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Eurazeo

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FY2016 Annual Report · Eurazeo
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Table of Contents 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, DC 20549

FORM 10-K

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE
ACT OF 1934

For the fiscal year ended December 31, 2016

OR

TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES
EXCHANGE ACT OF 1934

For the transition period from                     to                    

Commission File Number 001-34034

REGIONS FINANCIAL CORPORATION

(Exact name of registrant as specified in its charter)

Delaware

(State or other jurisdiction of
incorporation or organization)

63-0589368

(I.R.S. Employer
Identification No.)

1900 Fifth Avenue North, Birmingham, Alabama 35203

(Address of principal executive offices)

Registrant’s telephone number, including area code: (800) 734-4667

Securities registered pursuant to Section 12(b) of the Act:

Title of each class
Common Stock, $.01 par value

  Name of each exchange on which registered

New York Stock Exchange

Depositary Shares, each representing a 1/40th Interest in a Share of 6.375% Non-Cumulative 
Perpetual Preferred Stock, Series A

Depositary Shares, each representing a 1/40th Interest in a Share of 6.375% Fixed-to-Floating 
Rate Non-Cumulative Perpetual Preferred Stock, Series B

New York Stock Exchange

New York Stock Exchange

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities

Securities registered pursuant to Section 12(g) of the Act: None

Act.    Yes 

   No  

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act.    Yes  

    No  

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  

    No  

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 (§232.405 of this chapter) during the preceding 12 months 
(or for such shorter period that the registrant was required to submit and post such files). Yes  

   No  

Indicate by check mark if disclosure of delinquent filers pursuant to Item 405 of Regulation S-K is not contained herein, and will not be 
contained, to the best of registrant’s knowledge, in definitive proxy or information statements incorporated by reference in Part III of this Form 
10-K or any amendment to this Form 10-K.  

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.

 
 
 
 
 
 
 
Table of Contents 

  Large accelerated filer  

  Accelerated filer 

  Non-accelerated filer 

 (Do not check if a smaller reporting company)

  Smaller reporting company 

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act). Yes  

    No  

State the aggregate market value of the voting and non-voting common equity held by non-affiliates computed by reference to the price 
at which the common equity was last sold, or the average bid and asked price of such common equity, as of the last business day of the registrant’s 
most recently completed second fiscal quarter.

Common Stock, $.01 par value—$10,367,597,293 as of June 30, 2016.

Indicate the number of shares outstanding of each of the registrant’s classes of common stock, as of the latest practicable date.

Common Stock, $.01 par value—1,205,258,693 shares issued and outstanding as of February 22, 2017.

DOCUMENTS INCORPORATED BY REFERENCE

Portions of the proxy statement for the Annual Meeting to be held on April 20, 2017 are incorporated by reference into Part III.

 
 
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REGIONS FINANCIAL CORPORATION

FORM 10-K

INDEX

PART I

Forward-Looking Statements

Item 1.

Item 1A.

Item 1B.

Item 2.

Item 3.

Item 4.

PART  II

Item 5.

Item 6.

Item 7.

Item 7A.

Item 8.

Item 9.

Item 9A.

Item 9B.

PART  III

Item 10.

Item 11.

Item 12.

Item 13.

Item 14.

PART IV

Item 15.

Item 16.

SIGNATURES

Business

Risk Factors
Unresolved Staff Comments

Properties

Legal Proceedings

Mine Safety Disclosures

Market for Registrant's Common Equity, Related Stockholder Matters and Issuer Purchases
of Equity Securities

Selected Financial Data

Management's Discussion and Analysis of Financial Condition and Results of Operations

Quantitative and Qualitative Disclosures about Market Risk

Financial Statements and Supplementary Data

Changes in and Disagreements with Accountants on Accounting and Financial Disclosure

Controls and Procedures

Other Information

Directors, Executive Officers and Corporate Governance

Executive Compensation

Security Ownership of Certain Beneficial Owners and Management and Related
Stockholder Matters

Certain Relationships and Related Transactions, and Director Independence

Principal Accounting Fees and Services

Exhibits, Financial Statement Schedules

Form 10-K Summary

Page

6

9

21

34

34

34

34

35

37

37

37

89

175

175

175

176

178

178

178

178

179

184

185

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Glossary of Defined Terms

Agencies - collectively, FNMA, FHLMC and GNMA.

ALCO - Asset/Liability Management Committee.

AOCI - Accumulated other comprehensive income.

ATM - Automated teller machine.

Basel I - Basel Committee's 1988 Regulatory Capital Framework (First Accord).

Basel III - Basel Committee's 2010 Regulatory Capital Framework (Third Accord).

Basel III Rules - Final capital rules adopting the Basel III capital framework approved by U.S. federal

regulators in 2013.

Basel Committee - Basel Committee on Banking Supervision.

BHC - Bank Holding Company.

BHC Act - Bank Holding Company Act of 1956, as amended.

BITS - Technology arm of the Financial Services Roundtable.

Bank - Regions Bank.

Board - The Company’s Board of Directors.

CAMELS -  Bank’s Supervisory Ratings. 

CAP - Customer Assistance Program.

CAPM - Capital Asset Pricing Model.

CCAR - Comprehensive Capital Analysis and Review.

CD - Certificate of deposit.

CEO - Chief Executive Officer.

CET1 - Common Equity Tier 1.

CFO - Chief Financial Officer.

CFPB - Consumer Financial Protection Bureau.

COSO - Committee of Sponsoring Organizations of the Treadway Commission.

Company - Regions Financial Corporation and its subsidiaries.

CPR - Constant (or Conditional) Prepayment Rate.

CRA - Community Reinvestment Act of 1977.

DIF - Deposit Insurance Fund.

Dodd-Frank Act - The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.

DPD - Days Past Due.

DUS - Fannie Mae Delegated Underwriting & Servicing.

EAD- Exposure At Default.

FASB - Financial Accounting Standards Board.

FDIA - Federal Deposit Insurance Act, as amended.

FDIC - The Federal Deposit Insurance Corporation.

Federal Reserve - The Board of Governors of the Federal Reserve System.

FFIEC - Federal Financial Institutions Examination Council.

FHA - Federal Housing Administration.

FHLB - Federal Home Loan Bank.

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FHLMC - Federal Home Loan Mortgage Corporation, known as Freddie Mac. 

FICO Assessments - The Financing Corporation, established by the Competitive Equality Banking Act of

1987.

FICO Scores - Personal credit scores based on the model introduced by the Fair Isaac Corporation. 

FINRA - Financial Industry Regulatory Authority.

FNMA - Federal National Mortgage Association, known as Fannie Mae.

FOMC - Federal Open Market Committee.

FS-ISAC - Financial Services - Information Sharing & Analysis Center.

FRB - Federal Reserve Bank.

FSOC - Federal Stability Oversight Council.

FTP - Funds Transfer Pricing.

GAAP - Generally Accepted Accounting Principles in the United States. 

GCM - Guideline Public Company Method.

GDP - Gross Domestic Product.

GNMA - Government National Mortgage Association. 

GTM - Guideline Transaction Method. 

HUD - U.S. Department of Housing and Urban Development.

IPO - Initial public offering.

IRA - Individual Retirement Account.

IRS - Internal Revenue Service.

LCR - Liquidity coverage ratio.

LGD - Loss given default.

LIBOR - London InterBank Offered Rates.

LTIP - Long-term incentive plan.

LTV - Loan to value.

MBS - Mortgage-backed securities.

MD&A - Management’s Discussion and Analysis of Financial Condition and Results of Operations.

MSAs - Metropolitan Statistical Areas.

MSR - Mortgage servicing right.

MSRB - Municipal Securities Rulemaking Board.

NAV - Net Asset Value.

NM - Not meaningful.

NPR - Notice of Proposed Rulemaking.

NSFR - Net stable funding ratio.

NYSE - New York Stock Exchange.

OAS - Option-Adjusted Spread.

OCC - Office of the Comptroller of the Currency.

OCI - Other comprehensive income.

OFAC - U.S. Treasury Department - Office of Foreign Assets Control.

OLA - Orderly Liquidation Authority.

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OTTI - Other-than-temporary impairment.

PD - Probability of default.

Raymond James - Raymond James Financial, Inc.

Regions Securities - Regions Securities  LLC.

REIT - Real Estate Investment Trust.

RICO - Racketeer Influenced and Corrupt Organizations Act.

SEC - U.S. Securities and Exchange Commission.

SERP - Supplemental Executive Retirement Plan.

SSFA - Simplified Supervisory Formula Approach.

TBA - To Be Announced.

TDR - Troubled debt restructuring.

TRACE - Trade Reporting and Compliance Engine.

U.S. - United States.

USA PATRIOT Act - Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept

and Obstruct Terrorism Act of 2001.

U.S. Treasury - The United States Department of the Treasury.

UTB - Unrecognized tax benefits.

VIE - Variable interest entity.

Visa - The Visa, U.S.A. Inc. card association or its affiliates, collectively.

Volcker Rule - Section 619 of the Dodd-Frank Act and regulations promulgated thereunder, as applicable.

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PART I

Forward-Looking Statements

This Annual  Report  on  Form  10-K,  other  periodic  reports  filed  by  Regions  Financial  Corporation  under  the  Securities 
Exchange Act of 1934, as amended, and any other written or oral statements made by us or on our behalf to analysts, investors, 
the media and others, may include forward-looking statements as defined in the Private Securities Litigation Reform Act of 1995. 
The terms “Regions,” the “Company,” “we,” “us” and “our” mean Regions Financial Corporation, a Delaware corporation, and 
its subsidiaries when or where appropriate. The words “anticipates,” “intends,” “plans,” “seeks,” “believes,” “estimates,” “expects,” 
“targets,” “projects,” “outlook,” “forecast,” “will,” “may,” “could,” “should,” “can,” and similar expressions often signify forward-
looking statements. Forward-looking statements are not based on historical information, but rather are related to future operations, 
strategies, financial results or other developments. Forward-looking statements are based on management’s current expectations 
as well as certain assumptions and estimates made by, and information available to, management at the time the statements are 
made. Those statements are based on general assumptions and are subject to various risks, and because they also relate to the future 
they are likewise subject to inherent uncertainties and other factors that may cause actual results to differ materially from the views, 
beliefs and projections expressed in such statements. Therefore, we caution you against relying on any of these forward-looking 
statements. These risks, uncertainties and other factors include, but are not limited to, the risks identified in Item 1A. “Risk Factors” 
of this Annual Report on Form 10-K and those described below:

•  Current  and  future  economic  and  market  conditions  in  the  United  States  generally  or  in  the  communities  we  serve, 
including the effects of declines in property values, unemployment rates and potential reductions of economic growth, 
which may adversely affect our lending and other businesses and our financial results and conditions. 

• 

Possible changes in trade, monetary and fiscal policies of, and other activities undertaken by, governments, agencies, 
central banks and similar organizations, which could have a material adverse effect on our earnings.

•  The effects of a possible downgrade in the U.S. government’s sovereign credit rating or outlook, which could result in 

risks to us and general economic conditions that we are not able to predict.

• 

Possible changes in market interest rates or capital markets could adversely affect our revenue and expense, the value of 
assets and obligations, and the availability and cost of capital and liquidity.

•  Any impairment of our goodwill or other intangibles, or any adjustment of valuation allowances on our deferred tax assets 

due to adverse changes in the economic environment, declining operations of the reporting unit, or other factors.

• 

Possible changes in the creditworthiness of customers and the possible impairment of the collectability of loans and 
leases, including operating leases.

•  Changes in the speed of loan prepayments, loan origination and sale volumes, charge-offs, loan loss provisions or actual 

loan losses where our allowance for loan losses may not be adequate to cover our eventual losses.

• 

Possible acceleration of prepayments on mortgage-backed securities due to low interest rates, and the related acceleration 
of premium amortization on those securities.

•  Our  ability  to  effectively  compete  with  other  financial  services  companies,  some  of  whom  possess  greater  financial 

resources than we do and are subject to different regulatory standards than we are.

•  Loss of customer checking and savings account deposits as customers pursue other, higher-yield investments, which could 

increase our funding costs.

•  Our inability to develop and gain acceptance from current and prospective customers for new products and services in a 

timely manner could have a negative impact on our revenue.

•  The effects of any developments, changes or actions relating to any litigation or regulatory proceedings brought against 

us or any of our subsidiaries.

•  Changes in laws and regulations affecting our businesses, such as the Dodd-Frank Act and other legislation and regulations 
relating to bank products and services, as well as changes in the enforcement and interpretation of such laws and regulations 
by applicable governmental and self-regulatory agencies, which could require us to change certain business practices, 
increase compliance risk, reduce our revenue, impose additional costs on us, or otherwise negatively affect our businesses.

•  Our ability to obtain a regulatory non-objection (as part of the CCAR process or otherwise) to take certain capital actions, 
including paying dividends and any plans to increase common stock dividends, repurchase common stock under current 
or future programs, or redeem preferred stock or other regulatory capital instruments, may impact our ability to return 
capital to stockholders and market perceptions of us. 

•  Our ability to comply with stress testing and capital planning requirements (as part of the CCAR process or otherwise) 
may continue to require a significant investment of our managerial resources due to the importance and intensity of such 
tests and requirements.

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•  Our ability to comply with applicable capital and liquidity requirements (including, among other things, the Basel III 
capital standards and the LCR rule), including our ability to generate capital internally or raise capital on favorable terms, 
and if we fail to meet requirements, our financial condition could be negatively impacted.

•  The Basel III framework calls for additional risk-based capital surcharges for globally systemically important banks.  
Although we are not subject to such surcharges, it is possible that in the future we may become subject to similar surcharges.

•  The costs, including possibly incurring fines, penalties, or other negative effects (including reputational harm) of any 
adverse judicial, administrative, or arbitral rulings or proceedings, regulatory enforcement actions, or other legal actions 
to which we or any of our subsidiaries are a party, and which may adversely affect our results. 

•  Our ability to manage fluctuations in the value of assets and liabilities and off-balance sheet exposure so as to maintain 

sufficient capital and liquidity to support our business.

•  Our ability to execute on our strategic and operational plans, including our ability to fully realize the financial and non-

financial benefits relating to our strategic initiatives.

•  The success of our marketing efforts in attracting and retaining customers.

• 

Possible changes in consumer and business spending and saving habits and the related effect on our ability to increase 
assets and to attract deposits, which could adversely affect our net income.

•  Our ability to recruit and retain talented and experienced personnel to assist in the development, management and operation 

of our products and services may be affected by changes in laws and regulations in effect from time to time.

• 

Fraud or misconduct by our customers, employees or business partners.

•  Any inaccurate or incomplete information provided to us by our customers or counterparties.

•  The risks and uncertainties related to our acquisition and integration of other companies.

• 

Inability of our framework to manage risks associated with our business such as credit risk and operational risk, including 
third-party vendors and other service providers, which could, among other things, result in a breach of operating or security 
systems as a result of a cyber attack or similar act. 

•  The  inability  of  our  internal  disclosure  controls  and  procedures  to  prevent,  detect  or  mitigate  any  material  errors  or 

fraudulent acts.

•  The effects of geopolitical instability, including wars, conflicts and terrorist attacks and the potential impact, directly or 

indirectly, on our businesses.

•  The effects of man-made and natural disasters, including fires, floods, droughts, tornadoes, hurricanes, and environmental 
damage,  which  may  negatively  affect  our  operations  and/or  our  loan  portfolios  and  increase  our  cost  of  conducting 
business.

•  Changes in commodity market prices and conditions could adversely affect the cash flows of our borrowers operating in 
industries that are impacted by changes in commodity prices (including businesses indirectly impacted by commodities 
prices such as businesses that transport commodities or manufacture equipment used in the production of commodities), 
which could impair their ability to service any loans outstanding to them and/or reduce demand for loans in those industries.

•  Our inability to keep pace with technological changes could result in losing business to competitors.

•  Our ability to identify and address cyber-security risks such as data security breaches, “denial of service” attacks, “hacking” 
and  identity  theft,  a  failure  of  which  could  disrupt  our  business  and  result  in  the  disclosure  of  and/or  misuse  or 
misappropriation of confidential or proprietary information; disruption or damage to our systems; increased costs; losses; 
or adverse effects to our reputation. 

•  Our ability to realize our adjusted efficiency ratio target as part of our expense management initiatives.

• 

• 

Significant disruption of, or loss of public confidence in, the Internet and services and devices used to access the Internet 
could affect the ability of our customers to access their accounts and conduct banking transactions.

Possible downgrades in our credit ratings or outlook could increase the costs of funding from capital markets. 

•  The effects of problems encountered by other financial institutions that adversely affect us or the banking industry generally 
could require us to change certain business practices, reduce our revenue, impose additional costs on us, or otherwise 
negatively affect our businesses.

•  The effects of the failure of any component of our business infrastructure provided by a third party could disrupt our 
businesses; result in the disclosure of and/or misuse of confidential information or proprietary information; increase our 
costs; negatively affect our reputation; and cause losses. 

•  Our ability to receive dividends from our subsidiaries could affect our liquidity and ability to pay dividends to stockholders.

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•  Changes in accounting policies or procedures as may be required by the FASB or other regulatory agencies could materially 

affect how we report our financial results.

•  Other risks identified from time to time in reports that we file with the SEC.

•  The effects of any damage to our reputation resulting from developments related to any of the items identified above.

You should not place undue reliance on any forward-looking statements, which speak only as of the date made. Factors or 
events that could cause our actual results to differ may emerge from time to time, and it is not possible to predict all of them. We 
assume no obligation to update or revise any forward-looking statements that are made from time to time, either as a result of 
future developments, new information or otherwise, except as may be required by law.

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Item 1.  Business

Regions Financial Corporation is a financial holding company headquartered in Birmingham, Alabama that operates in the 
South, Midwest and Texas. The terms "Regions," "the Company," "we," "us" and "our" mean Regions Financial Corporation, a 
Delaware corporation and its subsidiaries, when appropriate. Regions provides traditional commercial, retail and mortgage banking 
services, as well as other financial services in the fields of asset management, wealth management, securities brokerage, insurance 
brokerage, trust services, merger and acquisition advisory services, and other specialty financing. At December 31, 2016, Regions 
had total consolidated assets of approximately $126.0 billion, total consolidated deposits of approximately $99.0 billion and total 
consolidated stockholders’ equity of approximately $16.7 billion.

Regions is a Delaware corporation and on July 1, 2004, became the successor by merger to Union Planters Corporation and 
the former Regions Financial Corporation. Its principal executive offices are located at 1900 Fifth Avenue North, Birmingham, 
Alabama 35203, and its telephone number at that address is (800) 734-4667.

Banking Operations

Regions conducts its banking operations through Regions Bank, an Alabama state-chartered commercial bank that is a member 
of the Federal Reserve System. At December 31, 2016, Regions operated 1,906 ATMs and 1,527 banking offices in Alabama, 
Arkansas, Florida, Georgia, Illinois, Indiana, Iowa, Kentucky, Louisiana, Mississippi, Missouri, North Carolina, South Carolina, 
Tennessee, and Texas.

The following chart reflects the distribution of branch locations in each of the states in which Regions conducts its banking 

operations.

Florida

Tennessee

Alabama

Mississippi

Georgia

Louisiana

Arkansas

Texas

Missouri

Illinois

Indiana

South Carolina

Kentucky

Iowa

North Carolina

Total

Branches

326

230

226

132

124

104

88

76

57

55

55

26

12

10

6

1,527

Other Financial Services Operations

In addition to its banking operations, Regions provides additional financial services through the following subsidiaries:

Regions Insurance Group, Inc., a subsidiary of Regions, is an insurance broker that offers the placement of insurance coverage 
with  insurance  companies  or  other  risk  bearing  entities  through  its  subsidiaries:  Regions  Insurance,  Inc.,  headquartered  in 
Birmingham, Alabama; Trilogy Risk Specialists, Inc., headquartered in Memphis, Tennessee; and Regions Insurance Services, 
Inc., headquartered in Memphis, Tennessee. Through its insurance brokerage operations in Alabama, Arkansas, Florida, Georgia, 
Indiana, Louisiana, Mississippi, South Carolina, Tennessee and Texas, Regions Insurance, Inc. offers insurance coverage for various 
lines  of  personal  and  commercial  insurance,  such  as  property,  vehicle,  casualty,  life,  health  and  accident  insurance.  Regions 
Insurance, Inc. also provides services related to employee benefits. Trilogy Risk Specialists, Inc. operates as a wholesale insurance 
broker assisting retail insurance brokers in placing insurance coverage for the retail brokers’ customers with risk bearing entities.  
Regions Insurance Services, Inc. offers various insurance products, such as crop and life insurance. Regions Insurance Group, Inc. 
is one of the thirty largest insurance brokers in the United States based on annual revenues.

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Regions  Equipment  Finance  Corporation  and  Regions  Commercial  Equipment  Finance,  LLC,  each  a  wholly-owned 

subsidiary of Regions Bank, provide equipment financing products, focusing on commercial clients.

Regions Investment Services LLC , a wholly-owned subsidiary of Regions Bank, offers investments and insurance products 
to Regions Bank customers, provided by licensed insurance agents. In addition, Regions Bank and Regions Investment Services, 
Inc. also maintain an agreement with Cetera Investment Services, LLC to offer securities, insurance and advisory services to 
Regions Bank customers through dually-employed financial consultants.

Regions Securities LLC, a wholly-owned subsidiary of Regions headquartered in Atlanta, Georgia, serves as a broker-dealer 
to commercial clients and acts in an advisory capacity to merger and acquisition transactions. Additionally, BlackArch Partners 
LLC is a wholly-owned subsidiary of Regions and is headquartered in Charlotte, North Carolina. BlackArch Partners LLC and 
its subsidiaries offer merger and acquisition services to its institutional clients and commercial entities.

Regions Affordable Housing LLC is a wholly-owned subsidiary of Regions Bank headquartered in Great Neck, New York 

and engages in Low Income Housing Tax Credit corporate fund syndication and asset management. 

Segment Information

Reference is made to Note 23 “Business Segment Information” to the consolidated financial statements included under 

Item 8. of this Annual Report on Form 10-K for information required by this item.

Supervision and Regulation

We are subject to the extensive regulatory framework applicable to BHCs and their subsidiaries. This framework is intended 
primarily for the protection of depositors, the FDIC's DIF and the banking system as a whole, and generally is not intended for 
the protection of stockholders or other investors. Described below are the material elements of selected laws and regulations 
applicable to us and our subsidiaries. These descriptions are not intended to be complete and are qualified in their entirety by 
reference to the full text of the statutes and regulations described. Changes in applicable law or regulation, and in their interpretation 
and application by regulatory agencies and other governmental authorities, cannot be predicted, but may have a material effect on 
our business, financial condition or results of operations.

Applicable laws and regulations restrict our permissible activities and investments and impose conditions and requirements 
on the products and services we offer and the manner in which they are offered and sold. They also restrict our ability to repurchase 
stock or pay dividends, or to receive dividends from our banking subsidiary, and impose capital adequacy requirements on us and 
our banking subsidiary. The consequences of noncompliance with these laws and regulations can include substantial monetary 
and nonmonetary sanctions.

As described in more detail below, comprehensive reform of the legislative and regulatory landscape occurred with the 
passage of the Dodd-Frank Act in 2010, and implementation of the Dodd-Frank Act and related rulemaking activities continued 
in 2016.

Overview

We are registered with the Federal Reserve as a BHC and have elected to be treated as a financial holding company under 
the BHC Act. As such, we and our subsidiaries are subject to the supervision, examination and reporting requirements of the BHC 
Act and the regulations of the Federal Reserve.  Generally, the BHC Act provides for “umbrella” regulation of financial holding 
companies by the Federal Reserve and functional regulation of holding company subsidiaries by applicable regulatory agencies. 
The BHC Act, however, requires the Federal Reserve to examine any subsidiary of a BHC, other than a depository institution, 
engaged  in  activities  permissible  for  a  depository  institution.  The  Federal  Reserve  is  also  granted  the  authority,  in  certain 
circumstances, to require reports of, examine and adopt rules applicable to any holding company subsidiary.

Regions Bank is a member of the FDIC, and, as such, its deposits are insured by the FDIC to the extent provided by law. 
Regions Bank is an Alabama state-chartered bank and a member of the Federal Reserve System. Its operations are generally subject 
to supervision and examination by both the Federal Reserve and the Alabama State Banking Department and the bank regulators 
are given authority to approve or disapprove mergers, acquisitions, consolidations, the establishment of branches and similar 
corporate actions. The federal and state banking regulators also have the power to prevent the continuance or development of 
unsafe or unsound banking practices or other violations of law. State and federal law govern the activities in which Regions Bank 
engages, including the investments it makes and the aggregate amount of loans that may be granted to one borrower. Various 
consumer and compliance laws and regulations also affect its operations. Regions Bank also is affected by the actions of the Federal 
Reserve Board as it implements monetary policy.

All member banks of the Federal Reserve System, including Regions Bank, are required to hold stock in the Federal Reserve 
System's Reserve Banks in an amount equal to 6 percent of their capital stock and surplus (half paid to acquire the stock with the 
remainder held as a cash reserve). Member banks do not have any control over the Federal Reserve System as a result of owning 
the stock and the stock cannot be sold or traded. Prior to the enactment of the Fixing America's Surface Transportation Act (“FAST 
Act”) in December 2015, member banks received a fixed, 6 percent dividend annually on their stock. Under the FAST Act, beginning 

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on January 1, 2016, the annual dividend rate for member banks with total assets in excess of $10 billion, including Regions Bank, 
changed to a floating dividend rate tied to 10-year U.S. Treasuries with the maximum dividend rate capped at 6 percent. 

Regions Bank and its affiliates are also subject to supervision, regulation, examination and enforcement by the CFPB with 
respect to consumer protection laws and regulations. Some of Regions’ non-bank subsidiaries are also subject to regulation by 
various federal and state agencies, such as the SEC and FINRA in the case of our broker-dealer subsidiary, Regions Securities.

We are also subject to the disclosure and regulatory requirements of the Securities Exchange Act of 1934, as amended, as 
administered by the SEC.  Our common stock and depository shares representing our outstanding preferred stock are each listed 
on the NYSE. Consequently, we are also subject to NYSE’s rules for listed companies.

Financial Regulatory Reform

The financial crisis led to the adoption and revision of numerous laws and regulations applicable to financial institutions 
operating in the U.S. In particular, the Dodd-Frank Act and the rules that followed have significantly restructured the financial 
regulatory regime in the U.S. and provide for enhanced supervision and prudential standards for, among other institutions, BHCs 
like  Regions  that  have  total  consolidated  assets  of  $50  billion  or  more.  The  Dodd-Frank Act  is  extensive,  complicated  and 
comprehensive legislation that impacts practically all aspects of a banking organization, representing a significant overhaul of 
many aspects of the regulation of the financial services industry. 

The Dodd-Frank Act imposed regulatory requirements and oversight over banks and other financial institutions in a number 
of ways, among which were: (i) created the CFPB to regulate consumer financial products and services; (ii) created the FSOC to 
identify and impose additional regulatory oversight on large financial firms; (iii) granted orderly liquidation authority to the FDIC 
for the liquidation of financial corporations that pose a risk to the financial system of the U.S.; (iv) required certain financial 
institutions to draft a resolution plan that contemplates the dissolution of the enterprise and to submit that resolution plan to both 
the Federal Reserve and the FDIC; (v) limited debit card interchange fees; (vi) adopted certain changes to stockholder rights and 
responsibilities, including a stockholder “say on pay” vote on executive compensation; (vii) strengthened the SEC’s powers to 
regulate securities markets; (viii) restricted variable-rate lending by requiring the ability to repay to be determined for variable-
rate loans by using the maximum rate that will apply during the first five years of a variable-rate loan term, and making more loans 
subject to provisions for higher cost loans, new disclosures, and certain other revisions; (ix) changed the base upon which the 
deposit insurance assessment is assessed from deposits to, substantially, average consolidated assets minus equity; and (x) amended 
the Truth in Lending Act with respect to mortgage originations, including originator compensation, minimum repayment standards, 
and prepayment considerations.

 The Dodd-Frank Act requires the Federal Reserve to monitor emerging risks to financial stability and establish enhanced 
supervision  and  prudential  standards  applicable  to  large,  interconnected  financial  institutions,  including  Regions,  with  total 
consolidated assets of $50 billion or more (often referred to as systemically important financial institutions). During February 
2014, the FRB published the final rule implementing the enhanced prudential standards required to be established under section 
165 of the Dodd-Frank Act. The enhanced prudential standards include risk-based capital and leverage requirements, liquidity 
standards, risk management and risk committee requirements, stress test requirements and a debt-to-equity limit for companies 
that the FSOC has determined would pose a grave threat to financial stability were they to fail such limits.

Pursuant to the Dodd-Frank Act, BHCs with total consolidated assets of $50 billion or more, such as Regions, are required 
to submit resolution plans to the Federal Reserve and FDIC providing for the company’s strategy for rapid and orderly resolution 
in the event of its material financial distress or failure. In September 2011, these agencies issued a joint final resolution plan rule 
implementing this requirement. The FDIC issued a separate such rule applicable to insured depository institutions of $50 billion 
or more in total assets, such as Regions Bank. Regions and Regions Bank submitted their most recent resolution plans to these 
agencies in December 2016. If the Federal Reserve and the FDIC determine that these plans are not credible and we do not cure 
the deficiencies, the Federal Reserve and the FDIC may impose more stringent capital, leverage or liquidity requirements or 
restrictions on growth, activities or operations of the Company.

The Basel III Rules, summarized briefly below, have impacted our level of capital, and may influence the types of business 
we may pursue and how we pursue business opportunities. Among other things, the Basel III Rules raised the required minimums 
for certain capital ratios, added a common equity ratio, included capital buffers, and restricted what constitutes capital. The capital 
and risk weighting requirements became effective for us on January 1, 2015.

Many of the provisions of the Dodd-Frank Act and other laws are subject to further rulemaking, guidance and interpretation 
by the applicable federal regulators. We will continue to evaluate the impact of any changes in law and any new regulations 
promulgated, including changes in regulatory costs and fees, modifications to consumer products or disclosures required by the 
CFPB and the requirements of the enhanced supervision provisions, among others.

Permissible Activities under the BHC Act

In general, the BHC Act limits the activities permissible for BHCs to the business of banking, managing or controlling banks 
and such other activities as the Federal Reserve has determined to be so closely related to banking as to be properly incidental 
thereto. A BHC electing to be treated as a financial holding company, like Regions, may also engage in a range of activities that 

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are (i) financial in nature or incidental to such financial activity or (ii) complementary to a financial activity and that do not pose 
a substantial risk to the safety and soundness of a depository institution or to the financial system generally. These activities include 
securities dealing, underwriting and market making, insurance underwriting and agency activities, merchant banking and insurance 
company portfolio investments. 

