110 and $13,539 carried at fair value) (1) 
18,041

 
19,603

Loans held for sale
280

 
279

Loans (includes $5,221 and $5,316 carried at fair value) (1)
947,258

 
916,559

Allowance for loan losses 
(11,621
)
 
(11,545
)
Net loans
935,637

 
905,014

Mortgage servicing rights: 
 
 
  
Measured at fair value 
11,333

 
12,415

Amortized 
1,359

 
1,308

Premises and equipment, net 
8,349

 
8,704

Goodwill 
27,003

 
25,529

Other assets (includes $3,098 and $3,065 carried at fair value) (1) 
119,492

 
100,782

Total assets (2) 
$
1,849,182

 
1,787,632

Liabilities 
 
 
  
Noninterest-bearing deposits 
$
348,888

 
351,579

Interest-bearing deposits 
892,602

 
871,733

Total deposits 
1,241,490

 
1,223,312

Short-term borrowings 
107,703

 
97,528

Accrued expenses and other liabilities
73,597

 
73,365

Long-term debt 
227,888

 
199,536

Total liabilities (3) 
1,650,678

 
1,593,741

Equity 
 
 
  
Wells Fargo stockholders' equity: 
 
 
  
Preferred stock 
24,051

 
22,214

Common stock – $1-2/3 par value, authorized 9,000,000,000 shares; issued 5,481,811,474 shares 
9,136

 
9,136

Additional paid-in capital 
60,602

 
60,714

Retained earnings 
123,891

 
120,866

 Cumulative other comprehensive income
1,774

 
297

Treasury stock – 405,908,584 shares and 389,682,664 shares 
(19,687
)
 
(18,867
)
Unearned ESOP shares 
(2,271
)
 
(1,362
)
Total Wells Fargo stockholders' equity 
197,496

 
192,998

Noncontrolling interests 
1,008

 
893

Total equity 
198,504

 
193,891

Total liabilities and equity
$
1,849,182

 
1,787,632

(1)
Parenthetical amounts represent assets and liabilities for which we have elected the fair value option.
(2)
Our consolidated assets at March 31, 2016, and December 31, 2015, include the following assets of certain variable interest entities (VIEs) that can only be used to settle the liabilities of those VIEs: Cash and due from banks, $288 million and $157 million; Trading assets, $152 million and $1 million; Investment securities, $372 million and $425 million; Net loans, $13.9 billion and $4.8 billion; Other assets, $518 million and $242 million; and Total assets, $15.2 billion and $5.6 billion, respectively.
(3)
Our consolidated liabilities at March 31, 2016, and December 31, 2015, include the following VIE liabilities for which the VIE creditors do not have recourse to Wells Fargo: Accrued expenses and other liabilities, $146 million and $57 million; Long-term debt, $4.7 billion and $1.3 billion; and Total liabilities, $4.9 billion and $1.4 billion, respectively. 

The accompanying notes are an integral part of these statements.

65



Wells Fargo & Company and Subsidiaries
 
 
 
 
 
 
 
Consolidated Statement of Changes in Equity (Unaudited)
 
 
 
 
 
 
 
 
 
 
 
Preferred stock
 
 
Common stock
 
(in millions, except shares)
Shares

 
Amount

 
Shares

 
Amount

Balance January 1, 2015
11,138,818

 
$
19,213

 
5,170,349,198

 
$
9,136

Net income
 
 
 
 
 
 
 
Other comprehensive income, net of tax
 
 
 
 
 
 
 
Noncontrolling interests
 
 
 
 
 
 
 
Common stock issued
 
 
 
 
40,259,205

 
 
Common stock repurchased (1)
 
 
 
 
(48,426,207
)
 
 
Preferred stock issued to ESOP
826,598

 
826

 
 
 
 
Preferred stock released by ESOP
 
 
 
 
 
 
 
Preferred stock converted to common shares
(41,313
)
 
(41
)
 
759,429

 
 
Common stock warrants repurchased/exercised
 
 
 
 
 
 
 
Preferred stock issued
80,000

 
2,000

 
 
 
 
Common stock dividends
 
 
 
 
 
 
 
Preferred stock dividends
 
 
 
 
 
 
 
Tax benefit from stock incentive compensation
 
 
 
 
 
 
 
Stock incentive compensation expense
 
 
 
 
 
 
 
Net change in deferred compensation and related plans
 
 
 
 
 
 
 
Net change
865,285


2,785


(7,407,573
)


Balance March 31, 2015
12,004,103


$
21,998


5,162,941,625


$
9,136

Balance December 31, 2015
11,259,917

 
$
22,214

 
5,092,128,810

 
$
9,136

Cumulative effect from change in consolidation accounting (2)
 
 
 
 
 
 
 
Balance January 1, 2016
11,259,917

 
$
22,214

 
5,092,128,810

 
$
9,136

Net income
 
 
 
 
 
 
 
Other comprehensive income (loss), net of tax
 
 
 
 
 
 
 
Noncontrolling interests
 
 
 
 
 
 
 
Common stock issued
 
 
 
 
28,984,457

 
 
Common stock repurchased (1)
 
 
 
 
(51,674,544
)
 
 
Preferred stock issued to ESOP
1,150,000

 
1,150

 
 
 
 
Preferred stock released by ESOP
 
 
 
 
 
 
 
Preferred stock converted to common shares
(312,927
)
 
(313
)
 
6,464,167

 
 
Common stock warrants repurchased/exercised
 
 
 
 
 
 
 
Preferred stock issued
40,000

 
1,000

 
 
 
 
Common stock dividends
 
 
 
 
 
 
 
Preferred stock dividends
 
 
 
 
 
 
 
Tax benefit from stock incentive compensation
 
 
 
 
 
 
 
Stock incentive compensation expense
 
 
 
 
 
 
 
Net change in deferred compensation and related plans
 
 
 
 
 
 
 
Net change
877,073


1,837


(16,225,920
)


Balance March 31, 2016
12,136,990


$
24,051


5,075,902,890


$
9,136

(1)
We had no unsettled private share repurchase contracts at March 31, 2016. For the first three months of 2015, includes $750 million related to a private forward repurchase transaction entered into in first quarter 2015 that settled in second quarter 2015 for 14.0 million shares of common stock.
(2)
Effective January 1, 2016, we adopted changes in consolidation accounting pursuant to ASU 2015-02 (Amendments to the Consolidation Analysis). Accordingly, we recorded a $121 million increase to beginning noncontrolling interests as a cumulative-effect adjustment.

The accompanying notes are an integral part of these statements.


66



 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  

 
  
 
  
 
Wells Fargo stockholders' equity
 
 
  
 
  
Additional
paid-in
capital

 
Retained
earnings

 
Cumulative
other
comprehensive
income

 
Treasury
stock

 
Unearned
ESOP
shares

 
Total
Wells Fargo
stockholders'
equity

 
Noncontrolling
interests

 
Total
equity

60,537

 
107,040

 
3,518

 
(13,690
)
 
(1,360
)
 
184,394

 
868

 
185,262

 
 
5,804

 
 
 
 
 
 
 
5,804

 
80

 
5,884

 
 
 
 
259

 
 
 
 
 
259

 
301

 
560

1

 
 
 
 
 
 
 
 
 
1

 
(81
)
 
(80
)
(342
)
 

 
 
 
1,669

 
 
 
1,327

 
 
 
1,327


 
 
 
 
 
(2,592
)
 
 
 
(2,592
)
 
 
 
(2,592
)
74

 
 
 
 
 
 
 
(900
)
 

 
 
 

(4
)
 
 
 
 
 
 
 
45

 
41

 
 
 
41

7

 
 
 
 
 
34

 
 
 

 
 
 

(8
)
 
 
 
 
 
 
 
 
 
(8
)
 
 
 
(8
)
(3
)
 
 
 
 
 
 
 
 
 
1,997

 
 
 
1,997

19

 
(1,824
)
 
 
 
 
 
 
 
(1,805
)
 
 
 
(1,805
)
 
 
(344
)
 
 
 
 
 
 
 
(344
)
 
 
 
(344
)
354

 
 
 
 
 
 
 
 
 
354

 
 
 
354

376

 
 
 
 
 
 
 
 
 
376

 
 
 
376

(1,031
)
 
 
 
 
 
23

 
 
 
(1,008
)
 
 
 
(1,008
)
(557
)

3,636


259


(866
)

(855
)

4,402


300


4,702

59,980


110,676


3,777


(14,556
)

(2,215
)

188,796


1,168


189,964

60,714

 
120,866

 
297

 
(18,867
)
 
(1,362
)
 
192,998

 
893

 
193,891

 
 
 
 
 
 
 
 
 
 
 
 
121

 
121

60,714

 
120,866

 
297

 
(18,867
)
 
(1,362
)
 
192,998

 
1,014

 
194,012

 
 
5,462

 
 
 
 
 
 
 
5,462

 
52

 
5,514

 
 
 
 
1,477

 
 
 
 
 
1,477

 
(28
)
 
1,449

1

 
 
 
 
 
 
 
 
 
1

 
(30
)
 
(29
)
(160
)
 
(140
)
 
 
 
1,379

 
 
 
1,079

 
 
 
1,079

500

 
 
 
 
 
(2,529
)
 
 
 
(2,029
)
 
 
 
(2,029
)
99

 
 
 
 
 
 
 
(1,249
)
 

 
 
 

(27
)
 
 
 
 
 
 
 
340

 
313

 
 
 
313

1

 
 
 
 
 
312

 
 
 

 
 
 


 
 
 
 
 
 
 
 
 

 
 
 

(25
)
 
 
 
 
 
 
 
 
 
975

 
 
 
975

15

 
(1,919
)
 
 
 
 
 
 
 
(1,904
)
 
 
 
(1,904
)
 
 
(378
)
 
 
 
 
 
 
 
(378
)
 
 
 
(378
)
149

 
 
 
 
 
 
 
 
 
149

 
 
 
149

369

 
 
 
 
 
 
 
 
 
369

 
 
 
369

(1,034
)
 
 
 
 
 
18

 
 
 
(1,016
)
 
 
 
(1,016
)
(112
)

3,025


1,477


(820
)

(909
)

4,498


(6
)

4,492

60,602


123,891


1,774


(19,687
)

(2,271
)

197,496


1,008


198,504



67



Wells Fargo & Company and Subsidiaries
 
 
 
Consolidated Statement of Cash Flows (Unaudited)
 
 
 
 
Quarter ended March 31,
 
(in millions)
2016

 
2015

Cash flows from operating activities:
 
 
 
Net income before noncontrolling interests
$
5,514

 
5,884

Adjustments to reconcile net income to net cash provided by operating activities:
 
 
  

Provision for credit losses
1,086

 
608

Changes in fair value of MSRs, MHFS and LHFS carried at fair value
883

 
725

Depreciation, amortization and accretion
1,295

 
727

Other net gains
1,855

 
(2,301
)
Stock-based compensation
716

 
708

Excess tax benefits related to stock incentive compensation
(154
)
 
(354
)
Originations of MHFS
(37,109
)
 
(41,628
)
Proceeds from sales of and principal collected on mortgages originated for sale
29,605

 
31,266

Proceeds from sales of and principal collected on LHFS

 
6

Purchases of LHFS
(5
)
 
(23
)
Net change in:
 
 
  

Trading assets
14,134

 
5,777

Deferred income taxes
(1,240
)
 
(435
)
Accrued interest receivable
(247
)
 
(300
)
Accrued interest payable
251

 
76

Other assets
(14,228
)
 
(2,053
)
Other accrued expenses and liabilities
2,936

 
3,832

Net cash provided by operating activities
5,292

 
2,515

Cash flows from investing activities:
 
 
 
Net change in:
  
 
  
Federal funds sold, securities purchased under resale agreements and other short-term investments
(30,518
)
 
(33,026
)
Available-for-sale securities:
 
 
 
Sales proceeds
13,058

 
4,230

Prepayments and maturities
6,651

 
7,004

Purchases
(5,321
)
 
(14,634
)
Held-to-maturity securities:
 
 
 
Paydowns and maturities
997

 
1,204

Purchases

 
(8,068
)
Nonmarketable equity investments:
 
 
 
Sales proceeds
529

 
598

Purchases
(995
)
 
(281
)
Loans:
 
 
 
Loans originated by banking subsidiaries, net of principal collected
(9,798
)
 
(2,584
)
Proceeds from sales (including participations) of loans held for investment
2,134

 
2,596

Purchases (including participations) of loans
(727
)
 
(1,109
)
Principal collected on nonbank entities’ loans
3,376

 
2,328

Loans originated by nonbank entities
(2,875
)
 
(2,223
)
Net cash paid for acquisitions
(28,904
)
 

Proceeds from sales of foreclosed assets and short sales
1,859

 
1,874

Net cash from purchases and sales of MSRs
(21
)
 
(21
)
Other, net
189

 
(812
)
Net cash used by investing activities
(50,366
)
 
(42,924
)
Cash flows from financing activities:
 
 
 
Net change in:
  

 
  

Deposits
18,178

 
28,591

Short-term borrowings
10,175

 
14,174

Long-term debt:
 
 
  

Proceeds from issuance
23,934

 
5,286

Repayment
(4,523
)
 
(5,640
)
Preferred stock:
 
 
  

Proceeds from issuance
975

 
1,997

Cash dividends paid
(386
)
 
(364
)
Common stock:
 
 
  

Proceeds from issuance
479

 
614

Repurchased
(2,029
)
 
(2,592
)
Cash dividends paid
(1,858
)
 
(1,762
)
Excess tax benefits related to stock incentive compensation
154

 
354

Net change in noncontrolling interests
(32
)
 
(47
)
Other, net
(20
)
 
20

Net cash provided by financing activities
45,047

 
40,631

Net change in cash and due from banks
(27
)
 
222

Cash and due from banks at beginning of period
19,111

 
19,571

Cash and due from banks at end of period
$
19,084

 
19,793

Supplemental cash flow disclosures:
 
 
 
Cash paid for interest
$
1,054

 
901

Cash paid for income taxes
138

 
352


The accompanying notes are an integral part of these statements. See Note 1 (Summary of Significant Accounting Policies) for noncash activities.

68

Notes 1: Summary of Significant Accounting Policies (continued)

See the Glossary of Acronyms at the end of this Report for terms used throughout the Financial Statements and related Notes.
 
Note 1:  Summary of Significant Accounting Policies
Wells Fargo & Company is a diversified financial services company. We provide banking, insurance, trust and investments, mortgage banking, investment banking, retail banking, brokerage, and consumer and commercial finance through banking stores, the internet and other distribution channels to consumers, businesses and institutions in all 50 states, the District of Columbia, and in foreign countries. When we refer to “Wells Fargo,” “the Company,” “we,” “our” or “us,” we mean Wells Fargo & Company and Subsidiaries (consolidated). Wells Fargo & Company (the Parent) is a financial holding company and a bank holding company. We also hold a majority interest in a real estate investment trust, which has publicly traded preferred stock outstanding.
Our accounting and reporting policies conform with U.S. generally accepted accounting principles (GAAP) and practices in the financial services industry. For discussion of our significant accounting policies, see Note 1 (Summary of Significant Accounting Policies) in our Annual Report on Form 10-K for the year ended December 31, 2015 (2015 Form 10-K). There were no material changes to these policies in first quarter 2016. To prepare the financial statements in conformity with GAAP, management must make estimates based on assumptions about future economic and market conditions (for example, unemployment, market liquidity, real estate prices, etc.) that affect the reported amounts of assets and liabilities at the date of the financial statements, income and expenses during the reporting period and the related disclosures. Although our estimates contemplate current conditions and how we expect them to change in the future, it is reasonably possible that actual conditions could be worse than anticipated in those estimates, which could materially affect our results of operations and financial condition. Management has made significant estimates in several areas, including allowance for credit losses and purchased credit-impaired (PCI) loans (Note 5 (Loans and Allowance for Credit Losses)), valuations of residential mortgage servicing rights (MSRs) (Note 7 (Securitizations and Variable Interest Entities) and Note 8 (Mortgage Banking Activities)) and financial instruments (Note 13 (Fair Values of Assets and Liabilities)), and income taxes. Actual results could differ from those estimates.
These unaudited interim financial statements reflect all adjustments that are, in the opinion of management, necessary for a fair statement of the results for the periods presented. These adjustments are of a normal recurring nature, unless otherwise disclosed in this Form 10-Q. The results of operations in the interim financial statements do not necessarily indicate the results that may be expected for the full year. The interim financial information should be read in conjunction with our 2015 Form 10-K.
 
Accounting Standards Adopted in 2016
In first quarter 2016, we adopted the following new accounting guidance:

Accounting Standards Update (ASU or Update) 2015-16 Business Combinations (Topic 805): Simplifying the Accounting for Measurement-Period Adjustments;
 
ASU 2015-07 Fair Value Measurement (Topic 820): Disclosures for Investments in Certain Entities that Calculate Net Asset Value per Share (or Its Equivalent);
ASU 2015-03 – Interest – Imputation of Interest (Subtopic 835-30): Simplifying the Presentation of Debt Issuance Costs;
ASU 2015-02 – Consolidation (Topic 810): Amendments to the Consolidation Analysis;
ASU 2015-01 – Income Statement – Extraordinary and Unusual Items (Subtopic 225-20): Simplifying Income Statement Presentation by Eliminating the Concept of Extraordinary Items;
ASU 2014-16 – Derivatives and Hedging (Topic 815): Determining Whether the Host Contract in a Hybrid Financial Instrument Issued in the Form of a Share is More Akin to Debt or to Equity;
ASU 2014-13 – Consolidation (Topic 810): Measuring the Financial Assets and the Financial Liabilities of a Consolidated Collateralized Financing Entity; and
ASU 2014-12 – Compensation – Stock Compensation (Topic 718): Accounting for Share-Based Payments When the Terms of an Award Provide That a Performance Target Could Be Achieved after the Requisite Service Period.

ASU 2015-16 eliminates the requirement for companies to retrospectively adjust initial amounts recognized in business combinations when the accounting is incomplete at the acquisition date. Under the new guidance, companies should record adjustments in the same reporting period in which the amounts are determined. We adopted this accounting change in first quarter 2016 with prospective application. The Update did not have a material impact on our consolidated financial statements.

ASU 2015-07 eliminates the disclosure requirement to categorize investments within the fair value hierarchy that are measured at fair value using net asset value as a practical expedient. We adopted this change in first quarter 2016 with retrospective application. The Update did not affect our consolidated financial statements as it impacts only the fair value disclosure requirements for certain investments. For additional information, see Note 13 (Fair Values of Assets and Liabilities).

ASU 2015-03 changes the balance sheet presentation for debt issuance costs. Under the new guidance, debt issuance costs should be reported as a deduction from debt liabilities rather than as a deferred charge classified as an asset. We adopted this change in first quarter 2016, which resulted in a $180 million reclassification from Other assets to Long-term debt on January 1, 2016. Because the impact on prior periods was not material, we applied the guidance prospectively.

ASU 2015-02 requires companies to reevaluate all legal entities under new consolidation guidance. The new guidance primarily amends the criteria companies use to evaluate whether they should consolidate certain variable interest entities that have fee arrangements and the criteria used to determine whether partnerships and similar entities are variable interest entities. The new guidance also amends the consolidation analysis for certain investment funds and excludes certain money market


69


funds. We adopted the accounting changes on January 1, 2016, which resulted in a net increase in assets and a corresponding cumulative-effect adjustment to noncontrolling interests of $121 million. There was no impact to consolidated retained earnings. For additional information, see Note 7 (Securitizations and Variable Interest Entities).

ASU 2015-01 removes the concept of extraordinary items from GAAP and eliminates the requirement for extraordinary items to be separately presented in the statement of income. We adopted this change in first quarter 2016 with prospective application. This Update did not have a material impact on our consolidated financial statements.

ASU 2014-16 clarifies that the nature of host contracts in hybrid financial instruments that are issued in share form should be determined based on the entire instrument, including the embedded derivative. We adopted this new requirement in first quarter 2016. This Update did not have a material impact on our consolidated financial statements.

ASU 2014-13 provides a measurement alternative to companies that consolidate collateralized financing entities (CFEs), such as collateralized debt obligation and collateralized loan obligation structures. Under the new guidance, companies can measure both the financial assets and financial liabilities of a CFE using the more observable fair value of the financial assets or of the financial liabilities. We adopted this accounting change in first quarter 2016. The Update did not have a material impact on our consolidated financial statements.

ASU 2014-12 provides accounting guidance for employee share-based payment awards with specific performance targets. The Update clarifies that performance targets should be treated as performance conditions if the targets affect vesting and could be achieved after the requisite service period. We adopted this
 
change in first quarter 2016 with prospective application. The Update did not have a material effect on our consolidated financial statements, as our historical practice complies with the new requirements.

Private Share Repurchases
From time to time we enter into private forward repurchase transactions with unrelated third parties to complement our open-market common stock repurchase strategies, to allow us to manage our share repurchases in a manner consistent with our capital plans, currently submitted under the 2015 Comprehensive Capital Analysis and Review (CCAR), and to provide an economic benefit to the Company.
Our payments to the counterparties for these contracts are recorded in permanent equity in the quarter paid and are not subject to re-measurement. The classification of the up-front payments as permanent equity assures that we have appropriate repurchase timing consistent with our 2015 Capital Plan, which contemplated a fixed dollar amount available per quarter for share repurchases pursuant to Federal Reserve Board (FRB) supervisory guidance. In return, the counterparty agrees to deliver a variable number of shares based on a per share discount to the volume-weighted average stock price over the contract period. There are no scenarios where the contracts would not either physically settle in shares or allow us to choose the settlement method. Our total number of outstanding shares of common stock is not reduced until settlement of the private share repurchase contract.
We had no unsettled private share repurchase contracts at March 31, 2016. At March 31, 2015, we had a $750 million private repurchase contract outstanding that settled in April 2015 for 14.0 million shares of common stock.
 


SUPPLEMENTAL CASH FLOW INFORMATION  Significant noncash activities are presented below.


Table 1.1: Supplemental Cash Flow Information
 
Quarter ended March 31,
 
(in millions)
2016

 
2015

Trading assets retained from securitization of MHFS
$
9,955

 
6,874

Transfers from loans to MHFS
1,839

 
2,202

Transfers from available-for-sale to held-to-maturity securities

 
4,972


SUBSEQUENT EVENTS  We have evaluated the effects of events that have occurred subsequent to March 31, 2016, and there have been no material events that would require recognition in our first quarter 2016 consolidated financial statements or disclosure in the Notes to the consolidated financial statements.



70



Note 2:  Business Combinations
We regularly explore opportunities to acquire financial services companies and businesses. Generally, we do not make a public announcement about an acquisition opportunity until a definitive agreement has been signed. For information on additional contingent consideration related to acquisitions, which is considered to be a guarantee, see Note 10 (Guarantees, Pledged Assets and Collateral).
During first quarter 2016, we completed two acquisitions.  On January 1, 2016, we acquired $4.4 billion in assets associated with GE Railcar Services, which included 77,000 railcars and 1,000 locomotives. The acquired assets included $918 million of loans and capital leases and $3.2 billion of operating lease assets.
On March 1, 2016, we acquired $29.9 billion in assets associated with the North American portion of GE Capital’s Commercial Distribution Finance and Vendor Finance
 
businesses. The acquired assets included $24.0 billion of loans and capital leases, $2.7 billion of operating lease assets, and $2.3 billion of goodwill and identifiable intangible assets. The North American portion represented approximately 90% of the total assets to be acquired. The international portion is expected to close during the second half of 2016.
On March 31, 2016, we completed the divestiture of Rural Community Insurance, our crop insurance business. The transaction involved the sale of approximately $4 billion in assets which resulted in a pre-tax gain of $381 million.


    



Note 3:  Federal Funds Sold, Securities Purchased under Resale Agreements and Other Short-Term Investments
Table 3.1 provides the detail of federal funds sold, securities purchased under short-term resale agreements (generally less than one year) and other short-term investments. The majority of interest-earning deposits at March 31, 2016, and December 31, 2015, were held at the Federal Reserve. 
Table 3.1: Fed Funds Sold and Other Short-Term Investments
(in millions)
Mar 31,
2016

 
Dec 31,
2015

Federal funds sold and securities purchased under resale agreements
$
49,698

 
45,828

Interest-earning deposits
242,754

 
220,409

Other short-term investments
8,095

 
3,893

Total
$
300,547

 
270,130


 
As part of maintaining our memberships in certain clearing organizations, we are required to stand ready to provide liquidity meant to sustain market clearing activity in the event unforeseen events occur or are deemed likely to occur. This includes commitments we have entered into to purchase securities under resale agreements from a central clearing organization that, at its option, require us to provide funding under such agreements. We do not have any outstanding amounts funded, and the amount of our unfunded contractual commitment was $2.6 billion and $2.2 billion as of March 31, 2016, and December 31, 2015, respectively.
We have classified securities purchased under long-term resale agreements (generally one year or more), which totaled $21.1 billion and $20.1 billion at March 31, 2016, and December 31, 2015, respectively, in loans. For additional information on the collateral we receive from other entities under resale agreements and securities borrowings, see the “Offsetting of Resale and Repurchase Agreements and Securities Borrowing and Lending Agreements” section in Note 10 (Guarantees, Pledged Assets and Collateral).





71


Note 4:  Investment Securities
Table 4.1 provides the amortized cost and fair value by major categories of available-for-sale securities, which are carried at fair value, and held-to-maturity debt securities, which are carried at
 
amortized cost. The net unrealized gains (losses) for available-for-sale securities are reported on an after-tax basis as a component of cumulative OCI.

Table 4.1: Amortized Cost and Fair Value
(in millions)
Amortized Cost

 
Gross
unrealized
gains

 
Gross
unrealized
losses

 
Fair
value

March 31, 2016
 
 
 
 
 
 
 
Available-for-sale securities:
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
$
33,238

 
575

 

 
33,813

Securities of U.S. states and political subdivisions
51,794

 
1,019

 
(1,239
)
 
51,574

Mortgage-backed securities:
 
 
 
 
 
 
 
Federal agencies
93,005

 
2,558

 
(100
)
 
95,463

Residential
7,798

 
617

 
(41
)
 
8,374

Commercial
12,786

 
189

 
(103
)
 
12,872

Total mortgage-backed securities
113,589

 
3,364

 
(244
)
 
116,709

Corporate debt securities
13,837

 
346

 
(383
)
 
13,800

Collateralized loan and other debt obligations (1) 
32,578

 
118

 
(563
)
 
32,133

Other (2)
6,004

 
93

 
(74
)
 
6,023

Total debt securities
251,040

 
5,515

 
(2,503
)
 
254,052

Marketable equity securities:
 
 
 
 
 
 
 
Perpetual preferred securities
818

 
103

 
(14
)
 
907

Other marketable equity securities
216

 
376

 

 
592

Total marketable equity securities
1,034

 
479

 
(14
)
 
1,499

Total available-for-sale securities
252,074

 
5,994

 
(2,517
)
 
255,551

Held-to-maturity securities:
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
44,667

 
1,986

 

 
46,653

Securities of U.S. states and political subdivisions
2,183

 
100

 

 
2,283

Federal agency mortgage-backed securities
28,016

 
328

 

 
28,344

Collateralized loan obligations
1,406

 

 
(30
)
 
1,376

Other (2)
3,076

 

 
(7
)
 
3,069

Total held-to-maturity securities
79,348

 
2,414

 
(37
)
 
81,725

Total
$
331,422

 
8,408

 
(2,554
)
 
337,276

December 31, 2015
 
 
 
 
 
 
 
Available-for-sale securities:
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
$
36,374

 
24

 
(148
)
 
36,250

Securities of U.S. states and political subdivisions
49,167

 
1,325

 
(502
)
 
49,990

Mortgage-backed securities:
 
 
 
 
 
 
 
Federal agencies
103,391

 
1,983

 
(828
)
 
104,546

Residential
7,843

 
740

 
(25
)
 
8,558

Commercial
13,943

 
230

 
(85
)
 
14,088

Total mortgage-backed securities
125,177

 
2,953

 
(938
)
 
127,192

Corporate debt securities
15,548

 
312

 
(449
)
 
15,411

Collateralized loan and other debt obligations (1)
31,210

 
125

 
(368
)
 
30,967

Other (2)
5,842

 
115

 
(46
)
 
5,911

Total debt securities
263,318

 
4,854

 
(2,451
)
 
265,721

Marketable equity securities:
 
 
 
 
 
 
 
Perpetual preferred securities
819

 
112

 
(13
)
 
918

Other marketable equity securities
239

 
482

 
(2
)
 
719

Total marketable equity securities
1,058

 
594

 
(15
)
 
1,637

Total available-for-sale securities
264,376

 
5,448

 
(2,466
)
 
267,358

Held-to-maturity securities:
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
44,660

 
580

 
(73
)
 
45,167

Securities of U.S. states and political subdivisions
2,185

 
65

 

 
2,250

Federal agency mortgage-backed securities
28,604

 
131

 
(314
)
 
28,421

Collateralized loan obligations
1,405

 

 
(24
)
 
1,381

Other (2)
3,343

 
8

 
(3
)
 
3,348

Total held-to-maturity securities
80,197

 
784

 
(414
)
 
80,567

Total
$
344,573

 
6,232

 
(2,880
)
 
347,925

(1)
The available-for-sale portfolio includes collateralized debt obligations (CDOs) with both a cost basis and fair value of $542 million at March 31, 2016, and $247 million and $257 million, respectively, at December 31, 2015.
(2)
The “Other” category of available-for-sale securities largely includes asset-backed securities collateralized by credit cards, student loans, home equity loans and auto leases or loans and cash. Included in the “Other” category of held-to-maturity securities are asset-backed securities collateralized by auto leases or loans and cash with a cost basis and fair value of $1.6 billion each at March 31, 2016, and $1.9 billion each at December 31, 2015. Also included in the “Other” category of held-to-maturity securities are asset-backed securities collateralized by dealer floorplan loans with a cost basis and fair value of $1.5 billion each at March 31, 2016, and $1.4 billion each at December 31, 2015.

72

Note 4: Investment Securities (continued)

Gross Unrealized Losses and Fair Value
Table 4.2 shows the gross unrealized losses and fair value of securities in the investment securities portfolio by length of time that individual securities in each category have been in a continuous loss position. Debt securities on which we have taken credit-related OTTI write-downs are categorized as being “less
 
than 12 months” or “12 months or more” in a continuous loss position based on the point in time that the fair value declined to below the cost basis and not the period of time since the credit-related OTTI write-down.

Table 4.2: Gross Unrealized Losses and Fair Value
 
Less than 12 months
 
 
12 months or more
 
 
Total
 
(in millions)
Gross
unrealized
losses

 
Fair
value

 
Gross
unrealized
losses

 
Fair
value

 
Gross
unrealized
losses

 
Fair
value

March 31, 2016
 
 
 
 
 
 
 
 
 
 
 
Available-for-sale securities:
 
 
 
 
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
$

 

 

 

 

 

Securities of U.S. states and political subdivisions
(278
)
 
14,789

 
(961
)
 
12,590

 
(1,239
)
 
27,379

Mortgage-backed securities:
 
 
 
 
 
 
 
 

 

Federal agencies
(3
)
 
479

 
(97
)
 
13,385

 
(100
)
 
13,864

Residential
(32
)
 
1,924

 
(9
)
 
366

 
(41
)
 
2,290

Commercial
(38
)
 
4,064

 
(65
)
 
2,483

 
(103
)
 
6,547

Total mortgage-backed securities
(73
)
 
6,467

 
(171
)
 
16,234

 
(244
)
 
22,701

Corporate debt securities
(176
)
 
2,917

 
(207
)
 
1,318

 
(383
)
 
4,235

Collateralized loan and other debt obligations
(462
)
 
22,814

 
(101
)
 
4,848

 
(563
)
 
27,662

Other
(52
)
 
2,979

 
(22
)
 
493

 
(74
)
 
3,472

Total debt securities
(1,041
)
 
49,966

 
(1,462
)
 
35,483

 
(2,503
)
 
85,449

Marketable equity securities:
 
 
 
 
 
 
 
 

 

Perpetual preferred securities
(2
)
 
89

 
(12
)
 
110

 
(14
)
 
199

Other marketable equity securities

 

 

 

 

 

Total marketable equity securities
(2
)
 
89

 
(12
)
 
110

 
(14
)
 
199

Total available-for-sale securities
(1,043
)
 
50,055

 
(1,474
)
 
35,593

 
(2,517
)
 
85,648

Held-to-maturity securities:
 
 
 
 
 
 
 
 

 

Securities of U.S. Treasury and federal agencies

 

 

 

 

 

Federal agency mortgage-backed securities

 

 

 

 

 

Collateralized loan obligations
(25
)
 
1,145

 
(5
)
 
231

 
(30
)
 
1,376

Other
(7
)
 
2,178

 

 

 
(7
)
 
2,178

Total held-to-maturity securities
(32
)
 
3,323

 
(5
)
 
231

 
(37
)
 
3,554

Total
$
(1,075
)
 
53,378

 
(1,479
)
 
35,824

 
(2,554
)
 
89,202

December 31, 2015
 
 
 
 
 
 
 
 
 
 
 
Available-for-sale securities:
 
 
 
 
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
$
(148
)
 
24,795

 

 

 
(148
)
 
24,795

Securities of U.S. states and political subdivisions
(26
)
 
3,453

 
(476
)
 
12,377

 
(502
)
 
15,830

Mortgage-backed securities:
 
 
 
 
 
 
 
 
 
 
 
Federal agencies
(522
)
 
36,329

 
(306
)
 
9,888

 
(828
)
 
46,217

Residential
(20
)
 
1,276

 
(5
)
 
285

 
(25
)
 
1,561

Commercial
(32
)
 
4,476

 
(53
)
 
2,363

 
(85
)
 
6,839

Total mortgage-backed securities
(574
)
 
42,081

 
(364
)
 
12,536

 
(938
)
 
54,617

Corporate debt securities
(244
)
 
4,941

 
(205
)
 
1,057

 
(449
)
 
5,998

Collateralized loan and other debt obligations
(276
)
 
22,214

 
(92
)
 
4,844

 
(368
)
 
27,058

Other
(33
)
 
2,768

 
(13
)
 
425

 
(46
)
 
3,193

Total debt securities
(1,301
)
 
100,252

 
(1,150
)
 
31,239

 
(2,451
)
 
131,491

Marketable equity securities:
 
 
 
 
 
 
 
 
 
 
 
Perpetual preferred securities
(1
)
 
24

 
(12
)
 
109

 
(13
)
 
133

Other marketable equity securities
(2
)
 
40

 

 

 
(2
)
 
40

Total marketable equity securities
(3
)
 
64

 
(12
)
 
109

 
(15
)
 
173

Total available-for-sale securities
(1,304
)
 
100,316

 
(1,162
)
 
31,348

 
(2,466
)
 
131,664

Held-to-maturity securities:
 
 
 
 
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
(73
)
 
5,264

 

 

 
(73
)
 
5,264

Federal agency mortgage-backed securities
(314
)
 
23,115

 

 

 
(314
)
 
23,115

Collateralized loan obligations
(20
)
 
1,148

 
(4
)
 
233

 
(24
)
 
1,381

Other
(3
)
 
1,096

 

 

 
(3
)
 
1,096

Total held-to-maturity securities
(410
)
 
30,623

 
(4
)
 
233

 
(414
)
 
30,856

Total
$
(1,714
)
 
130,939

 
(1,166
)
 
31,581

 
(2,880
)
 
162,520



73


We have assessed each security with gross unrealized losses included in the previous table for credit impairment. As part of that assessment we evaluated and concluded that we do not intend to sell any of the securities and that it is more likely than not that we will not be required to sell prior to recovery of the amortized cost basis. For debt securities, we evaluate, where necessary, whether credit impairment exists by comparing the present value of the expected cash flows to the securities’ amortized cost basis. For equity securities, we consider numerous factors in determining whether impairment exists, including our intent and ability to hold the securities for a period of time sufficient to recover the cost basis of the securities.
For descriptions of the factors we consider when analyzing securities for impairment, see Note 1 (Summary of Significant Accounting Policies) and Note 5 (Investment Securities) to Financial Statements in our 2015 Form 10-K. There have been no material changes to our methodologies for assessing impairment in first quarter 2016
Table 4.3 shows the gross unrealized losses and fair value of debt and perpetual preferred investment securities by those rated investment grade and those rated less than investment grade,
 
according to their lowest credit rating by Standard & Poor’s Rating Services (S&P) or Moody’s Investors Service (Moody’s). Credit ratings express opinions about the credit quality of a security. Securities rated investment grade, that is those rated BBB- or higher by S&P or Baa3 or higher by Moody’s, are generally considered by the rating agencies and market participants to be low credit risk. Conversely, securities rated below investment grade, labeled as “speculative grade” by the rating agencies, are considered to be distinctively higher credit risk than investment grade securities. We have also included securities not rated by S&P or Moody’s in the table below based on our internal credit grade of the securities (used for credit risk management purposes) equivalent to the credit rating assigned by major credit agencies. The unrealized losses and fair value of unrated securities categorized as investment grade based on internal credit grades were $24 million and $4.8 billion, respectively, at March 31, 2016, and $17 million and $3.7 billion, respectively, at December 31, 2015. If an internal credit grade was not assigned, we categorized the security as non-investment grade. 