For a BHC to be eligible to elect financial holding company status, all of its subsidiary insured depository institutions must 
be well-capitalized and well-managed as described below under  “-Regulatory Remedies under the FDIA” and must have received 
at least a satisfactory rating on such institution’s most recent examination under CRA. The BHC itself must also be well-capitalized 
and well-managed in order to be eligible to elect financial holding company status. If a financial holding company fails to continue 
to be well-capitalized or well-managed after engaging in activities not permissible for BHCs that have not elected to be treated as 
financial holding companies, the company must enter into an agreement with the Federal Reserve to comply with all applicable 
capital and management requirements. If the company does not return to compliance within 180 days, the Federal Reserve may 
order the company to divest its subsidiary banks or the company may be required to discontinue or divest investments in companies 
engaged in activities permissible only for a BHC electing to be treated as a financial holding company.  Furthermore, if the Federal 
Reserve determines that a financial holding company has not maintained a CRA rating of at least "satisfactory", the financial 
holding company would not be able to commence any new financial activities or acquire a company that engages in such activities, 
although  the  financial  holding  company  would  still  be  allowed  to  engage  in  activities  closely  related  to  banking  and  make 
investments in the ordinary course of conducting banking activities.

The BHC Act does not place territorial restrictions on permissible non-banking activities of BHCs. The Federal Reserve has 
the power to order any BHC or its subsidiaries to terminate any activity or to terminate its ownership or control of any subsidiary 
when  the  Federal  Reserve  has  reasonable  grounds  to  believe  that  continuation  of  such  activity  or  such  ownership  or  control 
constitutes a serious risk to the financial soundness, safety or stability of any bank subsidiary of the BHC.

Capital Requirements

Regions and Regions Bank are each required to comply with applicable capital adequacy standards established by the Federal 
Reserve. The current risk-based capital standards applicable to Regions and Regions Bank, parts of which are currently being 
phased in, are based on Basel III. 

Prior to January 1, 2015, the risk-based capital standards applicable to Regions and Regions Bank (the “general risk-based 
capital rules”) were based on Basel I.  In July 2013, the federal bank regulators approved the final Basel III Rules implementing 
the Basel III framework as well as certain provisions of the Dodd-Frank Act.  The Basel III Rules substantially revised the risk-
based capital requirements applicable to BHCs and their depository institution subsidiaries, including Regions and Regions Bank, 
as compared to the general risk-based capital rules. The Basel III Rules became effective for Regions and Regions Bank on January 
1, 2015 (subject to a phase-in period for certain provisions).

The Basel III Rules, among other things, (i) introduced a new capital measure called CET1, (ii) specified that Tier 1 capital 
consists of CET1 and “Additional Tier 1 capital” instruments meeting certain revised requirements, (iii) defined CET1 narrowly 
by requiring that most deductions/adjustments to regulatory capital measures be made to CET1 and not to the other components 
of capital, and (iv) expanded the scope of the deductions/adjustments to capital as compared to existing regulations.

Under the Basel III Rules, the minimum capital ratios are:

•  4.5% CET1 to risk-weighted assets;

•  6.0% Tier 1 capital (that is, CET1 plus Additional Tier 1 capital) to risk-weighted assets; and

•  8.0% Total capital (that is, Tier 1 capital plus Tier 2 capital) to risk-weighted assets.

The Basel III Rules also introduced a new capital conservation buffer designed to absorb losses during periods of economic 
stress. The capital conservation buffer is on top of minimum risk-weighted asset ratios. In addition, the Basel III Rules provide 
for a countercyclical capital buffer applicable only to advanced approaches institutions.  Currently the countercyclical capital 
buffer is not applicable to Regions or Regions Bank. The reportable capital conservation buffer is equal to the lowest difference 
between the three risk-based capital ratios less the applicable minimum required ratio. Banking institutions with ratios that are 
above the minimum but below the combined capital conservation buffer and countercyclical capital buffer (when applicable) will 
face constraints on dividends, equity repurchases and compensation based on the amount of the shortfall.

When fully phased in on January 1, 2019, the Basel III Rules will require Regions and Regions Bank to maintain an additional 
capital conservation buffer of 2.5% of CET1 to risk-weighted assets, effectively resulting in minimum ratios of (i) CET1 to risk-
weighted assets of at least 7%, (ii) Tier 1 capital to risk-weighted assets of at least 8.5%, and (iii) Total capital to risk-weighted 
assets of at least 10.5%. 

The Basel III Rules also provided for a number of deductions from and adjustments to CET1.  These include, for example, 
the requirement that MSRs, certain deferred tax assets and significant investments in non-consolidated financial entities be deducted 
from CET1 to the extent that any one such category exceeds 10% of CET1 or all such items, in the aggregate, exceed 15% of 
CET1.

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Implementation of the deductions and other adjustments to CET1 began on January 1, 2015 and will be phased in over a 
remaining 3-year period (began at 40% on January 1, 2015 and an additional 20% per year thereafter). The implementation of the 
capital conservation buffer began on January 1, 2016 at the 0.625% level and will be phased in over a remaining 3-year period 
(increasing by that amount on each subsequent January 1, until it reaches 2.5% on January 1, 2019).

The Basel III Rules prescribed a new standardized approach for risk weightings that expands the risk-weighting categories 
from the four Basel I-derived categories (0%, 20%, 50% and 100%) to a much larger and more risk-sensitive number of categories, 
depending on the nature of the assets, generally ranging from 0% for U.S. government and agency securities, to 600% for certain 
equity exposures, and resulting in higher risk weights for a variety of asset classes.

Leverage Requirements 

BHCs and banks are also required to comply with minimum leverage ratio requirements. These requirements provide for a 
minimum ratio of Tier 1 capital to total consolidated quarterly average assets (as defined for regulatory purposes), net of the loan 
loss reserve, goodwill and certain other intangible assets (the “leverage ratio”), of 4.0% for all BHCs.

Liquidity Regulation 

Liquidity risk management and supervision have become increasingly important since the financial crisis.  During 2014, the 
federal banking agencies adopted final rules implementing for certain U.S. banking organizations one of the two new standards 
provided for in the Basel III liquidity framework - its LCR, which is designed to ensure that a covered bank or BHC maintains an 
adequate level of unencumbered high-quality liquid assets equal to the entity’s expected net cash outflow for a 30-day time horizon 
under an acute liquidity stress scenario. The LCR rule, as adopted, applies in its most comprehensive form only to advanced 
approaches BHCs and depository institutions subsidiaries of such BHCs and, in a modified form, to BHCs that are not advanced 
approaches BHCs but have $50 billion or more in total consolidated assets such as Regions. As of January 1, 2017, the rule has 
been fully phased in. Regions is required to calculate its LCR on a monthly basis. If a covered company fails to meet the required 
LCR, it must promptly notify its primary federal banking regulator and may be required to take remedial actions. In December 
2016, the Federal Reserve issued a final rule that requires BHCs, such as Regions, to disclose publicly, on a quarterly basis, 
quantitative and qualitative information about certain components of its LCR beginning for modified LCR BHC’s such as Regions 
on October 1, 2018. At December 31, 2016, Regions' LCR was above the minimum requirement.

The Basel III framework also included a second standard, referred to as the NSFR, which is designed to promote more 
medium- and long-term funding of the assets and activities of banks over a one-year time horizon.  In May 2016, the federal 
banking agencies issued a proposed rule that would implement the NSFR for large U.S. banking organizations. BHCs with less 
than $250 billion, but more than $50 billion, in total consolidated assets and less than $10 billion in on-balance sheet foreign 
exposure, such as Regions, would be subject to a modified NSFR requirement which would require such BHCs to maintain a 
minimum NSFR of 0.7 on an ongoing basis, calculated by dividing the organization's available stable funding ("ASF") by its 
required stable funding ("RSF").  Under the proposed rule, a banking organization’s ASF would be calculated by applying specified 
standard weightings to its equity and liabilities based on their expected stability over a one-year time horizon and its RSF would 
be calculated by applying specified standardized weightings to its assets, derivative exposures and commitments based on their 
liquidity characteristics over the same one-year time horizon.  If implemented, the proposed rule would take effect on January 1, 
2018.

Comprehensive Capital Analysis and Review and Stress Testing 

As  part  of  the  enhanced  prudential  requirements  applicable  to  systemically  important  financial  institutions,  the  Federal 
Reserve conducts annual analyses of BHCs with at least $50 billion in assets to determine whether the companies have sufficient 
capital on a consolidated basis necessary to absorb losses in three economic and financial scenarios generated by the Federal 
Reserve:  baseline, adverse and severely adverse.  Regions is also required to conduct its own semi-annual stress analysis (together 
with the Federal Reserve’s stress analysis, the “stress tests”) to assess the potential impact on Regions of the economic and financial 
conditions used as part of the Federal Reserve’s annual stress analysis. The Federal Reserve may also use, and require companies 
to use, additional components in the adverse and severely adverse scenarios or additional or more complex scenarios designed to 
capture salient risks to specific business groups. Regions Bank is also required to conduct annual stress testing using the same 
economic and financial scenarios as Regions and report the results to the Federal Reserve.  A summary of results of the Federal 
Reserve’s analysis under the adverse and severely adverse stress scenarios are publicly disclosed, and the BHCs subject to the 
rules, including Regions, must disclose a summary of the company-run severely adverse stress test results. Regions is required to 
include in its disclosure a summary of the severely adverse scenario stress test conducted by Regions Bank.

U.S. BHCs with total consolidated assets of $50 billion or more, such as Regions, must develop and maintain a capital plan, 
and must submit the capital plan to the Federal Reserve as part of the Federal Reserve’s CCAR process. The CCAR process is 
intended to help ensure that these BHCs have robust, forward-looking capital planning processes that account for each company’s 
unique risks and that permit continued operations during times of economic and financial stress. Each of the BHCs participating 
in the CCAR process is also required to collect and report certain related data to the Federal Reserve on a quarterly basis to allow 
the Federal Reserve to monitor progress against the approved capital plans. Each capital plan must include a view of capital 
adequacy under the stress test scenarios described below. 

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In addition to other limitations, our ability to make any capital distributions (including dividends and share repurchases) is 
contingent on the Federal Reserve's non-objection to our capital plan. Should the Federal Reserve object to a capital plan, a BHC 
may not make any capital distribution other than those capital distributions to which the Federal Reserve has indicated its non-
objection in writing.  The Federal Reserve may object to a capital plan if the plan does not show that the covered BHC has sufficient 
capital to continue operations under expected conditions and stressed scenarios throughout the nine-quarter planning horizon 
covered by the capital plan. The CCAR rules, consistent with prior Federal Reserve guidance, also provide that capital plans 
contemplating dividend payout ratios exceeding 30% of after-tax net income will receive particularly close scrutiny. As a result 
of a final rule adopted by the Federal Reserve in January 2017, beginning with the 2017 CCAR cycle, the Federal Reserve may 
no longer object to capital plans submitted by BHCs that have total consolidated assets of at least $50 billion but less than $250 
billion, non-bank assets of less than $75 billion, and that are not U.S. global-systemically important banks (referred to as “large 
and non-complex firms”), such as Regions, on the basis of qualitative criteria. Our annual capital planning submission is due by 
April and the Federal Reserve will publish the results of its supervisory CCAR review of our capital plan by June 30 of each year. 

Safety and Soundness Standards  

Guidelines adopted by the federal bank regulatory agencies pursuant to the FDIA, establish general standards relating to 
internal controls and information systems, internal audit systems, loan documentation, credit underwriting, interest rate exposure, 
asset growth and compensation, fees and benefits. In general, these guidelines require, among other things, appropriate systems 
and  practices  to  identify  and  manage  the  risk  and  exposures  specified  in  the  guidelines. Additionally,  the  agencies  adopted 
regulations that authorize, but do not require, an agency to order an institution that has been given notice by an agency that it is 
not satisfying any of such safety and soundness standards to submit a compliance plan. If, after being so notified, an institution 
fails to submit an acceptable compliance plan or fails in any material respect to implement an acceptable compliance plan, the 
agency must issue an order directing action to correct the deficiency and may issue an order directing other actions of the types 
to which an undercapitalized institution is subject under the FDIA. See “-Regulatory Remedies under the FDIA” below. If an 
institution fails to comply with such an order, the agency may seek to enforce such order in judicial proceedings and to impose 
civil money penalties.

Regulatory Remedies under the FDIA

The FDIA requires the federal banking agencies to take prompt corrective action in respect of depository institutions that do 
not meet specified capital requirements. The FDIA establishes five capital categories (“well-capitalized,” “adequately capitalized,” 
“undercapitalized,” “significantly undercapitalized” and “critically undercapitalized”), and the federal banking agencies must take 
certain mandatory supervisory actions, and are authorized to take other discretionary actions, with respect to institutions which 
are undercapitalized, significantly undercapitalized or critically undercapitalized. The severity of these mandatory and discretionary 
supervisory actions depends upon the capital category in which the institution is placed. Generally, subject to a narrow exception, 
the FDIA requires the banking regulator to appoint a receiver or conservator for an institution that is critically undercapitalized. 
As of December 31, 2016, both Regions and Regions Bank were well-capitalized.

An institution that is classified as well-capitalized based on its capital levels may be treated as adequately capitalized, and 
an institution that is adequately capitalized or undercapitalized based upon its capital levels may be treated as though it were 
undercapitalized  or  significantly  undercapitalized,  respectively,  if  the  appropriate  federal  banking  agency,  after  notice  and 
opportunity for hearing, determines that an unsafe or unsound condition or an unsafe or unsound practice warrants such treatment.

An institution that is categorized as undercapitalized, significantly undercapitalized or critically undercapitalized is required 
to submit an acceptable capital restoration plan to its appropriate federal banking regulator. Under the FDIA, in order for the capital 
restoration plan to be accepted by the appropriate federal banking agency, a BHC must guarantee that a subsidiary depository 
institution will comply with its capital restoration plan, subject to certain limitations. The BHC must also provide appropriate 
assurances of performance. The obligation of a controlling BHC under the FDIA to fund a capital restoration plan is limited to the 
lesser  of  5.0%  of  an  undercapitalized  subsidiary’s  assets  or  the  amount  required  to  meet  regulatory  capital  requirements. An 
undercapitalized institution is also generally prohibited from increasing its average total assets, making acquisitions, establishing 
any branches or engaging in any new line of business, except in accordance with an accepted capital restoration plan or with the 
approval of the FDIC. Institutions that are significantly undercapitalized or undercapitalized and either fail to submit an acceptable 
capital restoration plan or fail to implement an approved capital restoration plan may be subject to a number of requirements and 
restrictions, including orders to sell sufficient voting stock to become adequately capitalized, requirements to reduce total assets 
and cessation of receipt of deposits from correspondent banks. Critically undercapitalized depository institutions failing to submit 
or implement an acceptable capital restoration plan are subject to appointment of a receiver or conservator.

Additionally, FDIA requires the various regulatory agencies to prescribe certain non-capital standards for safety and soundness 
relating generally to operations and management, asset quality, and executive compensation and permits regulatory action against 
a financial institution that does not meet such standards. Regulators also must take into consideration: (i) concentrations of credit 
risk; (ii) interest rate risk (when the interest rate sensitivity of an institution’s assets does not match the sensitivity of its liabilities 
or its off-balance sheet position); and (iii) risks from non-traditional activities, as well as an institution’s ability to manage those 
risks,  when  determining  the  adequacy  of  an  institution’s  capital.  Regulators  make  this  evaluation  as  a  part  of  their  regular 

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examination of the institution’s safety and soundness. Additionally, regulators may choose to examine other factors in order to 
evaluate the safety and soundness of financial institutions. 

Payment of Dividends

We are a legal entity separate and distinct from our banking and other subsidiaries. The principal source of cash flow to us, 
including cash flow to pay dividends to our stockholders and principal and interest on any of our outstanding debt, is dividends 
from Regions Bank. There are statutory and regulatory limitations on the payment of dividends by Regions Bank to us, as well as 
by us to our stockholders.

If, in the opinion of a federal bank regulatory agency, an institution under its jurisdiction is engaged in or is about to engage 
in an unsafe or unsound practice (which, depending on the financial condition of the institution, could include the payment of 
dividends), such agency may require, after notice and hearing, that such institution cease and desist from such practice. The federal 
bank regulatory agencies have indicated that paying dividends that deplete an institution’s capital base to an inadequate level would 
be an unsafe and unsound banking practice. Under the FDIA, an insured institution may not pay a dividend if payment would 
cause  it  to  become  undercapitalized  or  if  it  already  is  undercapitalized.  See  “-Regulatory  Remedies  under  the  FDIA”  above. 
Moreover, the Federal Reserve and the FDIC have issued policy statements stating that BHCs and insured banks should generally 
pay dividends only out of current operating earnings.

Payment of Dividends by Regions Bank. Under the Federal Reserve’s Regulation H, Regions Bank may not, without approval 
of the Federal Reserve, declare or pay a dividend to us if the total of all dividends declared in a calendar year exceeds the total of 
(a) Regions Bank’s net income for that year and (b) its retained net income for the preceding two calendar years, less any required 
transfers to additional paid-in capital or to a fund for the retirement of preferred stock.

Under Alabama law, Regions Bank may not pay a dividend in excess of 90% of its net earnings unless its surplus is equal 
to at least 20% of capital. Regions Bank is also required by Alabama law to seek the approval of the Alabama Superintendent of 
Banking prior to the payment of dividends if the total of all dividends declared by Regions Bank in any calendar year will exceed 
the total of (a) Regions Bank’s net earnings for that year, plus (b) its retained net earnings for the preceding two years, less any 
required transfers to surplus. The statute defines net earnings as the remainder of all earnings from current operations plus actual 
recoveries on loans and investments and other assets, after deducting from the total thereof all current operating expenses, actual 
losses, accrued dividends on preferred stock, if any, and all federal, state and local taxes. Regions Bank cannot, without approval 
from the Federal Reserve and the Alabama Superintendent of Banking, declare or pay a dividend to Regions unless Regions Bank 
is able to satisfy the criteria discussed above.

Payment of Dividends by Regions. Our payment of dividends to our stockholders is subject to the oversight of the Federal 
Reserve. In particular, the dividend policies and share repurchases of a large BHC, such as Regions, are reviewed by the Federal 
Reserve based on capital plans submitted as part of the CCAR process and stress tests as submitted by the BHC, and will be 
assessed against, among other things, the BHC’s ability to achieve the required capital ratios under the Basel III Rules as they are 
phased in by U.S. regulators. See “-Capital Requirements” and “-Comprehensive Capital Analysis and Review and Stress Testing” 
above.

Support of Subsidiary Banks

Under longstanding Federal Reserve policy, which has been codified by the Dodd-Frank Act, Regions is expected to act as 
a source of financial strength to, and to commit resources to support, its subsidiary bank. This support may be required at times 
when Regions may not be inclined to provide it. In addition, any capital loans by a BHC to its subsidiary bank are subordinate in 
right of payment to deposits and to certain other indebtedness of such subsidiary bank. In the event of a BHC’s bankruptcy, any 
commitment by the BHC to a federal bank regulatory agency to maintain the capital of a subsidiary bank will be assumed by the 
bankruptcy trustee and entitled to a priority of payment.

Transactions with Affiliates

There are various legal restrictions governing transactions between Regions and its non-bank subsidiaries, on the one hand, 
and Regions Bank and its subsidiaries, on the other hand, including the extent to which Regions and its non-bank subsidiaries may 
borrow or otherwise obtain funding from Regions Bank.  In general, any “covered transaction” by Regions Bank (or its subsidiaries) 
with an affiliate that is an extension of credit must be secured by designated amounts of specified collateral and (i) in the case of 
any single such affiliate, the aggregate amount of covered transactions of Regions Bank and its subsidiaries may not exceed 10% 
of the capital stock and surplus of Regions Bank, and (ii) in the case of all affiliates, the aggregate amount of covered transactions 
of Regions Bank and its subsidiaries may not exceed 20% of the capital stock and surplus of Regions Bank. Covered transactions 
are defined to include, among other things, a loan or extension of credit, as well as a purchase of securities issued by an affiliate, 
a purchase of assets (unless otherwise exempted by the Federal Reserve) from the affiliate, the acceptance of securities issued by 
the affiliate as collateral for a loan, derivatives transactions and securities lending transactions where the bank has credit exposure 
to an affiliate, and the issuance of a guarantee, acceptance or letter of credit on behalf of an affiliate. All covered transactions, 
including certain additional transactions (such as transactions with a third party in which an affiliate has a financial interest), must 
be  conducted  on  market  terms.  The  Dodd-Frank Act  significantly  enhanced  and  expanded  the  scope  and  coverage  of  these 

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limitations, in particular, by including within its scope derivative transactions by and between Regions Bank or its subsidiaries 
and Regions or its other subsidiaries. The Federal Reserve enforces these restrictions and audits Regions for compliance.

Deposit Insurance

Regions Bank accepts deposits, and those deposits have the benefit of FDIC insurance up to the applicable limits. Under the 
FDIA, insurance of deposits may be terminated by the FDIC upon a finding that the insured depository institution has engaged in 
unsafe and unsound practices, is in an unsafe or unsound condition to continue operations or has violated any applicable law, 
regulation, rule, order or condition imposed by a bank’s federal regulatory agency.

Deposit Insurance Assessments. Regions Bank pays deposit insurance premiums to the FDIC based on an assessment rate 
established by the FDIC. FDIC assessment rates for large institutions are calculated based on one of two scorecards, one for most 
large institutions that have more than $10 billion in assets, such as Regions Bank, and another for “highly complex” institutions 
that have over $50 billion in assets and are fully owned by a parent with over $500 billion in assets. Each scorecard has a performance 
score and a loss-severity score that are combined to produce a total score, which is translated into an initial assessment rate. In 
calculating  these  scores,  the  FDIC  utilizes  the  CAMELS  ratings,  as  well  as  forward-looking  financial  measures  to  assess  an 
institution’s ability to withstand asset-related stress and funding-related stress. The FDIC has the ability to make discretionary 
adjustments to the total score, up or down, based upon significant risk factors that are not adequately captured in the scorecard. 
The total score is then translated to an initial base assessment rate on a non-linear, sharply-increasing scale. As of July 1, 2016, 
for large institutions, including Regions Bank, the initial base assessment rate ranges from 3 to 30 basis points on an annualized 
basis (basis points representing cents per $100). Prior to July 1, 2016, the initial base assessment rate ranged from 5 to 35 basis 
points.  After the effect of potential base-rate adjustments, the total base assessment rate could range from 1.5 to 40 basis points 
on an annualized basis. The deposit insurance assessment base is calculated based on the average of total assets less the average 
tangible equity of the insured depository institution during the assessment period, less allowable deductions. 

The FDIA establishes a minimum ratio of deposit insurance reserves to estimated insured deposits, the designated reserve 
ratio (the “DRR”), of 1.15% prior to September 2020 and 1.35% thereafter. On December 20, 2010, the FDIC issued a final rule 
setting the DRR at 2%. The FDIC will, at least semi-annually, update its income and loss projections for the DIF and, if necessary, 
propose rules to further increase assessment rates. Additionally, in October 2015, the FDIC proposed to impose a surcharge on the 
quarterly assessments of insured depository institutions with total consolidated assets of $10 billion or more. The final rule with 
respect to this surcharge became effective on July 1, 2016 and the surcharge will continue through the earlier of the quarter that 
the DRR first reaches or exceeds 1.35% or December 31, 2018. The combined reduction in the initial base assessment rate and 
the surcharge has increased our FDIC insurance assessments by approximately $5 million per quarter. During 2016, Regions Bank’s 
total FDIC insurance assessments and surcharge were $99 million, a $6 million increase from 2015.We cannot predict whether, 
as a result of an adverse change in economic conditions or other reasons, the FDIC will increase deposit insurance assessment 
levels in the future.

For more information, see the “FDIC Insurance Assessments” section of Item 7. “Management’s Discussion and Analysis 

of Financial Condition and Results of Operations” of this Annual Report on Form 10-K.

FICO Assessments. In addition, the Deposit Insurance Funds Act of 1996 authorized the FICO to impose assessments on 
DIF applicable deposits in order to service the interest on FICO’s bond obligations from deposit insurance fund assessments. The 
amount assessed on individual institutions by FICO will be in addition to the amount, if any, paid for deposit insurance according 
to the FDIC’s risk-related assessment rate schedules. FICO assessment rates may be adjusted quarterly to reflect a change in 
assessment base. Regions Bank had a FICO assessment of approximately $6 million in FDIC deposit premiums in 2016, which 
was included in the $99 million in total FDIC insurance assessments previously disclosed.

Acquisitions

The BHC Act requires every BHC to obtain the prior approval of the Federal Reserve before: (1) it may acquire direct or 
indirect ownership or control of any voting shares of any bank or savings and loan association, if after such acquisition, the BHC 
will directly or indirectly own or control 5% or more of the voting shares of the institution; (2) it or any of its subsidiaries, other 
than a bank, may acquire all or substantially all of the assets of any bank or savings and loan association; or (3) it may merge or 
consolidate with any other BHC. BHCs with consolidated assets exceeding $50 billion must (i) obtain prior approval from the 
Federal Reserve before acquiring certain non-bank financial companies with assets exceeding $10 billion and (ii) provide prior 
written notice to the Federal Reserve before acquiring direct or indirect ownership or control of any voting shares of any company 
having consolidated assets of $10 billion or more. BHCs seeking approval to complete an acquisition must be well-capitalized 
and well-managed.

The BHC Act further provides that the Federal Reserve may not approve any transaction that would result in a monopoly or 
would be in furtherance of any combination or conspiracy to monopolize or attempt to monopolize the business of banking in any 
section of the U.S., or the effect of which may be substantially to lessen competition or to tend to create a monopoly in any section 
of  the  country,  or  that  in  any  other  manner  would  be  in  restraint  of  trade,  unless  the  anticompetitive  effects  of  the  proposed 
transaction are clearly outweighed by the public interest in meeting the convenience and needs of the community to be served. 
The Federal Reserve is also required to consider the financial and managerial resources and future prospects of the BHCs and 

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banks impacted and the convenience and needs of the community to be served. Consideration of financial resources generally 
focuses on capital adequacy, and the consideration of convenience and needs of the community to be served includes the parties’ 
performance under the CRA. The Federal Reserve must also take into account the institutions’ effectiveness in combating money 
laundering. In addition, pursuant to the Dodd-Frank Act, the BHC Act was amended to require the Federal Reserve to, when 
evaluating a proposed transaction, consider the extent to which the transaction would result in greater or more concentrated risks 
to the stability of the U.S. banking or financial system.

Depositor Preference

Under federal law, depositors and certain claims for administrative expenses and employee compensation against an insured 
depository institution would be afforded a priority over other general unsecured claims against such an institution in the “liquidation 
or other resolution” of such an institution by any receiver.

Volcker Rule

The Dodd-Frank Act prohibits banks and their affiliates from engaging in proprietary trading and investing in, sponsoring 
and having certain relationships with private funds such  as hedge funds or private  equity funds that would be an investment 
company for purposes of the Investment Company Act of 1940 but for the exclusions in sections 3(c)(1) or 3(c)(7) of that act. The 
statutory provision is commonly called the “Volcker Rule.” In December 2013, federal regulators adopted final rules to implement 
the Volcker Rule, which became effective in July 2015. The final rules also require that large BHCs, such as Regions, design and 
implement compliance programs to ensure adherence to the Volcker Rule’s prohibitions. Development and monitoring of the 
required compliance program may require the expenditure of resources and management attention.

Consumer Protection Laws

We are subject to a number of federal and state consumer protection laws, including laws designed to protect customers and 
promote lending to various sectors of the economy and population. These laws include, but are not limited to the Equal Credit 
Opportunity Act, the Fair Credit Reporting Act, the Truth in Lending Act, the Home Mortgage Disclosure Act, the Real Estate 
Settlement Procedures Act, the Truth in Savings Act, the Electronic Funds Transfer Act, and their respective state law counterparts.

The CFPB has broad rulemaking, supervisory and enforcement powers under various federal consumer financial protection 
laws, including the laws referenced above, fair lending laws and certain other statutes.  The CFPB also has examination and primary 
enforcement authority with respect to depository institutions with $10 billion or more in assets, including the authority to prevent 
unfair, deceptive or abusive practices in connection with the offering of consumer financial products.

The Dodd-Frank Act permits states to adopt consumer protection laws and standards that are more stringent than those 
adopted at the federal level and, in certain circumstances, permits state attorneys general to enforce compliance with both the state 
and federal laws and regulations.

The CFPB has finalized a number of significant rules, including rules that impact nearly every aspect of the lifecycle of a 
residential mortgage loan.  These rules implement the Dodd-Frank Act amendments to the Equal Credit Opportunity Act, the Truth 
in Lending Act and the Real Estate Settlement Procedures Act.  Among other things, the rules adopted by the CFPB require banks 
to: (i) develop and implement procedures to ensure compliance with a “reasonable ability to repay” test and identify whether a 
loan meets a new definition for a “qualified mortgage,” in which case a rebuttable presumption exists that the creditor extending 
the loan has satisfied the reasonable ability to repay test; (ii) implement new or revised disclosures, policies and procedures for 
originating and servicing mortgages including, but not limited to, pre-loan counseling, early intervention with delinquent borrowers 
and specific loss mitigation procedures for loans secured by a borrower's principal residence; (iii) comply with additional restrictions 
on mortgage loan originator hiring and compensation; (iv) comply with new disclosure requirements and standards for appraisals 
and certain financial products; and (v) maintain escrow accounts for higher-priced mortgage loans for a longer period of time. 

Financial Privacy and Cybersecurity

The federal banking regulators have adopted rules that limit the ability of banks and other financial institutions to disclose 
non-public information about consumers to non-affiliated third parties. These limitations require disclosure of privacy policies to 
consumers and, in some circumstances, allow consumers to prevent disclosure of certain personal information to a non-affiliated 
third party. These regulations affect how consumer information is transmitted through diversified financial companies and conveyed 
to outside vendors. In addition, consumers may also prevent disclosure of certain information among affiliated companies that is 
assembled or used to determine eligibility for a product or service, such as that shown on consumer credit reports and asset and 
income information from applications. Consumers also have the option to direct banks and other financial institutions not to share 
information about transactions and experiences with affiliated companies for the purpose of marketing products or services.

In March 2015, federal regulators issued two related statements regarding cybersecurity. One statement indicates that financial 
institutions should design multiple layers of security controls to establish lines of defense and to ensure that their risk management 
processes also address the risk posed by compromised customer credentials, including security measures to reliably authenticate 
customers accessing Internet-based services of the financial institution. The other statement indicates that a financial institution’s 
management is expected to maintain sufficient business continuity planning processes to ensure the rapid recovery, resumption 
and maintenance of the institution’s operations after a cyber-attack involving destructive malware. A financial institution is also 

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expected to develop appropriate processes to enable recovery of data and business operations and address rebuilding network 
capabilities and restoring data if the institution or its critical service providers fall victim to this type of cyber-attack. The Regions 
Information Security Program reflects the requirements of this guidance. If, however, we fail to observe the regulatory guidance 
in the future, we could be subject to various regulatory sanctions, including financial penalties.

In  October  2016,  federal  regulators  jointly  issued  an  advance  notice  of  proposed  rulemaking  on  enhanced  cyber  risk 
management standards that are intended to increase the operational resilience of large and interconnected entities under their 
supervision. Once established, the enhanced cyber risk management standards would help to reduce the potential impact of a cyber-
attack or other cyber-related failure on the financial system. The advance notice of proposed rulemaking addresses five categories 
of cyber standards: (1) cyber risk governance; (2) cyber risk management; (3) internal dependency management; (4) external 
dependency management; and (5) incident response, cyber resilience, and situational awareness. We will continue to monitor any 
developments related to this proposed rulemaking.

Community Reinvestment Act 

Regions Bank is subject to the provisions of the CRA. Under the terms of the CRA, Regions Bank has a continuing and 
affirmative  obligation,  consistent  with  safe  and  sound  operation,  to  help  meet  the  credit  needs  of  its  communities,  including 
providing credit to individuals residing in low- and moderate-income neighborhoods. The CRA does not establish specific lending 
requirements or programs for financial institutions nor does it limit an institution’s discretion to develop the types of products and 
services that it believes are best suited to its particular community, so long as they are consistent with the CRA. The CRA requires 
each appropriate federal bank regulatory agency, in connection with its examination of a depository institution, to assess such 
institution’s record in assessing and meeting the credit needs of the community served by that institution, including low- and 
moderate-income neighborhoods. The regulatory agency’s assessment of the institution’s record is made available to the public. 
The assessment also is part of the Federal Reserve’s consideration of applications to acquire, merge or consolidate with another 
banking institution or its holding company, to establish a new branch office that will accept deposits or to relocate an office. In 
the case of a BHC applying for approval to acquire a bank or other BHC, the Federal Reserve will assess the records of each 
subsidiary depository institution of the applicant BHC, and such records may be the basis for denying the application. 

In 2014, the Federal Reserve Bank of Atlanta began a regularly scheduled CRA examination of Regions Bank covering 2012 
and 2013 performance. This review included, among other things, a review of Regions Bank's previously disclosed public consent 
orders. As a result of the examination, the results of which were communicated during the fourth quarter of 2015, Regions Bank 
received "High Satisfactory" ratings on its CRA components, but its overall CRA rating was downgraded from "Satisfactory" to 
“Needs to Improve.” The downgrade was attributed to the matters underlying Regions Bank’s April 2015 public consent order 
with the CFPB related to overdrafts and the Federal Reserve's Regulation E. Regions Bank had self-reported these matters and 
provided remuneration during  2011 and 2012. This downgrade imposed restrictions on the Company's ability to undertake certain 
activities, including mergers and acquisitions of insured depository institutions and applications to open branches or certain other 
facilities until such time as the rating was improved.  On December 19, 2016, the Federal Reserve Bank of Atlanta informed 
Regions that the Company's overall CRA rating had been reinstated from "Needs to Improve" to "Satisfactory" and this regulatory 
issue is resolved.  Further, Regions continued to receive a "High Satisfactory" rating on the lending, investment and service portions 
of the Company's most recent CRA review.

Compensation Practices

Our compensation practices are subject to oversight by the Federal Reserve. The federal banking regulators have provided 
guidance designed to ensure that incentive compensation arrangements at banking organizations take into account risk and are 
consistent with safe and sound practices. The guidance sets forth the following three key principles with respect to incentive 
compensation arrangements: (i) the arrangements should provide employees with incentives that appropriately balance risk and 
financial results in a manner that does not encourage employees to expose their organizations to imprudent risk; (ii) the arrangements 
should be compatible with effective controls and risk management; and (iii) the arrangements should be supported by strong 
corporate governance. The guidance provides that supervisory findings with respect to incentive compensation will be incorporated, 
as appropriate, into the organization’s supervisory ratings, which can affect its ability to make acquisitions or perform other actions. 
The guidance also provides that enforcement actions may be taken against a banking organization if its incentive compensation 
arrangements or related risk management, control or governance processes pose a risk to the organization’s safety and soundness.

During the second quarter of 2016, the U.S. financial regulators, including the Federal Reserve and the SEC, proposed revised 
rules on incentive-based payment arrangements at specified regulated entities having at least $1 billion in total assets (including 
Regions and Regions Bank). The proposed revised rules would establish general qualitative requirements applicable to all covered 
entities, additional specific requirements for entities with total consolidated assets of at least $50 billion, such as Regions, and 
further,  more  stringent  requirements  for  those  with  total  consolidated  assets  of  at  least  $250  billion.  The  general  qualitative 
requirements  include  (i)  prohibiting  incentive  arrangements  that  encourage  inappropriate  risks  by  providing  excessive 
compensation; (ii) prohibiting incentive arrangements that encourage inappropriate risks that could lead to a material financial 
loss; (iii) establishing requirements for performance measures to appropriately balance risk and reward; (iv) requiring board of 
director  oversight  of  incentive  arrangements;  and  (v)  mandating  appropriate  record-keeping.  For  larger  financial  institutions, 
including Regions, the proposed revised rules would also introduce additional requirements applicable only to “senior executive 

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officers” and “significant risk-takers” (as defined in the proposed rules), including (i) limits on performance measures and leverage 
relating to performance targets; (ii) minimum deferral periods; and (iii) subjecting incentive compensation to possible downward 
adjustment, forfeiture and clawback. If the rules are adopted in the form proposed, they may restrict our flexibility with respect 
to the manner in which we structure compensation and adversely affect our ability to compete for talent.

Anti-Money Laundering 

A  continued  focus  of  governmental  policy  relating  to  financial  institutions  in  recent  years  has  been  combating  money 
laundering and terrorist financing. The USA PATRIOT Act broadened the application of anti-money laundering regulations to 
apply  to  additional  types  of  financial  institutions  such  as  broker-dealers,  investment  advisors  and  insurance  companies,  and 
strengthened the ability of the U.S. Government to help prevent, detect and prosecute international money laundering and the 
financing of terrorism. The principal provisions of Title III of the USA PATRIOT Act require that regulated financial institutions, 
including  state  member  banks:  (i) establish  an  anti-money  laundering  program  that  includes  training  and  audit  components; 
(ii) comply with regulations regarding the verification of the identity of any person seeking to open an account; (iii) take additional 
required precautions with non-U.S. owned accounts; and (iv) perform certain verification and certification of money laundering 
risk for their foreign correspondent banking relationships. Failure of a financial institution to comply with the USA PATRIOT 
Act’s requirements could have serious legal and reputational consequences for the institution. Regions’ banking and insurance 
subsidiaries have augmented their systems and procedures to meet the requirements of these regulations and will continue to revise 
and  update  their  policies,  procedures  and  controls  to  reflect  changes  required  by  the  USA  PATRIOT Act  and  implementing 
regulations. The  USA  PATRIOT Act  also  requires  federal  banking  regulators  to  evaluate  the  effectiveness  of  an  applicant  in 
combating money laundering in determining whether to approve a proposed bank acquisition.

In 2014, the Financial Crimes Enforcement Network (“FinCEN”), which drafts regulations implementing the USA PATRIOT 
Act and other anti-money laundering and bank secrecy act legislation, proposed a rule that would require financial institutions to 
obtain beneficial ownership information with respect to legal entities with which such institutions conduct business, subject to 
certain exclusions and exemptions. In May 2016, FinCEN issued its final rules with respect to customer due diligence requirements, 
and  financial institutions  that  are  subject to  these  final  rules,  including  Regions,  are  required to  comply  by  May  2018.  Bank 
regulators are focusing their examinations on anti-money laundering compliance, and we continue to monitor and augment, where 
necessary, our anti-money laundering compliance programs.

Office of Foreign Assets Control Regulation

The U.S. has imposed economic sanctions that affect transactions with designated foreign countries, nationals and others. 
These are typically known as the “OFAC” rules based on their administration by the U.S. Treasury Department Office of Foreign 
Assets Control. The OFAC-administered sanctions targeting countries take many different forms. Generally, however, they contain 
one or more of the following elements: (i) restrictions on trade with or investment in a sanctioned country, including prohibitions 
against direct or indirect imports from and exports to a sanctioned country and prohibitions on U.S. persons engaging in financial 
transactions relating to, making investments in, or providing investment-related advice or assistance to, a sanctioned country; and 
(ii) a blocking of assets in which the government or specially designated nationals of the sanctioned country have an interest, by 
prohibiting transfers of property subject to U.S. jurisdiction (including property in the possession or control of U.S. persons). 
Blocked assets (e.g., property and bank deposits) cannot be paid out, withdrawn, set off or transferred in any manner without a 
license from OFAC. Failure to comply with these sanctions could have serious legal and reputational consequences.

Regulation of Insurers and Insurance Brokers

Our operations in the areas of insurance brokerage and reinsurance of credit life insurance are subject to regulation and 
supervision by various state insurance regulatory authorities. Although the scope of regulation and form of supervision may vary 
from state to state, insurance laws generally grant broad discretion to regulatory authorities in adopting regulations and supervising 
regulated activities. This supervision generally includes the licensing of insurance brokers and agents and the regulation of the 
handling of customer funds held in a fiduciary capacity. Certain of our insurance company subsidiaries are subject to extensive 
regulatory supervision and to insurance laws and regulations requiring, among other things, maintenance of capital, record keeping, 
reporting and examinations.

Regulation of Broker Dealers

Our subsidiary Regions Securities is a registered broker-dealer with the SEC and, as a result, is subject to regulation and 
examination by the SEC, FINRA and other self-regulatory organizations. These regulations cover a broad range of issues, including 
capital requirements; sales and trading practices; use of client funds and securities; the conduct of directors, officers and employees; 
record-keeping and recording; supervisory procedures to prevent improper trading on material non-public information; qualification 
and  licensing  of  sales  personnel;  and  limitations  on  the  extension  of  credit  in  securities  transactions.  In  addition  to  federal 
registration, state securities commissions require the registration of certain broker-dealers.

Competition

All aspects of our business are highly competitive. Our subsidiaries compete with other financial institutions located in the 
states  in  which  they  operate  and  other  adjoining  states,  as  well  as  large  banks  in  major  financial  centers  and  other  financial 

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intermediaries, such as savings and loan associations, credit unions, Internet banks, finance companies, mutual funds, insurance 
companies, brokerage and investment banking firms, mortgage companies and financial service operations of major commercial 
and retail corporations. We expect competition to intensify among financial services companies due to the sustained low interest 
rate and ongoing low-growth economic environment. Also, as banks in our footprint act to attain compliance with the LCR, there 
is a chance deposit pricing, particularly long-term time deposits could become even more competitive.  

Customers  for  banking  services  and  other  financial  services  offered  by  our  subsidiaries  are  generally  influenced  by 
convenience, quality of service, personal contacts, price of services and availability of products. Although our position varies in 
different markets, we believe that our affiliates effectively compete with other financial services companies in their relevant market 
areas.

Employees

As of December 31, 2016, Regions and its subsidiaries had 22,166 full-time equivalent employees.

Available Information

We maintain a website at www.regions.com. We make available on our website, free of charge, our annual reports on Form 
10-K, quarterly reports on Form 10-Q and current reports on Form 8-K, and amendments to those reports that are filed with or 
furnished to the SEC pursuant to Section 13(a) of the Securities Exchange Act of 1934. These documents are made available on 
our website as soon as reasonably practicable after they are electronically filed with or furnished to the SEC. Also available on 
the website are our (i) Corporate Governance Principles, (ii) Code of Business Conduct and Ethics, (iii) Code of Ethics for Senior 
Financial  Officers,  (iv)  Fair  Disclosure  Policy  Summary,  and  (v) the  charters  of  our  Nominating  and  Corporate  Governance 
Committee, Audit Committee, Compensation Committee and Risk Committee.

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Item 1A.  Risk Factors

An investment in the Company involves risk, some of which, including market, liquidity, credit, operational, legal, compliance, 
reputational and strategic risks, could be substantial and is inherent in our business. This risk also includes the possibility that the 
value of the investment could decrease considerably, and dividends or other distributions concerning the investment could be 
reduced or eliminated. Discussed below are risk factors that could adversely affect our financial results and condition, as well as 
the value of, and return on investment in the Company.

Risks Related to the Operation of Our Business

Our businesses have been, and may continue to be, adversely affected by conditions in the financial markets and economic 
conditions generally.

We provide traditional commercial, retail and mortgage banking services, as well as other financial services including asset 
management, wealth management, securities brokerage, insurance, merger-and-acquisition advisory services and other specialty 
financing.  All of our businesses are materially affected by conditions in the financial markets and economic conditions generally 
or specifically in the Southeastern U.S., the principal markets in which we conduct business.  A worsening of business and economic 
conditions generally or specifically in the principal markets in which we conduct business could have adverse effects on our 
business, including the following:

•  A decrease in the demand for, or the availability of, loans and other products and services offered by us;

•  A decrease in the value of our loans held for sale or other assets secured by consumer or commercial real estate;

•  An impairment of certain intangible assets, such as goodwill;

•  A decrease in interest income from variable rate loans, due to declines in interest rates; and

•  An increase in the number of clients and counterparties who become delinquent, file for protection under bankruptcy laws 
or default on their loans or other obligations to us, which could result in a higher level of nonperforming assets, net charge-
offs, provisions for loan losses, and valuation adjustments on loans held for sale.

In the event of severely adverse business and economic conditions generally or specifically in the principal markets in which 
we conduct business, there can be no assurance that the federal government and the Federal Reserve would intervene. There is 
also no assurance that the measures undertaken by the federal government and the Federal Reserve since the financial crisis will 
result in continued improvement in the general business environment or in the business environments in the principal markets in 
which we do business. If economic conditions worsen or remain volatile, our business, financial condition and results of operations 
could be materially adversely affected.

Ineffective liquidity management could adversely affect our financial results and condition.

Effective liquidity management is essential for the operation of our business. We require sufficient liquidity to meet customer 
loan  requests,  customer  deposit  maturities/withdrawals,  payments  on  our  debt  obligations  as  they  come  due  and  other  cash 
commitments under both normal operating conditions and unpredictable circumstances causing industry or general financial market 
stress. Our access to funding sources in amounts adequate to finance our activities on terms that are acceptable to us could be 
impaired by factors that affect us specifically or the financial services industry or economy generally. Factors that could detrimentally 
impact  our  access  to  liquidity  sources  include  a  downturn  in  the  geographic  markets  in  which  our  loans  and  operations  are 
concentrated or difficult credit markets. Our access to deposits may also be affected by the liquidity needs of our depositors. In 
particular, a majority of our liabilities during 2016 were checking accounts and other liquid deposits, which are payable on demand 
or upon several days’ notice, while by comparison, a substantial majority of our assets were loans, which cannot be called or sold 
in the same time frame. Although we have historically been able to replace maturing deposits and advances as necessary, we might 
not be able to replace such funds in the future, especially if a large number of our depositors seek to withdraw their accounts, 
regardless of the reason. A failure to maintain adequate liquidity could materially and adversely affect our business, results of 
operations or financial condition.

Our operations are concentrated in the Southeastern U.S., and adverse changes in the economic conditions in this region can 
adversely affect our financial results and condition.

Our operations are concentrated in the Southeastern U.S., particularly in the states of Alabama, Florida, Georgia, Louisiana, 
Mississippi and Tennessee.  As a result, local economic conditions in the Southeastern U.S. significantly affect the demand for the 
loans  and  other  products  we  offer  to  our  customers  (including  real  estate,  commercial  and  construction  loans),  the  ability  of 
borrowers to repay these loans and the value of the collateral securing these loans. Following the financial crisis, the national real 
estate market experienced a significant decline in value, and the value of real estate in the Southeastern U.S. in particular declined 
significantly more than real estate values in the U.S. as a whole. This decline has had an adverse impact on some of our borrowers 
and on the value of the collateral securing many of our loans. Although real estate in many geographies has begun to show signs 
of improvement, this recent decline and any further declines in the future may continue to affect borrowers and collateral values, 
which could adversely affect our currently performing loans, leading to future delinquencies or defaults and increases in our 

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provision for loan losses. Further or continued adverse changes in these economic conditions could materially adversely affect 
our business, results of operations or financial condition.

Weather-related events and other natural disasters, as well as man-made disasters, could cause a disruption in our operations 
or other consequences that could have an adverse impact on financial results and condition.

A significant portion of our operations are located in the areas bordering the Gulf of Mexico and the Atlantic Ocean, regions 
that are susceptible to hurricanes, or in areas of the Southeastern U.S. that are susceptible to tornadoes and other severe weather 
events. Many areas in the Southeastern U.S. have also experienced severe droughts and floods in recent years.  Any of these or 
any other severe weather event could cause disruption to our operations and could have a material adverse effect on our overall 
business, results of operations or financial condition. While we maintain insurance covering many of these weather-related events, 
including coverage for lost profits and extra expense, there is no insurance against the disruption that a catastrophic earthquake, 
hurricane, tornado or other severe weather event could produce to the markets that we serve and the resulting adverse impact on 
our borrowers to timely repay their loans and the value of any collateral held by us. The severity and impact of future earthquakes, 
hurricanes, tornadoes, droughts, floods and other weather-related events are difficult to predict and may be exacerbated by global 
climate change. Man-made disasters and other events connected with the Gulf of Mexico or Atlantic Ocean, such as the 2010 Gulf 
oil spill, could have similar effects.

Weakness in the residential real estate markets could adversely affect our performance.

As of December 31, 2016, consumer residential real estate loans represented approximately 30% of our total loan portfolio. 
Declines in home values would adversely affect the value of collateral securing the residential real estate that we hold, as well as 
the volume of loan originations and the amount we realize on the sale of real estate loans. These factors could result in higher 
delinquencies and greater charge-offs in future periods, which could materially adversely affect our business, financial condition 
or results of operations.

Weakness in the commercial real estate markets could adversely affect our performance.

As of December 31, 2016, approximately 8% of our loan portfolio consisted of investor real estate loans. The properties 
securing income-producing investor real estate loans are typically not fully leased at the origination of the loan. The borrower’s 
ability to repay the loan is instead dependent upon additional leasing through the life of the loan or the borrower’s successful 
operation of a business. Weak economic conditions may impair a borrower’s business operations and typically slow the execution 
of new leases. Such economic conditions may also lead to existing lease turnover. As a result of these factors, vacancy rates for 
retail, office and industrial space may increase. High vacancy rates could also result in rents falling. The combination of these 
factors could result in deterioration in the fundamentals underlying the commercial real estate market and the deterioration in value 
of some of our loans. Any such deterioration could adversely affect the ability of our borrowers to repay the amounts due under 
their loans. As a result, our business, results of operations or financial condition may be materially adversely affected.

Weakness in commodity businesses could adversely affect our performance.

Many of our borrowers operate in industries that are directly or indirectly impacted by changes in commodity prices. This 
includes agriculture, livestock, metals, timber, textiles and energy businesses (including oil, gas, and petrochemical), as well as 
businesses indirectly impacted by commodities prices such as businesses that transport commodities or manufacture equipment 
used in production of commodities. Changes in commodity products prices depend on local, regional and global events or conditions 
that affect supply and demand for the relevant commodity. These industries have been, and may in the future be, subject to significant 
volatility. In addition, legislative changes such as the elimination of certain tax incentives could have significant impacts on this 
portfolio.

Specifically, as of December 31, 2016, energy-related loan balances represented approximately 3% of our total loan portfolio. 
This amount is comprised of loans directly related to energy, such as oilfield services, exploration and production, and pipeline 
transportation of gas and crude oil, as well as loans indirectly impacted by the energy portfolio, such as petroleum wholesalers, 
oil and gas equipment manufacturing, air transportation, and petroleum bulk stations and terminals. Given the recent volatility in 
oil prices, the cash flows of our customers in the oil and gas industry could be adversely impacted, which could impair their ability 
to service any loans outstanding to them and/or reduce demand for loans. These factors could result in higher delinquencies and 
greater charge-offs in future periods, which could adversely affect our business, financial condition or results of operations.

If we experience greater credit losses in our loan portfolios than anticipated, our earnings may be materially adversely affected.

As a lender, we are exposed to the risk that our customers will be unable to repay their loans and leases according to their 
terms and that any collateral securing the payment of their loans and leases may not be sufficient to assure repayment. Credit losses 
are inherent in the business of making loans and could have a material adverse effect on our operating results.

We make various assumptions and judgments about the collectability of our loan portfolio and provide an allowance for loan 
losses based on a number of factors. Our management periodically determines the allowance for loan losses based on available 
information, including the quality of the loan portfolio, economic conditions, the value of the underlying collateral and the level 
of non-accrual loans. Increases in the allowance will result in an expense for the period, thereby reducing our reported net income. 
If, as a result of general economic conditions, there is a decrease in asset quality or growth in the loan portfolio,  management 

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determines that additional increases in the allowance for loan losses are necessary, we may incur additional expenses which will 
reduce our net income, and our business, results of operations or financial condition may be materially adversely affected.

Although  our  management  will  establish  an  allowance  for  loan  losses  it  believes  is  appropriate  to  absorb  probable  and 
reasonably estimable losses in our loan portfolio, this allowance may not be adequate. For example, if a hurricane or other natural 
disaster were to occur in one of our principal markets or if economic conditions in those markets were to deteriorate unexpectedly, 
additional loan losses not incorporated in the existing allowance for loan losses may occur. Losses in excess of the existing allowance 
for loan losses will reduce our net income and could adversely affect our business, results of operations or financial condition, 
perhaps materially.

In addition, bank regulatory agencies will periodically review our allowance for loan losses and the value attributed to non-
accrual loans and to real estate acquired through foreclosure. Such regulatory agencies may require us to adjust our determination 
of the value for these items. These adjustments could materially adversely affect our business, results of operations or financial 
condition.

Risks  associated  with  home  equity  products  where  we  are  in  a  second  lien  position  could  materially  adversely  affect  our 
performance.

Home equity products, particularly those where we are in a second lien position, and particularly those in certain geographic 
areas, may carry a higher risk of non-collection than other loans. Home equity lending includes both home equity loans and lines 
of credit. Of our $10.7 billion home equity portfolio at December 31, 2016, approximately $7.2 billion were home equity lines of 
credit and $3.5 billion were closed-end home equity loans (primarily originated as amortizing loans). This type of lending, which 
is secured by a first or second mortgage on the borrower’s residence, allows customers to borrow against the equity in their home. 
Real estate market values at the time of origination directly affect the amount of credit extended, and, in addition, past and future 
changes in these values impact the depth of potential losses. Second lien position lending carries higher credit risk because any 
decrease in real estate pricing may result in the value of the collateral being insufficient to cover the second lien after the first lien 
position has been satisfied. As of December 31, 2016, approximately $3.9 billion of our home equity lines and loans were in a 
second lien position.

Industry competition may adversely affect our degree of success.

Our profitability depends on our ability to compete successfully. We operate in a highly competitive environment, and we 
expect competition to intensify due in part to the sustained low interest rate and ongoing low-growth economic environment. 
Certain of our competitors are larger and have more resources than we do, enabling them to be more aggressive than us in competing 
for loans and deposits. In our market areas, we face competition from other commercial banks, savings and loan associations, 
credit unions, Internet banks, finance companies, mutual funds, insurance companies, brokerage and investment banking firms, 
mortgage companies, and other financial intermediaries that offer similar services. Some of our non-bank competitors are not 
subject to the same extensive regulations we are and, therefore, may have greater flexibility in competing for business. In particular, 
the activity and prominence of so-called marketplace lenders and other technological financial services companies have grown 
significantly over recent years and is expected to continue growing. 

Our ability to compete successfully depends on a number of factors, including customer convenience, quality of service, 
personal contacts, pricing and range of products.  If we are unable to successfully compete for new customers and to retain our 
current customers, our business, financial condition or results of operations may also be adversely affected, perhaps materially.  
In particular, if we experience an outflow of deposits as a result of our customers seeking investments with higher yields or greater 
financial stability, or a desire to do business with our competitors, we may be forced to rely more heavily on borrowings and other 
sources of funding to operate our business and meet withdrawal demands, thereby adversely affecting our net interest margin.

Fluctuations in market interest rates may adversely affect our performance.

Our profitability depends to a large extent on our net interest income and other financing income, which is the difference 
between the interest income received on interest-earning assets (primarily loans and investment securities) and the interest expense 
incurred in connection with interest-bearing liabilities (primarily deposits and borrowings). Net interest income and other financing 
income also includes rental income and depreciation expense associated with operating leases for which Regions is the lessor. The 
level of net interest income and other financing income is primarily a function of the average balance of interest-earning assets, 
the average balance of interest-bearing liabilities and the spread between the yield on such assets and the cost of such liabilities. 
These factors are influenced by both the pricing and mix of interest-earning assets and interest-bearing liabilities which, in turn, 
are impacted by external factors such as the local economy, competition for loans and deposits, the monetary policy of the FOMC 
and market interest rates.

The cost of our deposits and short-term wholesale borrowings is largely based on short-term interest rates, the level of which 
is influenced heavily by the FOMC’s actions. However, the yields generated by our loans and securities are typically driven by 
both short-term and longer-term interest rates. Longer-term rates are affected by multiple factors including the actions of the FOMC 
through  actions  such  as  quantitative  easing,  and  the  market's  expectations  for  future  inflation,  growth  and  other  economic 
considerations. The level of net interest income and other financing income is therefore influenced by movements in such interest 
rates and the pace at which such movements occur. Interest rate volatility can reduce unrealized gains or create unrealized losses 

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in our portfolios. If the interest rates on our interest-bearing liabilities increase at a faster pace than the interest rates on our interest-
earning assets, our net interest income and other financing income may decline and, with it, a decline in our earnings may occur. 
Our net interest income and other financing income and our earnings would be similarly affected if the interest rates on our interest-
earning assets declined at a faster pace than the interest rates on our interest-bearing liabilities. In particular, despite the rate increase 
in December 2016, short-term interest rates remain very low by historical standards. These low rates have reduced our cost of 
funding, which helped to stabilize our net interest margin.

Our current one-year interest rate sensitivity position is moderately asset sensitive. As a result, an immediate or gradual 
decrease in rates over a twelve-month period would likely have a negative impact on twelve-month net interest income and other 
financing income. An increasing interest rate environment, however, would increase debt service requirements for some of our 
borrowers  and  may  adversely  affect  those  borrowers’  ability  to  pay  as  contractually  obligated  and  could  result  in  additional 
delinquencies or charge-offs. Our results of operations and financial condition may be adversely affected as a result.

For a more detailed discussion of these risks and our management strategies for these risks, see the “Net Interest Income and 
Other Financing Income, Margin and Interest Rate Risk,” “Net Interest Income and Other Financing Income and Margin,” “Market 
Risk-Interest Rate Risk” and “Securities” sections of Item 7. “Management’s Discussion and Analysis of Financial Condition and 
Results of Operations” of this Annual Report on Form 10-K.

Any future reductions in our credit ratings may increase our funding costs and place limitations on business activities related 
to providing credit support to customers.

The major rating agencies regularly evaluate us, and their ratings are based on a number of factors, including our financial 
strength and conditions affecting the financial services industry generally. In general, ratings agencies base their ratings on many 
quantitative  and  qualitative  factors,  including  capital  adequacy,  liquidity,  asset  quality,  business  mix  and  level  and  quality  of 
earnings, and we may not be able to maintain our current credit ratings. The ratings assigned to Regions and Regions Bank remain 
subject to change at any time, and it is possible that any ratings agency will take action to downgrade Regions, Regions Bank or 
both in the future.  Additionally, ratings agencies may also make substantial changes to their ratings policies and practices, which 
may affect our credit ratings. In the future, changes to existing ratings guidelines and new ratings guidelines may, among other 
things, adversely affect the ratings of our securities or other securities in which we have an economic interest.

Regions’ credit ratings can have negative consequences that can impact our ability to access the debt and capital markets, as 
well as reduce our profitability through increased costs on future debt issuances. Although Regions and Regions Bank are currently 
rated investment grade, a one-notch downgrade of Regions’ rating would cause Regions to no longer be rated investment grade. 
When  Regions  was  downgraded  below  investment  grade  status  in  2010,  we  became  unable  to  reliably  access  the  short-term 
unsecured funding markets, which caused us to hold more cash and liquid investments to meet our ongoing cash needs. Such 
actions reduced our profitability as these liquid investments earned a lower return than other assets, such as loans. Regions’ liquidity 
policy requires that the holding company maintain cash sufficient to cover the greater of (i) 18 months of debt service and other 
cash needs or (ii) a minimum cash balance of $500 million.  Although this policy helps protect us against the costs of unexpected 
adverse funding environments, we cannot guarantee that this policy will be sufficient.

Additionally, at the time Regions was downgraded to below investment grade, certain counterparty contracts were required 
to be renegotiated, resulting in additional collateral postings of approximately $200 million. Refer to Note 21 “Derivative Financial 
Instruments and Hedging Activities  – Contingent Features” to the consolidated financial statements of this Annual Report on 
Form 10-K for the fair value of contracts subject to contingent credit features and the collateral postings associated with such 
contracts. Future downgrades could require Regions to post additional collateral. Although the exact amount of additional collateral 
is unknown, it is reasonable to conclude that Regions may be required to post additional collateral related to existing contracts 
with contingent credit features.

The value of our goodwill and other intangible assets may decline in the future.

As of December 31, 2016, we had $4.9 billion of goodwill and $221 million of other intangible assets. A significant decline 
in our expected future cash flows, a significant adverse change in the business climate, slower economic growth or a significant 
and sustained decline in the price of our common stock, any or all of which could be materially impacted by many of the risk 
factors discussed herein, may necessitate our taking charges in the future related to the impairment of our goodwill. Future regulatory 
actions could also have a material impact on assessments of goodwill for impairment. If the fair value of our net assets improves 
at a faster rate than the market value of our reporting units, or if we were to experience increases in book values of a reporting unit 
in excess of the increase in fair value of equity, we may also have to take charges related to the impairment of our goodwill. If we 
were to conclude that a future write-down of our goodwill is necessary, we would record the appropriate charge, which could have 
a material adverse effect on our results of operations.

Identifiable intangible assets other than goodwill consist of core deposit intangibles, purchased credit card relationship assets, 
customer relationship employment agreement assets, and the DUS license. Adverse events or circumstances could impact the 
recoverability of these intangible assets including loss of core deposits, significant losses of credit card accounts and/or balances, 
increased competition or adverse changes in the economy. To the extent these intangible assets are deemed unrecoverable, a non-
cash impairment charge would be recorded, which could have a material adverse effect on our results of operations.

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The value of our deferred tax assets could adversely affect our operating results and regulatory capital ratios.

As of December 31, 2016, Regions had approximately $308 million in net deferred tax assets (net of valuation allowance of 
$30 million). Our deferred tax assets are subject to an evaluation of whether it is more likely than not that they will be realized for 
financial statement purposes. In making this determination, we consider all positive and negative evidence available, including 
the impact of recent operating results, as well as potential carryback of tax to prior years’ taxable income, reversals of existing 
taxable temporary differences, tax planning strategies and projected earnings within the statutory tax loss carryover period. We 
have determined that the deferred tax assets are more likely than not to be realized at December 31, 2016 (except for $30 million
related to state deferred tax assets for which we have established a valuation allowance). If we were to conclude that a significant 
portion of our deferred tax assets were not more likely than not to be realized, the required valuation allowance could adversely 
affect our financial position, results of operations and regulatory capital ratios. In addition, the value of our deferred tax assets 
could be adversely affected by a change in statutory tax rates.

Changes in the soundness of other financial institutions could adversely affect us.