Table 4.3: Gross Unrealized Losses and Fair Value by Investment Grade
 
Investment grade
 
 
Non-investment grade
 
(in millions)
Gross
unrealized
losses

 
Fair
value

 
Gross
unrealized
losses

 
Fair
value

March 31, 2016
 
 
 
 
 
 
 
Available-for-sale securities:
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
$

 

 

 

Securities of U.S. states and political subdivisions
(1,194
)
 
26,913

 
(45
)
 
466

Mortgage-backed securities:
 
 
 
 
 
 
 
Federal agencies
(100
)
 
13,864

 

 

Residential
(17
)
 
1,165

 
(24
)
 
1,125

Commercial
(63
)
 
5,980

 
(40
)
 
567

Total mortgage-backed securities
(180
)
 
21,009

 
(64
)
 
1,692

Corporate debt securities
(96
)
 
2,386

 
(287
)
 
1,849

Collateralized loan and other debt obligations
(563
)
 
27,662

 

 

Other
(70
)
 
3,011

 
(4
)
 
461

Total debt securities
(2,103
)
 
80,981

 
(400
)
 
4,468

Perpetual preferred securities
(14
)
 
199

 

 

Total available-for-sale securities
(2,117
)

81,180


(400
)

4,468

Held-to-maturity securities:
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies

 

 

 

Federal agency mortgage-backed securities

 

 

 

Collateralized loan obligations
(30
)
 
1,376

 

 

Other
(7
)
 
2,178

 

 

Total held-to-maturity securities
(37
)
 
3,554

 

 

Total
$
(2,154
)
 
84,734

 
(400
)
 
4,468

December 31, 2015
 
 

 
 
 
 
Available-for-sale securities:
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
$
(148
)
 
24,795

 

 

Securities of U.S. states and political subdivisions
(464
)
 
15,470

 
(38
)
 
360

Mortgage-backed securities:
 
 
 
 
 
 
 
Federal agencies
(828
)
 
46,217

 

 

Residential
(12
)
 
795

 
(13
)
 
766

Commercial
(59
)
 
6,361

 
(26
)
 
478

Total mortgage-backed securities
(899
)
 
53,373

 
(39
)
 
1,244

Corporate debt securities
(140
)
 
4,167

 
(309
)
 
1,831

Collateralized loan and other debt obligations
(368
)
 
27,058

 

 

Other
(43
)
 
2,915

 
(3
)
 
278

Total debt securities
(2,062
)
 
127,778

 
(389
)
 
3,713

Perpetual preferred securities
(13
)
 
133

 

 

Total available-for-sale securities
(2,075
)
 
127,911

 
(389
)
 
3,713

Held-to-maturity securities:
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
(73
)
 
5,264

 

 

Federal agency mortgage-backed securities
(314
)
 
23,115



 

Collateralized loan obligations
(24
)
 
1,381

 

 

Other
(3
)
 
1,096



 

Total held-to-maturity securities
(414
)
 
30,856

 

 

Total
$
(2,489
)
 
158,767

 
(389
)
 
3,713


74

Note 4: Investment Securities (continued)

Contractual Maturities
Table 4.4 shows the remaining contractual maturities and contractual weighted-average yields (taxable-equivalent basis) of available-for-sale debt securities. The remaining contractual principal maturities for MBS do not consider
 
prepayments. Remaining expected maturities will differ from contractual maturities because borrowers may have the right to prepay obligations before the underlying mortgages mature.
 

Table 4.4: Contractual Maturities
  
  
 
 
Remaining contractual maturity
 
  
Total

 
  

 
Within one year
 
 
After one year
through five years
 
 
After five years
through ten years
 
 
After ten years
 
(in millions)

amount

 
Yield

 
Amount

 
Yield

 
Amount

 
Yield

 
Amount

 
Yield

 
Amount

 
Yield

March 31, 2016
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Available-for-sale debt securities (1): 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
$
33,813

 
1.47
%
 
$
155

 
0.83
%
 
$
30,567

 
1.43
%
 
$
3,091

 
1.87
%
 
$

 
%
Securities of U.S. states and political subdivisions
51,574

 
5.93

 
1,813

 
2.29

 
7,927

 
2.43

 
2,894

 
5.37

 
38,940

 
6.85

Mortgage-backed securities:
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Federal agencies
95,463

 
3.27

 
3

 
6.56

 
335

 
1.60

 
2,055

 
3.66

 
93,070

 
3.26

Residential
8,374

 
4.10

 

 

 
34

 
5.17

 
28

 
6.03

 
8,312

 
4.09

Commercial
12,872

 
4.94

 

 

 
59

 
2.89

 

 

 
12,813

 
4.95

Total mortgage-backed securities
116,709

 
3.51

 
3

 
6.56

 
428

 
2.06

 
2,083

 
3.69

 
114,195

 
3.51

Corporate debt securities
13,800

 
4.78

 
2,697

 
3.45

 
4,837

 
5.16

 
4,982

 
4.96

 
1,284

 
5.45

Collateralized loan and other debt obligations
32,133

 
2.35

 
1

 
0.97

 
773

 
1.11

 
15,131

 
2.31

 
16,228

 
2.45

Other
6,023

 
2.10

 
49

 
2.81

 
1,069

 
2.73

 
1,064

 
2.01

 
3,841

 
1.94

Total available-for-sale debt securities at fair value
$
254,052

 
3.62
%
 
$
4,718

 
2.91
%
 
$
45,601

 
2.03
%
 
$
29,245

 
3.10
%
 
$
174,488

 
4.14
%
December 31, 2015
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Available-for-sale debt securities (1):
 
 
 
 
 
 
 
 
`
 
 
 
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
$
36,250

 
1.49
%
 
$
216

 
0.77
%
 
$
31,602

 
1.44
%
 
$
4,432

 
1.86
%
 
$

 
%
Securities of U.S. states and political subdivisions
49,990

 
5.82

 
1,969

 
2.09

 
7,709

 
2.02

 
3,010

 
5.25

 
37,302

 
6.85

Mortgage-backed securities:
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Federal agencies
104,546

 
3.29

 
3

 
6.55

 
373

 
1.58

 
1,735

 
3.84

 
102,435

 
3.29

Residential
8,558

 
4.17

 

 

 
34

 
5.11

 
34

 
6.03

 
8,490

 
4.16

Commercial
14,088

 
5.06

 

 

 
61

 
2.79

 

 

 
14,027

 
5.07

Total mortgage-backed securities
127,192

 
3.54

 
3

 
6.55

 
468

 
1.99

 
1,769

 
3.88

 
124,952

 
3.55

Corporate debt securities
15,411

 
4.57

 
1,960

 
3.84

 
6,731

 
4.47

 
5,459

 
4.76

 
1,261

 
5.47

Collateralized loan and other debt obligations
30,967

 
2.08

 
2

 
0.33

 
804

 
0.90

 
12,707

 
2.01

 
17,454

 
2.19

Other
5,911

 
2.05

 
68

 
2.47

 
1,228

 
2.57

 
953

 
1.94

 
3,662

 
1.89

Total available-for-sale debt securities at fair value
$
265,721

 
3.55
%
 
$
4,218

 
2.84
%
 
$
48,542

 
1.98
%
 
$
28,330

 
2.98
%
 
$
184,631

 
4.07
%
(1)
Weighted-average yields displayed by maturity bucket are weighted based on fair value and predominantly represent contractual coupon rates without effect for any related hedging derivatives.


75


Table 4.5 shows the amortized cost and weighted-average yields of held-to-maturity debt securities by contractual maturity.

Table 4.5: Amortized Cost by Contractual Maturity
  
  
 
 
Remaining contractual maturity
 
  
Total

 
  

 
Within one year
 
 
After one year
through five years
 
 
After five years
through ten years
 
 
After ten years
 
(in millions)
amount

 
Yield

 
Amount

 
Yield

 
Amount

 
Yield

 
Amount

 
Yield

 
Amount

 
Yield

March 31, 2016
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Held-to-maturity securities (1): 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Amortized cost:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
$
44,667

 
2.12
%
 
$

 
%
 
$
8,271

 
2.03
%
 
$
36,396

 
2.14
%
 
$

 
%
Securities of U.S. states and political subdivisions
2,183

 
5.97

 

 

 

 

 
119

 
7.53

 
2,064

 
5.88

Federal agency mortgage-backed securities
28,016

 
3.47

 

 

 

 

 

 

 
28,016

 
3.47

Collateralized loan obligations
1,406

 
2.35

 

 

 

 

 

 

 
1,406

 
2.35

Other
3,076

 
1.63

 

 

 
2,428

 
1.69

 
648

 
1.41

 

 

Total held-to-maturity debt securities at amortized cost
$
79,348

 
2.69
%
 
$

 
%
 
$
10,699

 
1.95
%
 
$
37,163

 
2.14
%
 
$
31,486

 
3.58
%
December 31, 2015
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Held-to-maturity securities (1):
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Amortized cost:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
$
44,660

 
2.12
%
 
$

 
%
 
$
1,276

 
1.75
%
 
$
43,384

 
2.13
%
 
$

 
%
Securities of U.S. states and political subdivisions
2,185

 
5.97

 

 

 

 

 
104

 
7.49

 
2,081

 
5.89

Federal agency mortgage-backed securities
28,604

 
3.47

 

 

 

 

 

 

 
28,604

 
3.47

Collateralized loan obligations
1,405

 
2.03

 

 

 

 

 

 

 
1,405

 
2.03

Other
3,343

 
1.68

 

 

 
2,351

 
1.74

 
992

 
1.53

 

 

Total held-to-maturity debt securities at amortized cost
$
80,197

 
2.69
%
 
$

 
%
 
$
3,627

 
1.74
%
 
$
44,480

 
2.13
%
 
$
32,090

 
3.57
%
(1)
Weighted-average yields displayed by maturity bucket are weighted based on amortized cost and predominantly represent contractual coupon rates.

Table 4.6 shows the fair value of held-to-maturity debt securities by contractual maturity.
 


Table 4.6: Fair Value by Contractual Maturity
  
  

 
Remaining contractual maturity
 
  
Total

 
Within one year

 
After one year
through five years

 
After five years
through ten years

 
After ten years

(in millions)
amount

 
Amount

 
Amount

 
Amount

 
Amount

March 31, 2016
 
 
 
 
 
 
 
 
 
Held-to-maturity securities:
 
 
 
 
 
 
 
 
 
Fair value:
 
 
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
$
46,653

 

 
8,665

 
37,988

 

Securities of U.S. states and political subdivisions
2,283

 

 

 
123

 
2,160

Federal agency mortgage-backed securities
28,344

 

 

 

 
28,344

Collateralized loan obligations
1,376

 

 

 

 
1,376

Other
3,069

 

 
2,425

 
644

 

Total held-to-maturity debt securities at fair value
$
81,725

 

 
11,090

 
38,755

 
31,880

December 31, 2015
  
 
 
 
 
 
 
 
 
Held-to-maturity securities:
  
 
 
 
 
 
 
 
 
Fair value:
  
 
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
$
45,167

 

 
1,298

 
43,869

 

Securities of U.S. states and political subdivisions
2,250

 

 

 
105

 
2,145

Federal agency mortgage-backed securities
28,421

 

 

 

 
28,421

Collateralized loan obligations
1,381

 

 

 

 
1,381

Other
3,348

 

 
2,353

 
995

 

Total held-to-maturity debt securities at fair value
$
80,567

 

 
3,651

 
44,969

 
31,947


76

Note 4: Investment Securities (continued)

Realized Gains and Losses
Table 4.7 shows the gross realized gains and losses on sales and OTTI write-downs related to the available-for-sale securities
 
portfolio, which includes marketable equity securities, as well as net realized gains and losses on nonmarketable equity investments (see Note 6 (Other Assets)).

Table 4.7: Realized Gains and Losses
  
Quarter ended March 31,
 
(in millions)
2016

 
2015

Gross realized gains
$
385

 
348

Gross realized losses
(13
)
 
(20
)
OTTI write-downs
(69
)
 
(31
)
Net realized gains from available-for-sale securities
303

 
297

Net realized gains from nonmarketable equity investments
185

 
351

Net realized gains from debt securities and equity investments
$
488

 
648


Other-Than-Temporary Impairment
Table 4.8 shows the detail of total OTTI write-downs included in earnings for available-for-sale debt securities, marketable equity
 
securities and nonmarketable equity investments. There were no OTTI write-downs on held-to-maturity securities during first quarter 2016 and 2015.

Table 4.8: OTTI Write-downs
 
Quarter ended March 31,
 
(in millions)
2016

 
2015

OTTI write-downs included in earnings
 
 
 
Debt securities:
  
 
  
Securities of U.S. states and political subdivisions
$
4

 
16

Mortgage-backed securities:
  

 
  

Residential
12

 
15

Commercial
1

 

Corporate debt securities
45

 

Other debt securities
3

 

Total debt securities
65

 
31

Equity securities:
  

 
  

Marketable equity securities:
  

 
 
Other marketable equity securities
4

 

Total marketable equity securities
4

 

Total investment securities (1)
69

 
31

Nonmarketable equity investments (1)
129

 
42

Total OTTI write-downs included in earnings (1)
$
198

 
73

(1) The quarter ended March 31, 2016, includes $124 million in OTTI write-downs of oil and gas investments, of which $46 million related to investment securities and $78 million related to nonmarketable equity investments.


77


Other-Than-Temporarily Impaired Debt Securities
Table 4.9 shows the detail of OTTI write-downs on available-for-sale debt securities included in earnings and the related changes in OCI for the same securities.

Table 4.9: OTTI Write-downs Included in Earnings
  
Quarter ended March 31,
 
(in millions)
2016

 
2015

OTTI on debt securities
  

 
  

Recorded as part of gross realized losses:
  

 
  

Credit-related OTTI
$
61

 
20

Intent-to-sell OTTI
4

 
11

Total recorded as part of gross realized losses
65

 
31

Changes to OCI for losses (reversal of losses) in non-credit-related OTTI (1):
  

 
 
Securities of U.S. states and political subdivisions

 
(1
)
Residential mortgage-backed securities
10

 
(21
)
Commercial mortgage-backed securities
3

 
(15
)
Corporate debt securities
(4
)
 

Other debt securities
2

 

Total changes to OCI for non-credit-related OTTI
11

 
(37
)
Total OTTI losses (reversal of losses) recorded on debt securities
$
76

 
(6
)
(1)
Represents amounts recorded to OCI for impairment, due to factors other than credit, on debt securities that have also had credit-related OTTI write-downs during the period. Increases represent initial or subsequent non-credit-related OTTI on debt securities. Decreases represent partial to full reversal of impairment due to recoveries in the fair value of securities due to non-credit factors.
 
Table 4.10 presents a rollforward of the OTTI credit loss that has been recognized in earnings as a write-down of available-for-sale debt securities we still own (referred to as "credit-impaired" debt securities) and do not intend to sell. Recognized credit loss
 
represents the difference between the present value of expected future cash flows discounted using the security’s current effective interest rate and the amortized cost basis of the security prior to considering credit loss.

Table 4.10: Rollforward of OTTI Credit Loss
 
Quarter ended March 31,
 
(in millions)
2016

 
2015

Credit loss recognized, beginning of period
$
1,092

 
1,025

Additions:
  
 
  
For securities with initial credit impairments
38

 

For securities with previous credit impairments
23

 
20

Total additions
61

 
20

Reductions:
  
 
  
For securities sold, matured, or intended/required to be sold
(6
)
 
(14
)
For recoveries of previous credit impairments (1)
(2
)
 
(2
)
Total reductions
(8
)
 
(16
)
Credit loss recognized, end of period
$
1,145

 
1,029

(1)
Recoveries of previous credit impairments result from increases in expected cash flows subsequent to credit loss recognition. Such recoveries are reflected prospectively as interest yield adjustments using the effective interest method.


78

Note 5: Loans and Allowance for Credit Losses (continued)

Note 5:  Loans and Allowance for Credit Losses 
Table 5.1 presents total loans outstanding by portfolio segment and class of financing receivable. Outstanding balances include a total net reduction of $5.3 billion and $3.8 billion at March 31, 2016, and December 31, 2015, respectively, for unearned income,
 
net deferred loan fees, and unamortized discounts and premiums. Outstanding balances at March 31, 2016 also reflect the acquisition of various loans and capital leases from GE Capital as described in Note 2 (Business Combinations).

Table 5.1: Loans Outstanding
(in millions)
Mar 31,
2016

 
Dec 31,
2015

Commercial:
  

 
  

Commercial and industrial
$
321,547

 
299,892

Real estate mortgage
124,711

 
122,160

Real estate construction
22,944

 
22,164

Lease financing
19,003

 
12,367

Total commercial
488,205

 
456,583

Consumer:
 
 
 
Real estate 1-4 family first mortgage
274,734

 
273,869

Real estate 1-4 family junior lien mortgage
51,324

 
53,004

Credit card
33,139

 
34,039

Automobile
60,658

 
59,966

Other revolving credit and installment
39,198

 
39,098

Total consumer
459,053

 
459,976

Total loans
$
947,258

 
916,559


Our foreign loans are reported by respective class of financing receivable in the table above. Substantially all of our foreign loan portfolio is commercial loans. Loans are classified as foreign primarily based on whether the borrower’s primary
 
address is outside of the United States. Table 5.2 presents total commercial foreign loans outstanding by class of financing receivable.

Table 5.2: Commercial Foreign Loans Outstanding
(in millions)
Mar 31,
2016

 
Dec 31,
2015

Commercial foreign loans:
 
 
 
Commercial and industrial
$
51,884

 
49,049

Real estate mortgage
8,367

 
8,350

Real estate construction
311

 
444

Lease financing
983

 
274

Total commercial foreign loans
$
61,545

 
58,117



79


Loan Purchases, Sales, and Transfers
Table 5.3 summarizes the proceeds paid or received for purchases and sales of loans and transfers from loans held for investment to mortgages/loans held for sale at lower of cost or fair value. This loan activity primarily includes loans purchased and sales of whole loan or participating interests, whereby we receive or
 
transfer a portion of a loan after origination. The table excludes PCI loans and loans for which we have elected the fair value option, including loans originated for sale because their loan activity normally does not impact the allowance for credit losses.
 

Table 5.3: Loan Purchases, Sales, and Transfers
 
 
 
 
 
 
 
Quarter ended March 31,
 
  
2016
 
 
2015
 
(in millions)
Commercial

 
Consumer

 
Total

 
Commercial

 
Consumer

 
Total

Purchases (1)(2)
$
24,646

 

 
24,646

 
1,091

 

 
1,091

Sales (1)
(223
)
 
(272
)
 
(495
)
 
(206
)
 
(29
)
 
(235
)
Transfers to MHFS/LHFS (1)
(32
)
 
(3
)
 
(35
)
 
(7
)
 
(2
)
 
(9
)
(1)
All categories exclude activity in government insured/guaranteed real estate 1-4 family first mortgage loans. As servicer, we are able to buy delinquent insured/guaranteed loans out of the Government National Mortgage Association (GNMA) pools, and manage and/or resell them in accordance with applicable requirements. These loans are predominantly insured by the Federal Housing Administration (FHA) or guaranteed by the Department of Veterans Affairs (VA). Accordingly, these loans have limited impact on the allowance for loan losses.
(2)
Purchases in first quarter 2016 include loans and capital leases from the GE Capital acquisitions as described in Note 2 (Business Combinations).

Commitments to Lend
A commitment to lend is a legally binding agreement to lend funds to a customer, usually at a stated interest rate, if funded, and for specific purposes and time periods. We generally require a fee to extend such commitments. Certain commitments are subject to loan agreements with covenants regarding the financial performance of the customer or borrowing base formulas on an ongoing basis that must be met before we are required to fund the commitment. We may reduce or cancel consumer commitments, including home equity lines and credit card lines, in accordance with the contracts and applicable law.
We may, as a representative for other lenders, advance funds or provide for the issuance of letters of credit under syndicated loan or letter of credit agreements. Any advances are generally repaid in less than a week and would normally require default of both the customer and another lender to expose us to loss. These temporary advance arrangements totaled approximately $77 billion at March 31, 2016 and $75 billion at December 31, 2015.
We issue commercial letters of credit to assist customers in purchasing goods or services, typically for international trade. At March 31, 2016, and December 31, 2015, we had $1.2 billion and $1.1 billion, respectively, of outstanding issued commercial letters of credit. We also originate multipurpose lending commitments under which borrowers have the option to draw on the facility for different purposes in one of several forms, including a standby letter of credit. See Note 10 (Guarantees, Pledged Assets and Collateral) for additional information on standby letters of credit. 
When we make commitments, we are exposed to credit risk. The maximum credit risk for these commitments will generally be lower than the contractual amount because a significant portion of these commitments are expected to expire without being used by the customer. In addition, we manage the potential risk in commitments to lend by limiting the total amount of commitments, both by individual customer and in total, by monitoring the size and maturity structure of these commitments and by applying the same credit standards for these commitments as for all of our credit activities.
For loans and commitments to lend, we generally require collateral or a guarantee. We may require various types of collateral, including commercial and consumer real estate, autos, other short-term liquid assets such as accounts receivable or inventory and long-lived assets, such as equipment and other business assets. Collateral requirements for each loan or
 
commitment may vary based on the loan product and our assessment of a customer’s credit risk according to the specific credit underwriting, including credit terms and structure.
The contractual amount of our unfunded credit commitments, including unissued standby and commercial letters of credit, is summarized by portfolio segment and class of financing receivable in Table 5.4. The table excludes the standby and commercial letters of credit and temporary advance arrangements described above.
Table 5.4: Unfunded Credit Commitments
(in millions)
Mar 31,
2016

 
Dec 31,
2015

Commercial:
  

 
  

Commercial and industrial
$
298,498

 
296,710

Real estate mortgage
7,472

 
7,378

Real estate construction
18,563

 
18,047

Total commercial
324,533

 
322,135

Consumer:
 
 
 
Real estate 1-4 family first mortgage
38,264

 
34,621

Real estate 1-4 family
junior lien mortgage
43,264

 
43,309

Credit card
101,973

 
98,904

Other revolving credit and installment
27,604

 
27,899

Total consumer
211,105

 
204,733

Total unfunded
credit commitments
$
535,638

 
526,868



80

Note 5: Loans and Allowance for Credit Losses (continued)

Allowance for Credit Losses
Table 5.5 presents the allowance for credit losses, which consists of the allowance for loan losses and the allowance for unfunded credit commitments.

Table 5.5: Allowance for Credit Losses
 
Quarter ended March 31,
 
(in millions)
2016

 
2015

Balance, beginning of period
$
12,512

 
13,169

Provision for credit losses
1,086

 
608

Interest income on certain impaired loans (1)
(48
)
 
(52
)
Loan charge-offs:
 
 
 
Commercial:
 
 
 
Commercial and industrial
(349
)
 
(133
)
Real estate mortgage
(3
)
 
(23
)
Real estate construction

 
(1
)
Lease financing
(4
)
 
(3
)
Total commercial
(356
)
 
(160
)
Consumer:
 
 
 
Real estate 1-4 family first mortgage
(137
)
 
(130
)
Real estate 1-4 family junior lien mortgage
(133
)
 
(179
)
Credit card
(314
)
 
(278
)
Automobile
(211
)
 
(195
)
Other revolving credit and installment
(175
)
 
(154
)
Total consumer
(970
)
 
(936
)
Total loan charge-offs
(1,326
)
 
(1,096
)
Loan recoveries:
 
 
 
Commercial:
 
 
 
Commercial and industrial
76

 
69

Real estate mortgage
32

 
34

Real estate construction
8

 
10

Lease financing
3

 
3

Total commercial
119

 
116

Consumer:
 
 
 
Real estate 1-4 family first mortgage
89

 
47

Real estate 1-4 family junior lien mortgage
59

 
56

Credit card
52

 
39

Automobile
84

 
94

Other revolving credit and installment
37

 
36

Total consumer
321

 
272

Total loan recoveries
440

 
388

Net loan charge-offs
(886
)
 
(708
)
Other
4

 
(4
)
Balance, end of period
$
12,668

 
13,013

Components:
 
 
 
Allowance for loan losses
$
11,621

 
12,176

Allowance for unfunded credit commitments
1,047

 
837

Allowance for credit losses
$
12,668

 
13,013

Net loan charge-offs (annualized) as a percentage of average total loans
0.38
%
 
0.33

Allowance for loan losses as a percentage of total loans
1.23

 
1.41

Allowance for credit losses as a percentage of total loans
1.34

 
1.51

(1)
Certain impaired loans with an allowance calculated by discounting expected cash flows using the loan’s effective interest rate over the remaining life of the loan recognize reductions in the allowance as interest income.



81


Table 5.6 summarizes the activity in the allowance for credit losses by our commercial and consumer portfolio segments.

Table 5.6: Allowance Activity by Portfolio Segment
  
  

 
  

 
2016

 
  

 
  

 
2015

(in millions)
Commercial

 
Consumer

 
Total

 
Commercial

 
Consumer

 
Total

Quarter ended March 31,
  
 
  
 
  
 
  
 
  
 
  
Balance, beginning of period
$
6,872

 
5,640

 
12,512

 
6,377

 
6,792

 
13,169

Provision for credit losses
714

 
372

 
1,086

 
9

 
599

 
608

Interest income on certain impaired loans
(5
)
 
(43
)
 
(48
)
 
(5
)
 
(47
)
 
(52
)
 
 
 
 
 
 
 
 
 
 
 
 
Loan charge-offs
(356
)
 
(970
)
 
(1,326
)
 
(160
)
 
(936
)
 
(1,096
)
Loan recoveries
119

 
321

 
440

 
116

 
272

 
388

Net loan charge-offs
(237
)
 
(649
)
 
(886
)
 
(44
)
 
(664
)
 
(708
)
Other
4

 

 
4

 
(4
)
 

 
(4
)
Balance, end of period
$
7,348

 
5,320

 
12,668

 
6,333

 
6,680

 
13,013


Table 5.7 disaggregates our allowance for credit losses and recorded investment in loans by impairment methodology.

Table 5.7: Allowance by Impairment Methodology
 
Allowance for credit losses
 
 
Recorded investment in loans
 
(in millions)
Commercial

 
Consumer

 
Total

 
Commercial

 
Consumer

 
Total

March 31, 2016
 
 
 
 
 
 
 
 
 
 
 
Collectively evaluated (1)
$
6,155

 
3,328

 
9,483

 
480,745

 
421,036

 
901,781

Individually evaluated (2)
1,191

 
1,992

 
3,183

 
5,736

 
19,423

 
25,159

PCI (3)
2

 

 
2

 
1,724

 
18,594

 
20,318

Total
$
7,348

 
5,320

 
12,668

 
488,205

 
459,053

 
947,258

December 31, 2015
 
Collectively evaluated (1)
$
5,999

 
3,436

 
9,435

 
452,063

 
420,705

 
872,768

Individually evaluated (2)
872

 
2,204

 
3,076

 
3,808

 
20,012

 
23,820

PCI (3)
1

 

 
1

 
712

 
19,259

 
19,971

Total
$
6,872

 
5,640

 
12,512

 
456,583

 
459,976

 
916,559

(1)
Represents loans collectively evaluated for impairment in accordance with Accounting Standards Codification (ASC) 450-20, Loss Contingencies (formerly FAS 5), and pursuant to amendments by ASU 2010-20 regarding allowance for non-impaired loans.
(2)
Represents loans individually evaluated for impairment in accordance with ASC 310-10, Receivables (formerly FAS 114), and pursuant to amendments by ASU 2010-20 regarding allowance for impaired loans.
(3)
Represents the allowance and related loan carrying value determined in accordance with ASC 310-30, Receivables – Loans and Debt Securities Acquired with Deteriorated Credit Quality (formerly SOP 03-3) and pursuant to amendments by ASU 2010-20 regarding allowance for PCI loans.

Credit Quality
We monitor credit quality by evaluating various attributes and utilize such information in our evaluation of the appropriateness of the allowance for credit losses. The following sections provide the credit quality indicators we most closely monitor. The credit quality indicators are generally based on information as of our financial statement date, with the exception of updated Fair Isaac Corporation (FICO) scores and updated loan-to-value (LTV)/combined LTV (CLTV).We obtain FICO scores at loan origination and the scores are generally updated at least quarterly, except in limited circumstances, including compliance with the Fair Credit Reporting Act (FCRA). Generally, the LTV and CLTV indicators are updated in the second month of each quarter, with updates no older than December 31, 2015. See the “Purchased Credit-Impaired Loans” section in this Note for credit quality information on our PCI portfolio.
 


82

Note 5: Loans and Allowance for Credit Losses (continued)

COMMERCIAL CREDIT QUALITY INDICATORS  In addition to monitoring commercial loan concentration risk, we manage a consistent process for assessing commercial loan credit quality. Generally, commercial loans are subject to individual risk assessment using our internal borrower and collateral quality ratings. Our ratings are aligned to Pass and Criticized categories. The Criticized category includes Special Mention, Substandard, and Doubtful categories which are defined by bank regulatory agencies.
 
Table 5.8 provides a breakdown of outstanding commercial loans by risk category. Of the $6.7 billion in criticized commercial real estate (CRE) loans at March 31, 2016, $1.0 billion has been placed on nonaccrual status and written down to net realizable collateral value. CRE loans have a high level of monitoring in place to manage these assets and mitigate loss exposure.
 


Table 5.8: Commercial Loans by Risk Category
(in millions)
Commercial
and
industrial

 
Real
estate
mortgage

 
Real
estate
construction

 
Lease
financing

 
Total

March 31, 2016
 
 
 
 
 
 
 
 
 
By risk category:
 
 
 
 
 
 
 
 
 
Pass
$
290,451

 
118,117

 
22,313

 
17,280

 
448,161

Criticized
29,943

 
6,111

 
543

 
1,723

 
38,320

Total commercial loans (excluding PCI)
320,394

 
124,228

 
22,856

 
19,003

 
486,481

Total commercial PCI loans (carrying value)
1,153

 
483

 
88

 

 
1,724

Total commercial loans
$
321,547

 
124,711

 
22,944

 
19,003

 
488,205

December 31, 2015
 
 
 
 
 
 
 
 
 
By risk category:
 
 
 
 
 
 
 
 
 
Pass
$
281,356

 
115,025

 
21,546

 
11,772

 
429,699

Criticized
18,458

 
6,593

 
526

 
595

 
26,172

Total commercial loans (excluding PCI)
299,814

 
121,618

 
22,072

 
12,367

 
455,871

Total commercial PCI loans (carrying value)
78

 
542

 
92

 

 
712

Total commercial loans
$
299,892

 
122,160

 
22,164

 
12,367

 
456,583


Table 5.9 provides past due information for commercial loans, which we monitor as part of our credit risk management practices.
 
 

Table 5.9: Commercial Loans by Delinquency Status
(in millions)
Commercial
and
industrial

 
Real
estate
mortgage

 
Real
estate
construction

 
Lease
financing

 
Total

March 31, 2016
 
 
 
 
 
 
 
 
 
By delinquency status:
 
 
 
 
 
 
 
 
 
Current-29 DPD and still accruing
$
316,922

 
123,172

 
22,749

 
18,773

 
481,616

30-89 DPD and still accruing
537

 
152

 
42

 
131

 
862

90+ DPD and still accruing
24

 
8

 
2

 

 
34

Nonaccrual loans
2,911

 
896

 
63

 
99

 
3,969

Total commercial loans (excluding PCI)
320,394

 
124,228

 
22,856

 
19,003

 
486,481

Total commercial PCI loans (carrying value)
1,153

 
483

 
88

 

 
1,724

Total commercial loans
$
321,547

 
124,711

 
22,944

 
19,003

 
488,205

December 31, 2015
 
 
 
 
 
 
 
 
 
By delinquency status:
 
 
 
 
 
 
 
 
 
Current-29 DPD and still accruing
$
297,847

 
120,415

 
21,920

 
12,313

 
452,495

30-89 DPD and still accruing
507

 
221

 
82

 
28

 
838

90+ DPD and still accruing
97

 
13

 
4

 

 
114

Nonaccrual loans
1,363

 
969

 
66

 
26

 
2,424

Total commercial loans (excluding PCI)
299,814

 
121,618

 
22,072

 
12,367

 
455,871

Total commercial PCI loans (carrying value)
78

 
542

 
92

 

 
712

Total commercial loans
$
299,892

 
122,160

 
22,164

 
12,367

 
456,583



83


CONSUMER CREDIT QUALITY INDICATORS  We have various classes of consumer loans that present unique risks. Loan delinquency, FICO credit scores and LTV for loan types are common credit quality indicators that we monitor and utilize in our evaluation of the appropriateness of the allowance for credit losses for the consumer portfolio segment.
 
Many of our loss estimation techniques used for the allowance for credit losses rely on delinquency-based models; therefore, delinquency is an important indicator of credit quality and the establishment of our allowance for credit losses. Table 5.10 provides the outstanding balances of our consumer portfolio by delinquency status.

Table 5.10: Consumer Loans by Delinquency Status
(in millions)
Real estate
1-4 family
first
mortgage

 
Real estate
1-4 family
junior lien
mortgage

 
Credit
card

 
Automobile

 
Other
revolving
credit and
installment

 
Total

March 31, 2016
 
 
 
 
 
 
 
 
 
 
 
By delinquency status:
 
 
 
 
 
 
 
 
 
 
 
Current-29 DPD
$
228,403

 
50,201

 
32,381

 
59,550

 
38,818

 
409,353

30-59 DPD
1,797

 
306

 
211

 
870

 
158

 
3,342

60-89 DPD
743

 
157

 
158

 
175

 
93

 
1,326

90-119 DPD
317

 
96

 
137

 
59

 
87

 
696

120-179 DPD
373

 
125

 
251

 
3

 
24

 
776

180+ DPD
2,994

 
379

 
1

 
1

 
18

 
3,393

Government insured/guaranteed loans (1)
21,573

 

 

 

 

 
21,573

Total consumer loans (excluding PCI)
256,200

 
51,264

 
33,139

 
60,658

 
39,198

 
440,459

Total consumer PCI loans (carrying value)
18,534

 
60

 

 

 

 
18,594

Total consumer loans
$
274,734

 
51,324

 
33,139

 
60,658

 
39,198

 
459,053

December 31, 2015
 
 
 
 
 
 
 
 
 
 
 
By delinquency status:
 
 
 
 
 
 
 
 
 
 
 
Current-29 DPD
$
225,195

 
51,778

 
33,208

 
58,503

 
38,690

 
407,374

30-59 DPD
2,072

 
325

 
257

 
1,121

 
175

 
3,950

60-89 DPD
821

 
184

 
177

 
253

 
107

 
1,542

90-119 DPD
402

 
110

 
150

 
84

 
86

 
832

120-179 DPD
460

 
145

 
246

 
4

 
21

 
876

180+ DPD
3,376

 
393

 
1

 
1

 
19

 
3,790

Government insured/guaranteed loans (1)
22,353

 

 

 

 

 
22,353

Total consumer loans (excluding PCI)
254,679

 
52,935

 
34,039

 
59,966

 
39,098

 
440,717

Total consumer PCI loans (carrying value)
19,190

 
69

 

 

 

 
19,259

Total consumer loans
$
273,869

 
53,004

 
34,039

 
59,966

 
39,098

 
459,976

(1)
Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA. Loans insured/guaranteed by the FHA/VA and 90+ DPD totaled $11.4 billion at March 31, 2016, compared with $12.4 billion at December 31, 2015.

Of the $4.9 billion of consumer loans not government insured/guaranteed that are 90 days or more past due at March 31, 2016, $769 million was accruing, compared with $5.5 billion past due and $867 million accruing at December 31, 2015.
Real estate 1-4 family first mortgage loans 180 days or more past due totaled $3.0 billion, or 1.2% of total first mortgages (excluding PCI), at March 31, 2016, compared with $3.4 billion, or 1.3%, at December 31, 2015.
 
Table 5.11 provides a breakdown of our consumer portfolio by FICO. The majority of our portfolio is underwritten with a FICO score of 680 and above. FICO is not available for certain loan types and may not be obtained if we deem it unnecessary due to strong collateral and other borrower attributes, primarily security-based loans of $7.2 billion at March 31, 2016, and $7.0 billion at December 31, 2015.


84

Note 5: Loans and Allowance for Credit Losses (continued)

Table 5.11: Consumer Loans by FICO
(in millions)
Real estate
1-4 family
first
mortgage

 
Real estate
1-4 family
junior lien
mortgage

 
Credit
card

 
Automobile

 
Other
revolving
credit and
installment

 
Total

March 31, 2016
 
 
 
 
 
 
 
 
 
 
 
By FICO:
 
 
 
 
 
 
 
 
 
 
 
< 600
$
8,894

 
3,192

 
2,986

 
9,680

 
985

 
25,737

600-639
6,681

 
2,300

 
2,834

 
6,788

 
1,093

 
19,696

640-679
12,777

 
4,357

 
5,252

 
10,156

 
2,373

 
34,915

680-719
24,324

 
7,460

 
6,782

 
11,025

 
4,387

 
53,978

720-759
37,513

 
10,568

 
6,923

 
8,336

 
5,977

 
69,317

760-799
94,066

 
15,813

 
5,494

 
7,703

 
8,259

 
131,335

800+
46,099

 
6,790

 
2,728

 
6,546

 
6,588

 
68,751

No FICO available
4,273

 
784

 
140

 
424

 
2,367

 
7,988

FICO not required

 

 

 

 
7,169

 
7,169

Government insured/guaranteed loans (1)
21,573

 

 

 

 

 
21,573

Total consumer loans (excluding PCI)
256,200

 
51,264

 
33,139

 
60,658

 
39,198

 
440,459

Total consumer PCI loans (carrying value)
18,534

 
60

 

 

 

 
18,594

Total consumer loans
$
274,734

 
51,324

 
33,139

 
60,658

 
39,198

 
459,053

December 31, 2015
 
 
 
 
 
 
 
 
 
 


By FICO:
 
 
 
 
 
 
 
 
 
 

< 600
$
8,716

 
3,025

 
2,927

 
9,260

 
965

 
24,893

600-639
6,961

 
2,367

 
2,875

 
6,619

 
1,086

 
19,908

640-679
13,006

 
4,613

 
5,354

 
10,014

 
2,416

 
35,403

680-719
24,460

 
7,863

 
6,857

 
10,947

 
4,388

 
54,515

720-759
38,309

 
10,966

 
7,017

 
8,279

 
6,010

 
70,581

760-799
92,975

 
16,369

 
5,693

 
7,761

 
8,351

 
131,149

800+
44,452

 
6,895

 
3,090

 
6,654

 
6,510

 
67,601

No FICO available
3,447

 
837

 
226

 
432

 
2,395

 
7,337

FICO not required

 

 

 

 
6,977

 
6,977

Government insured/guaranteed loans (1)
22,353

 

 

 

 

 
22,353

Total consumer loans (excluding PCI)
254,679

 
52,935

 
34,039

 
59,966

 
39,098

 
440,717

Total consumer PCI loans (carrying value)
19,190

 
69

 

 

 

 
19,259

Total consumer loans
$
273,869

 
53,004

 
34,039

 
59,966

 
39,098

 
459,976

(1)
Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA.
 