Financial services companies are interrelated as a result of trading, clearing, counterparty or other relationships. We have 
exposure to many different industries and counterparties, and we routinely execute transactions with counterparties in the financial 
services  industry,  including  brokers  and  dealers,  commercial  banks,  investment  banks,  mutual  and  hedge  funds,  and  other 
institutional clients. As a result, defaults by, or even mere speculation about, one or more financial services companies, or the 
financial services industry generally, may lead to market-wide liquidity problems and could lead to losses or defaults by us or by 
other institutions. Many of these transactions expose us to credit risk in the event of default of our counterparty or client. In addition, 
our credit risk may be exacerbated if the collateral held by us cannot be realized or is liquidated at prices not sufficient to recover 
the full amount of the loan or lease or derivative exposure due us. Any such losses may materially and adversely affect our business, 
financial condition or results of operations.

Our businesses may be adversely affected if we are unable to hire and retain qualified employees.

Our success depends, in part, on our executive officers and other key personnel. The market for qualified individuals is highly 
competitive, and we may not be able to attract and retain qualified personnel or candidates to replace or succeed members of our 
senior management team or other key personnel. Our compensation practices are subject to review and oversight by the Federal 
Reserve,  the  FDIC  and  other  regulators. As  a  large  financial  and  banking  institution,  we  may  be  subject  to  limitations  on 
compensation practices, which may or may not affect our competitors, by the Federal Reserve, the FDIC or other regulators. These 
limitations could further affect our ability to attract and retain our executive officers and other key personnel.

In May 2016, the Federal Reserve, other federal banking agencies and the Securities and Exchange Commission jointly 
published re-proposed rules (originally proposed in April 2011) designed to implement provisions of the Dodd-Frank Act prohibiting 
incentive  compensation  arrangements  that  would  encourage  inappropriate  risk  taking  at  covered  financial  institutions,  which 
includes a bank or BHC with $1 billion or more of assets, such as Regions and Regions Bank. Although the re-proposed rules 
include more stringent requirements, particularly for larger institutions, it cannot be determined at this time whether or when a 
final rule will be adopted. Compliance with such a final rule may substantially affect the manner in which we structure compensation 
for our executives and other employees. Depending on the nature and application of the final rules, we may not be able to successfully 
compete with certain financial institutions and other companies that are not subject to some or all of the rules to retain and attract 
executives and other high performing employees. If this were to occur, our business, financial condition and results of operations 
could be adversely affected, perhaps materially. For a more detailed discussion of these proposed rules, see the “Supervision and 
Regulation-Compensation Practices” section of Item 1. “Business” of this Annual Report on Form 10-K.

Maintaining or increasing market share may depend on market acceptance and regulatory approval of new products and 
services.

Our success depends, in part, on the ability to adapt products and services to evolving industry standards. There is increasing 
pressure to provide products and services at lower prices. This can reduce net interest income and other financing income and non-
interest income from fee-based products and services. In addition, the widespread adoption of new technologies could require us 
to make substantial capital expenditures to modify or adapt existing products and services or develop new products and services. 
We may not be successful in introducing new products and services in response to industry trends or developments in technology, 
or those new products may not achieve market acceptance. As a result, we could lose business, be forced to price products and 
services on less advantageous terms to retain or attract clients, or be subject to cost increases, and our business, financial condition 
or results of operations may be adversely affected.

We need to stay current on technological changes in order to compete and meet customer demands.

The financial services market, including banking services, is undergoing rapid changes with frequent introductions of new 
technology-driven products and services. In addition to better serving customers, the effective use of technology increases efficiency 
and may enable us to reduce costs. Our future success may depend, in part, on our ability to use technology to provide products 
and services that provide convenience to customers and to create additional efficiencies in our operations. Some of our competitors 
have  substantially  greater  resources  to  invest  in  technological  improvements  than  we  currently  have. We  may  not  be  able  to 
effectively implement new technology-driven products and services or be successful in marketing these products and services to 

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our customers. As a result, our ability to effectively compete to retain or acquire new business may be impaired, and our business, 
financial condition or results of operations, may be adversely affected.

We are subject to a variety of operational risks, including the risk of fraud or theft by employees, which may adversely affect 
our business and results of operations.

We are exposed to many types of operational risks, including liquidity risk, credit risk, market risk, interest rate risk, legal 
and compliance risk, strategic risk, information security risk, and reputational risk. We are also reliant upon our employees, and 
our operations are subject to the risk of fraud, theft or malfeasance by our employees. We have established processes and procedures 
intended to identify, measure, monitor, mitigate, report and analyze these risks; however, there are inherent limitations to our risk 
management strategies as there may exist, or develop in the future, risks that we have not appropriately anticipated, monitored or 
identified. If our risk management framework proves ineffective, we could suffer unexpected losses, we may have to expend 
resources detecting and correcting the failure in our systems and we may be subject to potential claims from third parties and 
government agencies.  We may also suffer severe reputational damage. Any of these consequences could adversely affect our 
business, financial condition or results of operations. In particular, the unauthorized disclosure, misappropriation, mishandling or 
misuse  of  personal,  non-public,  confidential  or  proprietary  information  of  customers  could  result  in  significant  regulatory 
consequences, reputational damage and financial loss.

Damage to our reputation could significantly harm our businesses.

Our ability to attract and retain customers and highly-skilled management and employees is impacted by our reputation. A 
negative public opinion of us and our business can result from any number of activities, including our lending practices, corporate 
governance and regulatory compliance, acquisitions and actions taken by our regulators or by community organizations in response 
to these activities. Significant harm to our reputation could also arise as a result of regulatory or governmental actions, litigation, 
employee misconduct or the activities of our customers, other participants in the financial services industry or our contractual 
counterparties, such as our service providers and vendors. Damage to our reputation could also adversely affect our credit ratings 
and access to the capital markets.

We are subject to a variety of systems failure and cybersecurity risks that could adversely affect our business and financial 
performance.

Failure in or breach of our systems or infrastructure, or those of our third-party service providers, including as a result of 
cyber-attacks, could disrupt our businesses or the businesses of our customers. This could result in the disclosure or misuse of 
confidential or proprietary information, damage our reputation, increase our costs and cause losses. As a large financial institution, 
we depend on our ability to process, record and monitor a large number of customer transactions on a continuous basis. As public 
and regulatory expectations, as well as our customers' expectations have increased regarding operational and information security, 
our systems and infrastructure must continue to be safeguarded and monitored for potential failures, disruptions and breakdowns. 
Our business, financial, accounting, data processing systems or other operating systems and facilities may stop operating properly 
or become disabled or damaged as a result of a number of factors, including events that are wholly or partially beyond our control. 
For example, there could be sudden increases in customer transaction volume; electrical or telecommunications outages; natural 
disasters such as earthquakes, tornadoes and hurricanes; disease pandemics; events arising from local or larger scale political or 
social matters, including terrorist acts; and, as described below, cyber-attacks. Although we have business continuity plans and 
other safeguards in place, our business operations may be adversely affected by significant and widespread disruption to our 
physical infrastructure or operating systems that support our businesses and customers. For a discussion of the guidance that federal 
banking  regulators  have  released  regarding  cybersecurity  and  cyber  risk  management  standards,  see  the  “Supervision  and 
Regulation-Financial Privacy and Cybersecurity” section of Item 1. “Business” of this Annual Report on Form 10-K. 

Information security risks for large financial institutions such as Regions have increased significantly in recent years in part 
because of the proliferation of new technologies, such as Internet and mobile banking to conduct financial transactions, and the 
increased sophistication and activities of organized crime, hackers, terrorists, nation-states, activists and other external parties. 
Third parties with whom we or our customers do business also present operational and information security risks to us, including 
security breaches or failures of their own systems. As noted above, our operations rely on the secure processing, transmission and 
storage of confidential information in our computer systems and networks. In addition, to access our products and services, our 
customers may use personal computers, smartphones, tablets, and other mobile devices that are beyond our control environment. 
Although we believe that we have appropriate information security procedures and controls, our technologies, systems, networks 
and our customers’ devices may be the target of cyber-attacks or information security breaches that could result in the unauthorized 
release,  gathering,  monitoring,  misuse,  loss  or  destruction  of  Regions’  or  our  customers’  confidential,  proprietary  and  other 
information. Additionally, cyber-attacks, such as denial of service attacks, hacking or terrorist activities, could disrupt Regions’ 
or our customers’ or other third parties’ business operations. For example, denial of service attacks have been launched against a 
number of large financial services institutions, including Regions. Although these past events have not resulted in a breach of 
Regions’ client data or account information, such attacks have adversely affected the performance of Regions Bank’s website, 
www.regions.com, and, in some instances, prevented customers from accessing Regions Bank’s secure websites for consumer and 
commercial applications. In all cases, the attacks primarily resulted in inconvenience; however, future cyber-attacks could be more 
disruptive and damaging, and Regions may not be able to anticipate or prevent all such attacks. As cyber threats continue to evolve, 

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we may be required to expend significant additional resources to continue to modify or enhance our layers of defense or to investigate 
and remediate any information security vulnerabilities. The techniques used by cyber criminals change frequently, may not be 
recognized until launched and can be initiated from a variety of sources, including terrorist organizations and hostile foreign 
governments. These criminals may attempt to fraudulently induce employees, customers or other users of our systems to disclose 
sensitive information in order to gain access to data or our systems. These risks may increase as the use of mobile payment and 
other Internet-based applications expands.

Disruptions or failures in the physical infrastructure or operating systems that support our businesses and customers, or cyber-
attacks or security breaches of the networks, systems or devices that our customers use to access our products and services, could 
result in customer attrition, regulatory fines, penalties or intervention, reputational damage, reimbursement or other compensation 
costs and/or additional compliance costs, any of which could materially adversely affect our business, results of operations or 
financial condition. For a more detailed discussion of these risks and specific occurrences, see the "Information Security Risk" 
section of Item 7. "Management's Discussion and Analysis of Financial Condition and Results of Operations" of this Annual Report 
on Form 10-K.

We rely on other companies to provide key components of our business infrastructure.

Third  parties  provide  key  components  of  our  business  operations  such  as  data  processing,  recording  and  monitoring 
transactions, online banking interfaces and services, Internet connections and network access. While we have selected these third-
party vendors carefully, we do not control their actions. Any problems caused by these third parties, including those resulting from 
disruptions in services provided by a vendor, failure of a vendor to handle current or higher volumes, failure of a vendor to provide 
services for any reason, poor performance of services, failure to comply with applicable laws and regulations, or fraud or misconduct 
on the part of employees of any of our vendors, could adversely affect our ability to deliver products and services to our customers, 
our reputation and our ability to conduct our business. Financial or operational difficulties of a third-party vendor could also hurt 
our operations if those difficulties interfere with the vendor’s ability to serve us. Replacing these third-party vendors could also 
create significant delay and expense. Accordingly, use of such third parties creates an unavoidable, inherent risk to our business 
operations.

We depend on the accuracy and completeness of information about clients and counterparties.

In deciding whether to extend credit or enter into other transactions with clients and counterparties, we may rely on information 
furnished by or on behalf of clients and counterparties, including financial statements and other financial information. We also 
may rely on representations of clients and counterparties as to the accuracy and completeness of that information and, with respect 
to financial statements, on reports of independent auditors if made available. If this information is inaccurate, we may be subject 
to regulatory action, reputational harm or other adverse effects with respect to the operation of our business, our financial condition 
and our results of operations.

We are exposed to risk of environmental liability when we take title to property.

In the course of our business, we may foreclose on and take title to real estate. As a result, we could be subject to environmental 
liabilities with respect to these properties. We may be held liable to a governmental entity or to third parties for property damage, 
personal injury, investigation and clean-up costs incurred by these parties in connection with environmental contamination or may 
be required to investigate or clean up hazardous or toxic substances or chemical releases at a property. The costs associated with 
investigation or remediation activities could be substantial. In addition, if we are the owner or former owner of a contaminated 
site,  we  may  be  subject  to  common  law  claims  by  third  parties  based  on  damages  and  costs  resulting  from  environmental 
contamination emanating from the property. If we become subject to significant environmental liabilities, our business, financial 
condition or results of operations could be adversely affected.

We rely on the mortgage secondary market for some of our liquidity.

In 2016, we sold 45% of the mortgage loans we originated to the Agencies. We rely on the Agencies to purchase loans that 
meet their conforming loan requirements in order to reduce our credit risk and provide funding for additional loans we desire to 
originate. We cannot provide assurance that the Agencies will not materially limit their purchases of conforming loans due to 
capital constraints, a change in the criteria for conforming loans or other factors. Additionally, various proposals have been made 
to reform the U.S. residential mortgage finance market, including the role of the Agencies. The exact effects of any such reforms 
are not yet known, but they may limit our ability to sell conforming loans to the Agencies. If we are unable to continue to sell 
conforming loans to the Agencies, our ability to fund, and thus originate, additional mortgage loans may be adversely affected, 
which would adversely affect our results of operations.

We are subject to a variety of risks in connection with any sale of loans we may conduct.

In  connection  with  our  sale  of  one  or  more  loan  portfolios,  we  may  make  certain  representations  and  warranties  to  the 
purchaser concerning the loans sold and the procedures under which those loans have been originated and serviced. If any of these 
representations and warranties are incorrect, we may be required to indemnify the purchaser for any related losses, or we may be 
required to repurchase part or all of the effected loans.  We may also be required to repurchase loans as a result of borrower fraud 
or in the event of early payment default by the borrower on a loan we have sold. If we are required to make any indemnity payments 

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or repurchases and do not have a remedy available to us against a solvent counterparty, we may not be able to recover our losses 
resulting from these indemnity payments and repurchases. Consequently, our results of operations may be adversely affected.

In addition, we must report as held for sale any loans that we have undertaken to sell, whether or not a purchase agreement 
for the loans has been executed. We may, therefore, be unable to ultimately complete a sale for part or all of the loans we classify 
as held for sale. Management must exercise its judgment in determining when loans must be reclassified from held to maturity 
status to held for sale status under applicable accounting guidelines. Any failure to accurately report loans as held for sale could 
result in regulatory investigations and monetary penalties. Any of these actions could adversely affect our financial condition and 
results of operations.  Reclassifying loans from held to maturity to held for sale also requires that the affected loans be marked to 
the lower of cost or fair value. As a result, any loans classified as held for sale may be adversely affected by changes in interest 
rates and by changes in the borrower’s creditworthiness. We may be required to reduce the value of any loans we mark held for 
sale, which could adversely affect our results of operations.

A downgrade or potential downgrade of the U.S. Government’s sovereign credit rating by one or more credit ratings agencies 
could adversely affect our business.

Future uncertainty over U.S. fiscal policy could result in a downgrade or a reduction in the outlook of the U.S. long-term 
sovereign credit rating by one or more credit ratings agencies. Any downgrade, or perceived future downgrade, in the U.S. sovereign 
credit rating or outlook could adversely affect global financial markets and economic conditions and may result in, among other 
things, increased volatility and illiquidity in the capital markets, declines in consumer confidence, increased unemployment levels 
and declines in the value of U.S. Treasury securities and securities guaranteed by the U.S. government. As a result, our business, 
liquidity, results of operations and financial conditions may be adversely affected. Additionally, the economic conditions resulting 
from any such downgrade or perceived future downgrade may significantly exacerbate the other risks we face.

Our reported financial results depend on management’s selection of accounting methods and certain assumptions and estimates.

Our accounting policies and assumptions are fundamental to our reported financial condition and results of operations. Our 
management must exercise judgment in selecting and applying many of these accounting policies and methods so they comply 
with generally accepted accounting principles and reflect management’s judgment of the most appropriate manner to report our 
financial condition and results. In some cases, management must select the accounting policy or method to apply from two or 
more alternatives, any of which may be reasonable under the circumstances, yet may result in us reporting materially different 
results than would have been reported under a different alternative.

Certain accounting policies are critical to presenting our reported financial condition and results of operations. They require 
management to make difficult, subjective or complex judgments about matters that are uncertain. Materially different amounts 
could  be  reported  under  different  conditions  or  using  different  assumptions  or  estimates. The  Company's  critical  accounting 
estimates include: the allowance for credit losses; fair value measurements; intangible assets; residential MSRs; and income taxes. 
Because of the uncertainty of estimates involved in these matters, we may be required to do one or more of the following: significantly 
increase the allowance for credit losses and/or sustain credit losses that are significantly higher than the reserve provided; recognize 
significant impairment on our goodwill, other intangible assets or deferred tax asset balances; or significantly increase our accrued 
income taxes. Any of these actions could adversely affect our reported financial condition and results of operations.

If the models that we use in our business perform poorly or provide inadequate information, our business or results of operations 
may be adversely affected.

We utilize quantitative models to assist in measuring risks and estimating or predicting certain financial values. Models may 
be used in processes such as determining the pricing of various products, grading loans and extending credit, measuring interest 
rate  and  other  market  risks,  forecasting  financial  performance,  predicting  losses,  assessing  capital  adequacy,  and  calculating 
regulatory  capital  levels,  as  well  as  to  estimate  the  value  of  financial  instruments  and  balance  sheet  items.  Poorly  designed, 
implemented, or managed models present the risk that our business decisions that consider information based on such models will 
be adversely affected due to the inadequacy or inaccuracy of that information. Also, information we provide to the public or to 
our regulators based on poorly designed, implemented, or managed models could be inaccurate or misleading. Some of the decisions 
that our regulators make, including those related to capital distributions to our stockholders, could be affected adversely due to 
the perception that the quality of the models used to generate the relevant information is insufficient.

Changes in our accounting policies or in accounting standards could materially affect how we report our financial results and 
condition.

From time to time, the FASB and SEC change the financial accounting and reporting standards that govern the preparation 
of our financial statements. These changes can be difficult to predict and can materially impact how we record and report our 
financial condition and results of operations. For example, in June 2016, the FASB issued Accounting Standards Update 2016-13, 
Measurement of Credit Losses on Financial Instruments, that will, effective January 1, 2020, substantially change the accounting 
for credit losses on loans and other financial assets held by banks, financial institutions and other organizations. The standard 
removes the existing “probable” threshold in GAAP for recognizing credit losses and instead requires companies to reflect their 
estimate of credit losses over the life of the financial assets. Companies must consider all relevant information when estimating 
expected  credit  losses,  including  details  about  past  events,  current  conditions,  and  reasonable  and  supportable  forecasts. The 

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standard is likely to have a negative impact, potentially material, to the allowance and capital at adoption in 2020; however, Regions 
is still evaluating the impact.  It is also possible that Regions’ ongoing reported earnings and lending activity will be negatively 
impacted in periods following adoption.

Risks Arising From the Legal and Regulatory Framework in which Our Business Operates

We are, and may in the future be, subject to litigation, investigations and governmental proceedings that may result in liabilities 
adversely affecting our financial condition, business or results of operations or in reputational harm.

We and our subsidiaries are, and may in the future be, named as defendants in various class actions and other litigation, and 
may  be  the  subject  of  subpoenas,  reviews,  requests  for  information,  investigations,  and  formal  and  informal  proceedings  by 
government and self-regulatory agencies regarding our and their businesses and activities. Any such matters may result in material 
adverse  consequences  to  our  results  of  operations,  financial  condition  or  ability  to  conduct  our  business,  including  adverse 
judgments, settlements, fines, penalties (including civil money penalties under applicable banking laws), injunctions, restrictions 
on our business activities or other relief. Our involvement in any such matters, even if the matters are ultimately determined in 
our favor, could also cause significant harm to our reputation and divert management attention from the operation of our business. 
Further, any settlement, consent order or adverse judgment in connection with any formal or informal proceeding or investigation 
by government or self-regulatory agencies may result in additional litigation, investigations or proceedings as other litigants and 
government or self-regulatory agencies (including the inquiries mentioned above) begin independent reviews of the same businesses 
or activities. In general, the amounts paid by financial institutions in settlement of proceedings or investigations, including those 
relating to anti-money laundering matters, have been increasing dramatically and are likely to continue to increase. In some cases, 
governmental authorities have required criminal pleas or other extraordinary terms as part of such settlements, which could have 
significant collateral consequences for a financial institution, including loss of customers, restrictions on the ability to access the 
capital markets, and the inability to operate certain businesses or offer certain products for a period of time.  In addition, enforcement 
matters could impact our supervisory and CRA ratings, which may in turn restrict or limit our activities. 

In addition, in recent years, a number of judicial decisions have upheld the right of borrowers to sue lending institutions on 
the basis of various evolving legal theories, collectively termed “lender liability.” Generally, lender liability is founded on the 
premise that a lender has either violated a duty, whether implied or contractual, of good faith and fair dealing owed to the borrower 
or has assumed a degree of control over the borrower resulting in the creation of a fiduciary duty owed to the borrower or its other 
creditors or stockholders. In the future, Regions could become subject to claims based on this or other evolving legal theories.

Additional information relating to our litigation, investigations and other proceedings is discussed in Note 24 “Commitments, 

Contingencies and Guarantees” to the consolidated financial statements of this Annual Report on Form 10-K.

We may face significant claims for indemnification in connection with our sale of Morgan Keegan in 2012.

On  January 11,  2012,  Regions  entered  into  a  stock  purchase  agreement  to  sell  Morgan  Keegan  and  related  affiliates  to 
Raymond James. The transaction closed on April 2, 2012. In connection with the closing of the sale, Regions agreed to indemnify 
Raymond James for all litigation and certain other matters related to pre-closing activities of Morgan Keegan. Indemnifiable losses 
under the indemnification provision include legal and other expenses, such as costs for defense, judgments, settlements and awards 
associated with the resolution of litigation related to pre-closing activities. As of  December 31, 2016, the carrying value of the 
indemnification obligation is approximately $28 million. This amount reflects an estimate of liability; however, actual liabilities 
can potentially be higher than amounts reserved. The amount of liability that we may ultimately incur from indemnification claims 
may have an adverse impact, perhaps materially, on our financial condition or results of operations.

We are subject to extensive governmental regulation, which could have an adverse impact on our operations.

We are subject to extensive state and federal regulation, supervision and examination governing almost all aspects of our 
operations, which limits the businesses in which we may permissibly engage. The laws and regulations governing our business 
are intended primarily for the protection of our depositors, our customers, the financial system and the FDIC insurance fund, not 
our stockholders or other creditors. These laws and regulations govern a variety of matters, including certain debt obligations, 
changes in control, maintenance of adequate capital, and general business operations and financial condition (including permissible 
types, amounts and terms of loans and investments, the amount of reserves against deposits, restrictions on dividends, establishment 
of branch offices, and the maximum interest rate that may be charged by law). Further, we must obtain approval from our regulators 
before engaging in many activities, and our regulators have the ability to compel us to, or restrict us from, taking certain actions 
entirely. There can be no assurance that any regulatory approvals we may require or otherwise seek will be obtained.

We are also subject to changes in federal and state law, as well as regulations and governmental policies, income tax laws 
and accounting principles. Regulations affecting banks and other financial institutions are undergoing continuous review and 
frequently change, and the ultimate effect of such changes cannot be predicted. Changes to the legal and regulatory framework 
governing our operations, including the passage and continued implementation of the Dodd-Frank Act, have drastically revised 
the laws and regulations under which we operate. These changes have resulted in increased costs of doing business, decreased 
revenues and net income, and may impact our ability to effectively compete in attracting and retaining customers. Recent political 
developments, including the change in administration in the U.S., have added additional uncertainty to the implementation, scope 

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and timing of regulatory reforms. Regulations and laws may be modified or repealed at any time, and new legislation may be 
enacted that will affect us, Regions Bank and our subsidiaries. 

Any changes in any federal and state law, as well as regulations and governmental policies, income tax laws and accounting 
principles, could affect us in substantial and unpredictable ways, including ways that may adversely affect our business, financial 
condition or results of operations. Failure to appropriately comply with any such laws, regulations or principles could result in 
sanctions by regulatory agencies, civil money penalties or damage to our reputation, all of which could adversely affect our business, 
financial condition or results of operations. Our regulatory position is discussed in greater detail in Note 14 “Regulatory Capital 
Requirements and Restrictions” in the Notes to the Consolidated Financial Statements in Item 8. of this Annual Report on Form 
10-K.

We may be subject to more stringent capital and liquidity requirements.

Regions and Regions Bank are each subject to capital adequacy and liquidity guidelines and other regulatory requirements 
specifying minimum amounts and types of capital that must be maintained. From time to time, the regulators implement changes 
to these regulatory capital adequacy and liquidity guidelines. If we fail to meet these minimum capital adequacy and liquidity 
guidelines and other regulatory requirements, we or our subsidiaries may be restricted in the types of activities we may conduct 
and may be prohibited from taking certain capital actions, such as paying dividends and repurchasing or redeeming capital securities.

In particular, the capital adequacy and liquidity guidelines applicable to Regions and Regions Bank under the Basel III Rules, 
which began to be phased in starting in 2015, require Regions to satisfy additional, more stringent capital adequacy and liquidity 
standards than in the past. In addition, these requirements could have a negative impact on our ability to lend, grow deposit balances, 
make acquisitions and make capital distributions in the form of increased dividends or share repurchases. Higher capital levels 
could also lower our return on equity. 

We may also be required to satisfy even more stringent standards depending on the implementation of the liquidity guidelines 
as well as the additional capital and other surcharges being considered by supervisory bodies. For more information concerning 
our compliance with capital and liquidity requirements, see Note 14 “Regulatory Capital Requirements and Restrictions” in the 
Notes to the Consolidated Financial Statements in Item 8. of this Annual Report on Form 10-K.

Rulemaking changes implemented by the CFPB will result in higher regulatory and compliance costs that may adversely affect 
our results of operations.

Since its formation, the CFPB has finalized a number of significant rules that could have a significant impact on our business 
and the financial services industry more generally. In particular, the CFPB has adopted rules impacting nearly every aspect of the 
lifecycle of a residential mortgage loan as discussed in the “Supervision and Regulation” section of Item 1. “Business” of this 
Annual Report on Form 10-K above. The CFPB has also issued guidance, which has faced Congressional opposition, that could 
radically reshape the automotive financing industry by subjecting indirect automobile lenders, such as Regions, to regulation as 
creditors under the Equal Credit Opportunity Act, which would make indirect automobile lenders monitor and control certain credit 
policies and procedures undertaken by automobile dealers. Compliance with the rules and policies adopted by the CFPB may limit 
the products we may permissibly offer to some or all of our customers, or limit the terms on which those products may be issued, 
or may adversely affect our ability to conduct our business as previously conducted (including our residential mortgage and indirect 
auto lending businesses in particular). We may also be required to add additional compliance personnel or incur other significant 
compliance-related expenses. Our business, results of operations or competitive position may be adversely affected as a result.

We may not be able to complete future acquisitions, may not be successful in realizing the benefits of any future acquisitions 
that are completed, or may choose not to pursue acquisition opportunities we might find beneficial.

A substantial part of our historical growth has been a result of acquisitions of other financial institutions, and we may, from 
time to time, evaluate and engage in the acquisition or divestiture of businesses (including their assets or liabilities, such as loans 
or deposits). We must generally satisfy a number of meaningful conditions prior to completing any such transaction, including in 
certain cases, federal and state bank regulatory approvals. Bank regulators consider a number of factors when determining whether 
to approve a proposed transaction, including the supervisory ratings and compliance history of all institutions involved, the anti-
money laundering and Bank Secrecy Act compliance history of all institutions involved, CRA examination results and the effect 
of the transaction on financial stability.  In 2014, the Federal Reserve Bank of Atlanta began a regularly scheduled CRA examination 
of Regions Bank covering 2012 and 2013 performance. This review included, among other things, a review of Regions Bank’s 
previously disclosed public consent orders. As a result of the examination, the results of which were communicated during the 
fourth quarter of 2015, Regions Bank received “High Satisfactory” ratings on its CRA components, but its overall CRA rating was 
downgraded from “Satisfactory” to “Needs to Improve.” The downgrade was attributable to the matters underlying Regions Bank’s 
April 2015 public consent order with the CFPB related to overdrafts and the Federal Reserve's Regulation E. Regions Bank had 
self-reported  these  matters  and  provided  remuneration  during  2011  and  2012.  This  downgrade  imposed  restrictions  on  the 
Company’s  ability  to  undertake  certain  activities,  including  mergers  and  acquisitions  of  insured  depository  institutions  and 
applications to open branches or certain other facilities until such time as the rating was improved. On December 19, 2016, the 
Federal Reserve Bank of Atlanta informed Regions that the Company's overall CRA rating had been reinstated from "Needs to 

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Improve" to "Satisfactory" and this regulatory issue is resolved.  Further, Regions continued to receive a "High Satisfactory" rating 
on the lending, investment and service portions of the Company's most recent CRA review. 

Additionally, the process for obtaining required regulatory approvals has become substantially more difficult, time-consuming 
and  unpredictable  as  a  result  of  the  financial  crisis. We  may  fail  to  pursue,  evaluate  or  complete  strategic  and  competitively 
significant business opportunities as a result of our inability, or our perceived inability, to obtain required regulatory approvals in 
a timely manner or at all.

Assuming we are able to successfully complete one or more transactions, we may not be able to successfully integrate and 
realize the expected synergies from any completed transaction in a timely manner or at all. In particular, we may be held responsible 
by federal and state regulators for regulatory and compliance failures at an acquired business prior to the date of the acquisition, 
and these failures by the acquired company may have negative consequences for us, including the imposition of formal or informal 
enforcement actions. Completion and integration of any transaction may also divert management attention from other matters, 
result in additional costs and expenses, or adversely affect our relationships with our customers and employees, any of which may 
adversely affect our business or results of operations. Future acquisitions may also result in dilution of our current stockholders’ 
ownership interests or may require we incur additional indebtedness or use a substantial amount of our available cash and other 
liquid assets. As a result, our financial condition may be affected, and we may become more susceptible to economic conditions 
and competitive pressures.

Increases in FDIC insurance premiums may adversely affect our earnings.

Our deposits are insured by the FDIC up to legal limits and, accordingly, we are subject to FDIC deposit insurance assessments. 
We generally cannot control the amount of premiums we will be required to pay for FDIC insurance. High levels of bank failures 
over the past several years and increases in the statutory deposit insurance limits have increased resolution costs to the FDIC and 
put pressure on the DIF. In order to maintain a strong funding position and restore the reserve ratios of the DIF, the FDIC increased 
assessment rates on insured institutions, charged a special assessment to all insured institutions as of June 30, 2009, and required 
banks to prepay three years’ worth of premiums on December 30, 2009. If there are additional financial institution failures, we 
may be required to pay even higher FDIC premiums than the recently increased levels, or the FDIC may charge additional special 
assessments or require future prepayments. Additional increases in our assessment rate may be required in the future to achieve 
the FDIC’s designated reserve ratio. These increases in deposit assessments and any future increases, required prepayments or 
special assessments of FDIC insurance premiums may adversely affect our business, financial condition or results of operations.  
See the “Supervision and Regulation-Deposit Insurance” discussion within Item 1. "Business" and the "Non-Interest Expense" 
discussion within Item 7. "Management's Discussion and Analysis of Financial Condition and Results of Operations" of this Annual 
Report on Form 10-K for additional information related to the FDIC’s deposit insurance assessments applicable to Regions Bank.

Unfavorable results from ongoing stress analyses may adversely affect our ability to retain customers or compete for new 
business opportunities.

The Federal Reserve conducts an annual stress analysis of Regions to evaluate our ability to absorb losses in three economic 
and financial scenarios generated by the Federal Reserve, including adverse and severely adverse economic and financial scenarios. 
The rules also require us to conduct our own semi-annual stress analysis to assess the potential impact on Regions of the scenarios 
used as part of the Federal Reserve’s annual stress analysis. A summary of the results of certain aspects of the Federal Reserve’s 
annual stress analysis is released publicly and contains information and results specific to BHCs. The rules also require us to 
disclose publicly a summary of the results of our semi-annual stress analyses, and Regions Bank’s annual stress analyses, under 
the severely adverse scenario.

Although the stress tests are not meant to assess our current condition, our customers may misinterpret and adversely react 
to the results of these stress tests despite the strength of our financial condition. Any potential misinterpretations and adverse 
reactions could limit our ability to attract and retain customers or to effectively compete for new business opportunities. The 
inability to attract and retain customers or effectively compete for new business may have a material and adverse effect on our 
business, financial condition or results of operations.

Our regulators may also require us to raise additional capital or take other actions, or may impose restrictions on our business, 
based on the results of the stress tests, including rejecting, or requiring revisions to, our annual capital plan submitted in connection 
with the CCAR. The failure of our capital plan to pass the CCAR could adversely affect our ability to pay dividends and repurchase 
stock. In addition, we may not be able to raise additional capital if required to do so, or may not be able to do so on terms that we 
believe are advantageous to Regions or its current stockholders. Any such capital raises, if required, may also be dilutive to our 
existing stockholders.

If  an  orderly  liquidation  of  a  systemically  important  BHC  or  non-bank  financial  company  were  triggered,  we  could  face 
assessments for the Orderly Liquidation Fund.

The Dodd-Frank Act created a new mechanism, the OLA, for liquidation of systemically important BHCs and non-bank 
financial companies. The OLA is administered by the FDIC and is based on the FDIC’s bank resolution model. The Secretary of 
the U.S. Treasury may trigger a liquidation under this authority only after consultation with the President of the U.S. and after 
receiving a recommendation from the boards of the FDIC and the Federal Reserve upon a two-thirds vote. Liquidation proceedings 

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will be funded by the Orderly Liquidation Fund, which will borrow from the U.S. Treasury and impose risk-based assessments on 
covered financial companies. Risk-based assessments would be made, first, on entities that received more in the resolution than 
they would have received in the liquidation to the extent of such excess, and second, if necessary, on, among others, BHCs with 
total consolidated assets of $50 billion or more, such as Regions. Any such assessments may adversely affect our business, financial 
condition or results of operations.

Risks Related to Our Capital Stock

The market price of shares of our capital stock will fluctuate.

The market price of our capital stock could be subject to significant fluctuations due to a change in sentiment in the market 

regarding our operations or business prospects. Such risks may be affected by:

•  Our  operating  performance,  financial  condition  and  prospects,  or  the  operating  performance,  financial  condition  and 

prospects of our competitors;

•  Operating results that vary from the expectations of management, securities analysts and investors;

•  Our creditworthiness;

•  Developments in our business or in the financial sector generally;

•  Regulatory changes affecting our industry generally or our business and operations;

•  The operating and securities price performance of companies that investors consider to be comparable to us;

•  Announcements of strategic developments, acquisitions and other material events by us or our competitors;

•  Expectations of or actual equity dilution;

•  Whether we declare or fail to declare dividends on our capital stock from time to time;

•  The ratings given to our securities by credit-rating agencies;

•  Changes in the credit, mortgage and real estate markets, including the markets for mortgage-related securities; and

•  Changes in global financial markets, global economies and general market conditions, such as interest or foreign exchange 

rates, stock, commodity, credit or asset valuations or volatility.

Stock markets in general (and our common stock in particular) have shown considerable volatility in the recent past. The 
market price of our capital stock, including our common stock and depositary shares representing fractional interests in our preferred 
stock, may continue to be subject to similar fluctuations unrelated to our operating performance or prospects. Increased volatility 
could result in a decline in the market price of our capital stock.

Our capital stock is subordinate to our existing and future indebtedness.

Our capital stock, including our common stock and depositary shares representing fractional interests in our preferred stock, 
ranks junior to all of Regions’ existing and future indebtedness and Regions’ other non-equity claims with respect to assets available 
to satisfy claims against us, including claims in the event of our liquidation. As of December 31, 2016, Regions’ total liabilities 
were approximately $109.3  billion, and  we may incur additional indebtedness in  the future  to increase our  capital resources. 
Additionally, if our capital ratios or the capital ratios of Regions Bank fall below the required minimums, we or Regions Bank 
could be forced to raise additional capital by making additional offerings of debt securities, including medium-term notes, senior 
or subordinated notes or other applicable securities.

We are a holding company and depend on our subsidiaries for dividends, distributions and other payments.

We are a legal entity separate and distinct from our banking and other subsidiaries. Our principal source of cash flow, including 
cash flow to pay dividends to our stockholders and principal and interest on our outstanding debt, is dividends from Regions Bank. 
There are statutory and regulatory limitations on the payment of dividends by Regions Bank to us, as well as by us to our stockholders. 
Regulations of both the Federal Reserve and the State of Alabama affect the ability of Regions Bank to pay dividends and other 
distributions to us and to make loans to us. If Regions Bank is unable to make dividend payments to us and sufficient cash or 
liquidity is not otherwise available, we may not be able to make dividend payments to our common and preferred stockholders or 
principal  and  interest  payments  on  our  outstanding  debt.  See  the  “Stockholders’  Equity”  section  of  Item 7.  “Management’s 
Discussion and Analysis of Financial Condition and Results of Operations” of this Annual Report on Form 10-K. In addition, our 
right to participate in a distribution of assets upon a subsidiary’s liquidation or reorganization is subject to the prior claims of 
creditors of that subsidiary, except to the extent that any of our claims as a creditor of such subsidiary may be recognized. As a 
result, shares of our capital stock are effectively subordinated to all existing and future liabilities and obligations of our subsidiaries. 
At December 31, 2016, our subsidiaries’ total deposits and borrowings were approximately $107.4 billion.

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We may not pay dividends on shares of our capital stock.

Holders of shares of our capital stock are only entitled to receive such dividends as our Board may declare out of funds 
legally available for such payments. Although we have historically declared cash dividends on our common stock, we are not 
required to do so and may reduce or eliminate our common stock dividend in the future. This could adversely affect the market 
price of our common stock.  Furthermore, the terms of our outstanding preferred stock prohibit us from declaring or paying any 
dividends on any junior series of our capital stock, including our common stock, or from repurchasing, redeeming or acquiring 
such junior stock, unless we have declared and paid full dividends on our outstanding preferred stock for the most recently completed 
dividend period.

We are also subject to statutory and regulatory limitations on our ability to pay dividends on our capital stock. For example, 
it is the policy of the Federal Reserve that BHCs should generally pay dividends on common stock only out of earnings, and only 
if prospective earnings retention is consistent with the organization’s expected future needs, asset quality and financial condition. 
Moreover,  the  Federal  Reserve  will  closely  scrutinize  any  dividend  payout  ratios  exceeding  30%  of  after-tax  net  income. 
Additionally, we are required to submit annual capital plans to the Federal Reserve for review before we can take certain capital 
actions, including declaring and paying dividends and repurchasing or redeeming capital securities. If our capital plan or any 
amendment to our capital plan is objected to for any reason, our ability to declare and pay dividends on our capital stock may be 
limited.  Further, if we are unable to satisfy the capital requirements applicable to us for any reason, we may be limited in our 
ability to declare and pay dividends on our capital stock.

Anti-takeover and banking laws and certain agreements and charter provisions may adversely affect share value.

Certain provisions of state and federal law and our certificate of incorporation may make it more difficult for someone to 
acquire control of us without our Board's approval. Under federal law, subject to certain exemptions, a person, entity or group 
must notify the federal banking agencies before acquiring control of a BHC. Acquisition of 10% or more of any class of voting 
stock of a BHC or state member bank, including shares of our common stock, creates a rebuttable presumption that the acquirer 
“controls” the BHC or state member bank. Also, as noted under the “Supervision and Regulation” section of Item 1. of this Annual 
Report on Form 10-K, a BHC must obtain the prior approval of the Federal Reserve before, among other things, acquiring direct 
or indirect ownership or control of more than 5% of the voting shares of any bank, including Regions Bank. One factor the federal 
banking agencies must consider in certain acquisitions is the systemic impact of the transaction. This may make it more difficult 
for large institutions to acquire other large institutions and may otherwise delay the regulatory approval process, possibly by 
requiring public hearings. There also are provisions in our certificate of incorporation that may be used to delay or block a takeover 
attempt. For example, holders of our preferred stock have certain voting rights that could adversely affect share value. If and when 
dividends on the preferred stock have not been declared and paid for at least six quarterly dividend periods or their equivalent 
(whether or not consecutive), the authorized number of directors then constituting our Board will automatically be increased by 
two, and the preferred stockholders will be entitled to elect the two additional directors. Also, the affirmative vote or consent of 
the holders of at least two-thirds of all of the then-outstanding shares of the preferred stock is required to consummate a binding 
share-exchange or reclassification involving the preferred stock, or a merger or consolidation of Regions with or into another 
entity, unless certain requirements are met. These statutory provisions and provisions in our certificate of incorporation, including 
the rights of the holders of our preferred stock, could result in Regions being less attractive to a potential acquirer.

We may need to raise additional debt or equity capital in the future, but may be unable to do so.

We may need to raise additional capital in the future to provide us with sufficient capital resources and liquidity to meet our 
commitments and other business purposes. Our ability to raise additional capital, if needed, will depend on, among other things, 
prevailing  conditions  in  the  capital  markets,  which  are  outside  of  our  control,  and  our  financial  performance. The  economic 
slowdown and loss of confidence in financial institutions over the past several years may increase our cost of funding and limit 
our access to some of our customary sources of capital, including inter-bank borrowings, repurchase agreements and borrowings 
from the discount window of the Federal Reserve. We cannot be assured that capital will be available to us on acceptable terms 
or at all. Any occurrence that may limit our access to the capital markets, such as a decline in the confidence of debt purchasers, 
depositors of Regions Bank or counterparties participating in the capital markets, or a downgrade of our debt ratings, may adversely 
affect our capital costs and our ability to raise capital and, in turn, our liquidity. An inability to raise additional capital on acceptable 
terms when needed could have a materially adverse effect on our business, financial condition or results of operations.

Future issuances of additional equity securities could result in dilution of existing stockholders’ equity ownership.

We may determine from time to time to issue additional equity securities to raise additional capital, support growth, or to 
make acquisitions. Further, we may issue stock options or other stock grants to retain and motivate our employees. These issuances 
of our securities could dilute the voting and economic interests of our existing stockholders.

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Item 1B.  Unresolved Staff Comments

None.

Item 2.  Properties

Regions’ corporate headquarters occupy the main banking facility of Regions Bank, located at 1900 Fifth Avenue North, 

Birmingham, Alabama 35203.

At December 31, 2016, Regions Bank, Regions’ banking subsidiary, operated 1,527 banking offices. At December 31, 2016, 
there  were  no  significant  encumbrances  on  the  offices,  equipment  and  other  operational  facilities  owned  by  Regions  and  its 
subsidiaries.

See Item 1. “Business” of this Annual Report on Form 10-K for a list of the states in which Regions Bank’s branches are 

located.

Item 3.  Legal Proceedings

Information required by this item is set forth in Note 24 “Commitments, Contingencies and Guarantees” in the Notes to 

the Consolidated Financial Statements, which are included in Item 8. of this Annual Report on Form 10-K.

Item 4.  Mine Safety Disclosures.

  Not applicable.

Executive Officers of the Registrant

Information concerning the Executive Officers of Regions is set forth under Item 10. “Directors, Executive Officers and 

Corporate Governance” of this Annual Report on Form 10-K.

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PART II

Item 5. Market For Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities

Regions common stock, par value $.01 per share, is listed for trading on the New York Stock Exchange under the symbol 
RF. Quarterly high and low sales prices of and cash dividends declared on Regions common stock are set forth in Table 27 “Quarterly 
Results of Operations” of “Management’s Discussion and Analysis”, which is included in Item 7. of this Annual Report on Form 
10-K. Information relating to compensation plans under which Regions' equity securities are authorized for issuance is presented 
in Part III, Item 12. As of February 21, 2017, there were 48,619 holders of record of Regions common stock (including participants 
in the Computershare Investment Plan for Regions Financial Corporation).

Restrictions on the ability of Regions Bank to transfer funds to Regions at December 31, 2016, are set forth in Note 14 
“Regulatory Capital Requirements and Restrictions” to the consolidated financial statements, which are included in Item 8. of this 
Annual Report on Form 10-K. A discussion of certain limitations on the ability of Regions Bank to pay dividends to Regions and 
the ability of Regions to pay dividends on its common stock is set forth in Item 1. “Business” under the heading “Supervision and 
Regulation—Payment of Dividends” of this Annual Report on Form 10-K.

In connection with Regions' acquisition of BlackArch Partners LLC  ("BlackArch") on October 20, 2015, Regions issued 
831,766 shares of Regions common stock to the former owners of BlackArch as partial consideration for the acquisition.  The 
shares issued in the transaction are exempt from the registration requirements of the Securities Act of 1933, as amended, pursuant 
to Section 4(a)(2).  Pursuant to contingent payment provisions in the purchase agreement, if certain conditions are met, Regions 
will issue up to 1,528,234 additional shares of Regions common stock to the former owners of BlackArch over the four-year period 
following the acquisition.  During 2016, an additional 196,991 shares were issued, leaving 1,331,243 additional shares to be 
potentially issued. Each of the former owners of BlackArch are accredited investors and no underwriters or placement agents were 
involved in connection with issuance of Regions common stock.

The following table presents information regarding issuer purchases of equity securities during the fourth quarter of 2016.

Issuer Purchases of Equity Securities

Period
October 1—31, 2016
November 1—30, 2016
December 1—31, 2016
Total 4th Quarter

Average Price Paid
 per Share

Total Number of Shares 
Purchased as Part of
Publicly Announced
Plans or Programs

Maximum Approximate 
Dollar Value of
Shares that May
Yet Be Purchased Under 
Publicly Announced 
Plans or Programs

10.70
11.88
—
11.52

7,182,991
16,218,954

$
$
— $
$

23,401,945

468,128,724
275,204,615
275,204,615
275,204,615

Total Number of 
Shares Purchased
7,182,991
16,218,954

$
$
— $
$

23,401,945

On July 14, 2016, Regions' Board authorized a new $640 million common stock repurchase plan, permitting repurchases 
from the beginning of the third quarter of 2016 through the second quarter of 2017. On October 12, 2016, Regions' Board authorized 
an additional $120 million repurchase, which increases the total amount authorized under the plan to $760 million. As of December 
31, 2016, Regions repurchased approximately 46.5 million shares of common stock at a total cost of approximately $485 million 
under this plan. The Company continued to repurchase shares under this plan in the first quarter of 2017, and as of February 23, 
2017, Regions had additional repurchases of approximately 10.2 million shares of common stock at a total cost of approximately 
$149.8 million. All of these shares were immediately retired upon repurchase and, therefore, will not be included in treasury stock.

Restrictions on Dividends and Repurchase of Stock

Holders of Regions common stock are only entitled to receive such dividends as Regions’ Board may declare out of funds 
legally available for such payments. Furthermore, holders of Regions common stock are subject to the prior dividend rights of any 
holders of Regions preferred stock then outstanding.

Regions understands the importance of returning capital to stockholders. Management will continue to execute the capital 
planning process, including evaluation of the amount of the common dividend, with the Board and in conjunction with the regulatory 
supervisors, subject to the Company’s results of operations. Also, Regions is a BHC, and its ability to declare and pay dividends 
is dependent on certain federal regulatory considerations, including the guidelines of the Federal Reserve regarding capital adequacy 
and dividends.

On November 1, 2012, Regions completed the sale of 20 million depositary shares each representing a 1/40th ownership 
interest in a share of its 6.375% Non-Cumulative Perpetual Preferred Stock, Series A, par value $1.00 per share (“Series A Preferred 
Stock”), with a liquidation preference of $1,000 per share of Series A Preferred Stock (equivalent to $25 per depositary share). 
The terms of the Series A Preferred Stock prohibit Regions from declaring or paying any dividends on any junior series of its 
capital stock, including its common stock, or from repurchasing, redeeming or acquiring such junior stock, unless Regions has 
declared and paid full dividends on the Series A Preferred Stock for the most recently completed dividend period. The Series A 

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Preferred Stock is redeemable at Regions’ option in whole or in part, from time to time, on any dividend payment date on or after 
December 15, 2017 or in whole, but not in part, at any time within 90 days following a regulatory capital treatment event (as 
defined in the certificate of designations establishing the Series A Preferred Stock).

On April 29, 2014, Regions completed the sale of 20 million depositary shares each representing a 1/40th ownership interest 
in a share of its 6.375% Fixed-to-Floating Rate Non-Cumulative Perpetual Preferred Stock, Series B, par value $1.00 per share 
(“Series B Preferred Stock”), with a liquidation preference of $1,000 per share of Series B Preferred Stock (equivalent to $25 per 
depositary share). The terms of the Series B Preferred Stock prohibit Regions from declaring or paying any dividends on any junior 
series of its capital stock, including its common stock, or from repurchasing, redeeming or acquiring such junior stock, unless 
Regions has declared and paid full dividends on the Series B Preferred Stock for the most recently completed dividend period. 
The Series B Preferred Stock is redeemable at Regions’ option in whole or in part, from time to time, on any dividend payment 
date on or after September 15, 2024, or in whole but not in part, at any time following a regulatory capital treatment event (as 
defined in the certificate of designations establishing the Series B Preferred Stock).

PERFORMANCE GRAPH

Set forth below is a graph comparing the yearly percentage change in the cumulative total return of Regions common stock 
against the cumulative total return of the S&P 500 Index and the S&P 500 Banks Index for the past five years. This presentation 
assumes that the value of the investment in Regions’ common stock and in each index was $100 and that all dividends were 
reinvested.

Regions
S&P 500 Index
S&P 500 Banks Index

Cumulative Total Return

12/31/2011

12/31/2012

12/31/2013

12/31/2014

12/31/2015

12/31/2016

$

$

100.00
100.00
100.00

$

166.82
115.99
124.06

$

233.92
153.54
168.37

$

254.11
174.54
194.49

$

236.52
176.94
196.14

362.82
198.09
243.82

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Item 6.  Selected Financial Data

The information required by Item 6. is set forth in Table 1 “Financial Highlights” of “Management’s Discussion and Analysis 

of Financial Condition and Results of Operations”, which is included in Item 7. of this Annual Report on Form 10-K.

Item 7.  Management’s Discussion and Analysis of Financial Condition and Results of Operations

Item 7A.  Quantitative and Qualitative Disclosures about Market Risk

EXECUTIVE OVERVIEW

Management believes the following sections provide an overview of several of the most relevant matters necessary for an 
understanding of the financial aspects of Regions Financial Corporation’s (“Regions” or “the Company”) business, particularly 
regarding its 2016 results. Cross references to more detailed information regarding each topic within Management’s Discussion 
and Analysis of Financial Condition and Results of Operations (“MD&A”) and the consolidated financial statements are included. 
This summary is intended to assist in understanding the information provided, but should be read in conjunction with the entire 
MD&A and consolidated financial statements, as well as the other sections of this Annual Report on Form 10-K.

2016 Results

Regions reported net income available to common shareholders from continuing operations of $1.1 billion, or $0.87 per 
diluted share, in 2016 compared to net income available to common shareholders from continuing operations of $1.0 billion, or 
$0.76 per diluted share, in 2015. 

Net interest income and other financing income (taxable-equivalent basis) from continuing operations totaled $3.5 billion 
in 2016 compared to $3.4 billion in 2015. The net interest margin (taxable-equivalent basis) was 3.14 percent in 2016, reflecting 
a 1 basis point increase from 2015 primarily due to the increases in yields on earning assets exceeding the slight increase in total 
funding costs.   

The provision for loan losses totaled $262 million in 2016 compared to $241 million in 2015. This increase was primarily 
due  to  higher  net  charge-offs,  including  $37  million  in  2016  energy  charge-offs,  and  the  increase  in  criticized  and  classified 
commercial loans, attributable primarily to downward risk rating migration in the energy portfolio.  This increase was offset by 
the impact of $2.0 billion in business services loan balance runoff, including $436 million in direct energy, and improvement in 
the risk profile of certain other loan classes. Net charge-offs were 0.34 percent of average loans in 2016, compared to 0.30 percent 
in 2015. 

Non-interest income from continuing operations was $2.2 billion in 2016 and $2.1 billion in 2015. The increase from the 
prior year was driven primarily by increases in capital markets fee income and other, card and ATM fees, and bank-owned life 
insurance income. These increases more than offset declines in insurance proceeds, net revenue from affordable housing, and 
securities gains, net. See Table 5 "Non-Interest Income from Continuing Operations" for further details. 

Non-interest expenses from continuing operations was $3.6 billion in both 2016 and 2015. While non-interest expenses from 
continuing operations was relatively consistent in 2016, there were increases in salaries and employee benefits, furniture and 
equipment expenses, and the provision (credit) for unfunded credit losses. Decreases in net occupancy expenses, FDIC insurance 
assessments, professional, legal and regulatory expenses, and loss on early extinguishment of debt offset the increases discussed 
above. See Table 6 "Non-Interest Expense from Continuing Operations" for further details.

A discussion of activity within discontinued operations is included at the end of "Operating Results" in the Management’s 

Discussion and Analysis section of this report.

For more information, refer to the following additional sections within this Form 10-K:

• 

"Operating Results" section of MD&A

Capital

Capital Actions

As part of its 2016 CCAR submission, Regions' proposed capital plans included increasing its quarterly common stock 
dividend from $0.06 per share to $0.065 per share during the second quarter of 2016 and the execution of up to $640 million in 
common share repurchases. The capital plan also provides the potential for a dividend increase beginning in the second quarter of 
2017, which is expected to be considered by the Board in early 2017. The 2016 capital plans cover the period from the second 
quarter of 2016 through the second quarter of 2017. The Federal Reserve did not object to these plans. 

Management expects to continue to evaluate the amount of the common stock dividend with the Board and in conjunction 

with regulatory supervisors, subject to the Company’s results of operations.

Regions’ Board approved the share repurchase plan. The share repurchase authority granted by the Board was available at 
the beginning of the second quarter of 2016 and will continue through the second quarter of 2017. Also, on October 12, 2016, 
Regions' Board authorized an additional $120 million repurchase, which increased the total amount authorized under the plan to 

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Table of Contents 

$760 million.  As of December 31, 2016, Regions had repurchased approximately 46.5 million shares of common stock at a total 
cost of approximately $485 million under this plan. The Company continued to repurchase shares under this plan into the first 
quarter of 2017. These shares were immediately retired upon repurchase and therefore are not included in treasury stock.

For more information refer to the following additional sections within this Form 10-K:

• 

“Stockholders’ Equity” discussion in MD&A

•  Note 15 “Stockholders’ Equity and Accumulated Other Comprehensive Income (Loss)” to the consolidated financial 

statements

Regulatory Capital

Regions and Regions Bank are required to comply with applicable capital adequacy standards established by the Federal 
Reserve. In 2013, the Federal Reserve published the final Basel III Rules establishing an updated comprehensive capital framework 
for U.S. banking organizations. The Basel III Rules substantially revised the regulatory capital requirements applicable to BHCs 
and depository institutions, including Regions and Regions Bank. The Basel III Rules were effective for Regions and Regions 
Bank beginning January 1, 2015 (subject to a phase-in period), and maintained the minimum guidelines for Regions to be considered 
well-capitalized for Tier 1 capital and Total capital at 6.0% and 10.0%, respectively. At December 31, 2016, Regions’ Basel III 
Tier 1 capital and Total capital ratios were estimated to be 11.98% and 14.15%, respectively. 

The Basel III Rules also officially defined CET1. When fully phased in on January 1, 2019, the minimum ratio of CET1 to 
risk-weighted assets will be at least 4.5%, plus a 2.5% “capital conservation buffer” (which is added to the 4.5% CET1 ratio as 
that  buffer  is  phased  in,  effectively  resulting  in  a  minimum  ratio  of  CET1  to  risk-weighted  assets  of  at  least  7.0%  upon  full 
implementation). Regions' Basel III CET1 ratio at December 31, 2016 on a transitional basis was estimated to be 11.21%. Regions’ 
understanding of the framework is evolving and will likely change as analysis and discussions with regulators continue. Based on 
its current understanding, Regions estimates its fully phased-in CET1 ratio (non-GAAP) at December 31, 2016 to be 11.05%.

For more information refer to the following additional sections within this Form 10-K:

• 

“Supervision and Regulation” discussion within Item 1. Business

•  Table 2 - “GAAP to Non-GAAP reconciliation” in MD&A

• 

"Regulatory Requirements" section of MD&A

•  Note 14 “Regulatory Capital Requirements and Restrictions” to the consolidated financial statements

Loan Portfolio and Credit

During 2016 total loans decreased by $1.1 billion or 1 percent compared to 2015.  Commercial and industrial loans declined 
$809 million, impacted by a $436 million reduction in direct energy loans. Owner-occupied commercial real estate mortgage loans 
declined  $671 million reflecting the softness in loan demand from middle market and small business customers, combined with 
the competitive market for this asset class.  Investor real estate loans declined $473 million as the Company curtailed growth in 
the multi-family sector. Home equity balances decreased $291 million as the pace of run-off continued to exceed production. These 
decreases were partially offset by increases in the consumer portfolio, which experienced growth in almost every product category. 
The consumer growth was led by increases in residential first mortgages of $629 million, and indirect-other of $375 million, as 
the Company continued to execute its point-of-sale initiatives. The economy has been and will continue to be the primary factor 
which influences Regions’ loan portfolio. Customers continued to benefit from improvement in overall economic conditions in 
2016, particularly low interest rates and low inflation. These factors generated excess cash that has been used to support spending 
in other areas including paying down debt and increasing savings as was experienced in 2015. Labor market and housing market 
conditions continued to improve at a steady pace over the course of 2016. Overall, the rate of economic growth in 2017 is expected 
to remain in line with the modest trend rate of growth that has prevailed since the end of the 2007-2009 recession. Management’s 
expectation for 2017 average loan growth is in the low single digits.

Net charge-offs totaled $277 million, or 0.34 percent of average loans, in 2016, compared to $238 million, or 0.30 percent 
in 2015. Net charge-offs increased within commercial and industrial, commercial real estate, indirect-vehicles, indirect-other, 
consumer credit card and other consumer, but were lower within residential first mortgage and home equity when comparing 2016
to the prior year. Total non-accrual loans, past due loans, and troubled debt restructurings also increased year-over-year. Criticized 
and classified commercial and investor real estate loans increased $241 million in 2016 compared to 2015. The increase in criticized 
and classified commercial loans was driven primarily by downward risk rating migration in the energy portfolio. The downward 
migration in direct energy and energy-related credits also drove the increase in commercial troubled debt restructurings as these 
credits were restructured at concessionary terms. The allowance for loan losses at both December 31, 2016 and December 31, 
2015 was 1.36 percent of total loans, net of unearned income. The coverage ratio of allowance for loan losses to non-performing 
loans was 1.10x at December 31, 2016 compared to 1.41x at December 31, 2015.  The adjusted coverage ratio of allowance for 
loan losses to non-performing loans, which excluded direct energy (non-GAAP), was 1.38x at December 31, 2016 compared to 
1.37x at December 31, 2015. 

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Table of Contents 

For more information, refer to the following additional sections within this Form 10-K:

•  Adjusted Non-Accrual Loans and Selected Ratios within the "Table 2 - GAAP-to-Non-GAAP Reconciliation"

• 

• 

• 

“Allowance for Credit Losses” discussion within the “Critical Accounting Policies and Estimates” section of  MD&A

“Provision for Loan Losses” discussion within the “Operating Results” section of MD&A

“Loans,” “Allowance for Credit Losses,” “Troubled Debt Restructurings” and “Non-performing Assets” discussions 
within the “Balance Sheet Analysis” section of MD&A

•  Note 1 "Summary of Significant Accounting Policies" to the consolidated financial statements

•  Note 5 "Loans" to the consolidated financial statements 

•  Note 6 “Allowance for Credit Losses” to the consolidated financial statements

Net Interest Income and Other Financing Income, Net Interest Margin and Interest Rate Risk

In 2016, the net interest margin increased 1 basis point to 3.14 percent, due to an increase in yields on earning assets exceeding 
the slight increase in total funding costs . Net interest income and other financing income (taxable equivalent basis) increased $100 
million in 2016, driven primarily by higher short-term interest rates, average loan growth, higher securities balances and balance 
sheet management strategies.  Despite continued improvement, net interest income and other financing income and the resulting 
net interest margin continued to be pressured by a sustained low interest rate environment. 

The Company expects to increase net interest income and other financing income in the range of 2 percent to 4 percent in 
2017, commensurate with average loan growth in the low single digits. The range assumes an interest rate scenario equal to the 
market forward interest rates as of November 10, 2016, including an average Fed Funds rate of 81 basis points and an average 10-
year U.S. Treasury rate of 2.26 percent for 2017.  

For more information, refer to the following additional sections within this Form 10-K:

“Net Interest Income and Other Financing Income and Net Interest Margin” discussion within the “Operating Results” 
section of MD&A

“Interest Rate Risk” discussion within “Risk Management” section of MD&A

• 

• 

Liquidity

At the end of 2016, Regions Bank had $3.6 billion in cash on deposit with the Federal Reserve and the loan-to-deposit ratio 
was 81 percent. Cash and cash equivalents at the parent company totaled $1.0 billion. Regions' liquidity policy related to minimum 
holding company cash requires the holding company to maintain cash sufficient to cover the greater of (1) 18 months of debt 
service and other cash needs or (2) a minimum cash balance of $500 million. 

At December 31, 2016, the Company’s borrowing capacity with the Federal Reserve was $15.6 billion based on available 
collateral. Borrowing availability with the FHLB was $12.1 billion based on available collateral at the same date. The Company 
has approximately $12.8 billion of unencumbered liquid securities available for pledging.  Regions also maintains a shelf registration 
statement with the U.S. Securities and Exchange Commission that can be utilized by the Company to issue various debt and/or 
equity securities. Additionally, Regions' Board has approved a bank note program which would allow Regions Bank to issue up 
to $5 billion in aggregate principal amount of bank notes outstanding at any one time.  As of December 31, 2016, no issuances 
have been made under this program. 

In 2014, the Federal Reserve Board, the Office of the Comptroller of the Currency and the FDIC approved a final rule 
implementing a minimum LCR requirement for certain large BHCs, savings and loan holding companies and depository institutions, 
and a less stringent LCR requirement (the "modified LCR") for other banking organizations, such as Regions, with $50 billion or 
more in total consolidated assets. The final rule imposes a monthly calculation requirement. In January 2016, the minimum phased-
in LCR requirement was 90 percent, followed by 100 percent in January 2017. The regulatory agencies finalized a rule that requires 
public disclosures of certain LCR measures beginning in October 2018 for Regions. At December 31, 2016, the Company was 
fully compliant with the LCR requirement. 