LTV refers to the ratio comparing the loan’s unpaid principal balance to the property’s collateral value. CLTV refers to the combination of first mortgage and junior lien mortgage (including unused line amounts for credit line products) ratios. LTVs and CLTVs are updated quarterly using a cascade approach which first uses values provided by automated valuation models (AVMs) for the property. If an AVM is not available, then the value is estimated using the original appraised value adjusted by the change in Home Price Index (HPI) for the property location. If an HPI is not available, the original appraised value is used. The HPI value is normally the only method considered for high value properties, generally with an original value of $1 million or more, as the AVM values have proven less accurate for these properties.
 
Table 5.12 shows the most updated LTV and CLTV distribution of the real estate 1-4 family first and junior lien mortgage loan portfolios. We consider the trends in residential real estate markets as we monitor credit risk and establish our allowance for credit losses. In the event of a default, any loss should be limited to the portion of the loan amount in excess of the net realizable value of the underlying real estate collateral value. Certain loans do not have an LTV or CLTV primarily due to industry data availability and portfolios acquired from or serviced by other institutions.


85


Table 5.12: Consumer Loans by LTV/CLTV
  
March 31, 2016
 
 
December 31, 2015
 
(in millions)
Real estate
1-4 family
first
mortgage
by LTV

 
Real estate
1-4 family
junior lien
mortgage
by CLTV

 
Total

 
Real estate
1-4 family
first
mortgage
by LTV

 
Real estate
1-4 family
junior lien
mortgage
by CLTV

 
Total

By LTV/CLTV:
  

 
  

 
  

 
  

 
  

 
  

0-60%
$
109,138

 
15,390

 
124,528

 
109,558

 
15,805

 
125,363

60.01-80%
93,772

 
16,155

 
109,927

 
92,005

 
16,579

 
108,584

80.01-100%
24,089

 
10,979

 
35,068

 
22,765

 
11,385

 
34,150

100.01-120% (1)
4,225

 
5,331

 
9,556

 
4,480

 
5,545

 
10,025

> 120% (1)
1,950

 
2,871

 
4,821

 
2,065

 
3,051

 
5,116

No LTV/CLTV available
1,453

 
538

 
1,991

 
1,453

 
570

 
2,023

Government insured/guaranteed loans (2)
21,573

 

 
21,573

 
22,353

 

 
22,353

Total consumer loans (excluding PCI)
256,200

 
51,264

 
307,464

 
254,679

 
52,935

 
307,614

Total consumer PCI loans (carrying value)
18,534

 
60

 
18,594

 
19,190

 
69

 
19,259

Total consumer loans
$
274,734

 
51,324

 
326,058

 
273,869

 
53,004

 
326,873

(1)
Reflects total loan balances with LTV/CLTV amounts in excess of 100%. In the event of default, the loss content would generally be limited to only the amount in excess of 100% LTV/CLTV.
(2)
Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA.
 
NONACCRUAL LOANS  Table 5.13 provides loans on nonaccrual status. PCI loans are excluded from this table because they continue to earn interest from accretable yield, independent of performance in accordance with their contractual terms.
Table 5.13: Nonaccrual Loans
(in millions)
Mar 31,
2016

 
Dec 31,
2015

Commercial:
  
 
  
Commercial and industrial
$
2,911

 
1,363

Real estate mortgage
896

 
969

Real estate construction
63

 
66

Lease financing
99

 
26

Total commercial
3,969

 
2,424

Consumer:
 
 
 
Real estate 1-4 family first mortgage (1)
6,683

 
7,293

Real estate 1-4 family junior lien mortgage
1,421

 
1,495

Automobile
114

 
121

Other revolving credit and installment
47

 
49

Total consumer
8,265

 
8,958

Total nonaccrual loans
(excluding PCI)
$
12,234

 
11,382

(1)
Includes MHFS of $157 million and $177 million at March 31, 2016, and December 31, 2015, respectively.
 
LOANS IN PROCESS OF FORECLOSURE  Our recorded investment in consumer mortgage loans collateralized by residential real estate property that are in process of foreclosure was $10.3 billion and $11.0 billion at March 31, 2016 and December 31, 2015, respectively, which included $5.7 billion and $6.2 billion, respectively, of loans that are government insured/guaranteed. We commence the foreclosure process on consumer real estate loans when a borrower becomes 120 days delinquent in accordance with Consumer Finance Protection Bureau Guidelines. Foreclosure procedures and timelines vary depending on whether the property address resides in a judicial or non-judicial state. Judicial states require the foreclosure to be processed through the state’s courts while non-judicial states are processed without court intervention. Foreclosure timelines vary according to state law.



86

Note 5: Loans and Allowance for Credit Losses (continued)

LOANS 90 DAYS OR MORE PAST DUE AND STILL ACCRUING  Certain loans 90 days or more past due as to interest or principal are still accruing, because they are (1) well-secured and in the process of collection or (2) real estate 1-4 family mortgage loans or consumer loans exempt under regulatory rules from being classified as nonaccrual until later delinquency, usually 120 days past due. PCI loans of $2.7 billion at March 31, 2016, and $2.9 billion at December 31, 2015, are not included in these past due and still accruing loans even though they are 90 days or more contractually past due. These PCI loans are considered to be accruing because they continue to earn interest from accretable yield, independent of performance in accordance with their contractual terms.
Table 5.14 shows non-PCI loans 90 days or more past due and still accruing by class for loans not government insured/guaranteed.
Table 5.14: Loans 90 Days or More Past Due and Still Accruing
(in millions)
Mar 31, 2016

 
Dec 31, 2015

Loans 90 days or more past due and still accruing:
 
 
 
Total (excluding PCI):
$
13,060

 
14,380

Less: FHA insured/guaranteed by the VA (1)(2)
12,233

 
13,373

Less: Student loans guaranteed under the FFELP (3)
24

 
26

Total, not government insured/guaranteed
$
803

 
981

By segment and class, not government insured/guaranteed:
 
 
 
Commercial:
 
 
 
Commercial and industrial
$
24

 
97

Real estate mortgage
8

 
13

Real estate construction
2

 
4

Total commercial
34

 
114

Consumer:
 
 
 
Real estate 1-4 family first mortgage (2)
167

 
224

Real estate 1-4 family junior lien mortgage (2)
55

 
65

Credit card
389

 
397

Automobile
55

 
79

Other revolving credit and installment
103

 
102

Total consumer
769

 
867

Total, not government insured/guaranteed
$
803

 
981

(1)
Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA.
(2)
Includes mortgage loans held for sale 90 days or more past due and still accruing.
(3)
Represents loans whose repayments are predominantly guaranteed by agencies on behalf of the U.S. Department of Education under the FFELP.


87


IMPAIRED LOANS Table 5.15 summarizes key information for impaired loans. Our impaired loans predominantly include loans on nonaccrual status in the commercial portfolio segment and loans modified in a TDR, whether on accrual or nonaccrual status. These impaired loans generally have estimated losses which are included in the allowance for credit losses. We have impaired loans with no allowance for credit losses when loss content has been previously recognized through charge-offs and we do not anticipate additional charge-offs or losses, or certain
 
loans are currently performing in accordance with their terms and for which no loss has been estimated. Impaired loans exclude PCI loans. Table 5.15 includes trial modifications that totaled $380 million at March 31, 2016, and $402 million at December 31, 2015.
For additional information on our impaired loans and allowance for credit losses, see Note 1 (Summary of Significant Accounting Policies) in our 2015 Form 10-K.

Table 5.15: Impaired Loans Summary
 
 
 
Recorded investment
 
 
 
(in millions)
Unpaid
principal
balance (1)

 
Impaired
loans

 
Impaired loans
with related
allowance for
credit losses

 
Related
allowance for
credit losses

March 31, 2016
 
 
 
 
 
 
 
Commercial:
 
 
 
 
 
 
 
Commercial and industrial
$
4,421

 
3,778

 
3,598

 
772

Real estate mortgage
2,234

 
1,734

 
1,708

 
371

Real estate construction
256

 
122

 
120

 
24

Lease financing
112

 
102

 
102

 
24

Total commercial
7,023

 
5,736

 
5,528

 
1,191

Consumer:
 
 
 
 
 
 
 
Real estate 1-4 family first mortgage
18,942

 
16,594

 
10,906

 
1,449

Real estate 1-4 family junior lien mortgage
2,622

 
2,354

 
1,784

 
428

Credit card
295

 
295

 
295

 
94

Automobile
165

 
98

 
37

 
6

Other revolving credit and installment
89

 
82

 
74

 
15

Total consumer (2)
22,113

 
19,423

 
13,096

 
1,992

Total impaired loans (excluding PCI)
$
29,136

 
25,159

 
18,624

 
3,183

December 31, 2015
 
 
 
 
 
 
 
Commercial:
 
 
 
 
 
 
 
Commercial and industrial
$
2,746

 
1,835

 
1,648

 
435

Real estate mortgage
2,369

 
1,815

 
1,773

 
405

Real estate construction
262

 
131

 
112

 
23

Lease financing
38

 
27

 
27

 
9

Total commercial
5,415

 
3,808

 
3,560

 
872

Consumer:
 
 
 
 
 
 
 
Real estate 1-4 family first mortgage
19,626

 
17,121

 
11,057

 
1,643

Real estate 1-4 family junior lien mortgage
2,704

 
2,408

 
1,859

 
447

Credit card
299

 
299

 
299

 
94

Automobile
173

 
105

 
41

 
5

Other revolving credit and installment
86

 
79

 
71

 
15

Total consumer (2)
22,888

 
20,012

 
13,327

 
2,204

Total impaired loans (excluding PCI)
$
28,303

 
23,820

 
16,887

 
3,076

(1)
Excludes the unpaid principal balance for loans that have been fully charged off or otherwise have zero recorded investment.
(2)
Periods ended March 31, 2016 and December 31, 2015 each include the recorded investment of $1.8 billion of government insured/guaranteed loans that are predominantly insured by the FHA or guaranteed by the VA and generally do not have an allowance. Impaired loans may also have limited, if any, allowance when the recorded investment of the loan approximates estimated net realizable value as a result of charge-offs prior to a TDR modification.

88

Note 5: Loans and Allowance for Credit Losses (continued)

Commitments to lend additional funds on loans whose terms have been modified in a TDR amounted to $364 million and $363 million at March 31, 2016 and December 31, 2015, respectively.
 
Table 5.16 provides the average recorded investment in impaired loans and the amount of interest income recognized on impaired loans by portfolio segment and class.

Table 5.16: Average Recorded Investment in Impaired Loans
 
Quarter ended March 31,
 
 
2016
 
 
2015
 
(in millions)
Average
recorded
investment

 
Recognized
interest
income

 
Average
recorded
investment

 
Recognized
interest
income

Commercial:
 
 
 
 
 
 
 
Commercial and industrial
$
2,766

 
19

 
1,000

 
20

Real estate mortgage
1,772

 
32

 
2,421

 
43

Real estate construction
130

 
2

 
291

 
4

Lease financing
75

 

 
21

 

Total commercial
4,743

 
53

 
3,733

 
67

Consumer:
 
 
 
 
 
 
 
Real estate 1-4 family first mortgage
16,911

 
221

 
18,486

 
231

Real estate 1-4 family junior lien mortgage
2,382

 
34

 
2,522

 
35

Credit card
297

 
9

 
332

 
10

Automobile
101

 
3

 
126

 
4

Other revolving credit and installment
82

 
1

 
45

 
1

Total consumer
19,773

 
268

 
21,511

 
281

Total impaired loans (excluding PCI)
$
24,516

 
321

 
25,244

 
348

Interest income:
 
 
 
 
 
 
 
Cash basis of accounting
 
 
$
95

 
 
 
108

Other (1)
 
 
226

 
 
 
240

Total interest income
 
 
$
321

 
 
 
348

(1)
Includes interest recognized on accruing TDRs, interest recognized related to certain impaired loans which have an allowance calculated using discounting, and amortization of purchase accounting adjustments related to certain impaired loans.


TROUBLED DEBT RESTRUCTURINGS (TDRs)  When, for economic or legal reasons related to a borrower’s financial difficulties, we grant a concession for other than an insignificant period of time to a borrower that we would not otherwise consider, the related loan is classified as a TDR. We do not consider any loans modified through a loan resolution such as foreclosure or short sale to be a TDR.
We may require some consumer borrowers experiencing financial difficulty to make trial payments generally for a period of three to four months, according to the terms of a planned permanent modification, to determine if they can perform according to those terms. These arrangements represent trial modifications, which we classify and account for as TDRs. While loans are in trial payment programs, their original terms are not considered modified and they continue to advance through delinquency status and accrue interest according to their original terms. The planned modifications for these arrangements predominantly involve interest rate reductions or other interest rate concessions; however, the exact concession type and resulting financial effect are usually not finalized and do not take effect until the loan is permanently modified. The trial period terms are developed in accordance with our proprietary programs or the U.S. Treasury’s Making Home Affordable programs for real estate 1-4 family first lien (i.e. Home Affordable Modification Program – HAMP) and junior lien (i.e. Second Lien Modification Program – 2MP) mortgage loans.
 
At March 31, 2016, the loans in trial modification period were $143 million under HAMP, $32 million under 2MP and $205 million under proprietary programs, compared with $130 million, $32 million and $240 million at December 31, 2015, respectively. Trial modifications with a recorded investment of $129 million at March 31, 2016, and $136 million at December 31, 2015, were accruing loans and $251 million and $266 million, respectively, were nonaccruing loans. Our experience is that substantially all of the mortgages that enter a trial payment period program are successful in completing the program requirements and are then permanently modified at the end of the trial period. Our allowance process considers the impact of those modifications that are probable to occur.
Table 5.17 summarizes our TDR modifications for the periods presented by primary modification type and includes the financial effects of these modifications. For those loans that modify more than once, the table reflects each modification that occurred during the period. Loans that both modify and pay off within the period, as well as changes in recorded investment during the period for loans modified in prior periods, are not included in the table.
 
 
 
 
 
 
 
 
 
 
 
 
 
 


89


Table 5.17: TDR Modifications
 
Primary modification type (1)
 
 
Financial effects of modifications
 
(in millions)
Principal (2)

 
Interest
rate
reduction

 
Other
concessions (3)

 
Total

 
Charge-
offs (4)

 
Weighted
average
interest
rate
reduction

 
Recorded
investment
related to
interest rate
reduction (5)

Quarter ended March 31, 2016
 
 
 
 
 
 
 
 
 
 
 
 
 
Commercial:
 
 
 
 
 
 
 
 
 
 
 
 
 
Commercial and industrial
$
42

 
78

 
632

 
752

 
106

 
1.89
%
 
$
78

Real estate mortgage

 
24

 
159

 
183

 

 
1.13

 
24

Real estate construction

 

 
44

 
44

 

 

 

Lease financing

 

 
4

 
4

 

 

 

Total commercial
42

 
102

 
839

 
983

 
106

 
1.71

 
102

Consumer:
 
 
 
 
 
 
 
 
 
 
 
 
 
Real estate 1-4 family first mortgage
96

 
65

 
450

 
611

 
13

 
2.81

 
119

Real estate 1-4 family junior lien mortgage
6

 
29

 
27

 
62

 
10

 
2.92

 
34

Credit card

 
44

 

 
44

 

 
11.94

 
44

Automobile

 
4

 
15

 
19

 
8

 
6.54

 
4

Other revolving credit and installment

 
8

 
3

 
11

 
1

 
6.10

 
8

Trial modifications (6)

 

 
15

 
15

 

 

 

Total consumer
102

 
150

 
510

 
762

 
32

 
4.94

 
209

Total
$
144

 
252

 
1,349

 
1,745

 
138

 
3.88
%
 
$
311

Quarter ended March 31, 2015
 
 
 
 
 
 
 
 
 
 
 
 
 
Commercial:
 
 
 
 
 
 
 
 
 
 
 
 
 
Commercial and industrial
$

 
10

 
224

 
234

 
2

 
0.76
%
 
$
10

Real estate mortgage

 
21

 
309

 
330

 
1

 
1.35

 
21

Real estate construction
11

 
1

 
44

 
56

 

 
0.17

 
1

Lease financing

 

 

 

 

 

 

Total commercial
11

 
32

 
577

 
620

 
3

 
1.14

 
32

Consumer:
 
 
 
 
 
 
 
 
 
 
 
 
 
Real estate 1-4 family first mortgage
104

 
83

 
516

 
703

 
15

 
2.46

 
165

Real estate 1-4 family junior lien mortgage
7

 
20

 
51

 
78

 
12

 
3.18

 
27

Credit card

 
45

 

 
45

 

 
11.29

 
44

Automobile
1

 
1

 
27

 
29

 
10

 
9.06

 
1

Other revolving credit and installment

 
5

 
2

 
7

 

 
5.82

 
5

Trial modifications (6)

 

 
(2
)
 
(2
)
 

 

 

Total consumer
112

 
154

 
594

 
860

 
37

 
4.27

 
242

Total
$
123

 
186

 
1,171

 
1,480

 
40

 
3.90
%
 
$
274

(1)
Amounts represent the recorded investment in loans after recognizing the effects of the TDR, if any. TDRs may have multiple types of concessions, but are presented only once in the first modification type based on the order presented in the table above. The reported amounts include loans remodified of $348 million and $522 million, for quarters ended March 31, 2016 and 2015, respectively.
(2)
Principal modifications include principal forgiveness at the time of the modification, contingent principal forgiveness granted over the life of the loan based on borrower performance, and principal that has been legally separated and deferred to the end of the loan, with a zero percent contractual interest rate.
(3)
Other concessions include loan renewals, term extensions and other interest and noninterest adjustments, but exclude modifications that also forgive principal and/or reduce the contractual interest rate.
(4)
Charge-offs include write-downs of the investment in the loan in the period it is contractually modified. The amount of charge-off will differ from the modification terms if the loan has been charged down prior to the modification based on our policies. In addition, there may be cases where we have a charge-off/down with no legal principal modification. Modifications resulted in legally forgiving principal (actual, contingent or deferred) of $19 million and $26 million for the quarters ended March 31, 2016 and 2015, respectively.
(5)
Reflects the effect of reduced interest rates on loans with an interest rate concession as one of their concession types, which includes loans reported as a principal primary modification type that also have an interest rate concession.
(6)
Trial modifications are granted a delay in payments due under the original terms during the trial payment period. However, these loans continue to advance through delinquency status and accrue interest according to their original terms. Any subsequent permanent modification generally includes interest rate related concessions; however, the exact concession type and resulting financial effect are usually not known until the loan is permanently modified. Trial modifications for the period are presented net of previously reported trial modifications that became permanent in the current period.

90

Note 5: Loans and Allowance for Credit Losses (continued)

Table 5.18 summarizes permanent modification TDRs that have defaulted in the current period within 12 months of their permanent modification date. We are reporting these defaulted TDRs based on a payment default definition of 90 days past due for the commercial portfolio segment and 60 days past due for the consumer portfolio segment.
 



Table 5.18: Defaulted TDRs
 
Recorded investment of defaults
 
 
Quarter ended March 31,
 
(in millions)
2016

 
2015

Commercial:
 
 
 
Commercial and industrial
$
25

 
8

Real estate mortgage
20

 
23

Real estate construction
2

 
1

Total commercial
47

 
32

Consumer:
 
 
 
Real estate 1-4 family first mortgage
31

 
52

Real estate 1-4 family junior lien mortgage
5

 
4

Credit card
13

 
13

Automobile
3

 
3

Other revolving credit and installment
1

 
1

Total consumer
53

 
73

Total
$
100

 
105


Purchased Credit-Impaired Loans
Substantially all of our PCI loans were acquired from Wachovia on December 31, 2008, at which time we acquired commercial and consumer loans with a carrying value of $18.7 billion and $40.1 billion, respectively. The unpaid principal balance on December 31, 2008 was $98.2 billion for the total of commercial and consumer PCI loans. Table 5.19 presents PCI loans net of any remaining purchase accounting adjustments. Commercial and industrial PCI loans at March 31, 2016, included $1.1 billion from the GE Capital acquisitions . Real estate 1-4 family first mortgage PCI loans are predominantly Pick-a-Pay loans.
Table 5.19: PCI Loans
(in millions)
Mar 31,
2016

 
Dec 31,
2015

Commercial:
 
 
 
Commercial and industrial
$
1,153

 
78

Real estate mortgage
483

 
542

Real estate construction
88

 
92

Total commercial
1,724

 
712

Consumer:
 
 
 
Real estate 1-4 family first mortgage
18,534

 
19,190

Real estate 1-4 family junior lien mortgage
60

 
69

Total consumer
18,594

 
19,259

Total PCI loans (carrying value)
$
20,318

 
19,971

Total PCI loans (unpaid principal balance)
$
28,623

 
28,278




91


ACCRETABLE YIELD The excess of cash flows expected to be collected over the carrying value of PCI loans is referred to as the accretable yield and is recognized in interest income using an effective yield method over the remaining life of the loan, or pools of loans. The accretable yield is affected by:
changes in interest rate indices for variable rate PCI loans – expected future cash flows are based on the variable rates in effect at the time of the regular evaluations of cash flows expected to be collected;
changes in prepayment assumptions – prepayments affect the estimated life of PCI loans which may change the amount of interest income, and possibly principal, expected to be collected; and
 
changes in the expected principal and interest payments over the estimated life – updates to expected cash flows are driven by the credit outlook and actions taken with borrowers. Changes in expected future cash flows from loan modifications are included in the regular evaluations of cash flows expected to be collected.
 
The change in the accretable yield related to PCI loans is presented in Table 5.20.
 

Table 5.20: Change in Accretable Yield
(in millions)
 
Balance, December 31, 2015
$
16,301

Addition of accretable yield due to acquisitions
(1
)
Accretion into interest income (1)
(339
)
Accretion into noninterest income due to sales (2)
(9
)
Reclassification from nonaccretable difference for loans with improving credit-related cash flows
34

Changes in expected cash flows that do not affect nonaccretable difference (3)
(8
)
Balance, March 31, 2016
$
15,978

(1)
Includes accretable yield released as a result of settlements with borrowers, which is included in interest income.
(2)
Includes accretable yield released as a result of sales to third parties, which is included in noninterest income.
(3)
Represents changes in cash flows expected to be collected due to the impact of modifications, changes in prepayment assumptions, changes in interest rates on variable rate PCI loans and sales to third parties.

COMMERCIAL PCI CREDIT QUALITY INDICATORS  Table 5.21 provides a breakdown of commercial PCI loans by risk category.
 
 

Table 5.21: Commercial PCI Loans by Risk Category
(in millions)
Commercial
and
industrial

 
Real
estate
mortgage

 
Real
estate
construction

 
Total

March 31, 2016
 
 
 
 
 
 
 
By risk category:
 
 
 
 
 
 
 
Pass
$
136

 
259

 
69

 
464

Criticized
1,017

 
224

 
19

 
1,260

Total commercial PCI loans
$
1,153

 
483

 
88

 
1,724

December 31, 2015
 
 
 
 
 
 
 
By risk category:
 
 
 
 
 
 
 
Pass
$
35

 
298

 
68

 
401

Criticized
43

 
244

 
24

 
311

Total commercial PCI loans
$
78

 
542

 
92

 
712




92

Note 5: Loans and Allowance for Credit Losses (continued)

Table 5.22 provides past due information for commercial PCI loans.

Table 5.22: Commercial PCI Loans by Delinquency Status
(in millions)
Commercial
and
industrial

 
Real
estate
mortgage

 
Real
estate
construction

 
Total

March 31, 2016
 
 
 
 
 
 
 
By delinquency status:
 
 
 
 
 
 
 
Current-29 DPD and still accruing
$
1,153

 
455

 
86

 
1,694

30-89 DPD and still accruing

 
12

 

 
12

90+ DPD and still accruing

 
16

 
2

 
18

Total commercial PCI loans
$
1,153

 
483

 
88

 
1,724

December 31, 2015
 
 
 
 
 
 
 
By delinquency status:
 
 
 
 
 
 
 
Current-29 DPD and still accruing
$
78

 
510

 
90

 
678

30-89 DPD and still accruing

 
2

 

 
2

90+ DPD and still accruing

 
30

 
2

 
32

Total commercial PCI loans
$
78

 
542

 
92

 
712

CONSUMER PCI CREDIT QUALITY INDICATORS  Our consumer PCI loans were aggregated into several pools of loans at acquisition. Below, we have provided credit quality indicators based on the unpaid principal balance (adjusted for write-downs) of the individual loans included in the pool, but we have not
 
allocated the remaining purchase accounting adjustments, which were established at a pool level. Table 5.23 provides the delinquency status of consumer PCI loans.
 

Table 5.23: Consumer PCI Loans by Delinquency Status
  
March 31, 2016
 
 
December 31, 2015
 
(in millions)
Real estate
1-4 family
first
mortgage

 
Real estate
1-4 family
junior lien
mortgage

 
Total

 
Real estate
1-4 family
first
mortgage

 
Real estate
1-4 family
junior lien
mortgage

 
Total

By delinquency status:
 
 
 
 
 
 
 
 
 
 
 
Current-29 DPD and still accruing
$
17,918

 
195

 
18,113

 
18,086

 
202

 
18,288

30-59 DPD and still accruing
1,454

 
7

 
1,461

 
1,686

 
7

 
1,693

60-89 DPD and still accruing
681

 
3

 
684

 
716

 
3

 
719

90-119 DPD and still accruing
260

 
2

 
262

 
293

 
2

 
295

120-179 DPD and still accruing
271

 
2

 
273

 
319

 
3

 
322

180+ DPD and still accruing
2,840

 
10

 
2,850

 
3,035

 
12

 
3,047

Total consumer PCI loans (adjusted unpaid principal balance)
$
23,424

 
219

 
23,643

 
24,135

 
229

 
24,364

Total consumer PCI loans (carrying value)
$
18,534

 
60

 
18,594

 
19,190

 
69

 
19,259


93


Table 5.24 provides FICO scores for consumer PCI loans.

Table 5.24: Consumer PCI Loans by FICO
 
March 31, 2016
 
 
December 31, 2015
 
(in millions)
Real estate
1-4 family
first
mortgage

 
Real estate
1-4 family
junior lien
mortgage

 
Total

 
Real estate
1-4 family
first
mortgage

 
Real estate
1-4 family
junior lien
mortgage

 
Total

By FICO:
 
 
 
 
 
 
 
 
 
 
 
< 600
$
5,917

 
55

 
5,972

 
5,737

 
52

 
5,789

600-639
4,062

 
34

 
4,096

 
4,754

 
38

 
4,792

640-679
5,520

 
43

 
5,563

 
6,208

 
48

 
6,256

680-719
4,081

 
42

 
4,123

 
4,283

 
43

 
4,326

720-759
1,889

 
24

 
1,913

 
1,914

 
24

 
1,938

760-799
870

 
13

 
883

 
910

 
13

 
923

800+
235

 
2

 
237

 
241

 
3

 
244

No FICO available
850

 
6

 
856

 
88

 
8

 
96

Total consumer PCI loans (adjusted unpaid principal balance)
$
23,424

 
219

 
23,643

 
24,135

 
229

 
24,364

Total consumer PCI loans (carrying value)
$
18,534

 
60

 
18,594

 
19,190

 
69

 
19,259



Table 5.25 shows the distribution of consumer PCI loans by LTV for real estate 1-4 family first mortgages and by CLTV for real estate 1-4 family junior lien mortgages. 

Table 5.25: Consumer PCI Loans by LTV/CLTV
 
March 31, 2016
 
 
December 31, 2015
 
(in millions)
Real estate
1-4 family
first
mortgage
by LTV

 
Real estate
1-4 family
junior lien
mortgage
by CLTV

 
Total

 
Real estate
1-4 family
first
mortgage
by LTV

 
Real estate
1-4 family
junior lien
mortgage
by CLTV

 
Total

By LTV/CLTV:
 
 
 
 
 
 
 
 
 
 
 
0-60%
$
5,669

 
32

 
5,701

 
5,437

 
32

 
5,469

60.01-80%
9,759

 
64

 
9,823

 
10,036

 
65

 
10,101

80.01-100%
5,894

 
77

 
5,971

 
6,299

 
80

 
6,379

100.01-120% (1)
1,623

 
32

 
1,655

 
1,779

 
36

 
1,815

> 120% (1)
474

 
13

 
487

 
579

 
15

 
594

No LTV/CLTV available
5

 
1

 
6

 
5

 
1

 
6

Total consumer PCI loans (adjusted unpaid principal balance)
$
23,424

 
219

 
23,643

 
24,135

 
229

 
24,364

Total consumer PCI loans (carrying value)
$
18,534

 
60

 
18,594

 
19,190

 
69

 
19,259

(1)
Reflects total loan balances with LTV/CLTV amounts in excess of 100%. In the event of default, the loss content would generally be limited to only the amount in excess of 100% LTV/CLTV.


94


Note 6:  Other Assets
Table 6.1 presents the components of other assets.
Table 6.1: Other Assets
(in millions)
Mar 31,
2016

 
Dec 31,
2015

Nonmarketable equity investments:
 
 
 
Cost method:
 
 
 
Federal bank stock
$
5,312

 
4,814

Private equity
1,491

 
1,626

Auction rate securities
566

 
595

Total cost method
7,369

 
7,035

Equity method:
 
 
 
LIHTC (1)
8,598

 
8,314

Private equity
3,489

 
3,300

Tax-advantaged renewable energy
1,630

 
1,625

New market tax credit and other
328

 
408

Total equity method
14,045

 
13,647

Fair value (2)
3,098

 
3,065

Total nonmarketable equity investments
24,512

 
23,747

Corporate/bank-owned life insurance
19,238

 
19,199

Accounts receivable (3)
35,458

 
26,251

Interest receivable
5,318

 
5,065

Core deposit intangibles
2,309

 
2,539

Customer relationship and other amortized intangibles
1,491

 
614

Foreclosed assets:
 
 
 
Residential real estate:
 
 
 
Government insured/guaranteed (3)
386

 
446

Non-government insured/guaranteed
368

 
414

Non-residential real estate
525

 
565

Operating lease assets
10,265

 
3,782

Due from customers on acceptances
240

 
273

Other (4)
19,382

 
17,887

Total other assets
$
119,492

 
100,782

(1)
Represents low income housing tax credit investments.
(2)
Represents nonmarketable equity investments for which we have elected the fair value option. See Note 13 (Fair Values of Assets and Liabilities) for additional information.
(3)
Certain government-guaranteed residential real estate mortgage loans upon foreclosure are included in Accounts receivable. Both principal and interest related to these foreclosed real estate assets are collectible because the loans were predominantly insured by the FHA or guaranteed by the VA. For more information on ASU 2014-14 and the classification of certain government-guaranteed mortgage loans upon foreclosure, see Note 1 (Summary of Significant Accounting Policies) to Financial Statements in our 2015 10-K.
(4)
Includes derivatives designated as hedging instruments, derivatives not designated as hedging instruments, and derivative loan commitments, which are carried at fair value. See Note 12 (Derivatives) for additional information.

 
Table 6.2 presents income (expense) related to nonmarketable equity investments. 
Table 6.2: Nonmarketable Equity Investments
 
Quarter ended March 31,
 
(in millions)
2016

 
2015

Net realized gains from nonmarketable equity investments
$
185

 
351

All other
(186
)
 
(148
)
Total
$
(1
)
 
203

Low Income Housing Tax Credit Investments We invest in affordable housing projects that qualify for the low income housing tax credit (LIHTC), which is designed to promote private development of low income housing. These investments generate a return primarily through realization of federal tax credits.
Total LIHTC investments were $8.6 billion and $8.3 billion at March 31, 2016 and December 31, 2015, respectively. In first quarter 2016, we recognized pre-tax losses of $202 million related to our LIHTC investments, compared with $178 million in first quarter 2015. We also recognized total tax benefits of $307 million in first quarter 2016 and $276 million in first quarter 2015, which included tax credits of $230 million and $209 million for the same periods, respectively, recorded in income taxes. We are periodically required to provide additional financial support during the investment period. Our liability for these unfunded commitments was $3.2 billion at March 31, 2016 and $3.0 billion at December 31, 2015. Predominantly all of this liability is expected to be paid over the next three years. This liability is included in long-term debt.



95


Note 7: Securitizations and Variable Interest Entities
Involvement with SPEs
In the normal course of business, we enter into various types of on- and off-balance sheet transactions with SPEs, which are corporations, trusts, limited liability companies or partnerships that are established for a limited purpose. Generally, SPEs are formed in connection with securitization transactions and are considered variable interest entities (VIEs). For further description of our involvement with SPEs, see Note 8 (Securitizations and Variable Interest Entities) to Financial Statements in our 2015 Form 10-K.
 
We have segregated our involvement with VIEs between those VIEs which we consolidate, those which we do not consolidate and those for which we account for the transfers of financial assets as secured borrowings. Secured borrowings are transactions involving transfers of our financial assets to third parties that are accounted for as financings with the assets pledged as collateral. Accordingly, the transferred assets remain recognized on our balance sheet. Subsequent tables within this Note further segregate these transactions by structure type.
Table 7.1 provides the classifications of assets and liabilities in our balance sheet for our transactions with VIEs.

Table 7.1: Balance Sheet Transactions with VIEs
(in millions)
VIEs that we
do not
consolidate

 
VIEs
that we
consolidate

Transfers that
we account
for as secured
borrowings
 
 
Total

March 31, 2016
 
 
 
 
 
Cash
$

 
288

 

 
288

Trading assets
1,269

 
152

 
203

 
1,624

Investment securities (1)
11,512

 
372

 
1,506

 
13,390

Loans
8,851

 
13,865

 
4,619

 
27,335

Mortgage servicing rights
11,547

 

 

 
11,547

Other assets
9,194

 
518

 
16

 
9,728

Total assets
42,373

 
15,195

 
6,344

 
63,912

Short-term borrowings

 

 
1,458

 
1,458

Accrued expenses and other liabilities  
588

 
146

(2)
1

 
735

Long-term debt  
3,151

 
4,731

(2)
4,569

 
12,451

Total liabilities
3,739

 
4,877

 
6,028

 
14,644

Noncontrolling interests

 
202

 

 
202

Net assets
$
38,634

 
10,116

 
316

 
49,066

December 31, 2015
 
 
 
 
 
 
 
Cash
$

 
157

 

 
157

Trading assets
1,340

 
1

 
203

 
1,544

Investment securities (1)
12,388

 
425

 
2,171

 
14,984

Loans
9,661

 
4,811

 
4,887

 
19,359

Mortgage servicing rights
12,518

 

 

 
12,518

Other assets
8,938

 
242

 
26

 
9,206

Total assets
44,845

 
5,636

 
7,287

 
57,768

Short-term borrowings

 

 
1,799

 
1,799

Accrued expenses and other liabilities
629

 
57

(2)
1

 
687

Long-term debt
3,021

 
1,301

(2)
4,844

 
9,166

Total liabilities
3,650

 
1,358

 
6,644

 
11,652

Noncontrolling interests

 
93

 

 
93

Net assets
$
41,195

 
4,185

 
643

 
46,023

(1)
Excludes certain debt securities related to loans serviced for the Federal National Mortgage Association (FNMA), Federal Home Loan Mortgage Corporation (FHLMC) and GNMA.
(2)
There were no VIE liabilities with recourse to the general credit of Wells Fargo for the periods presented.

Transactions with Unconsolidated VIEs
Our transactions with unconsolidated VIEs include securitizations of residential mortgage loans, CRE loans, student loans, auto loans and leases, certain dealer floorplan loans; investment and financing activities involving collateralized debt obligations (CDOs) backed by asset-backed and CRE securities, tax credit structures, collateralized loan obligations (CLOs) backed by corporate loans, and other types of structured financing. We have various forms of involvement with VIEs,
 
including servicing, holding senior or subordinated interests, entering into liquidity arrangements, credit default swaps and other derivative contracts. Involvements with these unconsolidated VIEs are recorded on our balance sheet primarily in trading assets, investment securities, loans, MSRs, other assets, other liabilities, and long-term debt, as appropriate.
Table 7.2 provides a summary of unconsolidated VIEs with which we have significant continuing involvement, but we are not the primary beneficiary. We do not consider our continuing


96

Note 7: Securitizations and Variable Interest Entities (continued)

involvement in an unconsolidated VIE to be significant when it relates to third-party sponsored VIEs for which we were not the transferor (unless we are servicer and have other significant forms of involvement) or if we were the sponsor only or sponsor and servicer but do not have any other forms of significant involvement.
Significant continuing involvement includes transactions where we were the sponsor or transferor and have other significant forms of involvement. Sponsorship includes transactions with unconsolidated VIEs where we solely or materially participated in the initial design or structuring of the entity or marketing of the transaction to investors. When we transfer assets to a VIE and account for the transfer as a sale, we are considered the transferor. We consider investments in
 
securities (other than those held temporarily in trading), loans, guarantees, liquidity agreements, written options and servicing of collateral to be other forms of involvement that may be significant. We have excluded certain transactions with unconsolidated VIEs from the balances presented in the following table where we have determined that our continuing involvement is not significant due to the temporary nature and size of our variable interests, because we were not the transferor or because we were not involved in the design of the unconsolidated VIEs. We also exclude from the table secured borrowing transactions with unconsolidated VIEs (for information on these transactions, see the Transactions with Consolidated VIEs and Secured Borrowings section in this Note).