For more information, refer to the following additional sections within this Form 10-K:

• 

• 

• 

• 

• 

“Supervision and Regulation” discussion within Item 1. Business 

“Short-Term Borrowings” discussion within the “Balance Sheet Analysis” section of MD&A

“Long-Term Borrowings” discussion within the “Balance Sheet Analysis” section of MD&A

“Regulatory Requirements” section of MD&A

“Liquidity Risk” discussion within the “Risk Management” section of MD&A

•  Note 12 “Short-Term Borrowings” to the consolidated financial statements

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•  Note 13 “Long-Term Borrowings” to the consolidated financial statements

2017 Expectations

Management expectations for 2017 are noted below:

•  Expectations for 2017 assume full year GDP growth of 2 to 2.5 percent and an interest rate scenario equal to the 
market forward interest rates as of November 10, 2016, which equates to an average Fed Funds rate of 81 basis 
points and an average 10-year U.S. Treasury rate of 2.26 percent for 2017

• 

• 

Full year average loan growth in the low single digits compared to 2016 average balances

Full year average deposit growth in the low single digits compared to 2016 average balances

•  Net interest income and other financing income up 2 to 4 percent on a full year basis; the higher end of the range 
assumes that the post-election interest rate environment holds and pressure on deposit costs remains relatively low; 
the  lower  end  of  the  range  assumes  a  lower  interest  rate  environment,  similar  to  pre-election  levels,  or  an 
environment where deposit costs are more reactive

•  Adjusted non-interest income (non-GAAP) growth of 3 to 5 percent on a full year basis

•  Adjusted non-interest expenses (non-GAAP) flat to up 1 percent on a full year basis

• 

• 

• 

Full year adjusted efficiency ratio (non-GAAP) of approximately 62 percent

Positive adjusted operating leverage (non-GAAP) of 2 to 4 percent on a full year basis

Full year net charge-offs of 35 to 50 basis points

The reconciliation with respect to these forward-looking non-GAAP measures is expected to be consistent with the actual 
non-GAAP reconciliations within Management's Discussion and Analysis of this Form 10-K. For more information related to the 
Company's 2017 expectations, refer to the related sub-sections discussed in more detail within Management's Discussion and 
Analysis of this Form 10-K.

GENERAL

The following discussion and financial information is presented to aid in understanding Regions’ financial position and 
results of operations. The emphasis of this discussion will be on continuing operations for the years 2017, 2016 and 2015; in 
addition, financial information for prior years will also be presented when appropriate. 

Regions’ profitability, like that of many other financial institutions, is dependent on its ability to generate revenue from net 
interest income and other financing income as well as non-interest income sources. Net interest income and other financing income 
is primarily the difference between the interest income Regions receives on interest-earning assets, such as loans and securities, 
and the interest expense Regions pays on interest-bearing liabilities, principally deposits and borrowings. Regions’ net interest 
income and other financing income is impacted by the size and mix of its balance sheet components and the interest rate spread 
between interest earned on its assets and interest paid on its liabilities. Net interest income and other financing income also includes 
rental income and depreciation expense associated with operating leases for which Regions is the lessor. Non-interest income 
includes fees from service charges on deposit accounts, card and ATM fees, mortgage servicing and secondary marketing, investment 
management and trust activities, insurance activities, capital markets and other customer services which Regions provides. Results 
of operations are also affected by the provision for loan losses and non-interest expenses such as salaries and employee benefits, 
occupancy, professional, legal and regulatory expenses, FDIC insurance assessments and other operating expenses, as well as 
income taxes.

Economic conditions, competition, new legislation and related rules impacting regulation of the financial services industry 
and the monetary and fiscal policies of the Federal government significantly affect most, if not all, financial institutions, including 
Regions. Lending and deposit activities and fee income generation are influenced by levels of business spending and investment, 
consumer income, consumer spending and savings, capital market activities, and competition among financial institutions, as well 
as customer preferences, interest rate conditions and prevailing market rates on competing products in Regions’ market areas.

Regions’ business strategy has been and continues to be focused on providing a competitive mix of products and services, 

delivering quality customer service and maintaining a branch distribution network with offices in convenient locations.

Recent Acquisitions

On October 17, 2016, Regions announced the acquisition of the low income housing tax credit corporate fund syndication 
and asset management businesses of First Sterling Financial, Inc., which is one of the leading national syndicators of investment 
funds benefiting from low income housing tax credits.  The acquisition complements Regions' existing low income housing tax 
credit origination business and further expands the Company's capabilities to serve more clients and communities. 

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Table of Contents 

Dispositions

On  January 11,  2012,  Regions  entered  into  a  stock  purchase  agreement  to  sell  Morgan  Keegan and  related  affiliates  to 
Raymond James. The sale closed on April 2, 2012. Regions Investment Management, Inc. (formerly known as Morgan Asset 
Management, Inc.) and Regions Trust were not included in the sale. They are now included in the Wealth Management segment.

Results of operations for the entities sold are presented separately as discontinued operations for all periods presented on the 
consolidated statements of income. Other expenses related to the transaction are also included in discontinued operations. Refer 
to Note 3 “Discontinued Operations” and Note 24 “Commitments, Contingencies, and Guarantees” to the consolidated financial 
statements for further details.

Business Segments

Regions provides traditional commercial, retail and mortgage banking services, as well as other financial services in the 
fields of asset management, wealth management, securities brokerage, insurance and other specialty financing. Regions carries 
out  its  strategies  and  derives  its  profitability  from  three  reportable  segments:  Corporate  Bank,  Consumer  Bank,  and  Wealth 
Management, with the remainder split between Discontinued Operations and Other. During the first quarter of 2016, Regions 
reorganized  its  internal  management  structure  and,  accordingly,  its  segment  reporting  structure.  Under  the  organizational 
realignment, Regions will continue to operate with the same three reporting units with the Relationship Management component 
of Business Banking moving to the Corporate Bank and the Branch Small Business component of Business Banking remaining 
part of the Consumer Bank. Previously, all of Business Banking was included within the Consumer Bank. The Wealth Management 
segment remained unchanged during the organizational realignment. Additionally, in prior years the provision for loan losses was 
allocated to each segment based on actual net charge-offs that had been recognized by the segment. During the first quarter of 
2016,  Regions  began  allocating  the  provision  for  loan  losses  to  each  segment  using  an  estimated  loss  methodology  with  the 
difference between the consolidated provision for loan losses and the segments’ estimated loss reflected in Other. Lastly, allocations 
of operational and overhead cost pools among the segments were modified during the first quarter of 2016 to better align the total 
costs to support each segment in accordance with the reorganized management structure. Segment results for all periods presented 
have been recast to reflect this organizational realignment, as well as the provision for loan losses methodology change and the 
cost allocation modifications. 

See Note 23 “Business Segment Information” to the consolidated financial statements for further information on Regions’ 

business segments.

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Table of Contents 

Table 1—Financial Highlights

EARNINGS SUMMARY

2016

2015

2014

2013

2012

(In millions, except per share data)

Interest income, including other financing income

$

3,814

$

3,603

$

3,589

$

3,647

$

3,904

Interest expense and depreciation expense on operating lease assets

Net interest income and other financing income

Provision for loan losses

Net interest income and other financing income after provision for loan losses

Non-interest income

Non-interest expense

Income from continuing operations before income taxes

Income tax expense

Income from continuing operations

Income (loss) from discontinued operations before income taxes

Income tax expense (benefit)

Income (loss) from discontinued operations, net of tax

Net income (loss)

Net income (loss) from continuing operations available to common
shareholders

Net income (loss) available to common shareholders

Earnings (loss) per common share from continuing operations – basic

Earnings (loss) per common share from continuing operations – diluted

Earnings (loss) per common share – basic

Earnings (loss) per common share – diluted

416

3,398

262

3,136

2,153

3,617

1,672

514

1,158

8

3

5

1,163

1,094

1,099

0.87

0.87

0.87

0.87

$

$

$

$

296

3,307

241

3,066

2,071

3,607

1,530

455

1,075

(22)

(9)

(13)

1,062

1,011

998

0.76

0.76

0.75

0.75

$

$

$

$

309

3,280

69

3,211

1,903

3,432

1,682

548

1,134

21

8

13

1,147

1,082

1,095

0.79

0.78

0.80

0.79

$

$

$

$

384

3,263

138

3,125

2,096

3,556

1,665

561

1,104

(24)

(11)

(13)

1,091

1,072

1,059

0.77

0.76

0.76

0.75

$

$

$

$

603

3,301

213

3,088

2,201

3,526

1,763

583

1,180

(99)

(40)

(59)

1,121

1,051

992

0.76

0.76

0.72

0.72

$

$

$

$

Return on average common stockholders' equity
Return on average tangible common stockholders’ equity (non-GAAP)(1)

Return on average assets from continuing operations

6.74%

9.69

0.87

6.21%

8.96

0.83

6.90%

7.09%

6.98%

10.00

0.91

10.59

0.91

10.79

0.86

BALANCE SHEET SUMMARY

As of December 31—Consolidated

Loans, net of unearned income

Allowance for loan losses

Assets

Deposits

Long-term debt

Stockholders’ equity

Average balances—Continuing Operations

Loans, net of unearned income

Assets

Deposits

Long-term debt

Stockholders’ equity

SELECTED RATIOS
Basel I Tier 1 common regulatory capital (non-GAAP) (3)
Basel III common equity Tier 1 ratio (2)

Basel III common equity Tier 1 ratio—Fully Phased-In Pro-Forma (non-
GAAP) (1)(2)(3)
Tier 1 capital (2)(3)(4)
Total capital (2)(3)(4)
Leverage capital (2)(3)(4)
Tangible common stockholders’ equity to tangible assets  (non-GAAP) (1)

Efficiency ratio

Adjusted efficiency ratio (non-GAAP) 

(1)

$

80,095

$

81,162

$

77,307

$

74,609

$

73,995

(1,091)

(1,106)

(1,103)

(1,341)

(1,919)

125,968

126,050

119,563

117,288

121,270

99,035

7,763

16,664

98,430

8,349

16,844

94,200

3,462

16,873

92,453

4,830

15,660

95,474

5,861

15,422

$

81,333

$

79,634

$

76,253

$

74,924

$

76,035

125,506

122,265

118,352

117,712

122,105

97,921

8,159

17,124

96,890

5,046

16,922

93,481

4,057

16,609

92,646

5,206

15,409

95,330

6,694

14,957

N/A%

11.21

11.05

11.98

14.15

10.20

8.99

64.20

63.28

N/A%

10.93

10.69

11.65

13.88

10.25

9.13

66.15

64.87

11.65%

N/A

11.21%

N/A

10.84%

N/A

11.00

12.54

15.26

10.86

9.66

65.42

64.45

10.58

11.68

14.73

10.03

9.15

65.69

64.46

8.87

12.00

15.38

9.65

8.57

63.50

63.21

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COMMON STOCK DATA

Cash dividends declared per common share

$

Common equity book value per share
Tangible common book value per share (non-GAAP)(1)

Market value at year-end
Market price range: (5)

High

Low

Total trading volume

Dividend payout ratio

2016

2015

2014

2013

2012

(In millions, except per share data)

0.255

13.04

8.95

14.36

14.73

7.00

5,241

$

0.23

$

0.18

$

0.10

$

12.35

8.52

9.60

10.87

8.54

4,243

11.81

8.18

10.56

11.54

8.85

3,689

11.04

7.47

9.89

10.52

7.13

3,962

0.04

10.57

7.05

7.13

7.73

4.21

5,282

29.25%

30.76%

22.80%

13.31%

5.59%

Stockholders of record at year-end (actual)

48,958

51,270

57,529

63,815

67,574

Weighted-average number of common shares outstanding

Basic

Diluted

1,255

1,261

1,325

1,334

1,375

1,387

1,395

1,410

1,381

1,387

________
N/A - not applicable.
(1)  See Table 2 for GAAP to non-GAAP reconciliations.
(2)  Current year Basel III common equity Tier 1, Tier 1 capital, Total capital, and Leverage capital ratios are estimated.
(3)  Regions' regulatory capital ratios for years prior to 2015 have not been revised to reflect the retrospective application of new accounting 

guidance related to investments in qualified affordable housing projects.

(4)  Beginning in 2015, Regions' regulatory capital ratios are calculated pursuant to the phase-in provisions of the Basel III Rules. All prior 

period ratios were calculated pursuant to the Basel I capital rules. 

(5)  High and low market prices are based on intraday sales prices.

NON-GAAP MEASURES

The table below presents computations of earnings and certain other financial measures, which exclude certain significant 
items that are included in the financial results presented in accordance with GAAP. These non-GAAP financial measures include 
"adjusted allowance for loan losses to non-performing loans, excluding loans held for sale ratio", “adjusted fee income ratio”, 
“adjusted efficiency ratio”, “return on average tangible common stockholders’ equity”, average and end of period “tangible common 
stockholders’ equity”, and “Basel III CET1, on a fully phased-in basis” and related ratios. Regions believes that expressing earnings 
and certain other financial measures excluding these significant items provides a meaningful base for period-to-period comparisons, 
which management believes will assist investors in analyzing the operating results of the Company and predicting future performance. 
These  non-GAAP  financial  measures  are  also  used  by  management  to  assess  the  performance  of  Regions’  business  because 
management does not consider the activities related to the adjustments to be indications of ongoing operations. Regions believes 
that presentation of these non-GAAP financial measures will permit investors to assess the performance of the Company on the 
same basis as that applied by management. Management and the Board utilize these non-GAAP financial measures as follows:

• 

Preparation of Regions’ operating budgets

•  Monthly financial performance reporting

•  Monthly close-out reporting of consolidated results (management only)

• 

Presentations to investors of Company performance

The adjusted allowance for loan losses to non-performing loans, excluding loans held for sale ratio (non-GAAP), which is a 
measure of credit quality performance, is generally calculated as adjusted allowance for loan losses divided by adjusted total non-
accrual loans, excluding loans held for sale. Management believes that excluding the portion of the allowance for loan losses related 
to  direct  energy  loans  and  the  direct  energy  non-accrual  loans  will  assist  investors  in  analyzing  the  Company's  credit  quality 
performance absent the volatility that has been experienced by energy businesses. The allowance for loan losses (GAAP) is presented 
excluding the portion of the allowance related to direct energy loans to arrive at the adjusted allowance for loan losses (non-GAAP). 
Total non-accrual loans (GAAP) is presented excluding direct energy non-accrual loans to arrive at adjusted total non-accrual loans, 
excluding loans held for sale (non-GAAP), which is the denominator for the allowance for loan losses to non-accrual loans ratio.

The adjusted efficiency ratio (non-GAAP), which is a measure of productivity, is generally calculated as non-interest expense 
divided by total revenue on a taxable-equivalent basis. The adjusted fee income ratio (non-GAAP) is generally calculated as non-
interest income divided by adjusted total revenue on a taxable-equivalent basis. Management uses these ratios to monitor performance 
and believes these measures provide meaningful information to investors. Non-interest expense (GAAP) is presented excluding 
adjustments to arrive at adjusted non-interest expense (non-GAAP), which is the numerator for the adjusted efficiency ratio. Non-
interest income (GAAP) is presented excluding adjustments to arrive at adjusted non-interest income (non-GAAP), which is the 

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numerator for the adjusted fee income ratio. Net interest income and other financing income on a taxable-equivalent basis and non-
interest income are added together to arrive at total revenue on a taxable-equivalent basis. Adjustments are made to arrive at adjusted 
total revenue on a taxable-equivalent basis (non-GAAP), which is the denominator for the adjusted efficiency and adjusted fee 
income ratios.  

Tangible common stockholders’ equity ratios have become a focus of some investors in analyzing the capital position of the 
Company absent the effects of intangible assets and preferred stock. Traditionally, the Federal Reserve and other banking regulatory 
bodies have assessed a bank’s capital adequacy based on Tier 1 capital, the calculation of which is codified in federal banking 
regulations. Analysts and banking regulators have assessed Regions’ capital adequacy using the tangible common stockholders’ 
equity measure. Because tangible common stockholders’ equity is not formally defined by GAAP, this measure is considered to be 
a non-GAAP financial measure and other entities may calculate it differently than Regions’ disclosed calculations. Since analysts 
and banking regulators may assess Regions’ capital adequacy using tangible common stockholders’ equity, Regions believes that 
it is useful to provide investors the ability to assess Regions’ capital adequacy on this same basis.

The Basel Committee's Basel III framework will strengthen international capital and liquidity regulations. When fully phased 
in, Basel III will increase capital requirements through higher minimum capital levels as well as through increases in risk-weights 
for certain exposures. Additionally, the Basel III rules place greater emphasis on common equity. The Federal Reserve released its 
final Basel III Rules detailing the U.S. implementation of Basel III in 2013. Regions, as a standardized approach bank, began 
transitioning to the Basel III framework in January 2015 subject to a phase-in period extending through January 2019. Because the 
Basel III implementation regulations will not be fully phased in until 2019 and, are not formally defined by GAAP, these measures 
are considered to be non-GAAP financial measures. Since analysts and banking regulators may assess Regions’ capital adequacy 
using the fully phased-in Basel III framework, Regions believes that it is useful to provide investors information enabling them to 
assess Regions’ capital adequacy on the same basis. 

Non-GAAP financial measures have inherent limitations, are not required to be uniformly applied and are not audited. Although 
these non-GAAP financial measures are frequently used by stakeholders in the evaluation of a company, they have limitations as 
analytical tools, and should not be considered in isolation, or as a substitute for analyses of results as reported under GAAP. In 
particular, a measure of earnings that excludes selected items does not represent the amount that effectively accrues directly to 
stockholders.

The following tables provide: 1) a reconciliation of allowance for loan losses (GAAP) to adjusted allowance for loan losses 
(non-GAAP), 2) a reconciliation of non-accrual loans (GAAP) to adjusted non-accrual loans (non-GAAP), 3) a computation of 
adjusted allowance for loan losses to non-performing loans, excluding loans held for sale (non-GAAP), 4) a reconciliation of net 
income  (GAAP)  to  net  income  available  to  common  shareholders  (GAAP),  5)  a  reconciliation  of  non-interest  expense  from 
continuing  operations  (GAAP)  to  adjusted  non-interest  expense  (non-GAAP),  6)  a  reconciliation  of  non-interest  income  from 
continuing operations (GAAP) to adjusted non-interest income (non-GAAP), 7) a computation of adjusted total revenue (non-
GAAP), 8) a computation of the adjusted efficiency ratio (non-GAAP), 9) a computation of the adjusted fee income ratio (non-
GAAP),  10)  a  reconciliation  of  average  and  ending  stockholders’  equity  (GAAP)  to  average  and  ending  tangible  common 
stockholders’ equity (non-GAAP) and calculations of related ratios (non-GAAP), 11) a reconciliation of stockholders’ equity (GAAP) 
to Basel III CET1, on a fully phased-in basis (non-GAAP), and calculation of the related ratio based on Regions’ current understanding 
of the Basel III requirements (non-GAAP). 

Table 2—GAAP to Non-GAAP Reconciliation

ADJUSTED NON-ACCRUAL LOANS AND SELECTED RATIOS

Allowance for loan losses (GAAP)

Less: Direct energy portion
Adjusted allowance for loan losses (non-GAAP)

Total non-accrual loans (GAAP)

Less: Direct energy non-accrual loans

Adjusted total non-accrual loans (non-GAAP)

Year Ended December 31

2016

2015

2014

2013

2012

(Dollars in millions)

A $

1,091

147
944

995

311

684

B $

C $

D $

$

$

$

$

1,106

151
955

782

83

699

$

$

$

$

1,103

28
1,075

829

37

792

$

$

$

$

1,341

15
1,326

1,082

—

1,082

$

$

$

$

1,919

24
1,895

1,681

20

1,661

Allowance for loan losses to non-performing loans, excluding loans
held for sale (GAAP)

Adjusted allowance for loan losses to non-performing loans, excluding
loans held for sale (non-GAAP)

A/C

1.10x

1.41x

1.33x

1.24x

1.14x

B/D

1.38x

1.37x

1.36x

1.23x

1.14x

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Year Ended December 31

2016

2015

2014

2013

2012

(Dollars in millions, except per share data)

INCOME

Net income (GAAP)

Preferred dividends and accretion (GAAP)

Net income available to common shareholders (GAAP)

ADJUSTED FEE INCOME AND EFFICIENCY RATIOS

$

1,163

(64)

E $

1,099

Non-interest expense from continuing operations (GAAP)

F $

3,617

$

$

$

1,062

(64)

998

3,607

Significant items:

Professional, legal and regulatory expenses (1)(2)
Branch consolidation, property and equipment charges

Securities impairment, net

Loss on early extinguishment of debt

Salary and employee benefits—severance charges

Gain on sale of TDRs held for sale, net
REIT investment early termination costs (3)

Adjusted non-interest expense (non-GAAP)

Net interest income and other financing income (GAAP)

Taxable-equivalent adjustment

Net interest income and other financing income, taxable-
equivalent basis

Non-interest income from continuing operations (GAAP)

Significant items:

Securities gains, net
Insurance proceeds (4)
Leveraged lease termination gains, net

Gain on sale of affordable housing residential mortgage 
loans (5)
Gain on sale of other assets (6)

(3)

(58)

—

(14)

(21)

—

—

G $

3,521

$

3,398

$

$

84

3,482

2,153

H

I

(6)

(50)

(8)

(5)

—

Adjusted non-interest income (non-GAAP)

Total revenue, taxable-equivalent basis

J

2,084

H+I=K $

5,635

Adjusted total revenue, taxable-equivalent basis (non-GAAP)

H+J=L $

5,566

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

1,147

(52)

1,095

3,432

(93)

(16)

—

—

—

35

—

3,358

3,280

63

3,343

1,903

(27)

—

(10)

—

—

1,866

5,246

5,209

65.42%

64.45%

36.28%

35.83%

$

$

$

$

$

$

$

1,091

(32)

1,059

3,556

(58)

(5)

—

(61)

—

—

—

3,432

3,263

54

3,317

2,096

(26)

—

(39)

—

(24)

2,007

5,413

5,324

65.69%

64.46%

38.72%

37.70%

1,121

(129)

992

3,526

—

—

(2)

(11)

—

—

(42)

3,471

3,301

50

3,351

2,201

(48)

—

(14)

—

—

2,139

5,552

5,490

63.50%

63.21%

39.65%

38.97%

(48)

(56)

—

(43)

(6)

—

—

3,454

3,307

75

3,382

2,071

(29)

(91)

(8)

—

—

1,943

5,453

5,325

66.15%

64.87%

37.98%

36.50%

F/K

G/L

I/K

J/L

64.20%

63.28%

38.21%

37.45%

Efficiency ratio (GAAP)

Adjusted efficiency ratio (non-GAAP)

Fee income ratio (GAAP)

Adjusted fee income ratio (non-GAAP)

RETURN ON AVERAGE TANGIBLE COMMON
STOCKHOLDERS’ EQUITY

Average stockholders’ equity (GAAP)

Less:     Average intangible assets (GAAP)

Average deferred tax liability related to
intangibles (GAAP)

Average preferred stock (GAAP)

$ 17,126

$ 16,916

$ 16,620

$ 15,411

$ 15,168

5,125

5,099

5,103

5,136

5,210

(162)

820

(170)

848

(182)

754

(188)

464

(195)

960

Average tangible common stockholders’ equity (non-GAAP)

M $ 11,343

$ 11,139

$ 10,945

$

9,999

$

9,193

Return on average tangible common stockholders’ equity (non-
GAAP)

E/M

9.69%

8.96%

10.00%

10.59%

10.79%

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TANGIBLE COMMON RATIOS-CONSOLIDATED

Ending stockholders’ equity (GAAP)

Less: Ending intangible assets (GAAP)

  Ending deferred tax liability related to intangibles (GAAP)

  Ending preferred stock (GAAP)

Year Ended December 31

2016

2015

2014

2013

2012

(Dollars in millions, except share data)

$ 16,664

$ 16,844

$ 16,873

$ 15,660

$ 15,422

5,125

(155)

820

5,137

(165)

820

5,091

(172)

884

5,111

(188)

450

5,161

(191)

482

Ending tangible common stockholders’ equity (non-GAAP)

N $ 10,874

$ 11,052

$ 11,070

$ 10,287

$

9,970

Ending total assets (GAAP)

Less: Ending intangible assets (GAAP)

  Ending deferred tax liability related to intangibles (GAAP)

Ending tangible assets (non-GAAP)

End of period shares outstanding

$125,968

$126,050

$119,563

$117,288

$121,270

5,125

(155)

5,137

(165)

5,091

(172)

5,111

(188)

5,161

(191)

O $120,998

$121,078

$114,644

$112,365

$116,300

P

1,215

1,297

1,354

1,378

1,431

Tangible common stockholders’ equity to tangible assets (non-
GAAP)

N/O

8.99%

9.13%

9.66%

9.15%

8.57%

Tangible common book value per share (non-GAAP)

N/P $

8.95

$

8.52

$

8.18

$

7.47

$

7.05

BASEL III COMMON EQUITY TIER 1 RATIO—FULLY 
PHASED-IN PRO-FORMA (7)
Stockholders’ equity (GAAP)

Non-qualifying goodwill and intangibles

Adjustments, including all components of accumulated other
comprehensive income, disallowed deferred tax assets, threshold
deductions and other adjustments

Preferred stock (GAAP)

$ 16,664

$ 16,844

(4,955)

(4,958)

489

(820)

286

(820)

Basel III common equity Tier 1—Fully Phased-In Pro-Forma 
(non-GAAP)

Basel III risk-weighted assets—Fully Phased-In Pro-Forma 
(non-GAAP)(8)
Basel III common equity Tier 1—Fully Phased-In Pro-Forma ratio 
(non-GAAP)

Q $ 11,378

$ 11,352

R $102,975

$106,188

Q/R

11.05%

10.69%

 _________
(1)  Regions recorded $3 million, $50 million and $100 million of contingent legal and regulatory accruals during the second quarter of 2016, 
the second quarter of 2015 and the fourth quarter of 2014, respectively, related to previously disclosed matters. The fourth quarter of 2014 
accruals were settled in the second quarter of 2015 for $2 million less than originally estimated and a corresponding recovery was recognized.
(2)   In the fourth quarter of 2013, Regions recorded a non-tax deductible charge of $58 million related to previously disclosed inquiries from 
government authorities concerning matters from 2009. The 2013 matters were settled in the second quarter of 2014 for $7 million less than 
originally estimated and a corresponding recovery was recognized. 

(3)   In the fourth quarter of 2012, Regions entered into an agreement with a third party investor in Regions Asset Management Company, Inc.,   

pursuant to which the investment was fully redeemed. This resulted in extinguishing a $203 million liability, including accrued, unpaid 
interest, as well as incurring early termination costs of approximately $42 million on a pre-tax basis ($38 million after tax).

(4)   Insurance proceeds recognized in the third quarter of 2016 are related to the previously disclosed settlement with the Department of Housing 
and Urban Development. Insurance proceeds recognized in 2015 are related to the settlement of the previously disclosed 2010 class-action 
lawsuit. 

(5)  Gain on sale of affordable housing residential mortgage loans in the fourth quarter of 2016 was due to the decision to sell approximately 
$171 million of loans to Freddie Mac. Approximately $91 million were sold with recourse, resulting in a deferred gain of $5 million, which 
will be evaluated when the recourse expires during the second quarter of 2017.

(6)   In the third quarter of 2013, Regions recorded a $24 million gain on sale of a non-core portion of a Wealth Management business.
(7)   The 2016 amounts and the resulting ratio are estimated. Regulatory capital measures for periods prior to 2015 were not revised to reflect  the 
retrospective  application  of  new  accounting  guidance  related  to  investments  in  qualified  affordable  housing  projects. As  a  result,  those 
calculations are not included in the table.

(8)   Regions continues to develop systems and internal controls to precisely calculate risk-weighted assets as required by Basel III on a fully 

phased-in basis. The amounts included above are a reasonable approximation, based on our understanding of the requirements.

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CRITICAL ACCOUNTING ESTIMATES AND RELATED POLICIES

In preparing financial information, management is required to make significant estimates and assumptions that affect the 
reported amounts of assets, liabilities, income and expenses for the periods shown. The accounting principles followed by Regions 
and the methods of applying these principles conform with GAAP and general banking practices. Estimates and assumptions most 
significant to Regions are related primarily to the allowance for credit losses, fair value measurements, intangible assets (goodwill 
and other identifiable intangible assets), residential MSRs and income taxes, and are summarized in the following discussion and 
in the notes to the consolidated financial statements.

Allowance for Credit Losses

The allowance for credit losses (“allowance”) consists of two components: the allowance for loan losses and the reserve for 
unfunded credit commitments. Unfunded credit commitments include items such as letters of credit, financial guarantees and 
binding unfunded loan commitments. The allowance represents management’s estimate of probable credit losses inherent in the 
loan and credit commitment portfolios as of period end. Regions determines its allowance in accordance with GAAP and applicable 
regulatory guidance.

For non-accrual commercial and investor real estate loans equal to or greater than $2.5 million, the allowance for loan losses 
is based on note-level evaluation considering the facts and circumstances specific to each borrower. For all other commercial and 
investor real estate loans, the allowance for loan losses is based on statistical models using a PD and an LGD. Historical default 
information for similar loans is used as an input for the statistical model.

For residential first mortgages, home equity lending and other consumer-related loans, individual products are reviewed on 
a group basis (e.g., residential first mortgage pools). Historical loss information for similar loans is used as an input for the models.

Factors considered by management in determining the adequacy of the allowance include, but are not limited to: 1) detailed 
reviews of individual loans; 2) historical and current trends in gross and net loan charge-offs for the various classes of loans 
evaluated; 3) the Company’s policies relating to delinquent loans and charge-offs; 4) the level of the allowance in relation to total 
loans and to historical loss levels; 5) levels and trends in non-performing, criticized, classified and past due loans; 6) collateral 
values  of  properties  securing  loans;  7) the  composition  of  the  loan  portfolio,  including  unfunded  credit  commitments; 
8) management’s analysis of current economic conditions; and 9) migration of loans between risk rating categories.

In  support  of  collateral  values,  Regions  obtains  updated  valuations  for  large  commercial  and  investor  real  estate  non-
performing loans on at least an annual basis. For loans that are individually identified for impairment, those valuations are currently 
discounted as appropriate from the most recent appraisal to consider continued declines in values. The discounted valuations are 
utilized in the measurement of the level of impairment in the allowance calculation. For loans that are not individually identified 
for impairment and secured by collateral, Regions considers the impact of declines in valuations in the loss given default estimates 
within the allowance calculation.

The  allowance  is  sensitive  to  a  variety  of  internal  factors,  such  as  modifications  in  the  mix  and  level  of  loan  balances 
outstanding, portfolio performance and assigned risk ratings. As a matter of business practice, Regions may require some form of 
credit support, such as a guarantee. Guarantees are legally binding and entered into simultaneously with the primary loan agreements. 
Evaluation of guarantors’ ability and willingness to pay is considered as part of the risk rating process, which provides the basis 
for  the  allowance  for  loan  losses  for  the  commercial  and  investor  real  estate  portfolios.  In  concluding  that  the  risk  rating  is 
appropriate, Regions considers a number of factors including whether underlying cash flow is adequate to service the debt, payment 
history, and whether there is appropriate guarantor support. Accordingly, Regions has concluded that the impact of credit support 
provided by guarantors has been appropriately considered in the calculation and assessment of the allowance for loan losses.

The allowance is also sensitive to a variety of external factors, such as the general health of the economy, as evidenced by 
volatility in commodity prices, changes in real estate demand and values, interest rates, unemployment rates, bankruptcy filings, 
fluctuations in the GDP, and the effects of weather and natural disasters such as droughts, floods and hurricanes. 

Management considers these variables and all other available information when establishing the final level of the allowance. 

These variables and others have the ability to result in actual loan losses that differ from the originally estimated amounts.

Management  considers  the  current  level  of  the  allowance  appropriate  to  absorb  losses  inherent  in  the  loan  and  credit 
commitment portfolios. Management’s determination of the appropriateness of the allowance requires the use of judgments and 
estimations that may change in the future. Changes in the factors used by management to determine the appropriateness of the 
allowance or the availability of new information could cause the allowance to be increased or decreased in future periods. In 
addition, bank regulatory agencies, as part of their examination process, may require changes in the level of the allowance based 
on their judgments and estimates. Given the current phase of the credit cycle, volatility in certain credit metrics is to be expected. 
Additionally, changes in circumstances related to individually large credits or certain portfolios may result in volatility. 

Management’s estimate of the allowance for the commercial and investor real estate portfolio segments could be affected 
by estimates of losses inherent in various product types as a result of fluctuations in the internal and external factors mentioned 
above. For pooled commercial and investor real estate accounts, a 5 percent increase in the PD for non-defaulted accounts and a 
5 percent increase in the LGD for all accounts would result in an increase to estimated inherent losses of approximately $55 million.

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Losses on residential real estate mortgages, home equity lending and other consumer-related loans can be affected by such 
factors as collateral value, loss severity, and other internal and external factors mentioned above. A 5 percent increase or decrease 
in the estimated loss rates on these loans would change estimated inherent losses by approximately $11 million.

These pro forma analyses demonstrate the sensitivity of the allowance to key assumptions; however, they do not reflect an 

expected outcome. 

For further discussion of the allowance for credit losses, see Note 1 “Summary of Significant Accounting Policies” and Note 

6 “Allowance for Credit Losses” to the consolidated financial statements.

Fair Value Measurements

A portion of the Company’s assets and liabilities is carried at fair value, with changes in fair value recorded either in earnings 
or accumulated other comprehensive income (loss). These include trading account securities, securities available for sale, mortgage 
loans held for sale, residential MSRs and derivative assets and liabilities. From time to time, the estimation of fair value also affects 
other loans held for sale, which are recorded at the lower of cost or fair value. Fair value determination is also relevant for certain 
other assets such as foreclosed property and other real estate, which are recorded at the lower of the recorded investment in the 
loan/property or fair value, less estimated costs to sell the property. For example, the fair value of other real estate is determined 
based on recent appraisals by third parties and other market information, less estimated selling costs. Adjustments to the appraised 
value are made if management becomes aware of changes in the fair value of specific properties or property types. The determination 
of fair value also impacts certain other assets that are periodically evaluated for impairment using fair value estimates, including 
goodwill and other identifiable intangible assets.

Fair value is generally defined as the price that would be received to sell an asset or paid to transfer a liability (an exit price) 
as opposed to the price that would be paid to acquire the asset or received to assume the liability (an entry price), in an orderly 
transaction  between  market  participants  at  the  measurement  date  under  current  market  conditions.  While  management  uses 
judgment when determining the price at which willing market participants would transact when there has been a significant decrease 
in the volume or level of activity for the asset or liability in relation to “normal” market activity, management’s objective is to 
determine the point within the range of fair value estimates that is most representative of a sale to a third-party investor under 
current market conditions. The value to the Company if the asset or liability were held to maturity is not included in the fair value 
estimates.

A  fair  value  measure  should  reflect  the  assumptions  that  market  participants  would  use  in  pricing  the  asset  or  liability, 
including the assumptions about the risk inherent in a particular valuation technique, the effect of a restriction on the sale or use 
of an asset and the risk of nonperformance. Fair value is measured based on a variety of inputs the Company utilizes. Fair value 
may be based on quoted market prices for identical assets or liabilities traded in active markets (Level 1 valuations). If market 
prices are not available, quoted market prices for similar instruments traded 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 are used (Level 2 valuations). Where observable market data is not available, the valuation is generated from model-
based techniques that use significant assumptions not observable in the market, but observable based on Company-specific data 
(Level 3 valuations). These unobservable assumptions reflect the Company’s own estimates for assumptions that market participants 
would use in pricing the asset or liability. Valuation techniques typically include option pricing models, discounted cash flow 
models and similar techniques, but may also include the use of market prices of assets or liabilities that are not directly comparable 
to the subject asset or liability.

See Note 1 “Summary of Significant Accounting Policies” to the consolidated financial statements for a detailed discussion 

of determining fair value, including pricing validation processes.

Intangible Assets 

Regions’ intangible assets consist primarily of the excess of cost over the fair value of net assets of acquired businesses 
(“goodwill”) and other identifiable intangible assets (primarily core deposit intangibles and purchased credit card relationships). 
Goodwill totaled $4.9 billion at both December 31, 2016 and 2015, respectively, and is allocated to each of Regions’ reportable 
segments (each a reporting unit: Corporate Bank, Consumer Bank, and Wealth Management). Refer to Note 23 “Business Segment 
Information” to the consolidated financial statements for discussion of Regions' reorganization of its management reporting structure 
during the first quarter of 2016 and, accordingly, its segment reporting structure and goodwill reporting units. In connection with 
the reorganization, management reallocated goodwill to the new reporting units using a relative fair value approach. Goodwill is 
tested for impairment on an annual basis as of October 1 or more often if events and circumstances indicate impairment may exist 
(refer to Note 1 “Summary of Significant Accounting Policies” to the consolidated financial statements for further discussion). 

A test of goodwill for impairment consists of two steps. In Step One, the fair value of the reporting unit is compared to its 
carrying amount, including goodwill. To the extent that the estimated fair value of the reporting unit exceeds the carrying value, 
impairment is not indicated and no further testing is required. Conversely, if the estimated fair value of the reporting unit is below 
its carrying amount, Step Two must be performed. Step Two consists of determining the implied estimated fair value of goodwill, 
which  is  the  net  difference  between  the  valuation  adjustments  of  assets  and  liabilities  excluding  goodwill  and  the  valuation 

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Table of Contents 

adjustment to equity (from Step One) of the reporting unit. The carrying value of equity for each reporting unit is determined from 
an allocation based upon risk weighted assets. Adverse changes in the economic environment, declining operations of the reporting 
unit, or other factors could result in a decline in the estimated implied fair value of goodwill. If the estimated implied fair value 
of goodwill is less than the carrying amount, a loss would be recognized to reduce the carrying amount to the estimated implied 
fair value.

The estimated fair value of the reporting unit is determined using a blend of both income and market approaches. Within the 
income approach, which is the primary valuation approach, Regions utilizes the CAPM in order to derive the base discount rate. 
The inputs to the CAPM include the 20-year risk-free rate, 5-year beta for a select peer set specific to each reporting unit, and a 
market risk premium, all based on published data. To determine the estimated cost of equity for each reporting unit, a size premium 
is added (also based on a published source) as well as a company-specific risk premium for each reporting unit, which is an estimate 
determined  by  the  Company  and  meant  to  compensate  for  the  risk  inherent  in  the  future  cash  flow  projections  and  inherent 
differences (such  as business  model and market perception of  risk) between Regions  and the peer set. Regions  evaluates the 
appropriateness of the inputs to the CAPM at each test date. Company specific factors considered during recent evaluation periods 
include positive results of operations, stable asset quality and strong capital and liquidity positions.

In estimating future cash flows, a balance sheet as of the test date and statements of income for the last twelve months of 
activity for each reporting unit is compiled. From that point, future balance sheets and statements of income are projected based 
on the inputs. Cash flows are based on expected future capitalization requirements due to balance sheet growth and anticipated 
changes in regulatory capital requirements. The baseline cash flows utilized in all models correspond to recent internal forecasts 
and/or budgets. These internal forecasts range from 1 to 3 years and are based on inputs developed in the Company’s internal 
strategic planning processes.

Regions uses the GCM and the GTM as its market approaches. The GCM applies a value multiplier derived from each 
reporting unit’s peer group to a financial metric and an implied control premium to the respective reporting units. The control 
premium is evaluated and compared to similar financial services transactions considering the absolute and relative potential revenue 
synergies and cost savings. The GTM applies a value multiplier to a financial metric of the reporting unit based on comparable 
observed purchase transactions in the financial services industry for the reporting unit.

Refer to Note 10 “Intangible Assets” to the consolidated financial statements for further discussion of these approaches and 
related assumptions. The fair values of assets and liabilities in Step Two, if applicable, are determined using an exit price concept. 
Refer to the discussion of fair value in Note 1 “Summary of Significant Accounting Policies” to the consolidated financial statements 
for discussions of the exit price concept and the determination of fair values of financial assets and liabilities.

 The results of the calculations for the fourth quarter of 2016 indicated that the estimated fair values of the Corporate Bank, 
Consumer Bank and Wealth Management reporting units were $10.2 billion, $9.3 billion and $1.7 billion, respectively, which were 
greater than their carrying amounts of $9.2 billion, $6.2 billion and $1.1 billion, respectively. Therefore, the goodwill of each 
reporting unit was considered not impaired as of the testing date, and Step Two of the goodwill impairment test was not required. 
Refer to Note 10 “Intangible Assets” to the consolidated financial statements for the key assumptions used in estimating the fair 
value of each reporting unit as of fourth quarter 2016 and fourth quarter 2015.

The table below summarizes the discount rate used in the goodwill impairment test of each reporting unit for the fourth 

quarter of 2016, first quarter of 2016 and the fourth quarter of 2015:

Discount Rate:
Fourth quarter 2016 (1)
First quarter 2016 (1)
Fourth quarter 2015

Corporate 
Bank

Consumer
Bank

Wealth
Management

10.00%
11.00%
11.00%

10.25%
11.25%
11.00%

11.50%
12.00%
12.00%

_______  
(1)  The discount rates decreased in the fourth quarter 2016 goodwill test as compared to the first quarter 2016 goodwill test due primarily to a 

decline in the risk-free rate.

Specific factors as of the date of filing the financial statements that could negatively impact the assumptions used in assessing 
goodwill for impairment include: a protracted decline in the Company’s market capitalization; disparities in the level of fair value 
changes in net assets (especially loans) compared to equity; increases in book values of equity of a reporting unit in excess of the 
increase in fair value of equity; adverse business trends resulting from litigation and/or regulatory actions; higher loan losses; 
lengthened  forecasts  of  high  unemployment  levels;  future  increased  minimum  regulatory  capital  requirements  above  current 
thresholds (refer to Note 14 “Regulatory Capital Requirements and Restrictions” to the consolidated financial statements for a 
discussion of current minimum regulatory requirements); future federal rules and regulations (e.g., such as those resulting from 
the Dodd-Frank Act); and/or a protraction in the current low level of interest rates significantly beyond 2017.

For sensitivity analysis, a discount rate of 11.00 percent for the Corporate Bank, 11.25 percent for the Consumer Bank 
reporting units and 12.50 percent for the Wealth Management reporting unit would result in estimated fair values of equity of $9.2 

49

Table of Contents 

billion, $8.3 billion, and $1.6 billion, respectively. All three reporting units' estimated fair value would continue to exceed the book 
value by approximately $13 million, $2.1 billion, and $468 million, respectively, and would not require Step Two procedures. This 
assumes all other assumptions would remain unchanged in the fourth quarter of 2016 calculation.

If the prior year inputs for GCM and GTM had remained the same for the fourth quarter of 2016, the estimated fair value 
would  continue  to  exceed  book  value  for  the  Corporate  Bank,  Consumer  Bank,  and Wealth  Management  reporting  units  by 
approximately  $1.6  billion,  $2.7  billion,  and  $668  million,  respectively.  This  assumes  all  other  assumptions  would  remain 
unchanged in the fourth quarter of 2016 calculation.

Sensitivity calculations are hypothetical and should not be considered to be predictive of future performance. Changes in 
implied fair value based on adverse changes in assumptions generally cannot be extrapolated because the relationship of the change 
in assumption to the change in fair value may not be linear. Also, the effect of an adverse variation in a particular assumption on 
the implied fair value of goodwill is calculated without changing any other assumption, while in reality changes in one factor may 
result in changes in another which may either magnify or counteract the effect of the change.

Other material identifiable intangible assets, primarily core deposit intangibles and purchased credit card relationships, are 
reviewed at least annually (usually in the fourth quarter) for events or circumstances which could impact the recoverability of the 
intangible  asset. These  events  could  include  loss  of  core  deposits,  significant  losses  of  credit  card  accounts  and/or  balances, 
increased  competition  or  adverse  changes  in  the  economy.  To  the  extent  an  other  identifiable  intangible  asset  is  deemed 
unrecoverable, an impairment loss would be recorded to reduce the carrying amount. These events or circumstances, if they occur, 
could be material to Regions’ operating results for any particular reporting period but the potential impact cannot be reasonably 
estimated.

Residential Mortgage Servicing Rights

Regions has elected to measure and report its residential MSRs using the fair value method. Although sales of residential 
MSRs do occur, residential MSRs do not trade in an active market with readily observable market prices and the exact terms and 
conditions of sales may not be readily available, and are therefore Level 3 valuations in the fair value hierarchy previously discussed 
in the “Fair Value Measurements” section. Specific characteristics of the underlying loans greatly impact the estimated value of 
the related residential MSRs. As a result, Regions stratifies its residential mortgage servicing portfolio on the basis of certain risk 
characteristics, including loan type and contractual note rate, and values its residential MSRs using discounted cash flow modeling 
techniques.  These  techniques  require  management  to  make  estimates  regarding  future  net  servicing  cash  flows,  taking  into 
consideration historical and forecasted residential mortgage loan prepayment rates, discount rates, escrow balances and servicing 
costs. Changes in interest rates, prepayment speeds or other factors impact the fair value of residential MSRs which impacts 
earnings. The carrying value of residential MSRs was $324 million at December 31, 2016. Based on a hypothetical sensitivity 
analysis, Regions estimates that a reduction in primary mortgage market rates of 25 basis points and 50 basis points would reduce 
the December 31, 2016 fair value of residential MSRs by approximately 4 percent ($13 million) and 9 percent ($28 million), 
respectively. Conversely, 25 basis point and 50 basis point increases in these rates would increase the December 31, 2016 fair 
value of residential MSRs by approximately 4 percent ($11 million) and 7 percent ($21 million), respectively. Regions also estimates 
that an increase in servicing costs of approximately $10 per loan, or 12 percent, would result in a decline in the value of the 
residential MSRs by approximately $12 million.

The pro forma fair value analysis presented above demonstrates the sensitivity of fair values to hypothetical changes in 
primary mortgage rates. This sensitivity analysis does not reflect an expected outcome. Refer to the “Residential Mortgage Servicing 
Rights” discussion in the “Balance Sheet” analysis section found later in this report.

Income Taxes

Accrued income taxes are reported as a component of either other assets or other liabilities, as appropriate, in the consolidated 

balance sheets and reflect management’s estimate of income taxes to be paid or received.

Deferred income taxes represent the amount of future income taxes to be paid or received and are accounted for using the 
asset and liability method. The net balance is reported as a component of either other assets or other liabilities, as appropriate, in 
the consolidated balance sheets. The Company determines the realization of the deferred tax asset based upon an evaluation of the 
four possible sources of taxable income: 1) the future reversals of taxable temporary differences; 2) future taxable income exclusive 
of reversing temporary differences and carryforwards; 3) taxable income in prior carryback years; and 4) tax-planning strategies. 
In projecting future taxable income, the Company utilizes forecasted pre-tax earnings, adjusts for the estimated book-tax differences 
and  incorporates  assumptions,  including  the  amounts  of  income  allocable  to  taxing  jurisdictions.  These  assumptions  require 
significant judgment and are consistent with the plans and estimates the Company uses to manage the underlying businesses. The 
realization of the deferred tax assets could be reduced in the future if these estimates are significantly different than forecasted. 
For a detailed discussion of realization of deferred tax assets, refer to the “Income Taxes” section found later in this report.

The Company is subject to income tax in the U.S. and multiple state and local jurisdictions. The tax laws and regulations in 
each jurisdiction may be interpreted differently in certain situations, which could result in a range of outcomes. Thus, the Company 
is required to exercise judgment regarding the application of these tax laws and regulations. The Company will evaluate and 

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Table of Contents 

recognize tax liabilities related to any tax uncertainties. Due to the complexity of some of these uncertainties, the ultimate resolution 
may result in a payment that is different from the current estimate of the tax liabilities.

The Company’s estimate of accrued income taxes, deferred income taxes and income tax expense can also change in any 
period as a result of new legislative or judicial guidance impacting tax positions, as well as changes in income tax rates. Any 
changes, if they occur, can be significant to the Company’s consolidated financial position, results of operations or cash flows.

OPERATING RESULTS

NET INTEREST INCOME AND OTHER FINANCING INCOME AND NET INTEREST MARGIN 

Net interest income and other financing income is Regions’ principal source of income and is one of the most important 
elements of Regions’ ability to meet its overall performance goals. Net interest income and other financing income (taxable-
equivalent basis) increased approximately $100 million, or 3 percent in 2016 from 2015, driven primarily by higher short-term 
interest rates, average loan growth, higher securities balances and balance sheet management strategies. The net interest margin 
increased to 3.14 percent in 2016 from 3.13 percent in 2015, due to an increase in yields on earning assets exceeding the slight 
increase in total funding costs during 2016.

Comparing 2016 to 2015, average earning asset yields were higher, increasing 3 basis points. Also, interest-bearing liability 
rates were higher, increasing by 5 basis points. As a result, the net interest rate spread decreased 2 basis points to 2.97 percent in 
2016 compared to 2.99 percent in 2015.

Market volatility driven by domestic as well as global events led to continued accommodative monetary policies from the 
Federal Reserve and global central banks for the majority of 2016. These dynamics, along with the modest pace of the economic 
recovery, resulted in continued low levels of both short and long-term interest rates in 2016, both of which have influence on net 
interest margin and net interest income and other financing income. Long-term interest rates are generally represented by the yield 
on the benchmark 10-year U.S. Treasury note. The 10-year U.S. Treasury note was 2.24 percent at the beginning of 2016 and 
ended the year at 2.45 percent. However, the previously mentioned global events led to new all-time low long-term rates as the 
10-year U.S. Treasury declined to 1.36 percent on July 8, 2016. The average yield on the benchmark 10-year U.S. Treasury note 
decreased to 1.84 percent in 2016, as compared to 2.14 percent in 2015.  As market rates stayed low, earning asset yields on fixed-
rate loans and securities remained under pressure. One way in which long-term interest rates affect asset yields is through their 
influence on prepayment activity. Low levels of long-term interest rates generate higher levels of prepayments, particularly within 
fixed-rate loan and securities portfolios, which has resulted in the replacement of these assets at lower rates of interest. As a result 
of lower interest rates, lower reinvestment yields and prepayments, the taxable investment securities portfolio, which contains 
significant residential fixed-rate exposure, decreased in yield to 2.28 percent in 2016 from 2.34 percent in 2015. The Company's 
loan pricing is also influenced by short-term interest rates such as the 30-day LIBOR. As the Federal Reserve modestly increased 
short term interest rates in December 2015, 30-day LIBOR averaged 50 basis points in 2016, compared to 20 basis points in 2015, 
leading to modestly higher loan yields.

Deposit costs remained low throughout 2016 given the continuation of historically low interest rates. Short-term interest 
rates such as the Federal Reserve's Rate of Interest on Excess Reserves and the Prime rate most directly influence deposit costs. 
These rates remained relatively low throughout 2016, even with the 0.25 percent rate increases during the fourth quarters of both 
2015 and 2016. Deposit costs, therefore, remained at a low level of 12 basis points for 2016 compared to 11 basis points for 2015.  
Average long-term borrowings increased to $8.2 billion in 2016 as compared to $5.0 billion in 2015, but the cost on these borrowings 
decreased 76 basis points as the mix transitioned from long-term debt securities to shorter-term FHLB advances. See the "Long-
Term Borrowings" section in Management's Discussion and Analysis and Note 13 "Long-Term Borrowings" to the consolidated 
financial statements for additional information.

See also the "Market Risk-Interest Rate Risk" section in Management's Discussion and Analysis for additional information.

Management expects net interest income and other financing income to increase in the range of 2 percent to 4 percent in 
2017, commensurate with average loan and deposit growth in the low single digits. The range assumes an interest rate scenario 
equal to the market forward interest rates as of November 10, 2016, which equates to an average Fed Funds rate of 81 basis points 
and an average 10-year U.S. Treasury rate of 2.26 percent for 2017. The higher end of the range assumes that the post-election 
interest rate environment holds, and pressure on deposit costs remains relatively low. Conversely, the lower end of the range 
assumes a lower interest rate environment, similar to pre-election levels, or an environment where deposit costs are more reactive.

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Table of Contents 

Table 3 “Consolidated Average Daily Balances and Yield/Rate Analysis for Continuing Operations” presents a detail of net 

interest income and other financing income (on a taxable-equivalent basis), the net interest margin, and the net interest spread.

Table 3—Consolidated Average Daily Balances and Yield/Rate Analysis for Continuing Operations 

Year Ended December 31

Average
Balance

2016

Income/
Expense

Yield/
Rate

Average
Balance

2015

Income/
Expense

Yield/
Rate

Average
Balance

2014

Income/
Expense

Yield/
Rate

(Dollars in millions; yields on taxable-equivalent basis)

Assets

Earning assets:

Federal funds sold and securities
purchased under agreements to
resell

$

4

$

Trading account securities

121

Total earning assets

111,012

3,795

Securities:

Taxable

Tax-exempt

Loans held for sale

Loans, net of unearned
 income (1)(2)(3)

Investment in operating leases, 
net (3)

Other earning assets

Allowance for loan losses

Cash and due from banks

Other non-earning assets

Liabilities and Stockholders’ Equity

Interest-bearing liabilities:

Savings

Interest-bearing checking

Money market

Time deposits

Total interest-bearing 
deposits (4)

Federal funds purchased and
securities sold under agreements
to repurchase

Other short-term borrowings

Long-term borrowings

Total interest-bearing
liabilities

Non-interest-bearing 
deposits (4)

Total funding sources

Net interest spread

Other liabilities

Stockholders’ equity

Net interest income and other 
financing income/margin on a 
taxable-equivalent basis from 
continuing operations (5)

24,830

1

479

81,333

3,150

775

3,469

22

36

(1,139)

1,824

13,809

$ 125,506

$

7,719

20,507

26,909

7,415

11

20

31

55

62,550

117

—

—

196

313

—

313

—

3

8,159

70,712

35,371

106,083

2,299

17,124

$ 125,506

3.73

2.28

—

3.33

3.86

2.85

1.05

3.41

0.14

0.10

0.11

0.75

0.19

—

—

2.38

0.44

—

0.29

2.97

—

5

566

—

16

—% $

9

$

117

24,130

1

442

—

5

564

—

16

—% $

4.49

2.34

—

3.65

$

12

107

23,637

3

564

—

3

584

—

22

79,634

3,017

3.79

76,253

3,004

214

3,324

5

43

107,871

3,650

2.60

1.28

3.38

—

3,521

—

39

104,097

3,652

(1,106)

1,702

13,798

$ 122,265

$

7,119

21,324

26,573

8,167

(1,235)

1,793

13,697

$118,352

9

18

28

54

0.13

0.08

0.10

0.66

$

6,596

20,804

26,006

9,003

8

19

29

49

63,183

109

0.17

62,409

105

588

338

5,046

69,155

33,707

102,862

2,481

16,922

$ 122,265

—

1

158

268

—

268

—

0.20

3.14

1,944

55

4,057

0.39

68,465

—

0.26

2.99

31,072

99,537

2,206

16,609

$118,352

2

—

202

309

—

309

—%

2.92

2.47

—

3.89

3.94

—

1.11

3.51

0.12

0.09

0.11

0.55

0.17

0.08

—

4.98

0.45

—

0.31

3.06

$

3,482

3.14%

$

3,382

3.13%

$ 3,343

3.21%

52

 
 
 
 
Table of Contents 

_______  
(1)  Loans, net of unearned income include non-accrual loans for all periods presented.
(2)  Interest income includes net loan fees of $33 million, $58 million and $78 million for the years ended December 31, 2016, 2015 and 2014, 

respectively.

(3)  During the fourth quarter of 2015, Regions corrected the accounting for approximately $214 million of year-to-date average balances of 
leases, for which Regions is the lessor. These leases had been previously classified as capital leases but were subsequently determined to 
be operating leases.

(4)  Total deposit costs may be calculated by dividing total interest expense on deposits by the sum of interest-bearing deposits and non-interest-
bearing deposits. The rates for total deposit costs equal 0.12%, 0.11% and 0.11% for the years ended December 31, 2016, 2015 and 2014, 
respectively.

(5)  The computation of taxable-equivalent net interest income and other financing income is based on the statutory federal income tax rate of 

35%, adjusted for applicable state income taxes net of the related federal tax benefit.

Table 4—Volume and Yield/Rate Variances from Continuing Operations

Table 4 “Volume and Yield/Rate Variances from Continuing Operations” provides additional information with which to 

analyze the changes in net interest income and other financing income.

Interest income including other
financing income on:
Trading account securities

Securities-taxable

Loans held for sale

Loans, including fees

Investment in operating leases, net

Other earning assets

Total earning assets
Interest expense on:

Savings

Interest-bearing checking

Money market

Time deposits

Total interest-bearing deposits

Federal funds purchased and securities
sold under agreements to repurchase

Other short-term borrowings

Long-term borrowings

Total interest-bearing liabilities
Increase (decrease) in net interest income
and other financing income

2016 Compared to 2015

Change Due to

2015 Compared to 2014

Change Due to

Volume

Yield/
Rate

Net

Volume

(Taxable-equivalent basis—in millions)

Yield/
Rate

Net

$

— $

16

1

65

16

2

100

1

(1)

—

(5)

(5)

—

—

81

76

— $
(14)
(1)
68

1
(9)
45

1

3

3

6

13

—
(1)
(43)
(31)

— $

— $

2

—

133

17
(7)
145

2

2

3

1

8

—
(1)
38

45

12
(4)
130

5
(2)
141

1

—

1
(5)
(3)

(1)
—

42

38

$

2
(32)
(2)
(117)
—

6
(143)

—
(1)
(2)
10

7

(1)
1
(86)
(79)

$

24

$

76

$

100

$

103

$

(64) $

2
(20)
(6)
13

5

4
(2)

1
(1)
(1)
5

4

(2)
1
(44)
(41)

39

______  
Notes:
• 

• 

The change in interest not due solely to volume or yield/rate has been allocated to the volume column and yield/rate column in proportion 
to the relationship of the absolute dollar amounts of the change in each.
The computation of taxable-equivalent net interest income and other financing income is based on the statutory federal income tax rate of 
35%, adjusted for applicable state income taxes net of the related federal tax benefit.

The mix of earning assets can also affect the interest rate spread. Regions’ primary types of earning assets are loans and 
investment  securities.  Certain  types  of  earning  assets  have  historically  generated  larger  spreads;  for  example,  loans  typically 
generate larger spreads than other assets, such as securities, Federal funds sold or securities purchased under agreements to resell. 
The spread on loans increased in 2016 as compared to 2015, due primarily to the increase in short-term interest rates. Average 
earning assets in 2016 totaled $111.0 billion, an increase of $3.1 billion as compared to the prior year. 

Average loans as a percentage of average earning assets was 73 percent in 2016 and 74 percent in 2015. The remaining 
categories of earning assets are shown in Table 3 “Consolidated Average Daily Balances and Yield/Rate Analysis for Continuing 

53

 
 
 
 
Table of Contents 

Operations”. The proportion of average earning assets to average total assets, which was 88 percent in both 2016 and 2015, measures 
the effectiveness of management’s efforts to invest available funds into the most profitable earning vehicles. Funding for Regions’ 
earning assets comes from interest-bearing and non-interest-bearing sources. Another significant factor affecting the net interest 
margin is the percentage of earning assets funded by interest-bearing liabilities. The percentage of average earning assets funded 
by average interest-bearing liabilities was 64 percent in both 2016 and 2015.

PROVISION FOR LOAN LOSSES

The provision for loan losses is used to maintain the allowance for loan losses at a level that in management’s judgment is 
appropriate to absorb probable losses inherent in the portfolio at the balance sheet date.  During 2016, the provision for loan losses 
totaled $262 million and net charge-offs were $277 million. This compares to a provision for loan losses of $241 million and net 
charge-offs of $238 million in 2015. The increase in the provision for loan losses in 2016 compared to 2015 was primarily due to 
higher net charge-offs, including $37 million in 2016 energy charge-offs, and the increase in criticized and classified commercial 
loans, attributable primarily to downward risk rating migration in the energy portfolio.  This increase was offset by the impact of 
$2.0 billion in business services loan balance runoff, including $436 million in direct energy, and improvement in the risk profile 
of certain other loan classes.

For further discussion and analysis of the total allowance for credit losses, see the "Allowance for Credit Losses" and  “Risk 
Management” sections found later in this report. See also Note 6 “Allowance for Credit Losses” to the consolidated financial 
statements.

NON-INTEREST INCOME

Table 5—Non-Interest Income from Continuing Operations

Year Ended December 31

Change 2016 vs. 2015

2016

2015

2014

Amount

Percent

(Dollars in millions)

Service charges on deposit accounts
Card and ATM fees
Investment management and trust fee income
Mortgage income
Capital markets fee income and other
Insurance commissions and fees
Bank-owned life insurance
Commercial credit fee income
Investment services fee income
Insurance proceeds
Net revenue from affordable housing
Securities gains, net
Market value adjustments on employee benefit
assets
Other miscellaneous income

$

$

$

664
402
213
173
152
148
95
73
58
50
17
6

$

662
364
202
162
104
140
74
76
55
91
24
29

$

695
334
193
149
73
124
85
61
43
—
16
27

3
99
2,153

$

(3)
91
2,071

$

4
99
1,903

$

2
38
11
11
48
8
21
(3)
3
(41)
(7)
(23)

6
8
82

0.3 %
10.4 %
5.4 %
6.8 %
46.2 %
5.7 %
28.4 %
(3.9)%
5.5 %
(45.1)%
(29.2)%
(79.3)%

(200.0)%
8.8 %
4.0 %

Service Charges on Deposit Accounts

Service  charges  on  deposit  accounts  include  non-sufficient  fund  fees  and  other  service  charges.  The  slight  increase 
during 2016 compared to 2015 was primarily due to growth in consumer checking accounts, which offset the impact of the change 
in posting order of customer deposit transactions that went into effect during the fourth quarter of 2015.

Card and ATM Fees

Card and ATM fees include the combined amounts of credit card/bank card income and debit card and ATM related revenue.   
The increase in 2016 compared to 2015 was a result of the continued growth in consumer checking accounts, and an increase in 
debit card transactions. Additionally, an increase in active credit cards generated greater purchase activity resulting in higher 
interchange income.

54

 
 
 
Table of Contents 

Investment Management and Trust Fee Income

Investment management and trust fee income represents income from asset management services provided to individuals, 
businesses and institutions.  The increase in investment management and trust fees during 2016 compared to 2015 was driven 
primarily from the increase in assets under administration.