Table 7.2: Unconsolidated VIEs
 
 
 
Carrying value – asset (liability)
 
(in millions)
Total
VIE
assets

 
Debt and
equity
interests (1)

 
Servicing
assets

 
Derivatives

 
Other
commitments
and
guarantees

 
Net
assets

March 31, 2016
 
 
 
 
 
 
 
 
 
 
 
Residential mortgage loan securitizations:
 
 
 
 
 
 
 
 
 
 
 
Conforming (2)
$
1,182,723

 
2,185

 
10,633

 

 
(365
)
 
12,453

Other/nonconforming
23,701

 
1,184

 
127

 

 
(2
)
 
1,309

Commercial mortgage securitizations
182,780

 
5,890

 
787

 
294

 
(32
)
 
6,939

Collateralized debt obligations:
 
 
 
 
 
 
 
 
 
 
 
Debt securities
2,893

 

 

 
76

 
(39
)
 
37

Loans (3)
2,764

 
2,656

 

 

 

 
2,656

Asset-based finance structures
12,265

 
8,428

 

 
(62
)
 

 
8,366

Tax credit structures
26,638

 
9,396

 

 

 
(3,164
)
 
6,232

Collateralized loan obligations
680

 
162

 

 

 

 
162

Investment funds
206

 
48

 

 

 

 
48

Other (4)
12,275

 
484

 

 
(52
)
 

 
432

Total
$
1,446,925

 
30,433

 
11,547

 
256

 
(3,602
)
 
38,634

 
 
 
Maximum exposure to loss
 
 
 
 
Debt and
equity
interests (1)

 
Servicing
assets

 
Derivatives

 
Other
commitments
and
guarantees

 
Total
exposure

Residential mortgage loan securitizations:
 
 
 
 
 
 
 
 
 
 
 
Conforming
 
 
$
2,185

 
10,633

 

 
1,484

 
14,302

Other/nonconforming
 
 
1,184

 
127

 

 
2

 
1,313

Commercial mortgage securitizations
 
 
5,890

 
787

 
294

 
8,548

 
15,519

Collateralized debt obligations:
 
 
 
 
 
 
 
 
 
 
 
Debt securities
 
 

 

 
77

 
39

 
116

Loans (3)
 
 
2,656

 

 

 

 
2,656

Asset-based finance structures
 
 
8,428

 

 
72

 
444

 
8,944

Tax credit structures
 
 
9,396

 

 

 
973

 
10,369

Collateralized loan obligations
 
 
162

 

 

 

 
162

Investment funds
 
 
48

 

 

 

 
48

Other (4)
 
 
484

 

 
125

 

 
609

Total
 
 
$
30,433

 
11,547

 
568

 
11,490

 
54,038


(continued on following page)

97


(continued from previous page)
 
 
 
Carrying value – asset (liability)
 
(in millions)
Total
VIE
assets

 
Debt and
equity
interests (1)

 
Servicing
assets

 
Derivatives

 
Other
commitments
and
guarantees

 
Net
assets

December 31, 2015
 
 
 
 
 
 
 
 
 
 
 
Residential mortgage loan securitizations:
 
 
 
 
 
 
 
 
 
 
 
Conforming (2)
$
1,199,225

 
2,458

 
11,665

 

 
(386
)
 
13,737

Other/nonconforming
24,809

 
1,228

 
141

 

 
(1
)
 
1,368

Commercial mortgage securitizations
184,959

 
6,323

 
712

 
203

 
(26
)
 
7,212

Collateralized debt obligations:
 
 
 
 
 
 
 
 
 
 
 
Debt securities
3,247

 

 

 
64

 
(57
)
 
7

Loans (3)
3,314

 
3,207

 

 

 

 
3,207

Asset-based finance structures
13,063

 
8,956

 

 
(66
)
 

 
8,890

Tax credit structures
26,099

 
9,094

 

 

 
(3,047
)
 
6,047

Collateralized loan obligations
898

 
213

 

 

 

 
213

Investment funds
1,131

 
47

 

 

 

 
47

Other (4)
12,690

 
511

 

 
(44
)
 

 
467

Total
$
1,469,435

 
32,037

 
12,518

 
157

 
(3,517
)
 
41,195

 
 
 
Maximum exposure to loss
 
 
 
 
Debt and
equity
interests (1)

 
Servicing
assets

 
Derivatives

 
Other
commitments
and
guarantees

 
Total
exposure

Residential mortgage loan securitizations:
 
 
 
 
 
 
 
 
 
 
 
Conforming
 
 
$
2,458

 
11,665

 

 
1,452

 
15,575

Other/nonconforming
 
 
1,228

 
141

 

 
1

 
1,370

Commercial mortgage securitizations
 
 
6,323

 
712

 
203

 
7,152

 
14,390

Collateralized debt obligations:
 
 
 
 
 
 
 
 
 
 
 
Debt securities
 
 

 

 
64

 
57

 
121

Loans (3)
 
 
3,207

 

 

 

 
3,207

Asset-based finance structures
 
 
8,956

 

 
76

 
444

 
9,476

Tax credit structures
 
 
9,094

 

 

 
866

 
9,960

Collateralized loan obligations
 
 
213

 

 

 

 
213

Investment funds
 
 
47

 

 

 

 
47

Other (4)
 
 
511

 

 
117

 
150

 
778

Total
 
 
$
32,037

 
12,518

 
460

 
10,122

 
55,137

(1)
Includes total equity interests of $9.2 billion and $8.9 billion at March 31, 2016, and December 31, 2015, respectively. Also includes debt interests in the form of both loans and securities. Excludes certain debt securities held related to loans serviced for FNMA, FHLMC and GNMA.
(2)
Excludes assets and related liabilities with a recorded carrying value on our balance sheet of $938 million and $1.3 billion at March 31, 2016, and December 31, 2015, respectively, for certain delinquent loans that are eligible for repurchase primarily from GNMA loan securitizations. The recorded carrying value represents the amount that would be payable if the Company was to exercise the repurchase option. The carrying amounts are excluded from the table because the loans eligible for repurchase do not represent interests in the VIEs.
(3)
Represents senior loans to trusts that are collateralized by asset-backed securities. The trusts invest primarily in senior tranches from a diversified pool of primarily U.S. asset securitizations, of which all are current and 71% and 70% were rated as investment grade by the primary rating agencies at March 31, 2016, and December 31, 2015, respectively. These senior loans are accounted for at amortized cost and are subject to the Company’s allowance and credit charge-off policies.
(4)
Includes structured financing and credit-linked note structures. Also contains investments in auction rate securities (ARS) issued by VIEs that we do not sponsor and, accordingly, are unable to obtain the total assets of the entity.



98

Note 7: Securitizations and Variable Interest Entities (continued)

In the two preceding tables, “Total VIE assets” represents the remaining principal balance of assets held by unconsolidated VIEs using the most current information available. For VIEs that obtain exposure to assets synthetically through derivative instruments, the remaining notional amount of the derivative is included in the asset balance. “Carrying value” is the amount in our consolidated balance sheet related to our involvement with the unconsolidated VIEs. “Maximum exposure to loss” from our involvement with off-balance sheet entities, which is a required disclosure under GAAP, is determined as the carrying value of our involvement with off-balance sheet (unconsolidated) VIEs plus the remaining undrawn liquidity and lending commitments, the notional amount of net written derivative contracts, and generally the notional amount of, or stressed loss estimate for, other commitments and guarantees. It represents estimated loss that would be incurred under severe, hypothetical circumstances, for which we believe the possibility is extremely remote, such as where the value of our interests and any associated collateral declines to zero, without any consideration of recovery or offset from any economic hedges. Accordingly, this required disclosure is not an indication of expected loss.
For complete descriptions of our types of transactions with unconsolidated VIEs with which we have a significant continuing involvement, but we are not the primary beneficiary, see Note 8 (Securitizations and Variable Interest Entities) to Financial Statements in our 2015 Form 10-K.

INVESTMENT FUNDS In first quarter 2016, we adopted ASU 2015-02 (Amendments to the Consolidation Analysis) which changed the consolidation analysis for certain investment funds. We do not consolidate these investment funds because we do not hold variable interests that are considered significant to the funds.
We voluntarily waived a portion of our management fees for certain money market funds that are exempt from the consolidation analysis to ensure the funds maintained a minimum level of daily net investment income. The amount of fees waived was $30 million and $56 million in first quarter 2016 and 2015, respectively.

OTHER TRANSACTIONS WITH VIEs  Other VIEs include certain entities that issue auction rate securities (ARS) which are debt instruments with long-term maturities, that re-price more frequently, and preferred equities with no maturity. At March 31, 2016, we held $473 million of ARS issued by VIEs compared with $502 million at December 31, 2015. We acquired the ARS pursuant to agreements entered into in 2008 and 2009.
We do not consolidate the VIEs that issued the ARS because we do not have power over the activities of the VIEs.

 
TRUST PREFERRED SECURITIES  VIEs that we wholly own issue debt securities or preferred equity to third party investors. All of the proceeds of the issuance are invested in debt securities or preferred equity that we issue to the VIEs. The VIEs’ operations and cash flows relate only to the issuance, administration and repayment of the securities held by third parties. We do not consolidate these VIEs because the sole assets of the VIEs are receivables from us, even though we own all of the voting equity shares of the VIEs, have fully guaranteed the obligations of the VIEs and may have the right to redeem the third party securities under certain circumstances. In our consolidated balance sheet at March 31, 2016, and December 31, 2015, we reported the debt securities issued to the VIEs as long-term junior subordinated debt with a carrying value of $2.2 billion, and the preferred equity securities issued to the VIEs as preferred stock with a carrying value of $2.5 billion at both dates. These amounts are in addition to the involvements in these VIEs included in the preceding table.
 
Loan Sales and Securitization Activity
We periodically transfer consumer and CRE loans and other types of financial assets in securitization and whole loan sale transactions. We typically retain the servicing rights from these sales and may continue to hold other beneficial interests in the transferred financial assets. We may also provide liquidity to investors in the beneficial interests and credit enhancements in the form of standby letters of credit. Through these transfers we may be exposed to liability under limited amounts of recourse as well as standard representations and warranties we make to purchasers and issuers. Table 7.3 presents the cash flows for our transfers accounted for as sales.


99


Table 7.3: Cash Flows From Sales and Securitization Activity
 
2016
 
 
2015
 
(in millions)
Mortgage
loans

 
Other
financial
assets

 
Mortgage
loans

 
Other
financial
assets

Quarter ended March 31,
 
 
 
 
 
 
 
Proceeds from securitizations and whole loan sales
$
45,016

 
50

 
41,909

 
21

Fees from servicing rights retained
881

 

 
935

 
2

Cash flows from other interests held (1)
407

 
1

 
266

 
12

Repurchases of assets/loss reimbursements (2):
 
 
 
 
 
 
 
Non-agency securitizations and whole loan transactions
3

 

 
6

 

Agency securitizations (3)
47

 

 
62

 

Servicing advances, net of repayments
(68
)
 

 
(100
)
 

(1)
Cash flows from other interests held include principal and interest payments received on retained bonds and excess cash flows received on interest-only strips.
(2)
Consists of cash paid to repurchase loans from investors and cash paid to investors to reimburse them for losses on individual loans that are already liquidated.
(3)
Represent loans repurchased from GNMA, FNMA, and FHLMC under representation and warranty provisions included in our loan sales contracts. First quarter 2016 and 2015 exclude $2.9 billion and $3.3 billion, respectively, in delinquent insured/guaranteed loans that we service and have exercised our option to purchase out of GNMA pools. These loans are predominantly insured by the FHA or guaranteed by the VA.

In first quarter 2016 and 2015, we recognized net gains of $195 million and $111 million, respectively, from transfers accounted for as sales of financial assets. These net gains primarily relate to commercial mortgage securitizations and residential mortgage securitizations where the loans were not already carried at fair value.
Sales with continuing involvement during first quarter 2016 and 2015 primarily related to securitizations of residential mortgages that are sold to the government-sponsored entities (GSEs), including FNMA, FHLMC and GNMA (conforming residential mortgage securitizations). During first quarter 2016 and 2015, we transferred $37.3 billion and $39.5 billion, respectively, in fair value of residential mortgages to unconsolidated VIEs and third-party investors and recorded the transfers as sales. Substantially all of these transfers did not result in a gain or loss because the loans were already carried at fair value. In connection with all of these transfers, in first quarter 2016, we recorded a $315 million servicing asset, measured at fair value using a Level 3 measurement technique, securities of $832 million, classified as Level 2, and a $7 million liability for repurchase losses which reflects management’s estimate of probable losses related to various representations and warranties for the loans transferred, initially measured at fair value. In first quarter 2015, we recorded a $308 million servicing asset, securities of $517 million, and a $10 million liability.
 
Table 7.4 presents the key weighted-average assumptions we used to measure residential mortgage servicing rights at the date of securitization.
Table 7.4: Residential Mortgage Servicing Rights
 
Residential mortgage
servicing rights
 
 
2016

 
2015

Quarter ended March 31,
 
 
 
Prepayment speed (1)
13.0
%
 
13.0

Discount rate
6.8

 
7.5

Cost to service ($ per loan) (2)
$
146

 
237

(1)
The prepayment speed assumption for residential mortgage servicing rights includes a blend of prepayment speeds and default rates. Prepayment speed assumptions are influenced by mortgage interest rate inputs as well as our estimation of drivers of borrower behavior.
(2)
Includes costs to service and unreimbursed foreclosure costs, which can vary period to period depending on the mix of modified government-guaranteed loans sold to GNMA.
During first quarter 2016 and 2015, we transferred $8.1 billion and $3.2 billion, respectively, in carrying value of commercial mortgages to unconsolidated VIEs and third-party investors and recorded the transfers as sales. These transfers resulted in gains of $135 million and $77 million for the same periods, respectively, because the loans were carried at lower of cost or market value (LOCOM). In connection with these transfers, in first quarter 2016, we recorded a servicing asset of $97 million, initially measured at fair value using a Level 3 measurement technique, and securities of $86 million, classified as Level 2. In first quarter 2015, we recorded a servicing asset of $50 million.


100

Note 7: Securitizations and Variable Interest Entities (continued)

Retained Interests from Unconsolidated VIEs
Table 7.5 provides key economic assumptions and the sensitivity of the current fair value of residential mortgage servicing rights and other interests held to immediate adverse changes in those assumptions. “Other interests held” relate predominantly to residential and commercial mortgage loan securitizations. Residential mortgage-backed securities retained in securitizations issued through GSEs, such as FNMA, FHLMC and GNMA, are excluded from the table because these securities have a remote risk of credit loss due to the GSE guarantee. These securities also have economic characteristics similar to GSE
 
mortgage-backed securities that we purchase, which are not included in the table. Subordinated interests include only those bonds whose credit rating was below AAA by a major rating agency at issuance. Senior interests include only those bonds whose credit rating was AAA by a major rating agency at issuance. The information presented excludes trading positions held in inventory.



Table 7.5: Retained Interests from Unconsolidated VIEs
 
 
 
Other interests held
 
 
Residential
mortgage
servicing
rights (1)

 
Interest-only
strips

 
Consumer

 
Commercial (2)
 
($ in millions, except cost to service amounts)
 
 
Subordinated
bonds

 
Subordinated
bonds

 
Senior
bonds

Fair value of interests held at March 31, 2016
$
11,333

 
32

 
1

 
337

 
778

Expected weighted-average life (in years)
5.6

 
3.5

 
10.2

 
1.5

 
6.0

Key economic assumptions:
  
 
  
 
  

 
  
 
  
Prepayment speed assumption (3)
12.6
%
 
19.5

 
16.5

 
  
 
  
Decrease in fair value from:
  
 
  
 
  

 
  
 
  
10% adverse change
$
604

 
1

 

 
  
 
  
25% adverse change
1,429

 
3

 

 
  
 
  
Discount rate assumption
6.9
%
 
13.6

 
10.0

 
6.5

 
2.7

Decrease in fair value from:
  
 
  
 
  

 
  
 
  
100 basis point increase
$
539

 
1

 

 
5

 
39

200 basis point increase
1,029

 
1

 

 
9

 
76

Cost to service assumption ($ per loan)
164

 
  
 
  

 
  
 
  
Decrease in fair value from:
  
 
  
 
  

 
  
 
  
10% adverse change
537

 
  
 
  

 
  
 
  
25% adverse change
1,343

 
  
 
  

 
  
 
  
Credit loss assumption
  
 
  
 
2.0
%
 
2.6

 

Decrease in fair value from:
  
 
  
 
  

 
  
 
  
10% higher losses
  
 
  
 
$

 

 

25% higher losses
  
 
  
 

 
3

 

Fair value of interests held at December 31, 2015
$
12,415

 
34

 
1

 
342

 
673

Expected weighted-average life (in years)
6.0

 
3.6

 
11.6

 
1.9

 
5.8

Key economic assumptions:
  
 
  
 
  

 
  
 
  
Prepayment speed assumption (3)
11.4
%
 
19.0

 
15.1

 
  
 
  
Decrease in fair value from:
  
 
  
 
  

 
  
 
  
10% adverse change
$
616

 
1

 

 
  
 
  
25% adverse change
1,463

 
3

 

 
  
 
  
Discount rate assumption
7.3
%
 
13.8

 
10.5

 
5.3

 
3.0

Decrease in fair value from:
  
 
  
 
  

 
  
 
  
100 basis point increase
$
605

 
1

 

 
6

 
33

200 basis point increase
1,154

 
1

 

 
11

 
63

Cost to service assumption ($ per loan)
168

 
  
 
  

 
  
 
  
Decrease in fair value from:
  
 
  
 
  

 
  
 
  
10% adverse change
567

 
  
 
  

 
  
 
  
25% adverse change
1,417

 
  
 
  

 
  
 
  
Credit loss assumption
  
 
  
 
1.1
%
 
2.8

 

Decrease in fair value from:
  
 
  
 
  

 
  
 
  
10% higher losses
  
 
  
 
$

 

 

25% higher losses
  
 
  
 

 
2

 

(1)
See narrative following this table for a discussion of commercial mortgage servicing rights.
(2)
Prepayment speed assumptions do not significantly impact the value of commercial mortgage securitization bonds as the underlying commercial mortgage loans experience significantly lower prepayments due to certain contractual restrictions, impacting the borrower’s ability to prepay the mortgage.
(3)
The prepayment speed assumption for residential mortgage servicing rights includes a blend of prepayment speeds and default rates. Prepayment speed assumptions are influenced by mortgage interest rate inputs as well as our estimation of drivers of borrower behavior.

101


In addition to residential mortgage servicing rights (MSRs) included in the previous table, we have a small portfolio of commercial MSRs with a fair value of $1.7 billion at both March 31, 2016, and December 31, 2015. The nature of our commercial MSRs, which are carried at LOCOM, is different from our residential MSRs. Prepayment activity on serviced loans does not significantly impact the value of commercial MSRs because, unlike residential mortgages, commercial mortgages experience significantly lower prepayments due to certain contractual restrictions, impacting the borrower’s ability to prepay the mortgage. Additionally, for our commercial MSR portfolio, we are typically master/primary servicer, but not the special servicer, who is separately responsible for the servicing and workout of delinquent and foreclosed loans. It is the special servicer, similar to our role as servicer of residential mortgage loans, who is affected by higher servicing and foreclosure costs due to an increase in delinquent and foreclosed loans. Accordingly, prepayment speeds and costs to service are not key assumptions for commercial MSRs as they do not significantly impact the valuation. The primary economic driver impacting the fair value of our commercial MSRs is forward interest rates, which are derived from market observable yield curves used to price capital markets instruments. Market interest rates most significantly affect interest earned on custodial deposit balances. The sensitivity of the current fair value to an immediate adverse 25% change in the assumption about interest earned on deposit balances at March 31, 2016, and December 31, 2015, results in a decrease in fair value of $145 million and $150 million, respectively. See Note 8 (Mortgage Banking Activities) for further information on our commercial MSRs.
We also have a loan to an unconsolidated third party VIE that we extended in fourth quarter 2014 in conjunction with our sale of government guaranteed student loans. The loan is carried at amortized cost and approximates fair value at March 31, 2016, and December 31, 2015. The carrying amount of the loan at March 31, 2016, and December 31, 2015, was $4.7 billion and $4.9 billion, respectively. The estimated fair value of the loan is considered a Level 3 measurement that is determined using discounted cash flows that are based on changes in the discount
 
rate due to changes in the risk premium component (credit spreads). The primary economic assumption impacting the fair value of our loan is the discount rate. Changes in the credit loss assumption are not expected to affect the estimated fair value of the loan due to the government guarantee of the underlying collateral. The sensitivity of the current fair value to an immediate adverse increase of 200 basis points in the risk premium component of the discount rate assumption is a decrease in fair value of $119 million and $82 million at March 31, 2016, and December 31, 2015, respectively.
The sensitivities in the preceding paragraphs and table are hypothetical and caution should be exercised when relying on this data. Changes in value based on variations in assumptions generally cannot be extrapolated because the relationship of the change in the assumption to the change in value may not be linear. Also, the effect of a variation in a particular assumption on the value of the other interests held is calculated independently without changing any other assumptions. In reality, changes in one factor may result in changes in others (for example, changes in prepayment speed estimates could result in changes in the credit losses), which might magnify or counteract the sensitivities.

Off-Balance Sheet Loans
Table 7.6 presents information about the principal balances of off-balance sheet loans that were sold or securitized, including residential mortgage loans sold to FNMA, FHLMC, GNMA and other investors, for which we have some form of continuing involvement (primarily servicer). Delinquent loans include loans 90 days or more past due and loans in bankruptcy, regardless of delinquency status. For loans sold or securitized where servicing is our only form of continuing involvement, we would only experience a loss if we were required to repurchase a delinquent loan or foreclosed asset due to a breach in representations and warranties associated with our loan sale or servicing contracts.



Table 7.6: Off-Balance Sheet Loans Sold or Securitized
 
 
 
 
 
 
 
 
 
Net charge-offs
 
 
Total loans
 
 
Delinquent loans and foreclosed assets (1)
 
 
Quarter ended Mar 31,
 
(in millions)
Mar 31, 2016

 
Dec 31, 2015

 
Mar 31, 2016

 
Dec 31, 2015

 
2016

 
2015

Commercial:
 
 
 
 
 
 
 
 
 
 
 
Real estate mortgage
$
113,069

 
110,815

 
2,730

 
6,670

 
83

 
52

Total commercial
113,069

 
110,815

 
2,730

 
6,670

 
83

 
52

Consumer:
 
 
 
 
 
 
 
 
 
 
 
Real estate 1-4 family first mortgage
1,216,440

 
1,235,662

 
19,725

 
20,904

 
287

 
205

Total consumer
1,216,440

 
1,235,662

 
19,725

 
20,904

 
287

 
205

Total off-balance sheet sold or securitized loans (2)
$
1,329,509

 
1,346,477

 
22,455

 
27,574

 
370

 
257

(1)
Includes $1.9 billion and $5.0 billion of commercial foreclosed assets and $2.1 billion and $2.2 billion of consumer foreclosed assets at March 31, 2016, and December 31, 2015, respectively.
(2)
At March 31, 2016, and December 31, 2015, the table includes total loans of $1.2 trillion at both dates, delinquent loans of $10.9 billion and $12.1 billion, and foreclosed assets of $1.6 billion and $1.7 billion, respectively, for FNMA, FHLMC and GNMA. Net charge-offs exclude loans sold to FNMA, FHLMC and GNMA as we do not service or manage the underlying real estate upon foreclosure and, as such, do not have access to net charge-off information.

102

Note 7: Securitizations and Variable Interest Entities (continued)

Transactions with Consolidated VIEs and Secured Borrowings
Table 7.7 presents a summary of financial assets and liabilities for asset transfers accounted for as secured borrowings and involvements with consolidated VIEs. “Assets” are presented using GAAP measurement methods, which may include fair value, credit impairment or other adjustments, and therefore in
 
some instances will differ from “Total VIE assets.” For VIEs that obtain exposure synthetically through derivative instruments, the remaining notional amount of the derivative is included in “Total VIE assets.” On the consolidated balance sheet, we separately disclose the consolidated assets of certain VIEs that can only be used to settle the liabilities of those VIEs.


Table 7.7: Transactions with Consolidated VIEs and Secured Borrowings
 
 
 
Carrying value
 
(in millions)
Total VIE
assets

 
Assets

 
Liabilities

 
Noncontrolling
interests

 
Net assets

March 31, 2016
 
 
 
 
 
 
 
 
 
Secured borrowings:
 
 
 
 
 
 
 
 
 
Municipal tender option bond securitizations
$
2,206

 
1,725

 
(1,459
)
 

 
266

Residential mortgage securitizations
4,473

 
4,619

 
(4,569
)
 

 
50

Total secured borrowings
6,679

 
6,344

 
(6,028
)
 

 
316

Consolidated VIEs:
 
 
 
 
 
 
 
 
 
Commercial and industrial loans and leases
9,532

 
9,532

 
(3,502
)
 
(11
)
 
6,019

Nonconforming residential mortgage loan securitizations
3,936

 
3,500

 
(1,186
)
 

 
2,314

Commercial real estate loans
1,195

 
1,195

 

 

 
1,195

Structured asset finance
49

 
18

 
(15
)
 

 
3

Investment funds (1)
679

 
679

 
(73
)
 
(115
)
 
491

Other
283

 
271

 
(101
)
 
(76
)
 
94

Total consolidated VIEs
15,674

 
15,195

 
(4,877
)
 
(202
)
 
10,116

Total secured borrowings and consolidated VIEs
$
22,353

 
21,539

 
(10,905
)
 
(202
)
 
10,432

December 31, 2015
 
 
 
 
 
 
 
 
 
Secured borrowings:
 
 
 
 
 
 
 
 
 
Municipal tender option bond securitizations
$
2,818

 
2,400

 
(1,800
)
 

 
600

Residential mortgage securitizations
4,738

 
4,887

 
(4,844
)
 

 
43

Total secured borrowings
7,556

 
7,287

 
(6,644
)
 

 
643

Consolidated VIEs:
 
 
 
 
 
 
 
 
 
Nonconforming residential mortgage loan securitizations
4,134

 
3,654

 
(1,239
)
 

 
2,415

Commercial real estate loans
1,185

 
1,185

 

 

 
1,185

Structured asset finance
54

 
20

 
(18
)
 

 
2

Investment funds
482

 
482

 

 

 
482

Other
305

 
295

 
(101
)
 
(93
)
 
101

Total consolidated VIEs
6,160

 
5,636

 
(1,358
)
 
(93
)
 
4,185

Total secured borrowings and consolidated VIEs
$
13,716

 
12,923

 
(8,002
)
 
(93
)
 
4,828

(1)
Includes investment funds with total VIE assets of $265 million that were considered consolidated VIEs effective January 1, 2016, pursuant to our adoption of ASU 2015-02 (Amendments to the Consolidation Analysis).
COMMERCIAL AND INDUSTRIAL LOANS AND LEASES In conjunction with the GE Capital transactions, on March 1, 2016, we acquired certain consolidated SPE entities. The most significant of these SPEs is a revolving master trust entity that purchases dealer floorplan loans and issues senior and subordinated notes. The senior notes are held by third parties and the subordinated notes and residual equity interests are held by us. At March 31, 2016, total assets held by the master trust were $7.9 billion and the outstanding senior notes were $3.2 billion. The other SPEs acquired include securitization term trust entities, which purchase vendor finance lease and loan assets and issue notes to investors, and a SPE that engages in leasing activities to specific vendors. At March 31, 2016, total assets held by these SPEs were $1.6 billion, with outstanding debt of $261 million. We are the primary beneficiary of these acquired SPEs due to our ability to direct the most significant activities of the SPEs, primarily through our role as servicer, and because we hold variable interests that are considered significant.
 
INVESTMENT FUNDS Our adoption of ASU 2015-02 (Amendments to the Consolidation Analysis) changed the consolidation analysis for certain investment funds. We consolidate certain investment funds because we have both the power to manage fund assets and hold variable interests that are considered significant.

OTHER CONSOLIDATED VIE STRUCTURES In addition to the structure types included in the previous table, at both March 31, 2016, and December 31, 2015, we had approximately $6.0 billion of private placement debt financing issued through a consolidated VIE. The issuance is classified as long-term debt in our consolidated financial statements. At March 31, 2016, we pledged approximately $505 million in loans (principal and interest eligible to be capitalized) and $5.9 billion in available-for-sale securities to collateralize the VIE’s borrowings, compared with $529 million and $5.9 billion, respectively, at December 31, 2015. These assets were not transferred to the VIE, and


103


accordingly we have excluded the VIE from the previous table.
For complete descriptions of our accounting for transfers accounted for as secured borrowings and involvements with consolidated VIEs, see Note 8 (Securitizations and Variable Interest Entities) to Financial Statements in our 2015 Form 10-K.
 


Note 8:  Mortgage Banking Activities

Mortgage banking activities, included in the Community Banking and Wholesale Banking operating segments, consist of residential and commercial mortgage originations, sale activity and servicing.
 
We apply the amortization method to commercial MSRs and apply the fair value method to residential MSRs. Table 8.1 presents the changes in MSRs measured using the fair value method.

Table 8.1: Analysis of Changes in Fair Value MSRs
  
Quarter ended March 31,
 
(in millions)
2016

 
2015

Fair value, beginning of period
$
12,415

 
12,738

Servicing from securitizations or asset transfers (1)
366

 
308

Sales and other (2)

 
(1
)
Net additions
366

 
307

Changes in fair value:
  
 
  
Due to changes in valuation model inputs or assumptions:
  
 
  
Mortgage interest rates (3)
(1,084
)
 
(572
)
Servicing and foreclosure costs (4)
27

 
(18
)
Prepayment estimates and other (5)
100

 
(183
)
Net changes in valuation model inputs or assumptions
(957
)
 
(773
)
Other changes in fair value (6)
(491
)
 
(533
)
Total changes in fair value
(1,448
)
 
(1,306
)
Fair value, end of period
$
11,333

 
11,739

(1)
Includes impacts associated with exercising our right to repurchase delinquent loans from GNMA loan securitization pools.
(2)
Includes sales and transfers of MSRs.
(3)
Includes prepayment speed changes as well as other valuation changes due to changes in mortgage interest rates (such as changes in estimated interest earned on custodial deposit balances).
(4)
Includes costs to service and unreimbursed foreclosure costs.
(5)
Represents changes driven by other valuation model inputs or assumptions including prepayment speed estimation changes and other assumption updates. Prepayment speed estimation changes are influenced by observed changes in borrower behavior and other external factors that occur independent of interest rate changes.
(6)
Represents changes due to collection/realization of expected cash flows over time.
 
Table 8.2 presents the changes in amortized MSRs.
 
 

Table 8.2: Analysis of Changes in Amortized MSRs
  
Quarter ended March 31,
 
(in millions)
2016

 
2015

Balance, beginning of period
$
1,308

 
1,242

Purchases
21

 
22

Servicing from securitizations or asset transfers
97

 
50

Amortization
(67
)
 
(62
)
Balance, end of period (1)
$
1,359

 
1,252

Fair value of amortized MSRs:
  
 
  
Beginning of period
$
1,680

 
1,637

End of period
1,725

 
1,522

(1)
Commercial amortized MSRs are evaluated for impairment purposes by the following risk strata: agency (GSEs) and non-agency. There was no valuation allowance recorded for the periods presented on the commercial amortized MSRs.




104

Note 8: Mortgage Banking Activities (continued)

We present the components of our managed servicing portfolio in Table 8.3 at unpaid principal balance for loans serviced and subserviced for others and at book value for owned loans serviced.
 
 

Table 8.3: Managed Servicing Portfolio
(in billions)
Mar 31, 2016

 
Dec 31, 2015

Residential mortgage servicing:
  

 
  

Serviced for others
$
1,280

 
1,300

Owned loans serviced
342

 
345

Subserviced for others
4

 
4

Total residential servicing
1,626

 
1,649

Commercial mortgage servicing:
  
 
  
Serviced for others
485

 
478

Owned loans serviced
125

 
122

Subserviced for others
8

 
7

Total commercial servicing
618

 
607

Total managed servicing portfolio
$
2,244

 
2,256

Total serviced for others
$
1,765

 
1,778

Ratio of MSRs to related loans serviced for others
0.72
%
 
0.77

 
Table 8.4 presents the components of mortgage banking noninterest income. 

Table 8.4: Mortgage Banking Noninterest Income
  
 
Quarter ended March 31,
 
(in millions)
 
2016

 
2015

Servicing income, net:
 
 
 
 
Servicing fees:
 
 
 
 
Contractually specified servicing fees
 
$
954

 
1,020

Late charges
 
48

 
53

Ancillary fees
 
61

 
71

Unreimbursed direct servicing costs (1)
 
(153
)
 
(134
)
Net servicing fees
 
910

 
1,010

Changes in fair value of MSRs carried at fair value:
 
 
 
 
Due to changes in valuation model inputs or assumptions (2)
(A)
(957
)
 
(773
)
Other changes in fair value (3)
 
(491
)
 
(533
)
Total changes in fair value of MSRs carried at fair value
 
(1,448
)
 
(1,306
)
Amortization
 
(67
)
 
(62
)
Net derivative gains from economic hedges (4)
(B)
1,455

 
881

Total servicing income, net
 
850

 
523

Net gains on mortgage loan origination/sales activities
 
748

 
1,024

Total mortgage banking noninterest income
 
$
1,598

 
1,547

Market-related valuation changes to MSRs, net of hedge results (2)(4)
(A)+(B)
$
498

 
108

(1)
Primarily associated with foreclosure expenses and unreimbursed interest advances to investors.
(2)
Refer to the changes in fair value of MSRs table in this Note for more detail.
(3)
Represents changes due to collection/realization of expected cash flows over time.
(4)
Represents results from economic hedges used to hedge the risk of changes in fair value of MSRs. See Note 12 (Derivatives Not Designated as Hedging Instruments) for additional discussion and detail.


105


Table 8.5 summarizes the changes in our liability for mortgage loan repurchase losses. This liability is in “Accrued expenses and other liabilities” in our consolidated balance sheet and the provision for repurchase losses reduces net gains on mortgage loan origination/sales activities in “Mortgage banking” in our consolidated income statement.
Because of the uncertainty in the various estimates underlying the mortgage repurchase liability, there is a range of losses in excess of the recorded mortgage repurchase liability that is reasonably possible. The estimate of the range of possible loss for representations and warranties does not represent a probable
 
loss, and is based on currently available information, significant judgment, and a number of assumptions that are subject to change. The high end of this range of reasonably possible losses exceeded our recorded liability by $274 million at March 31, 2016, and was determined based upon modifying the assumptions (particularly to assume significant changes in investor repurchase demand practices) used in our best estimate of probable loss to reflect what we believe to be the high end of reasonably possible adverse assumptions. 

Table 8.5: Analysis of Changes in Liability for Mortgage Loan Repurchase Losses
  
Quarter ended March 31,
 
(in millions)
2016

 
2015

Balance, beginning of period
$
378

 
615

Provision for repurchase losses:
 
 
 
Loan sales
7

 
10

Change in estimate (1)
(19
)
 
(26
)
Net reductions
(12
)
 
(16
)
Losses
(11
)
 
(13
)
Balance, end of period
$
355

 
586

(1)
Results from changes in investor demand and mortgage insurer practices, credit deterioration and changes in the financial stability of correspondent lenders.



106


Note 9:  Intangible Assets
Table 9.1 presents the gross carrying value of intangible assets and accumulated amortization.

Table 9.1: Intangible Assets
  
March 31, 2016
 
 
December 31, 2015
 
(in millions)
Gross
carrying
value

 
Accumulated
amortization

 
Net
carrying
value

 
Gross
carrying
value

 
Accumulated
amortization

 
Net
carrying
value

Amortized intangible assets (1):
 
 
 
 
 
 
 
 
 
 
 
MSRs (2)
$
3,346

 
(1,987
)
 
1,359

 
3,228

 
(1,920
)
 
1,308

Core deposit intangibles
12,834

 
(10,525
)
 
2,309

 
12,834

 
(10,295
)
 
2,539

Customer relationship and other intangibles
4,107

 
(2,616
)
 
1,491

 
3,163

 
(2,549
)
 
614

Total amortized intangible assets
$
20,287

 
(15,128
)
 
5,159

 
19,225

 
(14,764
)
 
4,461

Unamortized intangible assets:
 
 
 
 
 
 
 
 
 
 
 
MSRs (carried at fair value) (2)
$
11,333

 
 
 
 
 
12,415

 
 
 
 
Goodwill
27,003

 
 
 
 
 
25,529

 
 
 
 
Trademark
14

 
 
 
 
 
14

 
 
 
 
(1)
Excludes fully amortized intangible assets.
(2)
See Note 8 (Mortgage Banking Activities) for additional information on MSRs.

Table 9.2 provides the current year and estimated future amortization expense for amortized intangible assets. We based our projections of amortization expense shown below on existing
 
asset balances at March 31, 2016. Future amortization expense may vary from these projections.

Table 9.2: Amortization Expense for Intangible Assets
(in millions)
 
Amortized MSRs

 
Core deposit
intangibles

 
Customer
relationship
and other
intangibles

 
Total

Three months ended March 31, 2016
(actual)
$
67

 
230

 
67

 
364

Estimate for the remainder of 2016
 
$
200

 
689

 
258

 
1,147

Estimate for year ended December 31,
 
 
 
 
 
 
 
2017
 
223

 
851

 
349

 
1,423

2018
 
180

 
769

 
330

 
1,279

2019
 
160

 

 
134

 
294

2020
 
146

 

 
108

 
254

2021
 
123

 

 
97

 
220


For our goodwill impairment analysis, we allocate all of the goodwill to the individual operating segments. We identify reporting units that are one level below an operating segment (referred to as a component), and distinguish these reporting units based on how the segments and components are managed, taking into consideration the economic characteristics, nature of the products and customers of the components. At the time we
 
acquire a business, we allocate goodwill to applicable reporting units based on their relative fair value, and if we have a significant business reorganization, we may reallocate the goodwill. See Note 18 (Operating Segments) for further information on management reporting.
Table 9.3 shows the allocation of goodwill to our reportable operating segments for purposes of goodwill impairment testing.

Table 9.3: Goodwill
(in millions)
Community
Banking

 
Wholesale
Banking

 
Wealth and Investment Management

 
Consolidated
Company

December 31, 2014 and March 31, 2015
$
16,870

 
7,633

 
1,202


25,705

December 31, 2015
$
16,849

 
7,475

 
1,205

 
25,529

Reduction in goodwill related to divested businesses and other

 
(58
)
 

 
(58
)
Goodwill from business combinations

 
1,532

 

 
1,532

March 31, 2016
$
16,849

 
8,949

 
1,205

 
27,003




107


Note 10:  Guarantees, Pledged Assets and Collateral
Guarantees are contracts that contingently require us to make payments to a guaranteed party based on an event or a change in an underlying asset, liability, rate or index. Guarantees are generally in the form of standby letters of credit, securities lending and other indemnifications, written put options, recourse obligations, and other types of arrangements. For complete
 
descriptions of our guarantees, see Note 14 (Guarantees, Pledged Assets and Collateral) to Financial Statements in our 2015 Form 10-K. Table 10.1 shows carrying value, maximum exposure to loss on our guarantees and the related non-investment grade amounts.
 

Table 10.1: Guarantees – Carrying Value and Maximum Exposure to Loss
  
  

 
Maximum exposure to loss
 
(in millions)
Carrying
value

 
Expires in
one year
or less

 
Expires after
one year
through
three years

 
Expires after
three years
through
five years

 
Expires
after five
years

 
Total

 
Non-
investment
grade

March 31, 2016
 
 
 
 
 
 
 
 
 
 
 
 
 
Standby letters of credit (1)
$
40

 
16,911

 
8,129

 
3,782

 
2,249

 
31,071

 
9,343

Securities lending and other indemnifications (2)

 

 

 

 
1,160

 
1,160

 

Written put options (3)
140

 
8,964

 
7,054

 
4,356

 
1,499

 
21,873

 
11,376

Loans and MHFS sold with recourse (4)
67

 
108

 
709

 
703

 
7,876

 
9,396

 
6,210

Factoring guarantees (5)

 
771

 

 

 

 
771

 
771

Other guarantees
9

 
37

 
23

 
18

 
2,515

 
2,593

 
37

Total guarantees
$
256

 
26,791

 
15,915

 
8,859

 
15,299

 
66,864

 
27,737

December 31, 2015
 
 
 
 
 
 
 
 
 
 
 
 
 
Standby letters of credit (1)
$
38

 
16,360

 
9,618

 
4,116

 
642

 
30,736

 
8,981

Securities lending and other indemnifications (2)

 

 

 

 
1,841

 
1,841

 

Written put options (3)
371

 
7,387

 
6,463

 
4,505

 
1,440

 
19,795

 
9,583

Loans and MHFS sold with recourse (4)
62

 
112

 
723

 
690

 
6,434

 
7,959

 
4,864

Factoring guarantees (5)

 
1,598

 

 

 

 
1,598

 
1,598

Other guarantees
28

 
62

 
17

 
17

 
2,482

 
2,578

 
53

Total guarantees
$
499

 
25,519

 
16,821

 
9,328

 
12,839

 
64,507

 
25,079

(1)
Total maximum exposure to loss includes direct pay letters of credit (DPLCs) of $11.6 billion and $11.8 billion at March 31, 2016, and December 31, 2015, respectively. We issue DPLCs to provide credit enhancements for certain bond issuances. Beneficiaries (bond trustees) may draw upon these instruments to make scheduled principal and interest payments, redeem all outstanding bonds because a default event has occurred, or for other reasons as permitted by the agreement. We also originate multipurpose lending commitments under which borrowers have the option to draw on the facility in one of several forms, including as a standby letter of credit. Total maximum exposure to loss includes the portion of these facilities for which we have issued standby letters of credit under the commitments.
(2)
Includes indemnifications provided to certain third-party clearing agents. Outstanding customer obligations under these arrangements were $208 million and $352 million with related collateral of $952 million and $1.5 billion at March 31, 2016, and December 31, 2015, respectively. Estimated maximum exposure to loss was $1.2 billion and $1.8 billion as of the same periods, respectively.
(3)
Written put options, which are in the form of derivatives, are also included in the derivative disclosures in Note 12 (Derivatives).
(4)
Represent recourse provided, predominantly to the GSEs, on loans sold under various programs and arrangements. Under these arrangements, we repurchased $1 million of loans associated with these agreements in both first quarter 2016 and 2015.
(5)
Consists of guarantees made under certain factoring arrangements to purchase trade receivables from third parties, generally upon their request, if receivable debtors default on their payment obligations.

“Maximum exposure to loss” and “Non-investment grade” are required disclosures under GAAP. Non-investment grade represents those guarantees on which we have a higher risk of being required to perform under the terms of the guarantee. If the underlying assets under the guarantee are non-investment grade (that is, an external rating that is below investment grade or an internal credit default grade that is equivalent to a below investment grade external rating), we consider the risk of performance to be high. Internal credit default grades are determined based upon the same credit policies that we use to evaluate the risk of payment or performance when making loans and other extensions of credit. These credit policies are further described in Note 5 (Loans and Allowance for Credit Losses).
 
Maximum exposure to loss represents the estimated loss that would be incurred under an assumed hypothetical circumstance, despite what we believe is its extremely remote possibility, where the value of our interests and any associated collateral declines to zero. Maximum exposure to loss estimates in the table above do not reflect economic hedges or collateral we could use to offset or recover losses we may incur under our guarantee agreements. Accordingly, this required disclosure is not an indication of expected loss. We believe the carrying value, which is either fair value for derivative-related products or the allowance for lending-related commitments, is more representative of our exposure to loss than maximum exposure to loss.



108

Note 10: Guarantees, Pledge Assets and Collateral (continued)

Pledged Assets
As part of our liquidity management strategy, we pledge assets to secure trust and public deposits, borrowings and letters of credit from the FHLB and FRB, securities sold under agreements to repurchase (repurchase agreements), securities lending arrangements, and for other purposes as required or permitted by law or insurance statutory requirements. The types of collateral we pledge include securities issued by federal agencies, GSEs, domestic and foreign companies and various commercial and consumer loans. Table 10.2 provides the total carrying amount of pledged assets by asset type. The table excludes
 
pledged consolidated VIE assets of $15.2 billion and $5.6 billion at March 31, 2016, and December 31, 2015, respectively, which can only be used to settle the liabilities of those entities. The table also excludes $6.3 billion and $7.3 billion in assets pledged in transactions accounted for as secured borrowings at March 31, 2016, and December 31, 2015, respectively. See Note 7 (Securitizations and Variable Interest Entities) for additional information on consolidated VIE assets and secured borrowings.
 

Table 10.2: Pledged Assets
(in millions)
Mar 31,
2016

 
Dec 31,
2015

Trading assets and other (1)
$
87,524

 
73,396

Investment securities (2)
91,213

 
113,912

Mortgages held for sale and Loans (3)
484,187

 
453,058

Total pledged assets
$
662,924

 
640,366

(1)
Represent assets pledged to collateralize repurchase agreements and other securities financings. Balance includes $87.0 billion and $73.0 billion at March 31, 2016, and December 31, 2015, respectively, under agreements that permit the secured parties to sell or repledge the collateral.
(2)
Includes carrying value of $5.5 billion and $6.5 billion (fair value of $5.5 billion and $6.5 billion) in collateral for repurchase agreements at March 31, 2016, and December 31, 2015, respectively, which are pledged under agreements that do not permit the secured parties to sell or repledge the collateral. Also includes $12.9 billion and $13.0 billion in collateral pledged under repurchase agreements at March 31, 2016, and December 31, 2015, respectively, that permit the secured parties to sell or repledge the collateral. Substantially all other pledged securities are pursuant to agreements that do not permit the secured party to sell or repledge the collateral.
(3)
Includes mortgages held for sale of $9.9 billion and $8.7 billion at March 31, 2016, and December 31, 2015, respectively. Balance consists of mortgages held for sale and loans that are pledged under agreements that do not permit the secured parties to sell or repledge the collateral. Amounts exclude $938 million and $1.3 billion at March 31, 2016, and December 31, 2015, respectively, of pledged loans recorded on our balance sheet representing certain delinquent loans that are eligible for repurchase primarily from GNMA loan securitizations. See Note 7 (Securitizations and Variable Interest Entities) for additional information.



109


Securities Financing Activities
We enter into resale and repurchase agreements and securities borrowing and lending agreements (collectively, “securities financing activities”) primarily to finance inventory positions, acquire securities to cover short trading positions, accommodate customers’ financing needs, and settle other securities obligations. These activities are conducted through our broker dealer subsidiaries and to a lesser extent through other bank entities. The majority of our securities financing activities involve high quality, liquid securities such as U.S. Treasury securities and government agency securities, and to a lesser extent, less liquid securities, including equity securities, corporate bonds and asset-backed securities. We account for these transactions as collateralized financings in which we typically receive or pledge securities as collateral. We believe these financing transactions generally do not have material credit risk given the collateral provided and the related monitoring processes.

OFFSETTING OF RESALE AND REPURCHASE AGREEMENTS AND SECURITIES BORROWING AND LENDING AGREEMENTS Table 10.3 presents resale and repurchase agreements subject to master repurchase agreements (MRA) and securities borrowing and lending agreements subject to master securities lending agreements (MSLA). We account for transactions subject to these agreements as collateralized
 
financings, and those with a single counterparty are presented net on our balance sheet, provided certain criteria are met that permit balance sheet netting. Most transactions subject to these agreements do not meet those criteria and thus are not eligible for balance sheet netting.
Collateral we pledged consists of non-cash instruments, such as securities or loans, and is not netted on the balance sheet against the related liability. Collateral we received includes securities or loans and is not recognized on our balance sheet. Collateral pledged or received may be increased or decreased over time to maintain certain contractual thresholds as the assets underlying each arrangement fluctuate in value. Generally, these agreements require collateral to exceed the asset or liability recognized on the balance sheet. The following table includes the amount of collateral pledged or received related to exposures subject to enforceable MRAs or MSLAs. While these agreements are typically over-collateralized, U.S. GAAP requires disclosure in this table to limit the amount of such collateral to the amount of the related recognized asset or liability for each counterparty.
In addition to the amounts included in Table 10.3, we also have balance sheet netting related to derivatives that is disclosed in Note 12 (Derivatives).
 

Table 10.3: Offsetting – Resale and Repurchase Agreements
(in millions)
Mar 31,
2016

 
Dec 31,
2015

Assets:
  
 
  
Resale and securities borrowing agreements
  
 
  
Gross amounts recognized
$
82,400

 
74,935

Gross amounts offset in consolidated balance sheet (1)
(11,653
)
 
(9,158
)
Net amounts in consolidated balance sheet (2)
70,747

 
65,777

Collateral not recognized in consolidated balance sheet (3)
(69,933
)
 
(65,035
)
Net amount (4)
$
814

 
742

Liabilities:
  
 
  
Repurchase and securities lending agreements
  
 
  
Gross amounts recognized (5)
$
104,066

 
91,278

Gross amounts offset in consolidated balance sheet (1)
(11,653
)
 
(9,158
)
Net amounts in consolidated balance sheet (6)
92,413

 
82,120

Collateral pledged but not netted in consolidated balance sheet (7)
(92,044
)
 
(81,772
)
Net amount (8)
$
369

 
348

(1)
Represents recognized amount of resale and repurchase agreements with counterparties subject to enforceable MRAs or MSLAs that have been offset in the consolidated balance sheet.
(2)
At March 31, 2016, and December 31, 2015, includes $49.6 billion and $45.7 billion, respectively, classified on our consolidated balance sheet in federal funds sold, securities purchased under resale agreements and other short-term investments and $21.1 billion and $20.1 billion, respectively, in loans.
(3)
Represents the fair value of collateral we have received under enforceable MRAs or MSLAs, limited for table presentation purposes to the amount of the recognized asset due from each counterparty. At March 31, 2016, and December 31, 2015, we have received total collateral with a fair value of $93.3 billion and $84.9 billion, respectively, all of which, we have the right to sell or repledge. These amounts include securities we have sold or repledged to others with a fair value of $57.8 billion at March 31, 2016, and $51.1 billion at December 31, 2015.
(4)
Represents the amount of our exposure that is not collateralized and/or is not subject to an enforceable MRA or MSLA.
(5)
For additional information on underlying collateral and contractual maturities, see the "Repurchase and Securities Lending Agreements" section in this Note.
(6)
Amount is classified in short-term borrowings on our consolidated balance sheet.
(7)
Represents the fair value of collateral we have pledged, related to enforceable MRAs or MSLAs, limited for table presentation purposes to the amount of the recognized liability owed to each counterparty. At March 31, 2016, and December 31, 2015, we have pledged total collateral with a fair value of $105.9 billion and $92.9 billion, respectively, of which, the counterparty does not have the right to sell or repledge $6.0 billion as of March 31, 2016 and $6.9 billion as of December 31, 2015.
(8)
Represents the amount of our obligation that is not covered by pledged collateral and/or is not subject to an enforceable MRA or MSLA.


110

Note 10: Guarantees, Pledge Assets and Collateral (continued)

REPURCHASE AND SECURITIES LENDING AGREEMENTS Securities sold under repurchase agreements and securities lending arrangements are effectively short-term collateralized borrowings. In these transactions, we receive cash in exchange for transferring securities as collateral and recognize an obligation to reacquire the securities for cash at the transaction's maturity. These types of transactions create risks, including (1) the counterparty may fail to return the securities at maturity, (2) the fair value of the securities transferred may decline below the amount of our obligation to reacquire the securities, and therefore create an obligation for us to pledge additional amounts, and (3) the counterparty may accelerate the maturity
 
on demand requiring us to reacquire the security prior to contractual maturity. We attempt to mitigate these risks by the fact that the majority of our securities financing activities involve highly liquid securities, we underwrite and monitor the financial strength of our counterparties, we monitor the fair value of collateral pledged relative to contractually required repurchase amounts, and we monitor that our collateral is properly returned through the clearing and settlement process in advance of our cash repayment. Table 10.4 provides the underlying collateral types of our gross obligations under repurchase and securities lending agreements.

Table 10.4: Underlying Collateral Types of Gross Obligations
  
 
Mar 31,
2016

 
Dec 31,
2015

(in millions)
 
Total Gross Obligation
 
Repurchase agreements:
 
 
 
 
Securities of U.S. Treasury and federal agencies
 
$
41,678

 
32,254

Securities of U.S. States and political subdivisions
 
133

 
7

Federal agency mortgage-backed securities
 
41,530

 
37,033

Non-agency mortgage-backed securities
 
1,531

 
1,680

Corporate debt securities
 
5,072

 
4,674

Asset-backed securities
 
2,399

 
2,275

Equity securities
 
833

 
2,457

Other
 
884

 
1,162

Total repurchases
 
94,060

 
81,542

Securities lending:
 
 
 
 
Securities of U.S. Treasury and federal agencies
 
199

 
61

Federal agency mortgage-backed securities
 
69

 
76

Corporate debt securities
 
879

 
899

Equity securities (1)
 
8,859

 
8,700

Total securities lending
 
10,006

 
9,736

Total repurchases and securities lending
 
$
104,066

 
91,278

(1)
Equity securities are generally exchange traded and either re-hypothecated under margin lending agreements or obtained through contemporaneous securities borrowing transactions with other counterparties.

Table 10.5 provides the contractual maturities of our gross obligations under repurchase and securities lending agreements.

Table 10.5: Contractual Maturities of Gross Obligations
(in millions)
Overnight/Continuous

 
Up to 30 days

 
30-90 days

 
>90 days

 
Total Gross Obligation

March 31, 2016
 
 
 
 
 
 
 
 
 
Repurchase agreements
$
67,831

 
17,622

 
7,507

 
1,100

 
94,060

Securities lending
8,001

 
158

 
1,847

 

 
10,006

Total repurchases and securities lending (1)
$
75,832

 
17,780

 
9,354

 
1,100

 
104,066

December 31, 2015
 
Repurchase agreements
$
58,021

 
19,561

 
2,935

 
1,025

 
81,542

Securities lending
7,845

 
362

 
1,529

 

 
9,736

Total repurchases and securities lending (1)
$
65,866

 
19,923

 
4,464

 
1,025

 
91,278

(1)
Repurchase and securities lending transactions are largely conducted under enforceable master lending agreements that allow either party to terminate the transaction on demand. These transactions have been reported as continuous obligations unless the MRA or MSLA has been modified with an overriding agreement that specifies an alternative termination date.



111


Note 11:  Legal Actions
The following supplements our discussion of certain matters previously reported in Note 15 (Legal Actions) to Financial Statements in our 2015 Form 10-K for events occurring during first quarter 2016.

FHA INSURANCE LITIGATION On October 9, 2012, the United States filed a complaint, captioned United States of America v. Wells Fargo Bank, N.A., in the U.S. District Court for the Southern District of New York. The complaint makes claims with respect to Wells Fargo's Federal Housing Administration (FHA) lending program for the period 2001 to 2010. The complaint alleges, among other allegations, that Wells Fargo improperly certified certain FHA mortgage loans for United States Department of Housing and Urban Development (HUD) insurance that did not qualify for the program, and therefore Wells Fargo should not have received insurance proceeds from HUD when some of the loans later defaulted. The complaint further alleges Wells Fargo knew some of the mortgages did not qualify for insurance and did not disclose the deficiencies to HUD before making insurance claims. On February 1, 2016, Wells Fargo reached an agreement in principle with the United States Department of Justice, the United States Attorney’s Office for the Southern District of New York, the United States Attorney’s Office for the Northern District of California, and HUD (collectively, the Federal Government) to pay $1.2 billion to resolve the complaint’s allegations, as well as other potential civil claims relating to Wells Fargo’s FHA lending activities for other periods. The parties arrived at a final settlement which was entered by the court on April 8, 2016.

ORDER OF POSTING LITIGATION A series of putative class actions have been filed against Wachovia Bank, N.A. and Wells Fargo Bank, N.A., as well as many other banks, challenging the "high to low" order in which the banks post debit card transactions to consumer deposit accounts. There are currently several such cases pending against Wells Fargo Bank (including the Wachovia Bank cases to which Wells Fargo succeeded), most of which have been consolidated in multi- district litigation proceedings (the "MDL proceedings") in the U.S. District Court for the Southern District of Florida. The court in the MDL proceedings has certified a class of putative plaintiffs and Wells Fargo has moved to compel arbitration of the claims of unnamed class members.
 
On August 10, 2010, the U.S. District Court for the Northern District of California issued an order in Gutierrez v. Wells Fargo Bank, N.A., a case that was not consolidated in the MDL proceedings described above, enjoining the bank’s use of the high to low posting method for debit card transactions with respect to the plaintiff class of California depositors, directing the bank to establish a different posting methodology and ordering remediation of approximately $203 million. On October 26, 2010, a final judgment was entered in Gutierrez. Following appellate proceedings which reversed in part and affirmed in part the trial court's judgment, Wells Fargo filed a petition for writ of certiorari to the United States Supreme Court on April 10, 2015. The Supreme Court denied that petition on April 4, 2016.

OUTLOOK  When establishing a liability for contingent litigation losses, the Company determines a range of potential losses for each matter that is both probable and estimable, and records the amount it considers to be the best estimate within the range. The high end of the range of reasonably possible potential litigation losses in excess of the Company’s liability for probable and estimable losses was approximately $1.1 billion as of March 31, 2016. For these matters and others where an unfavorable outcome is reasonably possible but not probable, there may be a range of possible losses in excess of the established liability that cannot be estimated. Based on information currently available, advice of counsel, available insurance coverage and established reserves, Wells Fargo believes that the eventual outcome of the actions against Wells Fargo and/or its subsidiaries, including the matters described above, will not, individually or in the aggregate, have a material adverse effect on Wells Fargo’s consolidated financial position. However, in the event of unexpected future developments, it is possible that the ultimate resolution of those matters, if unfavorable, may be material to Wells Fargo’s results of operations for any particular period.


112

Note 12: Derivatives (continued)

Note 12:  Derivatives
We primarily use derivatives to manage exposure to market risk, including interest rate risk, credit risk and foreign currency risk, and to assist customers with their risk management objectives. We designate certain derivatives as hedging instruments in a qualifying hedge accounting relationship (fair value or cash flow hedge). Our remaining derivatives consist of economic hedges that do not qualify for hedge accounting and derivatives held for customer accommodation, trading, or other purposes. For more information on our derivative activities, see Note 16 (Derivatives) to Financial Statements in our 2015 Form 10-K.
Table 12.1 presents the total notional or contractual amounts and fair values for our derivatives. Derivative transactions can be
 
measured in terms of the notional amount, but this amount is not recorded on the balance sheet and is not, when viewed in isolation, a meaningful measure of the risk profile of the instruments. The notional amount is generally not exchanged but is used only as the basis on which interest and other payments are determined. Derivatives designated as qualifying hedging instruments and economic hedges are recorded on the balance sheet at fair value in other assets or other liabilities. Customer accommodation, trading and other derivatives are recorded on the balance sheet at fair value in trading assets, other assets or other liabilities.

Table 12.1: Notional or Contractual Amounts and Fair Values of Derivatives
 
March 31, 2016
 
 
December 31, 2015
 
 
Notional or
contractual
amount

 
 
 
Fair value

 
Notional or
contractual
amount

 
 
 
Fair value

(in millions)
 
Derivative
assets

 
Derivative
liabilities

 
 
Derivative
assets

 
Derivative
liabilities

Derivatives designated as hedging instruments
 
 
 
 
 
 
 
 
 
 
 
Interest rate contracts (1)
$
199,382

 
12,024

 
3,651

 
191,684

 
7,477

 
2,253

Foreign exchange contracts (1)
25,226

 
1,028

 
1,345

 
25,115

 
378

 
2,494

Total derivatives designated as qualifying hedging instruments
 
 
13,052

 
4,996

 
 
 
7,855

 
4,747

Derivatives not designated as hedging instruments
 
 
 
 
 
 
 
 
 
 
 
Economic hedges:
 
 
 
 
 
 
 
 
 
 
 
Interest rate contracts (2)
238,246

 
608

 
683

 
211,375

 
195

 
315

Equity contracts
7,553

 
491

 
247

 
7,427

 
531

 
47

Foreign exchange contracts
14,103

 
86

 
424

 
16,407

 
321

 
100

Subtotal
 
 
1,185

 
1,354

 
 
 
1,047

 
462

Customer accommodation, trading and
 
 
 
 
 
 
 
 
 
 
 
other derivatives:
 
 
 
 
 
 
 
 
 
 
 
Interest rate contracts
4,862,967

 
87,545

 
87,127

 
4,685,898

 
55,053

 
55,409

Commodity contracts
47,675

 
3,706

 
4,499

 
47,571

 
4,659

 
5,519

Equity contracts
145,580

 
6,623

 
5,512

 
139,956

 
7,068

 
4,761

Foreign exchange contracts
344,333

 
8,029

 
8,366

 
295,962

 
8,248

 
8,339

Credit contracts – protection sold
9,486

 
62

 
497

 
10,544

 
83

 
541

Credit contracts – protection purchased
19,721

 
514

 
79

 
18,018

 
567

 
88

Other contracts
964

 

 
77

 
1,041

 

 
58

Subtotal
 
 
106,479

 
106,157

 
 
 
75,678

 
74,715

Total derivatives not designated as hedging instruments
 
 
107,664

 
107,511

 
 
 
76,725

 
75,177

Total derivatives before netting
 
 
120,716

 
112,507

 
 
 
84,580

 
79,924

Netting (3)
 
 
(100,673
)
 
(97,323
)
 
 
 
(66,924
)
 
(66,004
)
Total
 
 
$
20,043

 
15,184

 
 
 
17,656

 
13,920

(1)
Notional amounts presented exclude $1.9 billion of interest rate contracts at both March 31, 2016 and December 31, 2015, for certain derivatives that are combined for designation as a hedge on a single instrument. The notional amount for foreign exchange contracts at March 31, 2016, and December 31, 2015 excludes $8.1 billion and $7.8 billion, respectively, for certain derivatives that are combined for designation as a hedge on a single instrument.
(2)
Includes economic hedge derivatives used to hedge the risk of changes in the fair value of residential MSRs, MHFS, loans, derivative loan commitments and other interests held.
(3)
Represents balance sheet netting of derivative asset and liability balances, related cash collateral and portfolio level counterparty valuation adjustments. See the next table in this Note for further information.


113


Table 12.2 provides information on the gross fair values of derivative assets and liabilities, the balance sheet netting adjustments and the resulting net fair value amount recorded on our balance sheet, as well as the non-cash collateral associated with such arrangements. We execute substantially all of our derivative transactions under master netting arrangements. We reflect all derivative balances and related cash collateral subject to enforceable master netting arrangements on a net basis within the balance sheet. The “Gross amounts recognized” column in the following table includes $104.9 billion and $106.1 billion of gross derivative assets and liabilities, respectively, at March 31, 2016, and $69.9 billion and $74.0 billion, respectively, at December 31, 2015, with counterparties subject to enforceable master netting arrangements that are carried on the balance sheet net of offsetting amounts. The remaining gross derivative assets and liabilities of $15.8 billion and $6.4 billion, respectively, at March 31, 2016 and $14.6 billion and $5.9 billion, respectively, at December 31, 2015, include those with counterparties subject to master netting arrangements for which we have not assessed the enforceability because they are with counterparties where we do not currently have positions to offset, those subject to master netting arrangements where we have not been able to confirm the enforceability and those not subject to master netting arrangements. As such, we do not net derivative balances or collateral within the balance sheet for these counterparties.
We determine the balance sheet netting adjustments based on the terms specified within each master netting arrangement. We disclose the balance sheet netting amounts within the column titled “Gross amounts offset in consolidated balance sheet.” Balance sheet netting adjustments are determined at the counterparty level for which there may be multiple contract types. For disclosure purposes, we allocate these adjustments to the contract type for each counterparty proportionally based upon the “Gross amounts recognized” by counterparty. As a result, the net amounts disclosed by contract type may not represent the actual exposure upon settlement of the contracts.
 
Balance sheet netting does not include non-cash collateral that we receive and pledge. For disclosure purposes, we present the fair value of this non-cash collateral in the column titled “Gross amounts not offset in consolidated balance sheet (Disclosure-only netting)” within the table. We determine and allocate the Disclosure-only netting amounts in the same manner as balance sheet netting amounts.
The “Net amounts” column within Table 12.2 represents the aggregate of our net exposure to each counterparty after considering the balance sheet and Disclosure-only netting adjustments. We manage derivative exposure by monitoring the credit risk associated with each counterparty using counterparty specific credit risk limits, using master netting arrangements and obtaining collateral. Derivative contracts executed in over-the-counter markets include bilateral contractual arrangements that are not cleared through a central clearing organization but are typically subject to master netting arrangements. The percentage of our bilateral derivative transactions outstanding at period end in such markets, based on gross fair value, is provided within the following table. Other derivative contracts executed in over-the-counter or exchange-traded markets are settled through a central clearing organization and are excluded from this percentage. In addition to the netting amounts included in the table, we also have balance sheet netting related to resale and repurchase agreements that are disclosed within Note 10 (Guarantees, Pledged Assets and Collateral).


114

Note 12: Derivatives (continued)

Table 12.2: Gross Fair Value of Derivative Assets and Liabilities
(in millions)
Gross
amounts
recognized

 
Gross amounts
offset in
consolidated
balance
sheet (1)

 
Net amounts in
consolidated
balance
sheet (2)

 
Gross amounts
not offset in
consolidated
balance sheet
(Disclosure-only
netting) (3)

 
Net
amounts

 
Percent
exchanged in
over-the-counter
market (4)

March 31, 2016
 
 
 
 
 
 
 
 
 
 
 
Derivative assets
 
 
 
 
 
 
 
 
 
 
 
Interest rate contracts
$
100,177

 
(90,552
)
 
9,625

 
(1,101
)
 
8,524

 
30
%
Commodity contracts
3,706

 
(884
)
 
2,822

 
(89
)
 
2,733

 
39

Equity contracts
7,114

 
(2,232
)
 
4,882

 
(525
)
 
4,357

 
51

Foreign exchange contracts
9,143

 
(6,499
)
 
2,644

 
(11
)
 
2,633

 
95

Credit contracts – protection sold
62

 
(57
)
 
5

 

 
5

 
94

Credit contracts – protection purchased
514

 
(449
)
 
65

 
(5
)
 
60

 
99

Total derivative assets
$
120,716

 
(100,673
)
 
20,043

 
(1,731
)
 
18,312

 
  
Derivative liabilities
 
 
 
 
 
 
 
 
 
 
 
Interest rate contracts
$
91,461

 
(85,287
)
 
6,174

 
(4,204
)
 
1,970

 
26
%
Commodity contracts
4,499

 
(875
)
 
3,624

 
(28
)
 
3,596

 
83

Equity contracts
5,759

 
(2,438
)
 
3,321

 
(403
)
 
2,918

 
85

Foreign exchange contracts
10,135

 
(8,262
)
 
1,873

 
(796
)
 
1,077

 
100

Credit contracts – protection sold
497

 
(413
)
 
84

 
(70
)
 
14

 
99

Credit contracts – protection purchased
79

 
(48
)
 
31

 
(5
)
 
26

 
70

Other contracts
77

 

 
77

 

 
77

 
100

Total derivative liabilities
$
112,507

 
(97,323
)
 
15,184

 
(5,506
)
 
9,678

 
  
December 31, 2015
 
 
 
 
 
 
 
 
 
 
 
Derivative assets
 
 
 
 
 
 
 
 
 
 
 
Interest rate contracts
$
62,725

 
(56,612
)
 
6,113

 
(749
)
 
5,364

 
39
%
Commodity contracts
4,659

 
(998
)
 
3,661

 
(76
)
 
3,585

 
35

Equity contracts
7,599

 
(2,625
)
 
4,974

 
(471
)
 
4,503

 
51

Foreign exchange contracts
8,947

 
(6,141
)
 
2,806

 
(34
)
 
2,772

 
98

Credit contracts – protection sold
83

 
(79
)
 
4

 

 
4

 
76

Credit contracts – protection purchased
567

 
(469
)
 
98

 
(2
)
 
96

 
100

Total derivative assets
$
84,580

 
(66,924
)
 
17,656

 
(1,332
)
 
16,324

 
  
Derivative liabilities
 
 
 
 
 
 
 
 
 
 
 
Interest rate contracts
$
57,977

 
(53,259
)
 
4,718

 
(3,543
)
 
1,175

 
35
%
Commodity contracts
5,519

 
(1,052
)
 
4,467

 
(40
)
 
4,427

 
84

Equity contracts
4,808

 
(2,241
)
 
2,567

 
(154
)
 
2,413

 
85

Foreign exchange contracts
10,933

 
(8,968
)
 
1,965

 
(634
)
 
1,331

 
100

Credit contracts – protection sold
541

 
(434
)
 
107

 
(107
)
 

 
100

Credit contracts – protection purchased
88

 
(50
)
 
38

 
(6
)
 
32

 
70

Other contracts
58

 

 
58

 

 
58

 
100

Total derivative liabilities
$
79,924

 
(66,004
)
 
13,920

 
(4,484
)
 
9,436

 
  
(1)
Represents amounts with counterparties subject to enforceable master netting arrangements that have been offset in the consolidated balance sheet, including related cash collateral and portfolio level counterparty valuation adjustments. Counterparty valuation adjustments were $433 million and $375 million related to derivative assets and $89 million and $81 million related to derivative liabilities at March 31, 2016 and December 31, 2015, respectively. Cash collateral totaled $7.8 billion and $4.8 billion, netted against derivative assets and liabilities, respectively, at March 31, 2016, and $5.3 billion and $4.7 billion, respectively, at December 31, 2015.
(2)
Net derivative assets of $10.5 billion and $12.4 billion are classified in Trading assets at March 31, 2016 and December 31, 2015, respectively. $9.5 billion and $5.3 billion are classified in Other assets in the consolidated balance sheet at March 31, 2016 and December 31, 2015, respectively. Net derivative liabilities are classified in Accrued expenses and other liabilities in the consolidated balance sheet.
(3)
Represents non-cash collateral pledged and received against derivative assets and liabilities with the same counterparty that are subject to enforceable master netting arrangements. U.S. GAAP does not permit netting of such non-cash collateral balances in the consolidated balance sheet but requires disclosure of these amounts.
(4)
Represents derivatives executed in over-the-counter markets that are not settled through a central clearing organization. Over-the-counter percentages are calculated based on gross amounts recognized as of the respective balance sheet date. The remaining percentage represents derivatives settled through a central clearing organization, which are executed in either over-the-counter or exchange-traded markets.




115


Fair Value Hedges
We use derivatives to hedge against changes in fair value of certain financial instruments, including available-for-sale debt securities, mortgages held for sale, and long-term debt. For more information on fair value hedges, see Note 16 (Derivatives) to Financial Statements in our 2015 Form 10-K.
Table 12.3 shows the net gains (losses) recognized in the income statement related to derivatives in fair value hedging relationships. The entire derivative gain or loss is included in the
 
assessment of hedge effectiveness for all fair value hedge relationships, except for those involving foreign-currency denominated available-for-sale securities and long-term debt hedged with foreign currency forward derivatives for which the time value component of the derivative gain or loss related to the changes in the difference between the spot and forward price is excluded from the assessment of hedge effectiveness.
 

Table 12.3: Derivatives in Fair Value Hedging Relationships
  
Interest rate
contracts hedging:
 
 
Foreign exchange
contracts hedging:
 
 
Total net
gains
(losses)
on fair
value
hedges

(in millions)
Available-
for-sale
securities

 
Mortgages
held for
sale

 
Long-term
debt

 
Available-
for-sale
securities

 
Long-term
debt

 
Quarter ended March 31, 2016
  

 
  

 
  

 
  

 
  

 
  
Net interest income (expense) recognized on derivatives
$
(181
)
 
(2
)
 
482

 

 
16

 
315

Gains (losses) recorded in noninterest income
  
 
  
 
  
 
  

 
  
 
  
Recognized on derivatives
(1,683
)
 
(37
)
 
3,103

 
(66
)
 
1,618

 
2,935

Recognized on hedged item
1,691

 
33

 
(2,807
)
 
59

 
(1,402
)
 
(2,426
)
Net recognized on fair value hedges (ineffective portion) (1)
$
8


(4
)

296


(7
)

216

 
509

Quarter ended March 31, 2015
  

 
  

 
  

 
  

 
  

 
  

Net interest income (expense) recognized on derivatives
$
(186
)
 
(3
)
 
472

 
1

 
61

 
345

Gains (losses) recorded in noninterest income
  

 
  

 
  

 
  

 
  
 
  
Recognized on derivatives
(666
)
 
(13
)
 
1,258

 
280

 
(1,887
)
 
(1,028
)
Recognized on hedged item
661

 
10

 
(1,150
)
 
(269
)
 
1,949

 
1,201

Net recognized on fair value hedges (ineffective portion) (1)
$
(5
)
 
(3
)
 
108

 
11

 
62

 
173

(1)
Included $(4) million and $(1) million, respectively, for the quarters ended March 31, 2016 and 2015, of the time value component recognized as net interest income (expense) on forward derivatives hedging foreign currency available-for-sale securities and long-term debt that were excluded from the assessment of hedge effectiveness.
Cash Flow Hedges
We use derivatives to hedge certain financial instruments against future interest rate increases and to limit the variability of cash flows on certain financial instruments due to changes in the benchmark interest rate. For more information on cash flow hedges, see Note 16 (Derivatives) to Financial Statements in our 2015 Form 10-K.
Based upon current interest rates, we estimate that $912 million (pre tax) of deferred net gains on derivatives in OCI
 
at March 31, 2016, will be reclassified into net interest income during the next twelve months. Future changes to interest rates may significantly change actual amounts reclassified to earnings. We are hedging our exposure to the variability of future cash flows for all forecasted transactions for a maximum of 7 years.
Table 12.4 shows the net gains (losses) recognized related to derivatives in cash flow hedging relationships.
 

Table 12.4: Derivatives in Cash Flow Hedging Relationships
  
Quarter ended March 31,
 
(in millions)
2016

 
2015

Gains (losses) (pre tax) recognized in OCI on derivatives
1,999

 
952

Gains (pre tax) reclassified from cumulative OCI into net income (1)
256

 
234

Gains (losses) (pre tax) recognized in noninterest income for hedge ineffectiveness (2)
1

 
1

  
(1)
See Note 17 (Other Comprehensive Income) for detail on components of net income.
(2)
None of the change in value of the derivatives was excluded from the assessment of hedge effectiveness. 


116

Note 12: Derivatives (continued)

Derivatives Not Designated as Hedging Instruments
We use economic hedges primarily to hedge the risk of changes in the fair value of certain residential MHFS, certain loans held for investment, residential MSRs measured at fair value, derivative loan commitments and other interests held. The resulting gain or loss on these economic hedge derivatives is reflected in mortgage banking noninterest income, net gains (losses) from equity investments and other noninterest income.
The derivatives used to hedge MSRs measured at fair value, resulted in net derivative gains of $1.5 billion in first quarter 2016, and $881 million in first quarter 2015, which are included in mortgage banking noninterest income. The aggregate fair value of these derivatives was a net asset of $340 million at March 31, 2016, and net liability of $3 million at December 31, 2015. The change in fair value of these derivatives for each period end is due to changes in the underlying market indices and
 
interest rates as well as the purchase and sale of derivative financial instruments throughout the period as part of our dynamic MSR risk management process.
Interest rate lock commitments for mortgage loans that we intend to sell are considered derivatives. The aggregate fair value of derivative loan commitments on the balance sheet was a net asset of $179 million and $56 million at March 31, 2016, and December 31, 2015, respectively, and is included in the caption “Interest rate contracts” under “Customer accommodation, trading and other derivatives” in Table 12.1 in this Note.
For more information on economic hedges and other derivatives, see Note 16 (Derivatives) to Financial Statements in our 2015 Form 10-K. Table 12.5 shows the net gains recognized in the income statement related to derivatives not designated as hedging instruments.
 

Table 12.5: Derivatives Not Designated as Hedging Instruments
  
Quarter ended March 31,
 
(in millions)
2016

 
2015

Net gains (losses) recognized on economic hedges derivatives:
  

 
  

Interest rate contracts
Recognized in noninterest income:
  

 
  

Mortgage banking (1)
865

 
647

Other (2)
(135
)
 
(64
)
Equity contracts (3)
83

 
(20
)
Foreign exchange contracts (2)
(166
)
 
648

Subtotal
647

 
1,211

Net gains (losses) recognized on customer accommodation, trading and other derivatives:
  

 
  

Interest rate contracts
Recognized in noninterest income:
  

 
  

Mortgage banking (4)
465

 
387

Other (5)
(450
)
 
(93
)
Commodity contracts (5)
53

 
31

Equity contracts (5)
20

 
189

Foreign exchange contracts (5)
222

 
110

Credit contracts (5)
(16
)
 
(8
)
Other (5)
(21
)
 
(8
)
Subtotal
273

 
608

Net gains recognized related to derivatives not designated as hedging instruments
920

 
1,819

(1)
Reflected in mortgage banking noninterest income including gains (losses) on the derivatives used as economic hedges of MSRs measured at fair value, interest rate lock commitments and mortgages held for sale.
(2)
Included in other noninterest income.
(3)
Predominantly included in net gains (losses) from equity investments in noninterest income.
(4)
Reflected in mortgage banking noninterest income including gains (losses) on interest rate lock commitments.
(5)
Predominantly included in net gains from trading activities in noninterest income.



117


Credit Derivatives
Credit derivative contracts are arrangements whose value is derived from the transfer of credit risk of a reference asset or entity from one party (the purchaser of credit protection) to another party (the seller of credit protection). We use credit derivatives primarily to assist customers with their risk management objectives. We may also use credit derivatives in structured product transactions or liquidity agreements written to special purpose vehicles. The maximum exposure of sold credit derivatives is managed through posted collateral, purchased credit derivatives and similar products in order to achieve our desired credit risk profile. This credit risk management provides an ability to recover a significant portion of any amounts that would be paid under the sold credit derivatives. We would be
 
required to perform under the noted credit derivatives in the event of default by the referenced obligors. Events of default include events such as bankruptcy, capital restructuring or lack of principal and/or interest payment. In certain cases, other triggers may exist, such as the credit downgrade of the referenced obligors or the inability of the special purpose vehicle for which we have provided liquidity to obtain funding.
Table 12.6 provides details of sold and purchased credit derivatives.

Table 12.6: Sold and Purchased Credit Derivatives
  
  
 
Notional amount
 
 
  
(in millions)
Fair value
liability

 
Protection
sold (A)

 
Protection
sold –
non-
investment
grade

 
Protection
purchased
with
identical
underlyings (B)

 
Net
protection
sold
(A) - (B)

 
Other
protection
purchased

 
Range of
maturities
March 31, 2016
 
 
 
 
 
 
 
 
 
 
 
 
 
Credit default swaps on:
 
 
 
 
 
 
 
 
 
 
 
 
 
Corporate bonds
$
38

 
4,861

 
1,686

 
3,631

 
1,230

 
2,223

 
2016 - 2025
Structured products
247

 
543

 
416

 
375

 
168

 
122

 
2019 - 2047
Credit protection on:
 
 
 
 
 
 
 
 
 
 
 
 
  
Default swap index

 
825

 
183

 
651

 
174

 
1,504

 
2016 - 2021
Commercial mortgage-backed securities index
192

 
719

 

 
631

 
88

 
222

 
2047 - 2058
Asset-backed securities index
18

 
46

 

 
1

 
45

 
70

 
2045 - 2046
Other
2

 
2,492

 
2,492

 

 
2,492

 
10,291

 
2016 - 2025
Total credit derivatives
$
497

 
9,486

 
4,777

 
5,289

 
4,197

 
14,432

 
 
December 31, 2015
 
 
 
 
 
 
 
 
 
 
 
 
 
Credit default swaps on:
 
 
 
 
 
 
 
 
 
 
 
 
 
Corporate bonds
$
44

 
4,838

 
1,745

 
3,602

 
1,236

 
2,272

 
2016 - 2025
Structured products
275

 
598

 
463

 
395

 
203

 
142

 
2017 - 2047
Credit protection on:
 
 
 
 
 
 
 
 
 
 
 
 
 
Default swap index

 
1,727

 
370

 
1,717

 
10

 
960

 
2016 - 2020
Commercial mortgage-backed securities index
203

 
822

 

 
766

 
56

 
316

 
2047 - 2057
Asset-backed securities index
18

 
47

 

 
1

 
46

 
71

 
2045 - 2046
Other
1

 
2,512

 
2,512

 

 
2,512

 
7,776

 
2016 - 2025
Total credit derivatives
$
541

 
10,544

 
5,090

 
6,481

 
4,063

 
11,537

 
 

Protection sold represents the estimated maximum exposure to loss that would be incurred under an assumed hypothetical circumstance, where the value of our interests and any associated collateral declines to zero, without any consideration of recovery or offset from any economic hedges. We believe this hypothetical circumstance to be an extremely remote possibility and accordingly, this required disclosure is not an indication of expected loss. The amounts under non-investment grade represent the notional amounts of those credit derivatives on which we have a higher risk of being required to perform under the terms of the credit derivative and are a function of the underlying assets.
 
We consider the risk of performance to be high if the underlying assets under the credit derivative have an external rating that is below investment grade or an internal credit default grade that is equivalent thereto. We believe the net protection sold, which is representative of the net notional amount of protection sold and purchased with identical underlyings, in combination with other protection purchased, is more representative of our exposure to loss than either non-investment grade or protection sold. Other protection purchased represents additional protection, which may offset the exposure to loss for protection sold, that was not purchased with an identical underlying of the protection sold.



118

Note 12: Derivatives (continued)

Credit-Risk Contingent Features
Certain of our derivative contracts contain provisions whereby if the credit rating of our debt were to be downgraded by certain major credit rating agencies, the counterparty could demand additional collateral or require termination or replacement of derivative instruments in a net liability position. The aggregate fair value of all derivative instruments with such credit-risk-related contingent features that are in a net liability position was $13.7 billion at March 31, 2016, and $12.3 billion at December 31, 2015, for which we posted $10.0 billion and $8.8 billion, respectively, in collateral in the normal course of business. If the credit rating of our debt had been downgraded below investment grade, which is the credit-risk-related contingent feature that if triggered requires the maximum amount of collateral to be posted, on March 31, 2016, or December 31, 2015, we would have been required to post additional collateral of $3.7 billion or $3.6 billion, respectively, or potentially settle the contract in an amount equal to its fair value. Some contracts require that we provide more collateral than the fair value of derivatives that are in a net liability position if a downgrade occurs.
 
 
Counterparty Credit Risk
By using derivatives, we are exposed to counterparty credit risk if counterparties to the derivative contracts do not perform as expected. If a counterparty fails to perform, our counterparty credit risk is equal to the amount reported as a derivative asset on our balance sheet. The amounts reported as a derivative asset are derivative contracts in a gain position, and to the extent subject to legally enforceable master netting arrangements, net of derivatives in a loss position with the same counterparty and cash collateral received. We minimize counterparty credit risk through credit approvals, limits, monitoring procedures, executing master netting arrangements and obtaining collateral, where appropriate. To the extent the master netting arrangements and other criteria meet the applicable requirements, including determining the legal enforceability of the arrangement, it is our policy to present derivative balances and related cash collateral amounts net on the balance sheet. We incorporate credit valuation adjustments (CVA) to reflect counterparty credit risk in determining the fair value of our derivatives. Such adjustments, which consider the effects of enforceable master netting agreements and collateral arrangements, reflect market-based views of the credit quality of each counterparty. Our CVA calculation is determined based on observed credit spreads in the credit default swap market and indices indicative of the credit quality of the counterparties to our derivatives.



119


Note 13:  Fair Values of Assets and Liabilities

We use fair value measurements to record fair value adjustments to certain assets and liabilities and to determine fair value disclosures. Assets and liabilities recorded at fair value on a recurring basis are presented in Table 13.2 in this Note. From time to time, we may be required to measure at fair value other assets on a nonrecurring basis, such as certain residential and commercial MHFS, certain LHFS, loans held for investment, nonmarketable equity investments and certain other assets. These nonrecurring fair value adjustments typically involve application of LOCOM accounting or write-downs of individual assets.
See Note 1 (Summary of Significant Accounting Policies) to Financial Statements in our 2015 Form 10-K for discussion of how we determine fair value. For descriptions of the valuation methodologies we use for assets and liabilities recorded at fair value on a recurring or nonrecurring basis and for estimating fair value for financial instruments that are not recorded at fair value, see Note 17 (Fair Values of Assets and Liabilities) to Financial Statements in our 2015 Form 10-K.
 
FAIR VALUE HIERARCHY  We group our assets and liabilities measured at fair value in three levels based on the markets in which the assets and liabilities are traded and the reliability of the assumptions used to determine fair value. These levels are:
Level 1 – Valuation is based upon quoted prices for identical instruments traded in active markets.
Level 2 – Valuation is based upon quoted prices for similar instruments in active markets, quoted prices for identical or similar instruments in markets that are not active, and model-based valuation techniques for which all significant assumptions are observable in the market.
Level 3 – Valuation is generated from techniques that use significant assumptions that are not observable in the market. These unobservable assumptions reflect estimates of assumptions that market participants would use in pricing the asset or liability. Valuation techniques include use of option pricing models, discounted cash flow models and similar techniques.
 
In accordance with new accounting guidance that we adopted effective January 1, 2016, we do not classify certain investments in the fair value hierarchy if we use the net asset value (NAV) per share (or its equivalent) as a practical expedient to measure fair value. This guidance was required to be applied retrospectively. Accordingly, certain prior period fair value disclosures have been revised to conform with current period presentation. Marketable equity investments with published NAVs continue to be classified in the fair value hierarchy.
Fair Value Measurements from Vendors
For certain assets and liabilities, we obtain fair value measurements from vendors, which predominantly consist of third party pricing services, and record the unadjusted fair value in our financial statements. For additional information, see Note 17 (Fair Values of Assets and Liabilities) to Financial Statements in our 2015 Form 10-K. Table 13.1. presents unadjusted fair value measurements provided by brokers or third-party pricing services by fair value hierarchy level. Fair value measurements obtained from brokers or third-party pricing services that we have adjusted to determine the fair value recorded in our financial statements are excluded from Table 13.1.


120

Note 13: Fair Values of Assets and Liabilities (continued)

Table 13.1: Fair Value Measurements by Brokers or Third-Party Pricing Services
  
Brokers
 
 
Third party pricing services
 
(in millions)
Level 1

 
Level 2

 
Level 3

 
Level 1

 
Level 2

 
Level 3

March 31, 2016
  
 
  
 
  
 
  
 
  
 
  
Trading assets (excluding derivatives)
$

 

 

 

 
107

 

Available-for-sale securities:
  
 
  
 
  
 
  
 
  
 
  
Securities of U.S. Treasury and federal agencies

 

 

 
30,658

 
3,155

 

Securities of U.S. states and political subdivisions

 

 

 

 
50,057

 
52

Mortgage-backed securities

 
233

 

 

 
116,017

 
73

Other debt securities (1)

 
200

 
684

 

 
48,563

 
307

Total debt securities

 
433

 
684

 
30,658

 
217,792

 
432

Total marketable equity securities

 

 

 

 
477

 

Total available-for-sale securities

 
433

 
684

 
30,658

 
218,269

 
432

Derivatives (trading and other assets)

 

 

 

 
214

 

Derivatives (liabilities)

 

 

 

 
(213
)
 

Other liabilities

 

 

 

 

 

December 31, 2015
  
 
  
 
  
 
  
 
  
 
  
Trading assets (excluding derivatives)
$

 

 

 

 
5

 

Available-for-sale securities:
  
 
  
 
  
 
  
 
  
 
  
Securities of U.S. Treasury and federal agencies

 

 

 
32,868

 
3,382

 

Securities of U.S. states and political subdivisions

 

 

 

 
48,443

 
51

Mortgage-backed securities

 
226

 

 

 
126,525

 
73

Other debt securities (1)

 
503

 
409

 

 
48,721

 
345

Total debt securities

 
729

 
409

 
32,868

 
227,071

 
469

Total marketable equity securities

 

 

 

 
484

 

Total available-for-sale securities

 
729

 
409

 
32,868

 
227,555

 
469

Derivatives (trading and other assets)

 

 

 

 
224

 

Derivatives (liabilities)

 

 

 

 
(221
)
 

Other liabilities

 

 

 

 
(1
)
 

(1)
Includes corporate debt securities, collateralized loan and other debt obligations, asset-backed securities, and other debt securities.

121


Assets and Liabilities Recorded at Fair Value on a Recurring Basis
 
Table 13.2 presents the balances of assets and liabilities recorded at fair value on a recurring basis.

Table 13.2: Fair Value on a Recurring Basis
(in millions)
Level 1

 
Level 2

 
Level 3

 
Netting

 
Total

March 31, 2016
 
 
 
 
 
 
 
 
 
Trading assets (excluding derivatives)
 
 
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies
$
14,761

 
3,443

 

  

  
18,204

Securities of U.S. states and political subdivisions

 
2,400

 
8

  

  
2,408

Collateralized loan obligations

 
95

 
268

  

  
363

Corporate debt securities

 
7,163

 
33

  

  
7,196

Mortgage-backed securities

 
19,849

 

  

 
19,849

Asset-backed securities

 
967

 

  

 
967

Equity securities
12,714

 
97

 

 

 
12,811

Total trading securities (1)
27,475

 
34,014

 
309

 

 
61,798

Other trading assets

 
827

 
32

  

 
859

Total trading assets (excluding derivatives)
27,475

 
34,841

 
341

 

 
62,657

Securities of U.S. Treasury and federal agencies
30,658

 
3,155

 

  

 
33,813

Securities of U.S. states and political subdivisions

 
50,117

 
1,457

(2)

 
51,574

Mortgage-backed securities:
  
 
 
 
  
  
  
 

Federal agencies

 
95,463

 

  

 
95,463

Residential

 
8,373

 
1

  

 
8,374

Commercial

 
12,799

 
73

  

 
12,872

Total mortgage-backed securities

 
116,635

 
74

 

 
116,709

Corporate debt securities
54

 
13,293

 
453

  

 
13,800

Collateralized loan and other debt obligations (3)

 
31,320

 
813

(2)

 
32,133

Asset-backed securities:
  
 
  
 
  
  
  
 

Auto loans and leases

 
14

 

 

 
14

Home equity loans

 
392

 

  

 
392

Other asset-backed securities

 
4,369

 
1,240

(2)

 
5,609

Total asset-backed securities

 
4,775

 
1,240

  

 
6,015

Other debt securities

 
8

 

  

 
8

Total debt securities
30,712

 
219,303

 
4,037

  

 
254,052

Marketable equity securities:
  
 
  
 
  
  
  
 

Perpetual preferred securities
430

 
477

 

 

 
907

Other marketable equity securities
592

 

 

  

 
592

Total marketable equity securities
1,022

 
477

 

 

 
1,499

Total available-for-sale securities
31,734

 
219,780

 
4,037

 

 
255,551

Mortgages held for sale

 
14,039

 
1,071

  

 
15,110

Loans

 

 
5,221

  

  
5,221

Mortgage servicing rights (residential)

 

 
11,333

  

  
11,333

Derivative assets:
  
 
  
 
  
  
  
  

Interest rate contracts
32

 
99,634

 
511

  

  
100,177

Commodity contracts

 
3,685

 
21

  

  
3,706

Equity contracts
3,465

 
2,729

 
920

  

  
7,114

Foreign exchange contracts
29

 
9,114

 

  

  
9,143

Credit contracts

 
327

 
249

  

  
576

Netting

 

 

  
(100,673
)
(4)
(100,673
)
Total derivative assets (5)
3,526

 
115,489

 
1,701

  
(100,673
)
 
20,043

Other assets – excluding nonmarketable equity investments at NAV

 
1

 
3,097

  

  
3,098

Total assets included in the fair value hierarchy
$
62,735

 
384,150

 
26,801

 
(100,673
)
 
373,013

Other assets – nonmarketable equity investments at NAV (6)


 
 
 
 
 
 
 

Total assets recorded at fair value


 


 
 
 


 
$
373,013

Derivative liabilities:
  
 
  
 
  
  
  
  

Interest rate contracts
$
(25
)
 
(91,426
)
 
(10
)
  

  
(91,461
)
Commodity contracts

 
(4,489
)
 
(10
)
  

  
(4,499
)
Equity contracts
(868
)
 
(3,688
)
 
(1,203
)
  

  
(5,759
)
Foreign exchange contracts
(25
)
 
(10,110
)
 

  

  
(10,135
)
Credit contracts

 
(327
)
 
(249
)
  

  
(576
)
Other derivative contracts

 

 
(77
)
  

  
(77
)
Netting

 

 

  
97,323

(4)
97,323

Total derivative liabilities (5)
(918
)
 
(110,040
)
 
(1,549
)
  
97,323

  
(15,184
)
Short sale liabilities:
  
 
  
 
  
  
  
  

Securities of U.S. Treasury and federal agencies
(9,551
)
 
(902
)
 

  

  
(10,453
)
Securities of U.S. states and political subdivisions

 

 

  

  

Corporate debt securities

 
(4,998
)
 

  

  
(4,998
)
Equity securities
(1,823
)
 
(7
)
 

  

  
(1,830
)
Other securities

 
(71
)
 

  

  
(71
)
Total short sale liabilities
(11,374
)
 
(5,978
)
 

  

  
(17,352
)
Other liabilities (excluding derivatives)

 

 
(5
)
  

  
(5
)
Total liabilities recorded at fair value
$
(12,292
)
 
(116,018
)
 
(1,554
)
  
97,323

  
(32,541
)
(1)
Net gains (losses) from trading activities recognized in the income statement for the quarters ended March 31, 2016 and 2015 include $572 million and $(430) million in net unrealized gains (losses) on trading securities held at March 31, 2016 and 2015, respectively.
(2)
Balances consist of securities that are mostly investment grade based on ratings received from the ratings agencies or internal credit grades categorized as investment grade if external ratings are not available. The securities are classified as Level 3 due to limited market activity.
(3)
Includes collateralized debt obligations of $542 million
(4)
Represents balance sheet netting of derivative asset and liability balances and related cash collateral. See Note 12 (Derivatives) for additional information.
(5)
Derivative assets and derivative liabilities include contracts qualifying for hedge accounting, economic hedges, and derivatives included in trading assets and trading liabilities, respectively.
(6)
Consists of certain nonmarketable equity investments that are measured at fair value using NAV per share (or its equivalent) as a practical expedient and are excluded from the fair value hierarchy.
(continued on following page)

122

Note 13: Fair Values of Assets and Liabilities (continued)

(continued from previous page)
(in millions)  
Level 1

 
Level 2

 
Level 3

 
Netting

 
Total

December 31, 2015
 
 
 
 
 
 
 
 
 
Trading assets (excluding derivatives)
 
 
 
 
 
 
 
 
 
Securities of U.S. Treasury and federal agencies  
$
13,357

 
3,469

 

 

 
16,826

Securities of U.S. states and political subdivisions  

 
1,667

 
8

 

 
1,675

Collateralized loan obligations

 
346

 
343

 

 
689

Corporate debt securities  

 
7,909

 
56

 

 
7,965

Mortgage-backed securities  

 
20,619

 

 

 
20,619

Asset-backed securities  

 
1,005

 

 

 
1,005

Equity securities  
15,010

 
101

 

 

 
15,111

Total trading securities (1)
28,367

 
35,116

 
407

 

 
63,890

Other trading assets  

 
891

 
34

 

 
925

Total trading assets (excluding derivatives)  
28,367

 
36,007

 
441

 

 
64,815

Securities of U.S. Treasury and federal agencies  
32,868

 
3,382

 

 

 
36,250

Securities of U.S. states and political subdivisions

 
48,490

 
1,500

(2)

 
49,990

Mortgage-backed securities:  
  
 
  
 
  
  
  
 

Federal agencies  

 
104,546

 

  

 
104,546

Residential  

 
8,557

 
1

  

 
8,558

Commercial  

 
14,015

 
73

  

 
14,088

Total mortgage-backed securities  

 
127,118

 
74

 

 
127,192

Corporate debt securities  
54

 
14,952

 
405

  

 
15,411

Collateralized loan and other debt obligations (3)

 
30,402

 
565

(2)

 
30,967

Asset-backed securities:  
  
 
  
 
  
  
  
 

Auto loans and leases  

 
15

 

 

 
15

Home equity loans  

 
414

 

  

 
414

Other asset-backed securities  

 
4,290

 
1,182

(2)

 
5,472

Total asset-backed securities  

 
4,719

 
1,182

  

 
5,901

Other debt securities  

 
10

 

  

 
10

Total debt securities  
32,922

 
229,073

 
3,726

  

 
265,721

Marketable equity securities:  
  
 
  
 
  
  
  
 

Perpetual preferred securities
434

 
484

 

 

 
918

Other marketable equity securities  
719

 

 

  

 
719

Total marketable equity securities  
1,153

 
484

 

 

 
1,637

Total available-for-sale securities  
34,075

 
229,557

 
3,726

 

 
267,358

Mortgages held for sale   

 
12,457

 
1,082

 

 
13,539

Loans  

 

 
5,316

 

 
5,316

Mortgage servicing rights (residential)  

 

 
12,415

 

 
12,415

Derivative assets:  
  
 
  
 
  
 
  
 

Interest rate contracts  
16

 
62,390

 
319

 

 
62,725

Commodity contracts  

 
4,623

 
36

 

 
4,659

Equity contracts  
3,726

 
2,907

 
966

 

 
7,599

Foreign exchange contracts  
48

 
8,899

 

 

 
8,947

Credit contracts  

 
375

 
275

 

 
650

Netting  

 

 

 
(66,924
)
(4)
(66,924
)
Total derivative assets (5)
3,790

 
79,194

 
1,596

 
(66,924
)
 
17,656

Other assets – excluding nonmarketable equity investments at NAV

 

 
3,065

 

 
3,065

Total assets included in the fair value hierarchy
$
66,232

 
357,215

 
27,641

 
(66,924
)
 
384,164

Other assets – nonmarketable equity investments at NAV (6)
 
 
 
 
 
 
 
 
23

Total assets recorded at fair value


 


 


 


 
$
384,187

Derivative liabilities:  
  
 
  
 
  
 
  
 

Interest rate contracts  
$
(41
)
 
(57,905
)
 
(31
)
 

 
(57,977
)
Commodity contracts  

 
(5,495
)
 
(24
)
 

 
(5,519
)
Equity contracts  
(704
)
 
(3,027
)
 
(1,077
)
 

 
(4,808
)
Foreign exchange contracts  
(37
)
 
(10,896
)
 

 

 
(10,933
)
Credit contracts  

 
(351
)
 
(278
)
 

 
(629
)
Other derivative contracts  

 

 
(58
)
 

 
(58
)
Netting  

 

 

 
66,004

(4)
66,004

Total derivative liabilities (5)
(782
)
 
(77,674
)
 
(1,468
)
 
66,004

 
(13,920
)
Short sale liabilities:  
  
 
  
 
  
 
  
 


Securities of U.S. Treasury and federal agencies  
(8,621
)
 
(1,074
)
 

 

 
(9,695
)
Securities of U.S. states and political subdivisions  

 

 

 

 

Corporate debt securities  

 
(4,209
)
 

 

 
(4,209
)
Equity securities  
(1,692
)
 
(4
)
 

 

 
(1,696
)
Other securities  

 
(70
)
 

 

 
(70
)
Total short sale liabilities  
(10,313
)
 
(5,357
)
 

 

 
(15,670
)
Other liabilities (excluding derivatives)  

 

 
(30
)
 

 
(30
)
Total liabilities recorded at fair value  
$
(11,095
)
 
(83,031
)
 
(1,498
)
 
66,004

 
(29,620
)
(1)
Net gains (losses) from trading activities recognized in the income statement for the year ended December 31, 2015, include $(1.0) billion in net unrealized gains (losses) on trading securities held at December 31, 2015.
(2)
Balances consist of securities that are mostly investment grade based on ratings received from the ratings agencies or internal credit grades categorized as investment grade if external ratings are not available. The securities are classified as Level 3 due to limited market activity.
(3)
Includes collateralized debt obligations of $257 million
(4)
Represents balance sheet netting of derivative asset and liability balances and related cash collateral. See Note 12 (Derivatives) for additional information.
(5)
Derivative assets and derivative liabilities include contracts qualifying for hedge accounting, economic hedges, and derivatives included in trading assets and trading liabilities, respectively.
(6)
Consists of certain nonmarketable equity investments that are measured at fair value using NAV per share (or its equivalent) as a practical expedient and are excluded from the fair value hierarchy.

123


Changes in Fair Value Levels
We monitor the availability of observable market data to assess the appropriate classification of financial instruments within the fair value hierarchy and transfer between Level 1, Level 2, and Level 3 accordingly. Observable market data includes but is not limited to quoted prices and market transactions. Changes in economic conditions or market liquidity generally will drive changes in availability of observable market data. Changes in availability of observable market data, which also may result in
 
changing the valuation technique used, are generally the cause of transfers between Level 1, Level 2, and Level 3.
Transfers into and out of Level 1, Level 2, and Level 3 are provided within Table 13.3 for the periods presented. The amounts reported as transfers represent the fair value as of the beginning of the quarter in which the transfer occurred.

Table 13.3: Transfers Between Fair Value Levels
  
Transfers Between Fair Value Levels
 
  
  
Level 1
 
Level 2
 
Level 3 (1)
 
  
(in millions)
In
 
Out
 
In
 
Out
 
In
 
Out
 
Total  
Quarter ended March 31, 2016
  
 
  
 
  
 
  
 
  
 
  
 
  
Trading assets (excluding derivatives)
$
4

 

 
11

 
(4
)
 

 
(11
)
 

Available-for-sale securities

 

 

 
(80
)
 
80

 

 

Mortgages held for sale

 

 
2

 
(29
)
 
29

 
(2
)
 

Net derivative assets and liabilities (2)

 

 
62

 
(25
)
 
25

 
(62
)
 

Short sale liabilities
(1
)
 

 

 
1

 

 

 

Total transfers
$
3

 

 
75

 
(137
)
 
134

 
(75
)
 

Quarter ended March 31, 2015
  
 
  
 
  
 
  
 
  
 
  
 
  
Trading assets (excluding derivatives)
$
15

 
(2
)
 
10

 
(16
)
 
1

 
(8
)
 

Available-for-sale securities

 

 
52

 

 

 
(52
)
 

Mortgages held for sale

 

 
67

 
(42
)
 
42

 
(67
)
 

Net derivative assets and liabilities (3)

 

 
34

 
12

 
(12
)
 
(34
)
 

Short sale liabilities
(1
)
 

 

 
1

 

 

 

Total transfers
$
14

 
(2
)
 
163

 
(45
)
 
31

 
(161
)
 

(1)
All transfers in and out of Level 3 are disclosed within the recurring Level 3 rollforward in Table 13.4 and Table 13.6 in this Note.
(2)
Includes net derivative assets that were transferred from Level 3 to Level 2 due to increased observable market data. Also includes net derivative assets that were transferred from Level 2 to Level 3 due to a decrease in observable market data.
(3)
Includes net derivative assets that were transferred from Level 3 to Level 2 due to increased observable market data. Also includes net derivative liabilities that were transferred from Level 2 to Level 3 due to a decrease in observable market data.


124

Note 13: Fair Values of Assets and Liabilities (continued)

The changes in Level 3 assets and liabilities measured at fair value on a recurring basis for the quarter ended March 31, 2016, are presented in Table 13.4.
Table 13.4: Changes in Level 3 Fair Value Assets and Liabilities on a Recurring Basis – Quarter ended March 31, 2016
  
  

 
Total net gains
(losses) included in
 
 
Purchases,
sales,
issuances
and
settlements,
net (1)

 
  

 
  

 
  

 
Net unrealized
gains (losses)
included in
income related
to assets and
liabilities held
at period end

  
(in millions)
Balance,
beginning
of period

 
Net
income

 
Other
compre-
hensive
income

 
 
Transfers
into
Level 3

 
Transfers
out of
Level 3

 
Balance,
end of
period

 
(2)
Quarter ended March 31, 2016
  
 
  
 
  
 
  
 
  
 
  
 
  
 
 
  
Trading assets (excluding derivatives):
  
 
  
 
  
 
  
 
  
 
  
 
  
 
 
  
Securities of U.S. states and
political subdivisions
$
8

 

 

 

 

 

 
8

 

  
Collateralized loan obligations
343

 
(25
)
 

 
(39
)
 

 
(11
)
 
268

 
(23
)
  
Corporate debt securities
56

 
(5
)
 

 
(18
)
 

 

 
33

 
(4
)
  
Mortgage-backed securities

 

 

 

 

 

 

 

  
Asset-backed securities

 

 

 

 

 

 

 

  
Equity securities

 

 

 

 

 

 

 

  
Total trading securities
407

 
(30
)
 

 
(57
)
 

 
(11
)
 
309

 
(27
)
  
Other trading assets
34

 
(2
)
 

 

 

 

 
32

 

 
Total trading assets
(excluding derivatives)
441

 
(32
)
 

 
(57
)
 

 
(11
)
 
341

 
(27
)
(3)
Available-for-sale securities:
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
  
Securities of U.S. states and
political subdivisions
1,500

 
1

 
3

 
(127
)
 
80

 

 
1,457

 

  
Mortgage-backed securities:
  
 
  
 
  
 
  
 
  
 
  
 
 
 
  
  
Residential
1

 

 

 

 

 

 
1

 

  
Commercial
73

 

 

 

 

 

 
73

 

  
Total mortgage-backed securities
74

 

 

 

 

 

 
74

 

 
Corporate debt securities
405

 
2

 
19

 
27

 

 

 
453

 

  
Collateralized loan and other
debt obligations
565

 
15

 
(24
)
 
257

 

 

 
813

 

  
Asset-backed securities:
  
 
  
 
  
 
  
 
  
 
  
 
 
 
  
  
Auto loans and leases

 

 

 

 

 

 

 

  
Other asset-backed securities
1,182

 

 

 
58

 

 

 
1,240

 

  
Total asset-backed securities
1,182

 

 

 
58

 

 

 
1,240

 

  
Total debt securities
3,726

 
18

 
(2
)
 
215

 
80

 

 
4,037

 

(4)
Marketable equity securities:
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
  
Perpetual preferred securities

 

 

 

 

 

 

 

  
Other marketable equity securities

 

 

 

 

 

 

 

  
Total marketable
equity securities

 

 

 

 

 

 

 

(5)
Total available-for-sale
securities
3,726

 
18

 
(2
)
 
215

 
80

 

 
4,037

 

  
Mortgages held for sale
1,082

 
24

 

 
(62
)
 
29

 
(2
)
 
1,071

 
21

(6)
Loans
5,316

 
(1
)
 

 
(94
)
 

 

 
5,221

 
(2
)
(6)
Mortgage servicing rights (residential) (7)
12,415

 
(1,448
)
 

 
366

 

 

 
11,333

 
(957
)
(6)
Net derivative assets and liabilities:
  
 
  
 
  
 
  
 
  
 
  
 
 
 
  
  
Interest rate contracts
288

 
599

 

 
(379
)
 

 
(7
)
 
501

 
270

  
Commodity contracts
12

 
2

 

 
(3
)
 

 

 
11

 
3

  
Equity contracts
(111
)
 
(2
)
 

 
(140
)
 
25

 
(55
)
 
(283
)
 
(147
)
  
Credit contracts
(3
)
 
9

 

 
(6
)
 

 

 

 
(1
)
  
Other derivative contracts
(58
)
 
(21
)
 

 
2

 

 

 
(77
)
 
(21
)
  
Total derivative contracts
128

 
587

 

 
(526
)
 
25

 
(62
)
 
152

 
104

(8)
Other assets
3,065

 
(57
)
 

 
89

 

 

 
3,097

 
(58
)
(3)
Short sale liabilities

 

 

 

 

 

 

 

(3)
Other liabilities (excluding derivatives)
(30
)
 

 

 
25

 

 

 
(5
)
 

(6)
(1)
See Table 13.5 for detail.
(2)
Represents only net gains (losses) that are due to changes in economic conditions and management’s estimates of fair value and excludes changes due to the collection/realization of cash flows over time.
(3)
Included in net gains (losses) from trading activities and other noninterest income in the income statement.
(4)
Included in net gains (losses) from debt securities in the income statement.
(5)
Included in net gains (losses) from equity investments in the income statement.
(6)
Included in mortgage banking and other noninterest income in the income statement.
(7)
For more information on the changes in mortgage servicing rights, see Note 8 (Mortgage Banking Activities).
(8)
Included in mortgage banking, trading activities, equity investments and other noninterest income in the income statement.
 

(continued on following page)


125


(continued from previous page)
 
Table 13.5 presents gross purchases, sales, issuances and settlements related to the changes in Level 3 assets and liabilities measured at fair value on a recurring basis for the quarter ended March 31, 2016.
Table 13.5: Gross Purchases, Sales, Issuances and Settlements – Level 3 – Quarter ended March 31, 2016
(in millions)
Purchases

 
Sales

 
Issuances

 
Settlements

 
Net

Quarter ended March 31, 2016
  
 
  
 
  
 
  
 
  
Trading assets (excluding derivatives):
  
 
  
 
  
 
  
 
  
Securities of U.S. states and political subdivisions
$

 

 

 

 

Collateralized loan obligations
56

 
(95
)
 

 

 
(39
)
Corporate debt securities
3

 
(21
)
 

 

 
(18
)
Mortgage-backed securities

 

 

 

 

Asset-backed securities

 

 

 

 

Equity securities

 

 

 

 

Total trading securities
59

 
(116
)
 

 

 
(57
)
Other trading assets

 

 

 

 

Total trading assets (excluding derivatives)
59

 
(116
)
 

 

 
(57
)
Available-for-sale securities:
  
 
  
 
  
 
  
 
  
Securities of U.S. states and political subdivisions
28

 

 
16

 
(171
)
 
(127
)
Mortgage-backed securities:
  
 
  
 
  
 
  
 
  
Residential

 

 

 

 

Commercial

 

 

 

 

Total mortgage-backed securities

 

 

 

 

Corporate debt securities
28

 

 

 
(1
)
 
27

Collateralized loan and other debt obligations
301

 

 

 
(44
)
 
257

Asset-backed securities:
  
 
  
 
  
 
  
 
  
Auto loans and leases

 

 

 

 

Other asset-backed securities

 

 
160

 
(102
)
 
58

Total asset-backed securities

 

 
160

 
(102
)
 
58

Total debt securities
357

 

 
176

 
(318
)
 
215

Marketable equity securities:
  
 
  
 
  
 
  
 
  
Perpetual preferred securities

 

 

 

 

Other marketable equity securities

 

 

 

 

Total marketable equity securities

 

 

 

 

Total available-for-sale securities
357

 

 
176

 
(318
)
 
215

Mortgages held for sale
22

 
(159
)
 
118

 
(43
)
 
(62
)
Loans
4

 

 
88

 
(186
)
 
(94
)
Mortgage servicing rights (residential)

 

 
366

 

 
366

Net derivative assets and liabilities:
  
 
  
 
  
 
  
 
  
Interest rate contracts

 

 

 
(379
)
 
(379
)
Commodity contracts

 

 

 
(3
)
 
(3
)
Equity contracts
13

 
(147
)
 

 
(6
)
 
(140
)
Credit contracts
3

 

 

 
(9
)
 
(6
)
Other derivative contracts

 

 

 
2

 
2

Total derivative contracts
16

 
(147
)
 

 
(395
)
 
(526
)
Other assets
89

 

 

 

 
89

Short sale liabilities

 

 

 

 

Other liabilities (excluding derivatives)

 

 

 
25

 
25


126

Note 13: Fair Values of Assets and Liabilities (continued)

The changes in Level 3 assets and liabilities measured at fair value on a recurring basis for the quarter ended March 31, 2015, are presented in Table 13.6.

Table 13.6: Changes in Level 3 Fair Value Assets and Liabilities on a Recurring Basis – Quarter ended March 31, 2015
  
Balance,
beginning
of period

 
Total net gains
(losses) included in
 
 
Purchases,
sales,
issuances
and
settlements,
net (1)

 
  

 
  

 
  

 
Net unrealized
gains (losses)
included in
income related
to assets and
liabilities held
at period end

  
(in millions)
 
Net
income 

 
Other
compre-
hensive
income

 
 
Transfers
into
Level 3

 
Transfers
out of
Level 3

 
Balance,
end of
period

 
(2)
Quarter ended March 31, 2015
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
  
Trading assets (excluding derivatives):
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
  
Securities of U.S. states and
political subdivisions
$
7

 

 

 
(1
)
 

 

 
6

 

  
Collateralized loan obligations
445

 
21

 

 
(85
)
 

 

 
381

 
(3
)
  
Corporate debt securities
54

 
2

 

 
(18
)
 

 
(7
)
 
31

 

  
Mortgage-backed securities

 

 

 

 

 

 

 

  
Asset-backed securities
79

 
16

 

 
(14
)
 

 

 
81

 
16

  
Equity securities
10

 

 

 

 

 

 
10

 

  
Total trading securities
595

 
39

 

 
(118
)
 

 
(7
)
 
509

 
13

  
Other trading assets
55

 
6

 

 
3

 
1

 
(1
)
 
64

 
8

  
Total trading assets
(excluding derivatives)
650

 
45

 

 
(115
)
 
1

 
(8
)
 
573

 
21

(3)
Available-for-sale securities:
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
  
Securities of U.S. states and
political subdivisions
2,277

 
(1
)
 
(3
)
 
(241
)
 

 
(52
)
 
1,980

 
(5
)
  
Mortgage-backed securities:
  
 
  
 
  
 
  
 
  
 
  
 
 
 
  
  
Residential
24

 
4

 
(6
)
 
(22
)
 

 

 

 

  
Commercial
109

 
1

 
(1
)
 
(5
)
 

 

 
104

 

  
Total mortgage-backed securities
133

 
5

 
(7
)
 
(27
)
 

 

 
104

 

  
Corporate debt securities
252

 

 

 
60

 

 

 
312

 

  
Collateralized loan and other
debt obligations
1,087

 
29

 
(16
)
 
(47
)
 

 

 
1,053

 

  
Asset-backed securities:
  
 
  
 
  
 
  
 
  
 
  
 
 
 
  
  
Auto loans and leases
245

 

 
4

 

 

 

 
249

 

  
Other asset-backed securities
1,372

 
1

 
(11
)
 
(156
)
 

 

 
1,206

 

  
Total asset-backed securities
1,617

 
1

 
(7
)
 
(156
)
 

 

 
1,455

 

  
Total debt securities
5,366

 
34

 
(33
)
 
(411
)
 

 
(52
)
 
4,904

 
(5
)
(4)
Marketable equity securities:
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
  
Perpetual preferred securities
663

 
3

 
(2
)
 
(24
)
 

 

 
640

 

  
Other marketable equity securities

 

 

 

 

 

 

 

  
Total marketable equity securities
663

 
3

 
(2
)
 
(24
)
 

 

 
640

 

(5)
Total available-for-sale
securities
6,029

 
37

 
(35
)
 
(435
)
 

 
(52
)
 
5,544

 
(5
)
  
Mortgages held for sale
2,313

 
38

 

 
(228
)
 
42

 
(67
)
 
2,098

 
22

(6)
Loans
5,788

 
(6
)
 

 
(52
)
 

 

 
5,730

 
(2
)
(6)
Mortgage servicing rights (residential) (7)
12,738

 
(1,306
)
 

 
307

 

 

 
11,739

 
(773
)
(6)
Net derivative assets and liabilities:
  
 
  
 
  
 
  
 
  
 
  
 
 
 
  
  
Interest rate contracts
293

 
482

 

 
(337
)
 

 

 
438

 
214

  
Commodity contracts
1

 
(1
)
 

 

 
(2
)
 

 
(2
)
 
(2
)
  
Equity contracts
(84
)
 
(7
)
 

 
(51
)
 
(10
)
 
(34
)
 
(186
)
 
(33
)
  
Credit contracts
(189
)
 
(2
)
 

 
37

 

 

 
(154
)
 
(1
)
  
Other derivative contracts
(44
)
 
(8
)
 

 

 

 

 
(52
)
 
(9
)
  
Total derivative contracts
(23
)
 
464

 

 
(351
)
 
(12
)
 
(34
)
 
44

 
169

(8)
Other assets
2,512

 
37

 

 

 

 

 
2,549

 
37

(3)
Short sale liabilities
(6
)
 

 

 
(9
)
 

 

 
(15
)
 

(3)
Other liabilities (excluding derivatives)
(28
)
 
1

 

 

 

 

 
(27
)
 

(6)
(1)
See Table 13.7 for detail.
(2)
Represents only net gains (losses) that are due to changes in economic conditions and management’s estimates of fair value and excludes changes due to the collection/realization of cash flows over time.
(3)
Included in net gains (losses) from trading activities and other noninterest income in the income statement.
(4)
Included in net gains (losses) from debt securities in the income statement.
(5)
Included in net gains (losses) from equity investments in the income statement.
(6)
Included in mortgage banking and other noninterest income in the income statement.
(7)
For more information on the changes in mortgage servicing rights, see Note 8 (Mortgage Banking Activities).
(8)
Included in mortgage banking, trading activities, equity investments and other noninterest income in the income statement.
 
(continued on following page)

127


(continued from previous page)

Table 13.7 presents gross purchases, sales, issuances and settlements related to the changes in Level 3 assets and liabilities measured at fair value on a recurring basis for the quarter ended March 31, 2015.
Table 13.7: Gross Purchases, Sales, Issuances and Settlements – Level 3 – Quarter ended March 31, 2015
(in millions)
Purchases

 
Sales

 
Issuances

 
Settlements

 
Net

Quarter ended March 31, 2015
  
 
  
 
  
 
  
 
  
Trading assets (excluding derivatives):
  
 
  
 
  
 
  
 
  
Securities of U.S. states and political subdivisions
$

 
(1
)
 

 

 
(1
)
Collateralized loan obligations
400

 
(485
)
 

 

 
(85
)
Corporate debt securities
15

 
(33
)
 

 

 
(18
)
Mortgage-backed securities

 

 

 

 

Asset-backed securities

 
(5
)
 

 
(9
)
 
(14
)
Equity securities

 

 

 

 

Total trading securities
415

 
(524
)
 

 
(9
)
 
(118
)
Other trading assets
3

 

 

 

 
3

Total trading assets (excluding derivatives)
418

 
(524
)
 

 
(9
)
 
(115
)
Available-for-sale securities:
  
 
  
 
  
 
  
 
  
Securities of U.S. states and political subdivisions

 
(20
)
 
55

 
(276
)
 
(241
)
Mortgage-backed securities:
  
 
  
 
  
 
  
 
 
Residential

 
(22
)
 

 

 
(22
)
Commercial

 
(5
)
 

 

 
(5
)
Total mortgage-backed securities

 
(27
)
 

 

 
(27
)
Corporate debt securities
60

 

 

 

 
60

Collateralized loan and other debt obligations
44

 
(3
)
 

 
(88
)
 
(47
)
Asset-backed securities:
 
 
 
 
 
 
 
 
 
Auto loans and leases

 

 

 

 

Other asset-backed securities

 
(1
)
 
59

 
(214
)
 
(156
)
Total asset-backed securities

 
(1
)
 
59

 
(214
)
 
(156
)
Total debt securities
104

 
(51
)
 
114

 
(578
)
 
(411
)
Marketable equity securities:
  
 
  
 
  
 
  
 
  
Perpetual preferred securities

 

 

 
(24
)
 
(24
)
Other marketable equity securities

 

 

 

 

Total marketable equity securities

 

 

 
(24
)
 
(24
)
Total available-for-sale securities
104

 
(51
)
 
114

 
(602
)
 
(435
)
Mortgages held for sale
53

 
(291
)
 
120

 
(110
)
 
(228
)
Loans
66

 

 
95

 
(213
)
 
(52
)
Mortgage servicing rights (residential)

 
(1
)
 
308

 

 
307

Net derivative assets and liabilities:
  
 
  
 
  
 
  
 
 
Interest rate contracts

 

 

 
(337
)
 
(337
)
Commodity contracts

 

 

 

 

Equity contracts

 
(32
)
 

 
(19
)
 
(51
)
Credit contracts
2

 

 

 
35

 
37

Other derivative contracts

 

 

 

 

Total derivative contracts
2

 
(32
)
 

 
(321
)
 
(351
)
Other assets

 

 

 

 

Short sale liabilities
6

 
(15
)
 

 

 
(9
)
Other liabilities (excluding derivatives)

 

 

 

 


Table 13.8 and Table 13.9 provide quantitative information about the valuation techniques and significant unobservable inputs used in the valuation of substantially all of our Level 3 assets and liabilities measured at fair value on a recurring basis for which we use an internal model.
The significant unobservable inputs for Level 3 assets and liabilities that are valued using fair values obtained from third party vendors are not included in the table, as the specific inputs applied are not provided by the vendor. In addition, the table excludes the valuation techniques and significant unobservable inputs for certain classes of Level 3 assets and liabilities measured using an internal model that we consider, both individually and in the aggregate, insignificant relative to our overall Level 3 assets and liabilities. We made this determination based upon an evaluation of each class, which considered the magnitude of the positions, nature of the unobservable inputs
 
and potential for significant changes in fair value due to changes in those inputs. For information on how changes in significant unobservable inputs affect the fair values of Level 3 assets and liabilities, see Note 17 (Fair Values of Assets and Liabilities) to Financial Statements in our 2015 Form 10-K. 


128

Note 13: Fair Values of Assets and Liabilities (continued)

Table 13.8: Valuation Techniques – Recurring Basis – March 31, 2016
($ in millions, except cost to service amounts)
Fair Value
Level 3

  
Valuation Technique(s)
 
Significant
Unobservable Input
 
Range of Inputs 
 
Weighted
Average (1)
 
March 31, 2016
  
  
  
 
  
 
  

  
  

  
 
  

Trading and available-for-sale securities:
 
 
 
 
 
 
 
 
 
 
 
 
Securities of U.S. states and
political subdivisions:
 
 
 
 
 
 
 
 
 
 
 
 
Government, healthcare and
other revenue bonds
$
1,180

 
Discounted cash flow
 
Discount rate
 
0.4

-
5.1

%
 
1.7

 
52

 
Vendor priced
 
 
 
  

 
  

 
 
  

Auction rate securities and other
municipal bonds
233

 
Discounted cash flow
 
Discount rate
 
1.1

-
5.2

 
 
3.2

 
 
 
 
 
Weighted average life
 
1.4

-
9.5

yrs
 
6.2

Collateralized loan and other debt
obligations (2)
268

 
Market comparable pricing
 
Comparability adjustment
 
(20.1
)
-
17.3

%
 
2.8

 
813

 
Vendor priced
 
 
 
  

 
  

 
 
  

Asset-backed securities:
  
 
 
 
 
 
  

 
  

 
 
  

Diversified payment rights (3)
555

 
Discounted cash flow
 
Discount rate
 
1.2

-
4.4

 
 
2.8

Other commercial and consumer
621

(4)
Discounted cash flow
 
Discount rate
 
2.3

-
5.8

 
 
3.3

 
  
 
 
 
Weighted average life
 
1.0

-
9.4

yrs
 
3.6

 
64

 
Vendor priced
 
 
 
  

 
  

 
 
  

Mortgages held for sale (residential)
1,031

 
Discounted cash flow
 
Default rate
 
0.5

-
11.6

%
 
2.2

 
  
 
 
 
Discount rate
 
1.1

-
6.6

 
 
4.7

 
  
 
 
 
Loss severity
 
0.1

-
38.5

 
 
20.7

 
  
 
 
 
Prepayment rate
 
7.8

-
17.0

 
 
11.2

 
40

 
Market comparable pricing
 
Comparability adjustment
 
(53.3
)
-
0.0

 
 
(36.8
)
Loans
5,221

(5)
Discounted cash flow
 
Discount rate
 
0.0

-
3.3

 
 
2.8

 
  
 
 
 
Prepayment rate
 
0.5

-
100.0

 
 
17.2

 
  
 
 
 
Utilization rate
 
0.0

-
0.8

 
 
0.3

Mortgage servicing rights (residential)
11,333

 
Discounted cash flow
 
Cost to service per loan (6)
 
$
71

-
576

 
 
164

 
  
 
 
 
Discount rate
 
6.4

-
11.4

%
 
6.9

 
  
 
 
 
Prepayment rate (7)
 
10.4

-
22.4

 
 
12.6

Net derivative assets and (liabilities):
  
 
 
 
 
 
  

 
  

 
 
  

Interest rate contracts
322

 
Discounted cash flow
 
Default rate
 
0.1

-
9.6

 
 
2.5

 
  
 
 
 
Loss severity
 
50.0

-
50.0

 
 
50.0

 
 
 
 
 
Prepayment rate
 
2.5

-
2.5

 
 
2.5

Interest rate contracts: derivative loan
commitments
179

 
Discounted cash flow
 
Fall-out factor
 
1.0

-
99.0

 
 
21.8

 
  
 
 
 
Initial-value servicing
 
(27.9
)
-
125.2

bps
 
55.7

Equity contracts
78

 
Discounted cash flow
 
Conversion factor
 
(10.7
)
-
0.0

%
 
(7.9
)
 
  
 
 
 
Weighted average life
 
1.3

-
2.5

yrs
 
1.7

 
(361
)
 
Option model
 
Correlation factor
 
(77.0
)
-
98.5

%
 
47.5

 
  
 
 
 
Volatility factor
 
6.5

-
137.6

 
 
31.0

Credit contracts
(7
)
 
Market comparable pricing
 
Comparability adjustment
 
(24.9
)
-
24.9

 
 
0.5

 
7

 
Option model
 
Credit spread
 
0.1

-
5.8

 
 
1.5

 
  
 
 
 
Loss severity
 
13.0

-
60.0

 
 
50.8

Other assets: nonmarketable equity investments
14

 
Discounted cash flow
 
Discount rate
 
5.0

 
10.5

 
 
6.2

 
3,083

 
Market comparable pricing
 
Comparability adjustment
 
(21.6
)
-
(4.8
)
 
 
(15.7
)
 
 

 
 
 
 
 
 
 
 
 
 
Insignificant Level 3 assets, net of liabilities
521

(8)
 
 
 
 
 
 
 
 
 
 
Total level 3 assets, net of liabilities
$
25,247

(9)
 
 
 
 
 
 
 
 
 
 
(1)
Weighted averages are calculated using outstanding unpaid principal balance for cash instruments, such as loans and securities, and notional amounts for derivative instruments.
(2)
Includes $542 million of collateralized debt obligations.
(3)
Securities backed by specified sources of current and future receivables generated from foreign originators.
(4)
Consists predominantly of investments in asset-backed securities that are revolving in nature, in which the timing of advances and repayments of principal are uncertain.
(5)
Consists predominantly of reverse mortgage loans securitized with GNMA that were accounted for as secured borrowing transactions.
(6)
The high end of the range of inputs is for servicing modified loans. For non-modified loans the range is $71 - $325.
(7)
Includes a blend of prepayment speeds and expected defaults. Prepayment speeds are influenced by mortgage interest rates as well as our estimation of drivers of borrower behavior.
(8)
Represents the aggregate amount of Level 3 assets and liabilities measured at fair value on a recurring basis that are individually and in the aggregate insignificant. The amount includes corporate debt securities, mortgage-backed securities, other trading assets, other liabilities and certain net derivative assets and liabilities, such as commodity contracts and other derivative contracts.
(9)
Consists of total Level 3 assets of $26.8 billion and total Level 3 liabilities of $1.6 billion, before netting of derivative balances.

129


Table 13.9: Valuation Techniques – Recurring Basis – December 31, 2015
($ in millions, except cost to service amounts)  
Fair Value
Level 3

  
Valuation Technique(s)
 
Significant
Unobservable Input
 
Range of Inputs 
 
Weighted   
Average (1)
 
December 31, 2015
  
  
  
 
  
 
  

  
  

  
 
 

Trading and available-for-sale securities:
  
  
  
 
  
 
  

  
  

  
 
 

Securities of U.S. states and
political subdivisions:
  
  
  
 
  
 
  

  
  

  
 
 

Government, healthcare and
other revenue bonds
$
1,213

  
Discounted cash flow
 
Discount rate
 
0.8

-
5.6

%
 
1.9

 
51

  
Vendor priced
 
  
 
  

  
  

  
 
  

Auction rate securities and other
municipal bonds
244

  
Discounted cash flow
 
Discount rate
 
0.8

-
4.5

  
 
2.0

 
  
  
  
 
Weighted average life
 
1.0

-
10.0

yrs
 
4.7

Collateralized loan and other debt
obligations (2)
343

  
Market comparable pricing
 
Comparability adjustment
 
(20.0
)
-
20.3

%
 
2.9

 
565

  
Vendor priced
 
  
 
  

  
  

  
 
  

Asset-backed securities:
  
  
  
 
  
 
  

  
  

  
 
  

Diversified payment rights (3)
608

  
Discounted cash flow
 
Discount rate
 
1.0

-
5.0

 
 
3.2

Other commercial and consumer
508

(4)
Discounted cash flow
 
Discount rate
 
2.5

-
6.3

  
 
3.8

 
  
  
  
 
Weighted average life
 
1.0

-
9.4

yrs
 
4.3

 
66

  
Vendor priced
 
  
 
  

  
  

  
 
  

Mortgages held for sale (residential)
1,033

  
Discounted cash flow
 
Default rate
 
0.5

-
13.7

%
 
3.6

  
  
  
  
 
Discount rate
 
1.1

-
6.3

  
 
4.7

  
  
  
  
 
Loss severity
 
0.1

-
22.7

  
 
11.2

  
  
  
  
 
Prepayment rate
 
2.6

-
9.6

  
 
6.4

 
49

 
Market comparable pricing
 
Comparability adjustment
 
(53.3
)
-
0.0

 
 
(32.6
)
Loans
5,316

(5)
Discounted cash flow
 
Discount rate
 
0.0

-
3.9

  
 
3.1

 
  
  
  
 
Prepayment rate
 
0.2

-
100.0

  
 
14.6

 
  
  
  
 
Utilization rate
 
0.0

-
0.8

  
 
0.3

Mortgage servicing rights (residential)
12,415

  
Discounted cash flow
 
Cost to service per
loan (6)
 
$
70

-
599

  
 
168

 
  
  
  
 
Discount rate
 
6.8

-
11.8

%
 
7.3

 
  
  
  
 
Prepayment rate (7)
 
10.1

-
18.9

  
 
11.4

Net derivative assets and (liabilities):
  
  
  
 
  
 
  

  
  

  
 
  

Interest rate contracts
230

  
Discounted cash flow
 
Default rate
 
0.1

-
9.60

  
 
2.6

  
  
  
  
 
Loss severity
 
50.0

-
50.0

  
 
50.0

 
 
 
 
 
Prepayment rate
 
0.3

-
2.5

 
 
2.2

Interest rate contracts: derivative loan
commitments
58

(8)
Discounted cash flow
 
Fall-out factor
 
1.0

-
99.0

  
 
18.8

 
  
  
  
 
Initial-value servicing
 
(30.6
)
-
127.0

bps
 
41.5

Equity contracts
72

  
Discounted cash flow
 
Conversion factor
 
(10.6
)
-
0.0

%
 
(8.1
)
 
  
  
  
 
Weighted average life
 
0.5

-
2.0

yrs
 
1.5

 
(183
)
  
Option model
 
Correlation factor
 
(77.0
)
-
98.5

%
 
66.0

 
  
  
  
 
Volatility factor
 
6.5

-
91.3

  
 
24.2

Credit contracts
(9
)
  
Market comparable pricing
 
Comparability adjustment
 
(53.6
)
-
18.2

  
 
(0.6
)
 
6

  
Option model
 
Credit spread
 
0.0

-
19.9

  
 
1.6

 
  
  
  
 
Loss severity
 
13.0

-
73.0

  
 
49.6

 
 
 
 
 
 
 
 
 
 
 
 
 
Other assets: nonmarketable equity investments
3,065

  
Market comparable pricing
 
Comparability adjustment
 
(19.1
)
-
(5.5
)
  
 
(15.1
)
 
 
 
 
 
 
 
 
 
 
 
 
 
Insignificant Level 3 assets, net of liabilities
493

(9)
  
 
  
 
  

  
  

  
 
 

Total level 3 assets, net of liabilities
$
26,143

(10)
  
 
  
 
  

  
  

  
 
 

(1)
Weighted averages are calculated using outstanding unpaid principal balance for cash instruments, such as loans and securities, and notional amounts for derivative instruments.
(2)
Includes $257 million of collateralized debt obligations.
(3)
Securities backed by specified sources of current and future receivables generated from foreign originators.
(4)
Consists largely of investments in asset-backed securities that are revolving in nature, in which the timing of advances and repayments of principal are uncertain.
(5)
Consists predominantly of reverse mortgage loans securitized with GNMA that were accounted for as secured borrowing transactions.
(6)
The high end of the range of inputs is for servicing modified loans. For non-modified loans the range is $70 - $335.
(7)
Includes a blend of prepayment speeds and expected defaults. Prepayment speeds are influenced by mortgage interest rates as well as our estimation of drivers of borrower behavior.
(8)
Total derivative loan commitments were a net asset of $56 million, of which a $2 million derivative liability was classified as level 2 at December 31, 2015.
(9)
Represents the aggregate amount of Level 3 assets and liabilities measured at fair value on a recurring basis that are individually and in the aggregate insignificant. The amount includes corporate debt securities, mortgage-backed securities, other trading assets, other liabilities and certain net derivative assets and liabilities, such as commodity contracts and other derivative contracts. 
(10)
Consists of total Level 3 assets of $27.6 billion and total Level 3 liabilities of $1.5 billion, before netting of derivative balances.



130

Note 13: Fair Values of Assets and Liabilities (continued)

The valuation techniques used for our Level 3 assets and liabilities, as presented in the previous tables, are described as follows: 
Discounted cash flow – Discounted cash flow valuation techniques generally consist of developing an estimate of future cash flows that are expected to occur over the life of an instrument and then discounting those cash flows at a rate of return that results in the fair value amount.
Market comparable pricing – Market comparable pricing valuation techniques are used to determine the fair value of certain instruments by incorporating known inputs, such as recent transaction prices, pending transactions, or prices of other similar investments that require significant adjustment to reflect differences in instrument characteristics.
Option model – Option model valuation techniques are generally used for instruments in which the holder has a contingent right or obligation based on the occurrence of a future event, such as the price of a referenced asset going above or below a predetermined strike price. Option models estimate the likelihood of the specified event occurring by incorporating assumptions such as volatility estimates, price of the underlying instrument and expected rate of return.
Vendor-priced  – Prices obtained from third party pricing vendors or brokers that are used to record the fair value of the asset or liability, of which the related valuation technique and significant unobservable inputs are not provided.
 
Significant unobservable inputs presented in the previous tables are those we consider significant to the fair value of the Level 3 asset or liability. We consider unobservable inputs to be significant if by their exclusion the fair value of the Level 3 asset or liability would be impacted by a predetermined percentage change, or based on qualitative factors, such as nature of the instrument, type of valuation technique used, and the significance of the unobservable inputs relative to other inputs used within the valuation. Following is a description of the significant unobservable inputs provided in the table.
 
Comparability adjustment – is an adjustment made to observed market data, such as a transaction price in order to reflect dissimilarities in underlying collateral, issuer, rating, or other factors used within a market valuation approach, expressed as a percentage of an observed price.
Conversion Factor – is the risk-adjusted rate in which a particular instrument may be exchanged for another instrument upon settlement, expressed as a percentage change from a specified rate.
Correlation factor – is the likelihood of one instrument changing in price relative to another based on an established relationship, expressed as a percentage of relative change in price over a period over time.

 
Cost to service – is the expected cost per loan of servicing a portfolio of loans, which includes estimates for unreimbursed expenses (including delinquency and foreclosure costs) that may occur as a result of servicing such loan portfolios.
Credit spread – is the portion of the interest rate in excess of a benchmark interest rate, such as OIS, LIBOR or U.S. Treasury rates, that when applied to an investment captures changes in the obligor’s creditworthiness.
Default rate – is an estimate of the likelihood of not collecting contractual amounts owed expressed as a constant default rate (CDR).
Discount rate – is a rate of return used to present value the future expected cash flow to arrive at the fair value of an instrument. The discount rate consists of a benchmark rate component and a risk premium component. The benchmark rate component, for example, OIS, LIBOR or U.S. Treasury rates, is generally observable within the market and is necessary to appropriately reflect the time value of money. The risk premium component reflects the amount of compensation market participants require due to the uncertainty inherent in the instruments’ cash flows resulting from risks such as credit and liquidity.
Fall-out factor – is the expected percentage of loans associated with our interest rate lock commitment portfolio that are likely of not funding.
Initial-value servicing – is the estimated value of the underlying loan, including the value attributable to the embedded servicing right, expressed in basis points of outstanding unpaid principal balance.
Loss severity – is the percentage of contractual cash flows lost in the event of a default.
Prepayment rate – is the estimated rate at which forecasted prepayments of principal of the related loan or debt instrument are expected to occur, expressed as a constant prepayment rate (CPR).
Utilization rate – is the estimated rate in which incremental portions of existing reverse mortgage credit lines are expected to be drawn by borrowers, expressed as an annualized rate.
Volatility factor – is the extent of change in price an item is estimated to fluctuate over a specified period of time, expressed as a percentage of relative change in price over a period over time.
Weighted average life – is the weighted average number of years an investment is expected to remain outstanding based on its expected cash flows reflecting the estimated date the issuer will call or extend the maturity of the instrument or otherwise reflecting an estimate of the timing of an instrument’s cash flows whose timing is not contractually fixed.


131


Assets and Liabilities Recorded at Fair Value on a Nonrecurring Basis
We may be required, from time to time, to measure certain assets at fair value on a nonrecurring basis in accordance with GAAP. These adjustments to fair value usually result from application of
 
LOCOM accounting or write-downs of individual assets. Table 13.10 provides the fair value hierarchy and carrying amount of all assets that were still held as of March 31, 2016, and December 31, 2015, and for which a nonrecurring fair value adjustment was recorded during the periods presented.

Table 13.10: Fair Value on a Nonrecurring Basis
 
March 31, 2016
 
 
December 31, 2015
 
(in millions)
Level 1

 
Level 2

 
Level 3

 
Total

 
Level 1

 
Level 2

 
Level 3

 
Total

Mortgages held for sale (LOCOM) (1)
$

 
1,627

 
1,071

 
2,698

 

 
4,667

 
1,047

 
5,714

Loans held for sale

 
273

 

 
273

 

 
279

 

 
279

Loans:
 
 
 
 
 
 
  
 
 
 
 
 
 
 
  
Commercial

 
158

 

 
158

 

 
191

 

 
191

Consumer

 
401

 
6

 
407

 

 
1,406

 
7

 
1,413

Total loans (2)

 
559

 
6

 
565

 

 
1,597

 
7

 
1,604

Other assets - excluding nonmarketable equity investments at NAV (3)

 
183

 
272

 
455

 

 
280

 
368

 
648

Total included in the fair value hierarchy
$

 
2,642

 
1,349

 
3,991

 

 
6,823

 
1,422

 
8,245

Other assets - nonmarketable equity investments at NAV (4)


 


 


 
19

 


 


 


 
286

Total assets at fair value on a nonrecurring basis


 


 


 
$
4,010

 


 


 


 
8,531

(1)
Consists of commercial mortgages and residential real estate 1-4 family first mortgage loans.
(2)
Represents carrying value of loans for which adjustments are based on the appraised value of the collateral.
(3)
Includes the fair value of foreclosed real estate, other collateral owned, operating lease assets and nonmarketable equity investments.
(4)
Consists of certain nonmarketable equity investments that are measured at fair value on a nonrecurring basis using NAV per share (or its equivalent) as a practical expedient and are excluded from the fair value hierarchy.

Table 13.11 presents the increase (decrease) in value of certain assets for which a nonrecurring fair value adjustment has been recognized during the periods presented.
Table 13.11: Change in Value of Assets with Nonrecurring Fair Value Adjustment
 
Quarter ended
March 31,
 
(in millions)
2016

 
2015

Mortgages held for sale (LOCOM)
$
31

 
31

Loans:
 
 
  
Commercial
(110
)
 
(35
)
Consumer
(260
)
 
(341
)
Total loans (1)
(370
)
 
(376
)
Other assets (2)
(99
)
 
(61
)
Total
$
(438
)
 
(406
)
(1)
Represents write-downs of loans based on the appraised value of the collateral.
(2)
Includes the losses on foreclosed real estate and other collateral owned that were measured at fair value subsequent to their initial classification as foreclosed assets. Also includes impairment losses on nonmarketable equity investments. 


132

Note 13: Fair Values of Assets and Liabilities (continued)

Table 13.12 provides quantitative information about the valuation techniques and significant unobservable inputs used in the valuation of most of our Level 3 assets and liabilities that are measured at fair value on a nonrecurring basis using an internal model. The table is limited to financial instruments that had nonrecurring fair value adjustments during the periods presented.

 
We have excluded from the table classes of Level 3 assets and liabilities measured using an internal model that we consider, both individually and in the aggregate, insignificant relative to our overall Level 3 nonrecurring measurements. We made this determination based upon an evaluation of each class that considered the magnitude of the positions, nature of the unobservable inputs and potential for significant changes in fair value due to changes in those inputs.

 
Table 13.12: Valuation Techniques – Nonrecurring Basis
($ in millions)
Fair Value
Level 3

 
Valuation Technique(s) (1)
 
Significant
Unobservable Inputs (1)
 
Range of inputs
 
Weighted
Average (2)

March 31, 2016
 
 
 
 
 
 
 
 
 
 
 
Residential mortgages held for sale (LOCOM)
$
1,071

(3)
Discounted cash flow
 
Default rate
(4)
0.3
12.3
%
 
2.2
%
 
 
 
 
 
Discount rate
 
1.5
8.5

 
3.6

 
 
 
 
 
Loss severity
 
0.8
45.7

 
2.8

 
 
 
 
 
Prepayment rate
(5)
3.5
100.0

 
57.8

Other assets: nonmarketable equity investments

 
Market comparable pricing
 
Comparability adjustment
 
0.0
0.0

 
0.0
Insignificant level 3 assets
278

 
 
 
 
 
 
 
 
 
 
Total
$
1,349

 
 
 
 
 
 
 
 
 
 
December 31, 2015
 
 
 
 
 
 
 
 
 
 
 
Residential mortgages held for sale (LOCOM)
$
1,047

(3)
Discounted cash flow
 
Default rate
(4)
0.5
5.0
%
 
4.2
%
 
 
 
 
 
Discount rate
 
1.5
8.5

 
3.5

 
 
 
 
 
Loss severity
 
0.0
26.1

 
2.9

 
 
 
 
 
Prepayment rate
(5)
2.6
100.0

 
65.4

Other assets: nonmarketable equity investments
228

 
Market comparable pricing
 
Comparability adjustment
 
5.0
9.2

 
8.5

Insignificant level 3 assets
147

 
 
 
 
 
 
 
 
 
 
Total
$
1,422

 
 
 
 
 
 
 
 
 
 
(1)
Refer to the narrative following Table 13.9 of this Note for a definition of the valuation technique(s) and significant unobservable inputs.
(2)
For residential MHFS, weighted averages are calculated using outstanding unpaid principal balance of the loans.
(3)
Consists of approximately $1.0 billion of government insured/guaranteed loans purchased from GNMA-guaranteed mortgage securitizations at both March 31, 2016, and December 31, 2015, and $39 million and $41 million of other mortgage loans that are not government insured/guaranteed at March 31, 2016 and December 31, 2015, respectively.
(4)
Applies only to non-government insured/guaranteed loans.
(5)
Includes the impact on prepayment rate of expected defaults for the government insured/guaranteed loans, which impacts the frequency and timing of early resolution of loans.

Alternative Investments
We hold certain nonmarketable equity investments for which we use NAV per share (or its equivalent) as a practical expedient for fair value measurements, including estimated fair values for investments accounted for under the cost method. The funds predominantly consist of private equity funds that invest in equity and debt securities issued by private and publicly-held companies in connection with leveraged buyouts, recapitalizations and expansion opportunities. The fair values of these investments and related unfunded commitments totaled $203 million and $78 million, respectively, at March 31, 2016, and $642 million and $144 million, respectively, at December 31, 2015. The investments do not allow redemptions. We receive distributions as the underlying assets of the funds liquidate, which we expect to occur over the next 2 years. 



133


Fair Value Option
The fair value option is an irrevocable election, generally only permitted upon initial recognition of financial assets or liabilities, to measure eligible financial instruments at fair value with changes in fair value reflected in earnings. We may elect the fair value option to align the measurement model with how the financial assets or liabilities are managed or to reduce complexity or accounting asymmetry. For more information, including the basis for our fair value option elections, see Note 17 (Fair Values of Assets and Liabilities) to Financial Statements in our 2015 Form 10-K.
 

Table 13.14 reflects differences between the fair value carrying amount of certain assets and liabilities for which we have elected the fair value option and the contractual aggregate unpaid principal amount at maturity.

 

Table 13.14: Fair Value Option
  
March 31, 2016
 
 
December 31, 2015
 
(in millions)
Fair value
carrying
amount

 
Aggregate
unpaid
principal

 
Fair value
carrying
amount
less
aggregate
unpaid
principal

 
Fair value
carrying
amount

 
Aggregate
unpaid
principal

 
Fair value
carrying
amount
less
aggregate
unpaid
principal

Trading assets – loans:
 
 
 
 
 
 
 
 
 
 
 
     Total loans
$
819

 
888

 
(69
)
 
886

 
935

 
(49
)
     Nonaccrual loans
16

 
25

 
(9
)
 

 

 

Mortgages held for sale:
 
 
 
 
 
 
 
 
 
 
 
Total loans
15,110

 
14,591

 
519

 
13,539

 
13,265

 
274

Nonaccrual loans
144

 
194

 
(50
)
 
161

 
228

 
(67
)
Loans 90 days or more past due and still accruing
15

 
18

 
(3
)
 
19

 
22

 
(3
)
Loans held for sale:
 
 
 
 
 
 
 
 
 
 
 
Total loans

 
6

 
(6
)
 

 
5

 
(5
)
Nonaccrual loans

 
6

 
(6
)
 

 
5

 
(5
)
Loans:
 
 
 
 
 
 
 
 
 
 
 
Total loans
5,221

 
5,089

 
132

 
5,316

 
5,184

 
132

Nonaccrual loans
254

 
273

 
(19
)
 
305

 
322

 
(17
)
Other assets (1)
3,098

 
N/A

 
N/A

 
3,065

 
N/A

 
N/A

(1)
Consists of nonmarketable equity investments carried at fair value. See Note 6 (Other Assets) for more information.


134

Note 13: Fair Values of Assets and Liabilities (continued)

The assets and liabilities accounted for under the fair value option are initially measured at fair value. Gains and losses from initial measurement and subsequent changes in fair value are recognized in earnings. The changes in fair value related to initial
 
measurement and subsequent changes in fair value included in earnings for these assets and liabilities measured at fair value are shown in Table 13.15 by income statement line item.

Table 13.15: Fair Value Option – Changes in Fair Value Included in Earnings
  
2016
 
 
2015
 
(in millions)
Mortgage banking noninterest income

 
Net gains
(losses)
from
trading
activities

 
Other
noninterest
income

 
Mortgage
banking
noninterest
income

 
Net gains
(losses)
from
trading
activities

 
Other
noninterest
income

Quarter ended March 31,
 
 
 
 
 
 
 
 
 
 
 
Trading assets – loans
$

 
10

 

 

 
15

 
1

Mortgages held for sale
565

 

 

 
581

 

 

Loans

 

 
(1
)
 

 

 
(4
)
Other assets

 

 
(58
)
 

 

 
38

Other interests held (1)

 
(2
)
 

 

 

 

(1)
Includes retained interests in securitizations.

For performing loans, instrument-specific credit risk gains or losses were derived principally by determining the change in fair value of the loans due to changes in the observable or implied credit spread. Credit spread is the market yield on the loans less the relevant risk-free benchmark interest rate. For
 
nonperforming loans, we attribute all changes in fair value to instrument-specific credit risk. Table 13.16 shows the estimated gains and losses from earnings attributable to instrument-specific credit risk related to assets accounted for under the fair value option.

Table 13.16: Fair Value Option – Gains/Losses Attributable to Instrument-Specific Credit Risk
  
 
Quarter ended March 31,
 
(in millions)
 
2016

 
2015

Gains (losses) attributable to instrument-specific credit risk:
 
 
 
 
Trading assets – loans
 
$
10

 
15

Mortgages held for sale
 
(4
)
 
17

Total
 
$
6

 
32


Disclosures about Fair Value of Financial Instruments
Table 13.17 is a summary of fair value estimates for financial instruments, excluding financial instruments recorded at fair value on a recurring basis, as they are included within Table 13.2 in this Note. The carrying amounts in the following table are recorded on the balance sheet under the indicated captions, except for nonmarketable equity investments, which are included in other assets.
We have not included assets and liabilities that are not financial instruments in our disclosure, such as the value of the long-term relationships with our deposit, credit card and trust customers, amortized MSRs, premises and equipment, goodwill and other intangibles, deferred taxes and other liabilities. The total of the fair value calculations presented does not represent, and should not be construed to represent, the underlying value of the Company.
 


135


Table 13.17: Fair Value Estimates for Financial Instruments
  
  

 
Estimated fair value
 
(in millions)
Carrying amount

 
Level 1

 
Level 2

 
Level 3

 
Total

March 31, 2016
 
 
 
 
 
 
 
 
 
Financial assets
 
 
 
 
 
 
 
 
 
Cash and due from banks (1)
$
19,084

 
19,084

 

 

 
19,084

Federal funds sold, securities purchased under resale agreements and other short-term investments (1)
300,547

 
17,441

 
282,960

 
146

 
300,547

Held-to-maturity securities
79,348

 
46,653

 
32,003

 
3,069

 
81,725

Mortgages held for sale (2)
2,931

 

 
1,879

 
1,072

 
2,951

Loans held for sale (2)
280

 

 
280

 

 
280

Loans, net (3)
911,588

 

 
60,583

 
869,126

 
929,709

Nonmarketable equity investments (cost method)
 
 
 
 
 
 
 
 
 
Excluding investments at NAV
7,249

 

 
13

 
7,797

 
7,810

Total financial assets included in the fair value hierarchy
1,321,027

 
83,178

 
377,718

 
881,210

 
1,342,106

Investments at NAV (4)
120

 
 
 
 
 
 
 
203

Total financial assets
$
1,321,147










 
1,342,309

Financial liabilities
 
 
 
 
 
 
 
 
 
Deposits
$
1,241,490

 

 
1,214,713

 
27,031

 
1,241,744

Short-term borrowings (1)
107,703

 

 
107,703

 

 
107,703

Long-term debt (5)
227,880

 

 
216,275

 
10,335

 
226,610

Total financial liabilities
$
1,577,073




1,538,691


37,366

 
1,576,057

December 31, 2015
 
 
 
 
 
 
 
 
 
Financial assets
 
 
 
 
 
 
 
 
 
Cash and due from banks (1)
$
19,111

 
19,111

 

 

 
19,111

Federal funds sold, securities purchased under resale agreements and other short-term investments (1)
270,130

 
14,057

 
255,911

 
162

 
270,130

Held-to-maturity securities
80,197

 
45,167

 
32,052

 
3,348

 
80,567

Mortgages held for sale (2)
6,064

 

 
5,019

 
1,047

 
6,066

Loans held for sale (2)
279

 

 
279

 

 
279

Loans, net (3)
887,497

 

 
60,848

 
839,816

 
900,664

Nonmarketable equity investments (cost method)
 
 
 
 
 
 
 
 
 
Excluding investments at NAV
6,659

 

 
14

 
7,271

 
7,285

Total financial assets included in the fair value hierarchy
1,269,937

 
78,335

 
354,123

 
851,644

 
1,284,102

Investments at NAV (4)
376










 
619

Total financial assets
$
1,270,313










 
1,284,721

Financial liabilities
 
 
 
 
 
 
 
 
 
Deposits
$
1,223,312

 

 
1,194,781

 
28,616

 
1,223,397

Short-term borrowings (1)
97,528

 

 
97,528

 

 
97,528

Long-term debt (5)
199,528

 

 
188,015

 
10,468

 
198,483

Total financial liabilities
$
1,520,368




1,480,324


39,084

 
1,519,408

(1)
Amounts consist of financial instruments in which carrying value approximates fair value.
(2)
Balance reflects MHFS and LHFS, as applicable, other than those MHFS and LHFS for which we elected the fair value option.
(3)
Loans exclude balances for which the fair value option was elected and also exclude lease financing with a carrying amount of $19.0 billion and $12.4 billion at March 31, 2016 and December 31, 2015, respectively.
(4)
Consists of certain nonmarketable equity investments for which estimated fair values are determined using NAV per share (or its equivalent) as a practical expedient and are excluded from the fair value hierarchy.
(5)
The carrying amount and fair value exclude obligations under capital leases of $8 million at both March 31, 2016 and December 31, 2015.
 
Loan commitments, standby letters of credit and commercial and similar letters of credit are not included in the table above. A reasonable estimate of the fair value of these instruments is the carrying value of deferred fees plus the related allowance, which totaled $1.1 billion and $1.0 billion at March 31, 2016, and December 31, 2015, respectively.
 




136

Note 14: Preferred Stock (continued)

Note 14:  Preferred Stock
We are authorized to issue 20 million shares of preferred stock and 4 million shares of preference stock, both without par value. Preferred shares outstanding rank senior to common shares both as to dividends and liquidation preference but have no general voting rights. We have not issued any preference shares under
 
this authorization. If issued, preference shares would be limited to one vote per share. Our total authorized, issued and outstanding preferred stock is presented in the following two tables along with the Employee Stock Ownership Plan (ESOP) Cumulative Convertible Preferred Stock.


Table 14.1: Preferred Stock Shares
  
March 31, 2016
 
 
December 31, 2015
 
  
Liquidation
preference
per share

 
Shares
authorized
and designated

 
Liquidation
preference
per share

 
Shares
authorized
and designated

DEP Shares
  

 
  

 
  

 
  

Dividend Equalization Preferred Shares (DEP)
$
10

 
97,000

 
$
10

 
97,000

Series H
 
 
 
 
 
 
 
Floating Class A Preferred Stock
20,000

 
50,000

 
20,000

 
50,000

Series I
 
 
 
 
 
 
 
Floating Class A Preferred Stock
100,000

 
25,010

 
100,000

 
25,010

Series J
 
 
 
 
 
 
 
8.00% Non-Cumulative Perpetual Class A Preferred Stock
1,000

 
2,300,000

 
1,000

 
2,300,000

Series K
 
 
 
 
 
 
 
7.98% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock
1,000

 
3,500,000

 
1,000

 
3,500,000

Series L
 
 
 
 
 
 
 
7.50% Non-Cumulative Perpetual Convertible Class A Preferred Stock
1,000

 
4,025,000

 
1,000

 
4,025,000

Series N
 
 
 
 
 
 
 
5.20% Non-Cumulative Perpetual Class A Preferred Stock
25,000

 
30,000

 
25,000

 
30,000

Series O
 
 
 
 
 
 
 
5.125% Non-Cumulative Perpetual Class A Preferred Stock
25,000

 
27,600

 
25,000

 
27,600

Series P
 
 
 
 
 
 
 
5.25% Non-Cumulative Perpetual Class A Preferred Stock
25,000

 
26,400

 
25,000

 
26,400

Series Q
 
 
 
 
 
 
 
5.85% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock
25,000

 
69,000

 
25,000

 
69,000

Series R
 
 
 
 
 
 
 
6.625% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock
25,000

 
34,500

 
25,000

 
34,500

Series S
 
 
 
 
 
 
 
5.900% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock
25,000

 
80,000

 
25,000

 
80,000

Series T
 
 
 
 
 
 
 
6.000% Non-Cumulative Perpetual Class A Preferred Stock
25,000

 
32,200

 
25,000

 
32,200

Series U
 
 
 
 
 
 
 
5.875% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock
25,000

 
80,000

 
25,000

 
80,000

Series V
 
 
 
 
 
 
 
6.000% Non-Cumulative Perpetual Class A Preferred Stock
25,000

 
40,000

 
25,000

 
40,000

Series W
 
 
 
 
 
 
 
5.700% Non-Cumulative Perpetual Class A Preferred Stock
25,000

 
40,000

 

 

ESOP
 
 
 
 
 
 
 
Cumulative Convertible Preferred Stock (1)

 
2,089,459

 

 
1,252,386

Total
 
 
12,546,169

 
 
 
11,669,096

(1)
See the ESOP Cumulative Convertible Preferred Stock section in this Note for additional information about the liquidation preference for the ESOP Cumulative Convertible Preferred Stock.

137


Table 14.2: Preferred Stock – Shares Issued and Carrying Value
  
March 31, 2016
 
 
December 31, 2015
 
(in millions, except shares)
Shares
issued and
outstanding

 
Liquidation preference
value

 
Carrying
value

 
Discount

 
Shares
issued and
outstanding

 
Liquidation preference
value

 
Carrying
value

 
Discount

DEP Shares
  

 
  

 
  

 
  

 
  

 
  

 
  

 
  

Dividend Equalization Preferred Shares (DEP)
96,546

 
$

 

 

 
96,546

 
$

 

 

Series I (1)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Floating Class A Preferred Stock
25,010

 
2,501

 
2,501

 

 
25,010

 
2,501

 
2,501

 

Series J (1) 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
8.00% Non-Cumulative Perpetual Class A Preferred Stock
2,150,375

 
2,150

 
1,995

 
155

 
2,150,375

 
2,150

 
1,995

 
155

Series K (1) 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
7.98% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock
3,352,000

 
3,352

 
2,876

 
476

 
3,352,000

 
3,352

 
2,876

 
476

Series L (1) 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
7.50% Non-Cumulative Perpetual Convertible Class A Preferred Stock
3,968,000

 
3,968

 
3,200

 
768

 
3,968,000

 
3,968

 
3,200

 
768

Series N (1) 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.20% Non-Cumulative Perpetual Class A Preferred Stock
30,000

 
750

 
750

 

 
30,000

 
750

 
750

 

Series O (1) 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.125% Non-Cumulative Perpetual Class A Preferred Stock
26,000

 
650

 
650

 

 
26,000

 
650

 
650

 

Series P (1) 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.25% Non-Cumulative Perpetual Class A Preferred Stock
25,000

 
625

 
625

 

 
25,000

 
625

 
625

 

Series Q (1)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.85% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock
69,000

 
1,725

 
1,725

 

 
69,000

 
1,725

 
1,725

 

Series R (1)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
6.625% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock
33,600

 
840

 
840

 

 
33,600

 
840

 
840

 

Series S (1)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.900% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock
80,000

 
2,000

 
2,000

 

 
80,000

 
2,000

 
2,000

 

Series T (1)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
6.000% Non-Cumulative Perpetual Class A Preferred Stock
32,000

 
800

 
800

 

 
32,000

 
800

 
800

 

Series U (1)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.875% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock
80,000

 
2,000

 
2,000

 

 
80,000

 
2,000

 
2,000

 

Series V (1)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
6.000% Non-Cumulative Perpetual Class A Preferred Stock
40,000

 
1,000

 
1,000

 

 
40,000

 
1,000

 
1,000

 

Series W (1)
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.700% Non-Cumulative Perpetual Class A Preferred Stock
40,000

 
1,000

 
1,000

 

 

 

 

 

ESOP
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cumulative Convertible Preferred Stock
2,089,459

 
2,089

 
2,089

 

 
1,252,386

 
1,252

 
1,252

 

Total
12,136,990

 
$
25,450

 
24,051

 
1,399

 
11,259,917

 
$
23,613

 
22,214

 
1,399

(1)
Preferred shares qualify as Tier 1 capital.

In January 2016, we issued 40 million Depositary Shares, each representing a 1/1,000th interest in a share of Non-Cumulative Perpetual Class A Preferred Stock, Series W, for an aggregate public offering price of $1.0 billion.
See Note 7 (Securitizations and Variable Interest Entities) for additional information on our trust preferred securities. We do not have a commitment to issue Series H preferred stock.


138

Note 14: Preferred Stock (continued)

ESOP CUMULATIVE CONVERTIBLE PREFERRED STOCK  All shares of our ESOP Cumulative Convertible Preferred Stock (ESOP Preferred Stock) were issued to a trustee acting on behalf of the Wells Fargo & Company 401(k) Plan (the 401(k) Plan). Dividends on the ESOP Preferred Stock are cumulative from the date of initial issuance and are payable quarterly at annual rates based upon the year of issuance. Each share of ESOP Preferred Stock released from the unallocated reserve of the 401(k) Plan is converted into shares of our common stock based on the stated
 
value of the ESOP Preferred Stock and the then current market price of our common stock. The ESOP Preferred Stock is also convertible at the option of the holder at any time, unless previously redeemed. We have the option to redeem the ESOP Preferred Stock at any time, in whole or in part, at a redemption price per share equal to the higher of (a) $1,000 per share plus accrued and unpaid dividends or (b) the fair market value, as defined in the Certificates of Designation for the ESOP Preferred Stock.

Table 14.3: ESOP Preferred Stock
  
Shares issued and outstanding
 
 
Carrying value
 
 
Adjustable dividend rate
(in millions, except shares)
Mar 31,
2016

 
Dec 31,
2015

 
Mar 31,
2016

 
Dec 31,
2015

 
Minimum

 
Maximum
ESOP Preferred Stock
  
 
  
 
  
 
  
 
  
 
  
$1,000 liquidation preference per share
  
 
  
 
  
 
  
 
  
 
  
2016
837,073

 

 
$
837

 

 
9.30
%
 
10.30
2015
220,408

 
220,408

 
220

 
220

 
8.90

 
9.90
2014
283,791

 
283,791

 
284

 
284

 
8.70

 
9.70
2013
251,304

 
251,304

 
251

 
251

 
8.50

 
9.50
2012
166,353

 
166,353

 
166

 
166

 
10.00

 
11.00
2011
177,614

 
177,614

 
178

 
178

 
9.00

 
10.00
2010
113,234

 
113,234

 
113

 
113

 
9.50

 
10.50
2008
28,972

 
28,972

 
29

 
29

 
10.50

 
11.50
2007
10,710

 
10,710

 
11

 
11

 
10.75

 
11.75
Total ESOP Preferred Stock (1)
2,089,459

 
1,252,386

 
$
2,089

 
1,252

 
 
 
 
Unearned ESOP shares (2)
 
 
 
 
$
(2,271
)
 
(1,362
)
 
 
 
 
(1)
At March 31, 2016 and December 31, 2015, additional paid-in capital included $182 million and $110 million, respectively, related to ESOP preferred stock.
(2)
We recorded a corresponding charge to unearned ESOP shares in connection with the issuance of the ESOP Preferred Stock. The unearned ESOP shares are reduced as shares of the ESOP Preferred Stock are committed to be released.


139



Note 15: Employee Benefits
We sponsor a frozen noncontributory qualified defined benefit retirement plan called the Wells Fargo & Company Cash Balance Plan (Cash Balance Plan), which covers eligible employees of Wells Fargo. The Cash Balance Plan was frozen on July 1, 2009, and no new benefits accrue after that date.
Table 15.1 presents the components of net periodic benefit cost.
 



 


Table 15.1: Net Periodic Benefit Cost
  
2016
 
 
2015
 
  
Pension benefits
 
 
  

 
Pension benefits
 
 
  

(in millions)
Qualified

 
Non-qualified

 
Other
benefits

 
Qualified

 
Non-qualified

 
Other
benefits

Quarter ended March 31,
  
 
 
  
 
Service cost
$
1

 

 

 

 

 
2

Interest cost
109

 
7

 
10

 
107

 
6

 
11

Expected return on plan assets
(142
)
 

 
(8
)
 
(161
)
 

 
(9
)
Amortization of net actuarial loss (gain)
33

 
3

 
(1
)
 
27

 
5

 
(1
)
Amortization of prior service credit

 

 

 

 

 
(1
)
Settlement loss

 
2

 

 

 
13

 

Net periodic benefit cost (income)
$
1

 
12

 
1

 
(27
)
 
24

 
2






140



Note 16:  Earnings Per Common Share
Table 16.1 shows earnings per common share and diluted earnings per common share and reconciles the numerator and denominator of both earnings per common share calculations.

Table 16.1: Earnings Per Common Share Calculations
  
Quarter ended March 31,
 
(in millions, except per share amounts)
2016

 
2015

Wells Fargo net income
$
5,462

 
5,804

Less: Preferred stock dividends and other
377

 
343

Wells Fargo net income applicable to common stock (numerator)
$
5,085

 
5,461

Earnings per common share
  
 
  
Average common shares outstanding (denominator)
5,075.7

 
5,160.4

Per share
$
1.00

 
1.06

Diluted earnings per common share
  
 
  
Average common shares outstanding
5,075.7

 
5,160.4

Add: Stock options
21.2

 
28.8

Restricted share rights
31.7

 
40.2

Warrants
10.8

 
14.2

Diluted average common shares outstanding (denominator)
5,139.4

 
5,243.6

Per share
$
0.99

 
1.04


Table 16.2 presents the outstanding options to purchase shares of common stock that were anti-dilutive (the exercise
price was higher than the weighted-average market price), and therefore not included in the calculation of diluted earnings per common share.
 

 

Table 16.2: Outstanding Anti-Dilutive Options
  
Weighted-average shares
 
  
Quarter ended March 31,
 
(in millions)
2016

 
2015

Options
4.4

 
7.1



141



Note 17:  Other Comprehensive Income
Table 17.1 provides the components of other comprehensive income (OCI), reclassifications to net income by income statement line item, and the related tax effects.
Table 17.1: Summary of Other Comprehensive Income
  
Quarter ended March 31,
 
  
2016
 
 
2015
 
(in millions)
Before
tax

 
Tax
effect

 
Net of
tax

 
Before
tax

 
Tax
effect

 
Net of
tax

Investment securities:
  
 
  
 
  
 
  
 
  
 
  
Net unrealized gains arising during the period
$
795

 
(310
)
 
485

 
393

 
(47
)
 
346

Reclassification of net gains to net income:
  
 
  
 
 
 
 
 
 
 
 
Interest income on investment securities (1)

 

 

 
(3
)
 
1

 
(2
)
Net gains on debt securities
(244
)
 
91

 
(153
)
 
(278
)
 
105

 
(173
)
Net gains from equity investments
(59
)
 
22

 
(37
)
 
(19
)
 
7

 
(12
)
Other noninterest income
(1
)
 

 
(1
)
 

 

 

Subtotal reclassifications to net income
(304
)
 
113

 
(191
)
 
(300
)
 
113

 
(187
)
Net change
491

 
(197
)
 
294

 
93

 
66

 
159

Derivatives and hedging activities:
  
 
  
 
  
 
  
 
  
 
  
Net unrealized gains arising during the period
1,999

 
(753
)
 
1,246

 
952

 
(359
)
 
593

Reclassification of net (gains) losses to net income:
  
 
  
 
 
 
 
 
 
 
 
Interest income on investment securities

 

 

 
(1
)
 
1

 

Interest income on loans
(260
)
 
98

 
(162
)
 
(237
)
 
89

 
(148
)
Interest expense on long-term debt
4

 
(2
)
 
2

 
4

 
(1
)
 
3

Subtotal reclassifications to net income
(256
)

96


(160
)

(234
)

89


(145
)
Net change
1,743


(657
)

1,086

 
718


(270
)

448

Defined benefit plans adjustments:
  
 
  
 
  
 
  
 
  
 
  
Net actuarial losses arising during the period
(8
)
 
3

 
(5
)
 
(11
)
 
4

 
(7
)
Reclassification of amounts to net periodic benefit costs (2):
 
 
 
 
 
 
 
 
 
 
 
Amortization of net actuarial loss
35

 
(13
)
 
22

 
31

 
(12
)
 
19

Settlements and other
2

 
(1
)
 
1

 
12

 
(5
)
 
7

Subtotal reclassifications to net periodic benefit costs
37

 
(14
)
 
23

 
43

 
(17
)
 
26

Net change
29

 
(11
)
 
18

 
32

 
(13
)
 
19

Foreign currency translation adjustments:
  
 
  
 
  
 
  
 
  
 
  
Net unrealized gains (losses) arising during the period
43

 
8

 
51

 
(55
)
 
(11
)
 
(66
)
Net change
43

 
8

 
51

 
(55
)
 
(11
)
 
(66
)
Other comprehensive income
$
2,306

 
(857
)
 
1,449

 
788

 
(228
)
 
560

Less: Other comprehensive income (loss) from noncontrolling interests, net of tax
  
 
  
 
(28
)
 
 
 
 
 
301

Wells Fargo other comprehensive income, net of tax
  
 
  
 
$
1,477

 
 
 
 
 
259

(1)
Represents net unrealized gains and losses amortized over the remaining lives of securities that were transferred from the available-for-sale portfolio to the held-to-maturity portfolio.
(2)
These items are included in the computation of net periodic benefit cost, which is recorded in employee benefits expense (see Note 15 (Employee Benefits) for additional details).

142



Table 17.2: Cumulative OCI Balances
(in millions)
Investment
securities

 
Derivatives
and
hedging
activities

 
Defined
benefit
plans
adjustments

 
Foreign
currency
translation
adjustments

 
Cumulative
other
compre-
hensive
income

Quarter ended March 31, 2016
  

 
  

 
  

 
  

 
  

Balance, beginning of period
$
1,813

 
620

 
(1,951
)
 
(185
)
 
297

Net unrealized gains (losses) arising during the period
485

 
1,246

 
(5
)
 
51

 
1,777

Amounts reclassified from accumulated other comprehensive income
(191
)
 
(160
)
 
23

 

 
(328
)
Net change
294

 
1,086

 
18

 
51

 
1,449

Less: Other comprehensive income (loss) from noncontrolling interests
(30
)
 

 

 
2

 
(28
)
Balance, end of period
$
2,137

 
1,706

 
(1,933
)
 
(136
)
 
1,774

Quarter ended March 31, 2015
  

 
  

 
  

 
  

 
  

Balance, beginning of period
$
4,926

 
333

 
(1,703
)
 
(38
)
 
3,518

Net unrealized gains (losses) arising during the period
346

 
593

 
(7
)
 
(66
)
 
866

Amounts reclassified from accumulated other comprehensive income
(187
)
 
(145
)
 
26

 

 
(306
)
Net change
159

 
448

 
19

 
(66
)
 
560

Less: Other comprehensive income from noncontrolling interests
301

 

 

 

 
301

Balance, end of period
$
4,784

 
781

 
(1,684
)
 
(104
)
 
3,777



143



Note 18:  Operating Segments
We have three reportable operating segments: Community Banking; Wholesale Banking; and Wealth and Investment Management. We define our operating segments by product type and customer segment and their results are based on our management accounting process, for which there is no comprehensive, authoritative guidance equivalent to GAAP for financial accounting. The management accounting process measures the performance of the operating segments based on
 
our management structure and is not necessarily comparable with similar information for other financial services companies. If the management structure and/or the allocation process changes, allocations, transfers and assignments may change. For a description of our operating segments, including the underlying management accounting process, see Note 24 (Operating Segments) to Financial Statements in our 2015 Form 10-K.

Table 18.1: Operating Segments
 
Community
Banking 
 
 
Wholesale
Banking
 
 
Wealth and Investment Management
 
 
Other (1)
 
 
Consolidated
Company
 
(income/expense in millions, average balances in billions)
2016

 
2015

 
2016

 
2015

 
2016

 
2015

 
2016

 
2015

 
2016

 
2015

Quarter ended March 31,
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Net interest income (2)
$
7,468

 
7,147

 
3,748

 
3,437

 
943

 
826

 
(492
)
 
(424
)
 
11,667

 
10,986

Provision (reversal of provision) for credit losses
720

 
658

 
363

 
(51
)
 
(14
)
 
(3
)
 
17

 
4

 
1,086

 
608

Noninterest income
5,146

 
4,964

 
3,210

 
2,972

 
2,911

 
3,150

 
(739
)
 
(794
)
 
10,528

 
10,292

Noninterest expense
6,836

 
6,591

 
3,968

 
3,618

 
3,042

 
3,122

 
(818
)
 
(824
)
 
13,028

 
12,507

Income (loss) before income tax expense (benefit)
5,058

 
4,862

 
2,627

 
2,842

 
826

 
857

 
(430
)
 
(398
)
 
8,081

 
8,163

Income tax expense (benefit)
1,697

 
1,290

 
719

 
817

 
314

 
324

 
(163
)
 
(152
)
 
2,567

 
2,279

Net income (loss) before noncontrolling interests
3,361

 
3,572

 
1,908

 
2,025

 
512

 
533

 
(267
)
 
(246
)
 
5,514

 
5,884

Less: Net income (loss) from noncontrolling interests
65

 
25

 
(13
)
 
51

 

 
4

 

 

 
52

 
80

Net income (loss) (3)
$
3,296

 
3,547

 
1,921

 
1,974

 
512

 
529

 
(267
)
 
(246
)
 
5,462

 
5,804

Average loans
$
484.3

 
472.2

 
429.8

 
380.0

 
64.1

 
56.9

 
(51.0
)
 
(45.8
)
 
927.2

 
863.3

Average assets
947.4

 
909.5

 
748.6

 
690.6

 
208.1

 
191.6

 
(84.2
)
 
(83.9
)
 
1,819.9

 
1,707.8

Average deposits
683.0

 
643.4

 
428.0

 
431.7

 
184.5

 
170.3

 
(76.1
)
 
(70.6
)
 
1,219.4

 
1,174.8

(1)
Includes items not specific to a business segment and elimination of certain items that are included in more than one business segment, substantially all of which represents products and services for Wealth and Investment Management customers served through Community Banking distribution channels. 
(2)
Net interest income is the difference between interest earned on assets and the cost of liabilities to fund those assets. Interest earned includes actual interest earned on segment assets and, if the segment has excess liabilities, interest credits for providing funding to other segments. The cost of liabilities includes interest expense on segment liabilities and, if the segment does not have enough liabilities to fund its assets, a funding charge based on the cost of excess liabilities from another segment.
(3)
Represents segment net income (loss) for Community Banking; Wholesale Banking; and Wealth and Investment Management segments and Wells Fargo net income for the consolidated company.


144



Note 19:  Regulatory and Agency Capital Requirements
The Company and each of its subsidiary banks are subject to regulatory capital adequacy requirements promulgated by federal bank regulatory agencies. The Federal Reserve establishes capital requirements for the consolidated financial holding company, and the OCC has similar requirements for the Company’s national banks, including Wells Fargo Bank, N.A. (the Bank).
Table 19.1 presents regulatory capital information for Wells Fargo & Company and the Bank using Basel III, which increased minimum required capital ratios, and introduced a minimum Common Equity Tier 1 (CET1) ratio. Beginning second quarter 2015, our capital ratios were calculated in accordance with the Standardized and Advanced Approaches. Accordingly, we must report the lower of our CET1, tier 1 and total capital ratios calculated under the Standardized Approach and under the Advanced Approach in the assessment of our capital adequacy. The information presented reflects risk-weighted assets (RWAs) under the Standardized and Advanced Approaches with Transition Requirements. The Standardized Approach applies assigned risk weights to broad risk categories, while the
 
calculation of RWAs under the Advanced Approach differs by requiring applicable banks to utilize a risk-sensitive methodology, which relies upon the use of internal credit models, and includes an operational risk component. The Basel III revised definition of capital, and changes are being phased-in effective January 1, 2014, through the end of 2021.
The Bank is an approved seller/servicer of mortgage loans and is required to maintain minimum levels of shareholders’ equity, as specified by various agencies, including the United States Department of Housing and Urban Development, GNMA, FHLMC and FNMA. At March 31, 2016, the Bank met these requirements. Other subsidiaries, including the Company’s insurance and broker-dealer subsidiaries, are also subject to various minimum capital levels, as defined by applicable industry regulations. The minimum capital levels for these subsidiaries, and related restrictions, are not significant to our consolidated operations.
 


Table 19.1: Regulatory Capital Information
 
Wells Fargo & Company
 
Wells Fargo Bank, N.A.
 
March 31, 2016
 
 
 
December 31, 2015
 
 
 
March 31, 2016
 
December 31, 2015
(in billions, except ratios)
Advanced Approach

 
Standardized
Approach

 
 
Advanced Approach

 
Standardized
Approach

 
 
Advanced Approach

Standardized
Approach

 
 
Advanced Approach

Standardized
Approach

 
Regulatory capital:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Common equity
tier 1
$
144.1

 
144.1

 
 
144.2

 
144.2

 
 
127.4

127.4

 
 
126.9

126.9

 
Tier 1
165.6

 
165.6

 
 
164.6

 
164.6

 
 
127.4

127.4

 
 
126.9

126.9

 
Total
194.3

 
205.8

 
 
195.2

 
205.6

 
 
140.1

150.6

 
 
140.5

150.0

 
Assets:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk-weighted
$
1,303.1

 
1,325.6

 
 
1,263.2

 
1,303.1

 
 
1,128.7

1,218.2

 
 
1,100.9

1,197.6

 
Adjusted average (1)
1,788.6

 
1,788.6

 
 
1,757.1

 
1,757.1

 
 
1,612.4

1,612.4

 
 
1,584.3

1,584.3

 
Regulatory capital ratios:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Common equity
tier 1 capital
11.06
%
 
10.87

*
 
11.42

 
11.07

*
 
11.28

10.46

*
 
11.53

10.60

*
Tier 1 capital
12.71

 
12.49

*
 
13.03

 
12.63

*
 
11.28

10.46

*
 
11.53

10.60

*
Total capital
14.91

*
15.52

 
 
15.45

*
15.77

 
 
12.41

12.36

*
 
12.77

12.52

*
Tier 1 leverage (1)
9.26

 
9.26

 
 
9.37

 
9.37

 
 
7.90

7.90

 
 
8.01

8.01

 
*Denotes the lowest capital ratio as determined under the Advanced and Standardized Approaches.
(1)
The leverage ratio consists of Tier 1 capital divided by quarterly average total assets, excluding goodwill and certain other items.
Table 19.2 presents the minimum required regulatory capital ratios under Transition Requirements to which the Company and
 
the Bank were subject as of March 31, 2016 and December 31, 2015.

Table 19.2: Minimum Required Regulatory Capital Ratios – Transition Requirements (1)
  
Wells Fargo & Company
 
Wells Fargo Bank, N.A.
 
March 31, 2016

 
December 31, 2015
 
March 31, 2016
 
December 31, 2015
Regulatory capital ratios:
 
 
 
 
  
 
 
Common equity tier 1 capital
5.625
%
 
4.500
 
5.125
 
4.500
Tier 1 capital
7.125

 
6.000
 
6.625
 
6.000
Total capital
9.125

 
8.000
 
8.625
 
8.000
Tier 1 leverage
4.000

 
4.000
 
4.000
 
4.000
(1)
At March 31, 2016, under transition requirements, the CET1, tier 1 and total capital minimum ratio requirements for Wells Fargo & Company include a capital conservation buffer of 0.625% and a global systemically important bank (G-SIB) surcharge of 0.5%. Only the 0.625% capital conservation buffer applies to the Bank at March 31, 2016.


145



Glossary of Acronyms
  
  
  
  
ABS
Asset-backed security
G-SIB
Globally systemic important bank
ACL
Allowance for credit losses
HAMP
Home Affordability Modification Program
ALCO
Asset/Liability Management Committee
HUD
U.S. Department of Housing and Urban Development
ARM 
Adjustable-rate mortgage
LCR
Liquidity Coverage Ratio
ASC 
Accounting Standards Codification
LHFS
Loans held for sale
ASU
Accounting Standards Update
LIBOR
London Interbank Offered Rate
AUA
Assets under administration
LIHTC
Low-Income Housing Tax Credit
AUM
Assets under management
LOCOM
Lower of cost or market value
AVM
Automated valuation model
LTV
Loan-to-value
BCBS
Basel Committee on Bank Supervision
MBS
Mortgage-backed security
BHC
Bank holding company
MHA
Making Home Affordable programs
CCAR
Comprehensive Capital Analysis and Review
MHFS
Mortgages held for sale
CD
Certificate of deposit
MSR
Mortgage servicing right
CDO
Collateralized debt obligation
MTN
Medium-term note
CDS
Credit default swaps
NAV
Net asset value
CET1
Common Equity Tier 1
NPA
Nonperforming asset
CLO
Collateralized loan obligation
OCC
Office of the Comptroller of the Currency
CLTV
Combined loan-to-value
OCI
Other comprehensive income
CMBS
Commercial mortgage-backed securities
OTC
Over-the-counter
CPP
Capital Purchase Program
OTTI
Other-than-temporary impairment
CRE
Commercial real estate
PCI Loans
Purchased credit-impaired loans
DPD
Days past due
PTPP
Pre-tax pre-provision profit
ESOP
Employee Stock Ownership Plan
RBC
Risk-based capital
FAS
Statement of Financial Accounting Standards
RMBS
Residential mortgage-backed securities
FASB
Financial Accounting Standards Board
ROA
Wells Fargo net income to average total assets
FDIC
Federal Deposit Insurance Corporation
ROE
Wells Fargo net income applicable to common stock
FFELP
Federal Family Education Loan Program
  
to average Wells Fargo common stockholders' equity
FHA
Federal Housing Administration
RWAs
Risk-weighted assets
FHLB
Federal Home Loan Bank
SEC
Securities and Exchange Commission
FHLMC
Federal Home Loan Mortgage Corporation
S&P
Standard & Poor’s Ratings Services
FICO
Fair Isaac Corporation (credit rating)
SPE
Special purpose entity
FNMA
Federal National Mortgage Association
TARP
Troubled Asset Relief Program
FRB
Board of Governors of the Federal Reserve System
TDR
Troubled debt restructuring
GAAP
Generally accepted accounting principles
VA
Department of Veterans Affairs
GNMA
Government National Mortgage Association
VaR
Value-at-Risk
GSE
Government-sponsored entity
VIE
Variable interest entity
 
 
 
 

146



PART II – OTHER INFORMATION


Item 1.            Legal Proceedings
 
Information in response to this item can be found in Note 11 (Legal Actions) to Financial Statements in this Report which information is incorporated by reference into this item.

Item 1A.         Risk Factors
 
Information in response to this item can be found under the “Financial Review – Risk Factors” section in this Report which information is incorporated by reference into this item. 

Item 2.            Unregistered Sales of Equity Securities and Use of Proceeds
 
The following table shows Company repurchases of its common stock for each calendar month in the quarter ended March 31, 2016.
Calendar month
Total number
of shares
repurchased (1)

 
Weighted-average
price paid per share

 
Maximum number of
shares that may yet
be repurchased under
the authorizations

January (2)
19,386,861

 
$
51.10

 
407,592,411

February (2)
26,144,580

 
47.32

 
381,447,831

March
6,143,103

 
49.05

 
375,304,728

Total
51,674,544

 
 
 
 
 
 
 
 
 
 
(1)
All shares were repurchased under an authorization covering up to 350 million shares of common stock approved by the Board of Directors and publicly announced by the Company on March 26, 2014. In addition, the Company publicly announced on January 26, 2016, that the Board of Directors authorized the repurchase of an additional 350 million shares of common stock. Unless modified or revoked by the Board, these authorizations do not expire.
(2)
January includes a private repurchase transaction of 9,239,769 shares at a weighted-average price paid per share of $54.11 and February includes a private repurchase transaction of 15,932,836 shares at a weighted-average price paid per share of $47.07.


The following table shows Company repurchases of the warrants for each calendar month in the quarter ended March 31, 2016.
Calendar month
Total number
of warrants
repurchased (1)

 
Average price
paid per warrant

 
Maximum dollar value
of warrants that
may yet be repurchased

January

 
$

 
451,944,402

February

 

 
451,944,402

March

 

 
451,944,402

Total

 
 
 
 
 
 
 
 
 
 
(1)
Warrants are repurchased under the authorization covering up to $1 billion in warrants approved by the Board of Directors (ratified and approved on June 22, 2010). Unless modified or revoked by the Board, this authorization does not expire.

147



Item 6.
Exhibits
 
A list of exhibits to this Form 10-Q is set forth on the Exhibit Index immediately preceding such exhibits and is incorporated herein by reference.
 
The Company’s SEC file number is 001-2979. On and before November 2, 1998, the Company filed documents with the SEC under the name Norwest Corporation. The former Wells Fargo & Company filed documents under SEC file number 001-6214.
 

SIGNATURE
 
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this Report to be signed on its behalf by the undersigned, thereunto duly authorized.
 
Dated: May 4, 2016                                                             WELLS FARGO & COMPANY
 
 
By:      /s/ RICHARD D. LEVY                                   
Richard D. Levy
Executive Vice President and Controller
(Principal Accounting Officer)

148



EXHIBIT INDEX
 
Exhibit
Number
 
Description 
 
Location 
3(a)
 
Restated Certificate of Incorporation, as amended and in effect on the date hereof.
 
Incorporated by reference to Exhibit 3(a) to the Company’s Annual Report on Form 10-K for the year ended December 31, 2015.
3(b)
 
By-Laws.
 
Incorporated by reference to Exhibit 3.1 to the Company’s Current Report on Form 8-K filed December 22, 2015.
4(a)
 
See Exhibits 3(a) and 3(b).
 
 
4(b)
 
The Company agrees to furnish upon request to the Commission a copy of each instrument defining the rights of holders of senior and subordinated debt of the Company.
 
 
12(a)
 
Computation of Ratios of Earnings to Fixed Charges:
 
Filed herewith.
  
 
  
 
Quarter ended March 31,
 
 
  
  
 
  
 
2016

 
2015

 
  
  
 
Including interest on deposits
 
6.70

 
8.51

 
  
  
 
Excluding interest on deposits
 
8.29

 
10.87

 
  
 
 
 
 
 
12(b)
 
Computation of Ratios of Earnings to Fixed Charges and Preferred Dividends:
 
Filed herewith.
  
 
  
 
Quarter ended March 31,
 
 
  
  
 
  
 
2016

 
2015

 
  
  
 
Including interest on deposits
 
4.80

 
5.89

 
  
  
 
Excluding interest on deposits
 
5.51

 
6.86

 
  
 
 
 
 
 
 
 
 
 
31(a)
 
Certification of principal executive officer pursuant to Section 302 of the Sarbanes-Oxley Act of 2002.
 
Filed herewith.
31(b)
 
Certification of principal financial officer pursuant to Section 302 of the Sarbanes-Oxley Act of 2002.
 
Filed herewith.
32(a)
 
Certification of Periodic Financial Report by Chief Executive Officer Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 and 18 U.S.C. § 1350.
 
Furnished herewith.
32(b)
 
Certification of Periodic Financial Report by Chief Financial Officer Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 and 18 U.S.C. § 1350.
 
Furnished herewith.
101.INS
 
XBRL Instance Document
 
Filed herewith.
101.SCH
 
XBRL Taxonomy Extension Schema Document
 
Filed herewith.
101.CAL
 
XBRL Taxonomy Extension Calculation Linkbase Document
 
Filed herewith.
101.DEF
 
XBRL Taxonomy Extension Definitions Linkbase Document
 
Filed herewith.
101.LAB
 
XBRL Taxonomy Extension Label Linkbase Document
 
Filed herewith.
101.PRE
 
XBRL Taxonomy Extension Presentation Linkbase Document
 
Filed herewith.


149