Mortgage Income

Mortgage income is generated through the origination and servicing of residential mortgage loans for long-term investors 
and sales of residential mortgage loans in the secondary market. The increase in mortgage income during 2016 compared to 2015 
was due to increased gains from loan sales partially offset by declines in the market valuation of mortgage servicing rights and 
related hedging activity. In addition, mortgage servicing income has increased as a result of purchasing the rights to service a total 
of approximately $8 billion in residential mortgage loans during 2016. See Note 7 "Servicing of Financial Assets" to the consolidated 
financial statements for more information. 

Capital Markets Fee Income and Other 

Capital markets fee income and other primarily relates to capital raising activities that includes securities underwriting and 
placement, loan syndication and placement, as well as foreign exchange, derivatives, merger and acquisition and other advisory 
services. The increase in 2016 compared to 2015 was primarily due to mergers and acquisitions advisory fees, which the Company 
began recognizing in the fourth quarter of 2015 in connection with the purchase of a middle-market advisory firm. Also contributing 
to the increase were higher loan syndication fees and fees generated from the placement of permanent financing for real estate 
customers.  

Insurance Commissions and Fees

Regions sells property and casualty, life and health, mortgage, and other specialty insurance and credit related products to 
businesses and individuals. The increase in 2016 compared to 2015 was partially due to additional revenue generated by the third 
quarter of 2015 acquisition of an insurance team that specializes in group employee benefits. 

Bank-owned Life Insurance

Bank-owned life insurance increased in 2016 compared to 2015 primarily due to income from insurance claims as well as a 

gain recognized upon the exchange of policies in the first quarter of 2016.

Insurance Proceeds

Insurance proceeds recognized in 2016 decreased compared to 2015. During the third quarter of 2016, the Company received 
$47 million of insurance proceeds related to a previously disclosed settlement with the Department of Justice on behalf of HUD 
regarding FHA insured mortgage loans. The $91 million of insurance proceeds recognized in 2015 was related to the settlement 
of the previously disclosed and accrued 2010 class-action lawsuit. 

Net Revenue from Affordable Housing

Net revenue from affordable housing includes actual gains or losses resulting from the sale of affordable housing investments, 
cash distributions from the investments and any related impairment charges. The decrease in revenue for 2016 compared to 2015 
reflects a lower level of gains on sales of investments.

Securities Gains, Net

Net securities gains result from the Company's asset/liability management process. The decrease in securities gains, net 
during 2016 compared to 2015 was primarily due to the Company reducing its exposure to energy-related corporate bonds in an 
effort to mitigate the risk of future downgrades and incurring losses in 2016. See Note 4 "Securities" to the consolidated financial 
statements for more information.

Market Value Adjustments on Employee Benefit Assets

Market value adjustments on employee benefit assets increased in 2016 compared to 2015 reflecting market value variations 

related to assets held for certain employee benefits. These adjustments are offset in salaries and employee benefits expense.

Other Miscellaneous Income

Other miscellaneous income includes fees from safe deposit boxes, check fees and other miscellaneous fees. The increase 
in 2016 compared to 2015 was primarily due to a recovery of approximately $10 million related to the 2010 Gulf of Mexico oil 
spill that occurred during the third quarter of 2016.

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Table of Contents 

NON-INTEREST EXPENSE

Table 6—Non-Interest Expense from Continuing Operations

Year Ended December 31

Change 2016 vs. 2015

2016

2015

2014

Amount

Percent

Salaries and employee benefits
Net occupancy expense
Furniture and equipment expense
Outside services
Marketing
FDIC insurance assessments
Professional, legal and regulatory expenses
Branch consolidation, property and equipment charges
Credit/checkcard expenses
Provision (credit) for unfunded credit losses
Visa class B shares expense
Loss on early extinguishment of debt
Other miscellaneous expenses

$

$

1,913
348
317
154
101
99
89
58
55
17
15
14
437
3,617

$

$

$

(Dollars in millions)
1,810
368
287
131
95
75
235
16
44
(13)
12
—
372
3,432

1,883
361
303
149
98
105
137
56
54
(13)
9
43
422
3,607

$

$

$

30
(13)
14
5
3
(6)
(48)
2
1
30
6
(29)
15
10

1.6 %
(3.6)%
4.6 %
3.4 %
3.1 %
(5.7)%
(35.0)%
3.6 %
1.9 %
(230.8)%
66.7 %
(67.4)%
3.6 %
0.3 %

Salaries and Employee Benefits

Salaries and employee benefits are comprised of salaries, incentive compensation, long-term incentives, payroll taxes, and 
other employee benefits such as 401(k), pension, and medical, life and disability insurance, as well as, expenses from liabilities 
held for employee benefit purposes. Salaries and employee benefits increased during 2016 compared to 2015 primarily due to 
increased production-based incentives related to capital markets income growth, increases in base salaries from annual merit 
increases, and increases in severance expenses. Staffing levels decreased to 22,166 at December 31, 2016 from 23,393 full-time 
equivalent positions at December 31, 2015, serving to partially offset the aforementioned increases.

Net Occupancy Expense

Net  occupancy  expense  includes  rent,  depreciation  and  amortization,  utilities,  maintenance,  insurance,  taxes,  and  other 
expenses of premises occupied by Regions and its affiliates. Net occupancy expense decreased during 2016 compared to 2015 
primarily related to the Company's branch consolidation and occupancy optimization initiatives.

Furniture and Equipment Expense

Furniture and equipment expense includes depreciation, maintenance and repairs, rent, taxes and other expenses of equipment 
utilized by Regions and its affiliates.  Furniture and equipment expense increased during 2016 compared to 2015 primarily driven 
by increased depreciation on new technology-related assets placed in service.

Outside Services

Outside services consists of expenses related to routine services provided by third parties, such as contract labor, servicing 
costs, data processing, loan pricing and research, data license purchases, data subscriptions, and check printing. Outside services 
increased during 2016 compared to 2015 primarily due to increases in servicing costs related to continued purchases of indirect 
loans from third parties and costs for services related to data processing.

FDIC Insurance Assessments

FDIC insurance assessments decreased during 2016 compared to 2015 primarily due to $23 million of additional assessment 
expenses recorded in the third quarter of 2015 related to prior assessments. The surcharge imposed by the FDIC went into effect 
during the third quarter of 2016 creating offsetting additional expense. 

Professional, Legal and Regulatory Expenses

Professional,  legal  and  regulatory  expenses  consist  of  amounts  related  to  legal,  consulting,  other  professional  fees  and 
regulatory charges. Professional, legal and regulatory expenses decreased during 2016 compared to 2015 primarily as the result 
of a net $48 million accrual for contingent legal and regulatory expenses recorded in the second quarter of 2015, as well as a 
favorable legal settlement of $7 million recorded in the first quarter of 2016. 

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Branch Consolidation, Property and Equipment Charges

Branch consolidation, property and equipment charges include valuation adjustments related to owned branches when the 
decision to close them is made. Accelerated depreciation and lease write-off charges are recorded for leased branches through and 
at the actual branch close date. Branch consolidation, property and equipment charges also include costs related to occupancy 
optimization initiatives.

Provision (Credit) for Unfunded Credit Losses

        Provision (credit) for unfunded credit losses is the adjustment to the reserve for unfunded credit commitments. The provision  
for  unfunded  credit  losses  during  2016  was  attributable  to  increases  in  commercial  and  industrial  reserve  rates  for  unfunded 
commitments and letters of credit and a large specific reserve on an unfunded energy credit.  The (credit) for unfunded credit losses 
in 2015 was primarily due to loan fundings during 2015 which resulted in reductions to the reserve.

Visa Class B Shares Expense

Visa class B shares expense is associated with shares sold in a prior year. The Visa class B shares have restrictions tied to 
finalization of certain covered litigation. Changes in the status of that litigation drove the increased expense during 2016. Refer 
to Note 24 "Commitments, Contingencies and Guarantees" to the consolidated financial statements for additional information. 

Loss on Early Extinguishment of Debt

Loss on early extinguishment of debt decreased during 2016 compared to 2015. In 2015, Regions purchased approximately 
$250  million  of  its  7.50%  subordinated  notes  due  May  2018,  incurring  a  related  early  extinguishment  pre-tax  charge  of 
approximately $43 million. In 2016, the Company purchased approximately $649 million of its 2.00% senior notes due May 2018.  
Pre-tax losses on the early extinguishment related to this tender offer were approximately $14 million.  

Other Miscellaneous Expenses

Other miscellaneous expenses include expenses related to communications, postage, supplies, certain credit-related costs, 
foreclosed  property  expenses  and  mortgage  repurchase  costs.  Other  miscellaneous  expenses  increased  during 2016 compared 
to 2015 primarily due to increased credit-related valuation charges associated with other real estate and loans held for sale.

INCOME TAXES

The Company’s income tax expense from continuing operations was $514 million and $455 million, resulting in effective 
tax rates of 30.7 percent and 29.7 percent for 2016 and 2015, respectively. The effective tax rate was higher in 2016 principally 
due to higher pre-tax income. 

The Company’s effective tax rate is affected by many factors including, but not limited to, the level of pre-tax income, the 
mix of income between various tax jurisdictions with differing tax rates, net tax benefits related to affordable housing investments, 
income from bank-owned life insurance and tax exempt interest. In addition, the effective tax rate is affected by items that may 
occur in any given period but are not consistent from period-to-period, such as the termination of certain leveraged leases, valuation 
allowance changes and changes to unrecognized tax benefits. Accordingly, the comparability of the effective tax rate between 
periods may be impacted.

New guidance related to accounting for share-based payments was issued in March 2016.  The guidance eliminates additional 
paid-in capital pools and designates that all excess tax benefits and deficiencies should be recorded in income tax expense or 
benefit  when  the  awards  vest  or  are  settled.  Regions  adopted  the  guidance  effective  January  1,  2017.  Regions  estimates  an 
incremental increase to income tax expense of approximately $5 million in the second quarter of 2017 and the first quarter of 2018 
related to expiring stock options. The vesting of restricted and performance stock awards, which will occur in the second quarters 
of 2017 and 2018, could also impact income tax expense depending on Regions' stock price when vested. Refer to Note 1 "Summary 
of Significant Accounting Policies" to the consolidated financial statements for additional information.

  At  December 31,  2016,  the  Company  reported  a  net  deferred  tax  asset  of  $308  million,  compared  to  $254  million  at 
December 31, 2015. The increase in the net deferred tax asset was primarily due to an increase in unrealized losses related to 
securities available for sale and derivative instruments, reflecting an increase in market interest rates in late 2016.

The Company continually assesses the realizability of its deferred tax assets based on an evaluative process that considers 
all available positive and negative evidence. As part of this evaluative process, the Company considers the following sources of 
taxable income: 1) the future reversals of taxable temporary differences; 2) future taxable income exclusive of reversing temporary 
differences and carryforwards; 3) taxable income in prior carryback years; and 4) tax-planning strategies. In making a conclusion, 
the Company has evaluated all available positive and negative evidence impacting these sources of taxable income. The primary 
sources of evidence impacting the Company's judgment regarding the realization of its deferred tax assets are summarized below.

•  History of earnings - In 2016, the Company has continued its positive earnings trend with positive earnings from 2012 
through 2016. All federal net operating losses and federal tax credit carryforwards with expiration dates have been utilized. 
There is no history of significant tax carryforwards expiring unused.

57

•  Reversals of taxable temporary differences - The Company anticipates that future reversals of taxable temporary differences, 
including the accretion of taxable temporary differences related to leveraged leases acquired in a prior business combination, 
can absorb up to approximately $665 million of deferred tax assets.

•  Creation of future taxable income - The Company has projected future taxable income that will be sufficient to absorb the 

remaining deferred tax assets after the reversal of future taxable temporary differences.

•  Ability to implement tax planning strategies - The Company has the ability to implement tax planning strategies such as 

asset sales to maximize the realization of deferred tax assets.

Based  on  this  evaluative  process,  the  Company  has  established  a  valuation  allowance  in  the  amount  of  $30  million  at 
December 31, 2016 and $29 million at December 31, 2015 because the Company believes that a portion of the state net operating 
loss carryforwards and state tax credit carryforwards will not be utilized. 

See  Note  1  “Summary  of  Significant Accounting  Policies”  and  Note  20  “Income  Taxes”  to  the  consolidated  financial 

statements for additional information about income taxes.

DISCONTINUED OPERATIONS

Morgan  Keegan  was  sold  on  April 2,  2012.  Regions'  results  from  discontinued  operations  are  presented  in  Note  3 
"Discontinued  Operations"  to  the  consolidated  financial  statements.  During  2016,  income  from  discontinued  operations  was 
primarily the result of recoveries of legal expenses. During 2015, the loss from discontinued operations was primarily the result 
of legal fees incurred during the year. 

BALANCE SHEET ANALYSIS

The following sections provide expanded discussion of significant changes in certain line items in asset, liability, and equity 

categories. 

Cash and Cash Equivalents

At December 31, 2016, cash and cash equivalents totaled $5.5 billion as compared to $5.3 billion at December 31, 2015. 
The slight increase year-over-year was driven by an increase in cash and due from banks. This increase was somewhat offset by 
a decrease in interest-bearing deposits in other banks as a result of normal day-to-day operating variations.

Securities

Regions  utilizes  the  securities  portfolio  to  manage  liquidity,  interest  rate  risk,  and  regulatory  capital,  as  well  as  to  take 

advantage of market conditions to generate a favorable return on investments without undue risk. 

The “Market Risk-Interest Rate Risk” and "Liquidity Risk" sections, found later in this report, further explain Regions’ 
interest rate and liquidity risk management practices. The weighted-average yield earned on securities, less equities, was 2.41
percent in 2016 and 2.49 percent in 2015. Table 7 “Securities” details the carrying values of securities, including both available 
for sale and held to maturity.

Table 7—Securities

U.S. Treasury securities
Federal agency securities
Obligations of states and political subdivisions
Mortgage-backed securities:
Residential agency
Residential non-agency
Commercial agency
Commercial non-agency
Corporate and other debt securities
Equity securities

2016

2015

2014

$

(In millions)
229
558
1

303
35
1

18,571
4
3,625
1,129
1,274
201
25,143

$

17,491
5
3,194
1,231
1,667
280
24,656

$

$

$

$

177
573
2

17,665
8
2,173
1,494
1,990
146
24,228

Regions maintains a highly rated securities portfolio consisting primarily of agency mortgage-backed securities. The securities 
at December 31, 2016 increased $487 million from December 31, 2015 primarily due to additional portfolio purchases, which 
were partially offset by decreases in the fair value of certain securities based on changes in market interest rates.

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Table of Contents 

Maturity Analysis—The average life of the securities portfolio (excluding equities) at December 31, 2016 was estimated to 
be 5.8 years, with a duration of approximately 4.3 years. These metrics compare with an estimated average life of 5.4 years, with 
a  duration  of  approximately  3.8  years  for  the  portfolio  at  December 31,  2015. Table  8  “Relative  Contractual  Maturities  and 
Weighted-Average Yields for Securities” provides additional details.

Table 8—Relative Contractual Maturities and Weighted-Average Yields for Securities

Securities Maturing as of December 31, 2016

Within One
Year

After One But
Within Five
Years

After Five But
Within Ten
Years

After Ten
Years

Total

(Dollars in millions)

Securities (1):

U.S. Treasury securities

Federal agency securities

$

Obligations of states and political subdivisions

Mortgage-backed securities:

Residential agency

Residential non-agency

Commercial agency

Commercial non-agency

Corporate and other debt securities

Weighted-average yield (2)

18

5

—

1

—

—

64

51

$

217

$

6

1

148

—

723

31

362

$

66

24

—

$

2

—

—

303

35

1

1,800

—

2,462

308

630

16,622

18,571

4

440

726

231

4

3,625

1,129

1,274

$

139

$

1,488

$

5,290

$

18,025

$

24,942

1.50%

2.15%

2.46%

2.42%

2.41%

_________
(1)  Equity securities of other corporations held by Regions are not included in the table.
(2)  The weighted-average yields are calculated on the basis of the yield to maturity based on the book value of each security.  Weighted-average 
yields on tax-exempt obligations have been computed on a taxable-equivalent basis using a tax rate of 35%, adjusted for applicable state 
income taxes net of the related federal tax benefit. Average tax-exempt securities were maintained at such a small balance in 2016 that the 
taxable-equivalent adjustments for the calculation of yields amounted to zero for the year ended December 31, 2016. Yields on tax-exempt 
obligations have not been adjusted for the non-deductible portion of interest expense used to finance the purchase of tax-exempt obligations.

Portfolio Quality—Regions’ investment policy emphasizes credit quality and liquidity. Securities rated in the highest category 
by nationally recognized rating agencies and securities backed by the U.S. Government and government sponsored agencies, both 
on a direct and indirect basis, represented approximately 95 percent of the investment portfolio at December 31, 2016. All other 
securities  rated  below AAA,  not  backed  by  the  U.S.  Government  or  government  sponsored  agencies,  or  which  are  not  rated 
represented approximately 5 percent of total securities at year-end 2016.

Loans Held For Sale

At December 31, 2016, loans held for sale totaled $718 million, consisting of $505 million of residential real estate mortgage 
loans, $200 million of commercial mortgage loans and $13 million of non-performing loans. At December 31, 2015, loans held 
for sale totaled $448 million, consisting of $354 million of residential real estate mortgage loans, $56 million of commercial 
mortgage loans, and $38 million of non-performing loans. The level of residential real estate mortgage loans held for sale that are 
part of the Company's mortgage originations to be sold in the secondary market fluctuates depending on the timing of the origination 
and sale to third parties. The level of commercial mortgage loans held for sale also fluctuates depending on timing. 

Loans

GENERAL

Average  loans,  net  of  unearned  income,  represented  73  percent  of  average  interest-earning  assets  for  the  year  ended 
December 31, 2016, compared to 74 percent for the year ended December 31, 2015. Lending at Regions is generally organized 
along three portfolio segments: commercial loans (including commercial and industrial, and owner-occupied commercial real 
estate mortgage and construction loans), investor real estate loans (commercial real estate mortgage and construction loans) and 
consumer loans (residential first mortgage, home equity, indirect-vehicles, indirect-other consumer, consumer credit card and other 
consumer loans).

Table 9 illustrates a year-over-year comparison of loans, net of unearned income, by portfolio segment and class and Table 

10 provides information on selected loan maturities.

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Table 9—Loan Portfolio 

2016

2015

2014

2013

2012

Commercial and industrial

$

35,012

$

(In millions, net of unearned income)
35,821

32,732

$

$

29,413

$

26,674

Commercial real estate mortgage—owner-occupied

Commercial real estate construction—owner-occupied

Total commercial

Commercial investor real estate mortgage

Commercial investor real estate construction

Total investor real estate

Residential first mortgage

Home equity

Indirect—vehicles

Indirect—other consumer

Consumer credit card

Other consumer

Total consumer

Table 10—Selected Loan Maturities 

Commercial and industrial (2)
Commercial real estate mortgage—owner-occupied
Commercial real estate construction—owner-occupied

Total commercial

Commercial investor real estate mortgage
Commercial investor real estate construction

Total investor real estate

Due after one year but within five years
Due after five years

6,867

334

42,213

4,087

2,387

6,474

13,440

10,687

4,040

920

1,196

1,125

7,538

423

43,782

4,255

2,692

6,947

12,811

10,978

3,984

545

1,075

1,040

8,263

407

41,402

4,680

2,133

6,813

12,315

10,932

3,642

206

1,009

988

9,495

310

39,218

5,318

1,432

6,750

12,163

11,294

3,075

198

948

963

31,408
80,095

$

30,433
81,162

$

29,092
77,307

$

28,641
74,609

$

$

10,095

302

37,071

6,808

914

7,722

12,963

11,800

2,336

197

906

1,000

29,202
73,995

Loans Maturing as of December 31, 2016 

(1)

Within
One Year

After One
But  Within
Five Years

After
Five
Years

(In millions)

$

$

5,070
892
16
5,978
1,900
750
2,650
8,628

$

$

22,275
3,185
83
25,543
1,915
1,607
3,522
29,065

$

$

7,504
2,790
235
10,529
272
30
302
10,831

$

$

Total

34,849
6,867
334
42,050
4,087
2,387
6,474
48,524

Predetermined
Rate

Variable
Rate

$

$

(In millions)

5,029
7,246
12,275

$

$

24,036
3,585
27,621

_________
(1)  Excludes residential first mortgage, home equity, indirect-vehicles, indirect-other consumer, consumer credit card and other consumer loans.
(2)  Excludes $163 million of small business credit card accounts.

Loans, net of unearned income, totaled $80.1 billion at December 31, 2016, a decrease of $1.1 billion from year-end 2015
levels. Regions manages loan growth with a focus on risk management and risk-adjusted return on capital. Loan balances decreased  
year over year in the commercial and investor real estate portfolio classes with the largest decrease in commercial and industrial, 
while most consumer portfolio classes increased.

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PORTFOLIO CHARACTERISTICS

The following sections describe the composition of the portfolio segments and classes disclosed in Table 9, explain changes 
in balances from the 2015 year-end, and highlight the related risk characteristics. Regions believes that its loan portfolio is well 
diversified by product, client, and geography throughout its footprint. However, the loan portfolio may be exposed to certain 
concentrations of credit risk which exist in relation to individual borrowers or groups of borrowers, certain types of collateral, 
certain types of industries, certain loan products, or certain regions of the country. See Note 5 “Loans” and Note 6 “Allowance 
for Credit Losses” to the consolidated financial statements for additional discussion.

Commercial

The commercial portfolio segment includes commercial and industrial loans to commercial customers for use in normal 
business operations to finance working capital needs, equipment purchases and other expansion projects. Commercial and industrial 
loans decreased $809 million or 2 percent since year-end 2015 driven primarily by declines in direct energy loans, softness in 
demand for middle market commercial small business loans, management of concentration risk limits, and a continued focus on 
achieving appropriate risk-adjusted returns. Commercial also includes owner-occupied commercial real estate mortgage loans and 
owner-occupied  commercial  real  estate  construction  loans  to  operating  businesses.  Owner-occupied  commercial  real  estate 
mortgage loans are for long-term financing of land and buildings, and are repaid by cash flow generated by business operations. 
These loans declined $671 million or 9 percent from year-end 2015 as a result of continued customer deleveraging. Owner-occupied 
commercial real estate construction loans are made to commercial businesses for the development of land or construction of a 
building where the repayment is derived from revenues generated from the business of the borrower.  

Over half of the Company’s total loans are included in the commercial portfolio segment. These balances are spread across 
numerous industries, as noted in the table below. The Company manages the related risks to this portfolio by setting certain lending 
limits for each significant industry.

The following table provides detail of Regions' commercial lending balances in selected industries as of December 31:

Table 11—Selected Industry Exposure

Administrative, support, waste and repair

Agriculture

Educational services

Energy
Financial services (1)

Government and public sector

Healthcare

Information
Manufacturing (1)
Professional, scientific and technical services (1)
Real estate (1)

Religious, leisure, personal and non-profit services

Restaurant, accommodation and lodging

Retail trade
Transportation and warehousing (1)

Utilities
Wholesale goods (1)

Other

Total commercial

Loans

$

December 31, 2016

Unfunded
Commitments

(In millions)

Total Exposure

$

899

612

1,929

2,097

3,473

2,485

4,178

1,111

4,101

1,701

6,513

1,934

2,436

2,570

2,196

1,147

2,795

36

$

481

241

307

1,968

3,228

246

1,483

817

4,024

1,052

5,445

495

650

2,339

1,005

2,008

2,396

1,162

1,380

853

2,236

4,065

6,701

2,731

5,661

1,928

8,125

2,753

11,958

2,429

3,086

4,909

3,201

3,155

5,191

1,198

$

42,213

$

29,347

$

71,560

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Table of Contents 

Administrative, support, waste and repair

Agriculture

Educational services

Energy
Financial services (3)

Government and public sector

Healthcare

Information
Manufacturing (3)
Professional, scientific and technical services (3)

Real estate

Religious, leisure, personal and non-profit services

Restaurant, accommodation and lodging

Retail trade
Transportation and warehousing (3)

Utilities
Wholesale goods (3)

Other

Total commercial

Loans

$

December 31, 2015 (2)

Unfunded
Commitments

(In millions)

Total Exposure

$

901

747

1,846

2,533

3,556

2,408

4,322

1,281

4,407

1,730

6,427

2,165

2,489

2,492

2,228

1,047

2,981

222

$

575

295

312

2,461

2,984

238

1,407

744

3,938

1,114

5,046

600

633

2,507

1,084

1,674

2,588

1,600

1,476

1,042

2,158

4,994

6,540

2,646

5,729

2,025

8,345

2,844

11,473

2,765

3,122

4,999

3,312

2,721

5,569

1,822

$

43,782

$

29,800

$

73,582

_______
(1)  Regions' definition of indirect energy-related lending includes certain balances within each of these selected industry categories. As of 
December 31, 2016, total indirect energy-related loans were approximately $536 million, with approximately $506 million included in 
commercial loans and $30 million in investor real estate loans. Total unfunded commitments for indirect energy-related lending were $446 
million as of December 31, 2016.

(2)  As customers' businesses evolve (e.g. up or down the vertical manufacturing chain), Regions may need to change the assigned business 
industry code used to define the customer relationship. When these changes occur, Regions does not recast the customer history for prior 
periods into the new classification because the business industry code used in the prior period was deemed appropriate. As a result, year 
over year changes may be impacted.

(3)  Regions' definition of indirect energy-related lending includes certain balances within each of these selected industry categories. As of 
December 31, 2015, total indirect energy-related loans were approximately $519 million, with approximately $497 million included in 
commercial loans and $22 million in investor real estate loans. Total unfunded commitments for indirect energy-related lending were $446 
million as of December 31, 2015.

Regions continues to monitor the impacts of low oil prices on both its direct and indirect energy lending portfolios. Regions’ 
direct energy loan balances at December 31, 2016 amounted to approximately $2.1 billion, consisting of loans for oilfield services, 
exploration and production, and pipeline transportation of gas and crude oil. Other types of lending are tangentially impacted by 
the energy portfolio, such as petroleum wholesalers, oil and gas equipment manufacturing, air transportation, and petroleum bulk 
stations and terminals. These indirect energy loan balances were approximately $536 million at December 31, 2016. The entire 
energy-related  portfolio,  combining  direct  and  indirect  loans,  was  approximately  $2.6  billion  or  3  percent  of  total  loans  at 
December 31, 2016. Regions also has $131 million of energy-related operating leases. Regions evaluates the current value of these 
operating lease assets and tests for impairment when indicators of impairment are present. Economic trends such as volatility in 
commodity prices and collateral valuations, as well as circumstances related to individually large operating lease assets could 
result in impairment. If an impairment loss is deemed necessary on operating lease assets, the impairment is recorded through 
other non-interest income.  

Regions’  energy-related  portfolio  is  geographically  concentrated  primarily  in Texas  and,  to  a  lesser  extent,  in  southern 
Louisiana. Regions employs a variety of risk management strategies, including the use of concentration limits and continuous 
monitoring, as well as utilizing underwriting with borrowing base structures tied to energy commodity reserve bases or other 
tangible assets. Additionally, heightened credit requirements have been adopted for select segments of the portfolio. Regions also 
employs experienced lending and underwriting teams including petroleum engineers, all with extensive energy sector experience 
through multiple economic cycles. Given the recent volatility in oil prices, this energy-related portfolio may be subject to additional 
pressure on credit quality metrics including past due, criticized, and non-performing loans, as well as net charge-offs. Regions' 
energy-related portfolio consists of a relatively small number of customers, which provides the Company granular insight into the 

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financial health of those borrowers. Through its on-going portfolio credit quality assessment, Regions will continue to assess the 
impact to the allowance and make adjustments as appropriate.

Investor Real Estate

Loans for real estate development are repaid through cash flow related to the operation, sale or refinance of the property. 
This portfolio segment includes extensions of credit to real estate developers or investors where repayment is dependent on the 
sale of real estate or income generated from the real estate collateral. A portion of Regions’ investor real estate portfolio segment 
consists of loans secured by residential product types (land, single-family and condominium loans) within Regions’ markets. 
Additionally, this category includes loans made to finance income-producing properties such as apartment buildings, office and 
industrial  buildings,  and  retail  shopping  centers. Total  investor  real  estate  loans  decreased  $473  million  from  2015  year-end 
balances. 

Due to the nature of the cash flows typically used to repay investor real estate loans, these loans are particularly vulnerable 

to weak economic conditions. As a result, this loan type has a higher risk of non-collection than other loans. 

Residential First Mortgage

Residential first mortgage loans represent loans to consumers to finance a residence. These loans are typically financed over 
a 15 to 30 year term and, in most cases, are extended to borrowers to finance their primary residence. These loans experienced a 
$629 million or 5 percent increase from year-end 2015, as prepayments have slowed. Approximately $3.3 billion in new loan 
originations were retained on the balance sheet during 2016.

Home Equity

Home equity lending includes both home equity loans and lines of credit. This type of lending, which is secured by a first 
or second mortgage on the borrower's residence, allows customers to borrow against the equity in their homes. The home equity 
portfolio totaled $10.7 billion at December 31, 2016 as compared to $11.0 billion at December 31, 2015. Substantially all of this 
portfolio was originated through Regions’ branch network. 

The following table presents information regarding the future principal payment reset dates for the Company's home equity 
lines of credit as of December 31, 2016. The balances presented are based on maturity date for lines with a balloon payment and 
draw period expiration date for lines that convert to a repayment period.

Table 12—Home Equity Lines of Credit - Future Principal Payment Resets

2017

2018

2019

2020

2021

2022-2026
2027-2031

Thereafter

Total

First Lien

% of Total

Second Lien

% of Total

Total

(Dollars in millions)

$

$

10

12

77

159

187

1,679
1,551

—

3,675

0.14% $

0.17

1.07

2.19

2.58

23.22
21.44

—

50.81% $

20

17

69

124

161

1,760
1,406

1

3,558

0.27% $

0.24

0.96

1.72

2.22

24.33
19.44

0.01

49.19% $

30

29

146

283

348

3,439
2,957

1

7,233

Of the $10.7 billion home equity portfolio at December 31, 2016, approximately $7.2 billion were home equity lines of credit 
and $3.5 billion were closed-end home equity loans (primarily originated as amortizing loans). Beginning December 2016, new 
home equity lines of credit have a 10-year draw period and a 20-year repayment term. During the 10-year draw period customers 
do not have an interest-only payment option, except on a very limited basis. From May 2009 to December 2016, new home equity 
lines of credit had a 10-year draw period and a 10-year repayment period. Prior to May 2009,  home equity lines of credit had a 
20-year term with a balloon payment upon maturity or a 5-year draw period with a balloon payment upon maturity. The term 
“balloon payment” means there are no principal payments required until the balloon payment is due for interest-only lines of credit. 
As of December 31, 2016, none of Regions' home equity lines of credit have converted to mandatory amortization under the 
contractual terms. As presented in the table above, the majority of home equity lines of credit will either mature with a balloon 
payment or convert to amortizing status after fiscal year 2020.

63

Table of Contents 

Other Consumer Credit Quality Data

The Company calculates an estimate of the current value of property secured as collateral for both residential first mortgage 
and home equity lending products (“current LTV”). The estimate is based on home price indices compiled by a third party. The 
third party data indicates trends for MSAs. Regions uses the third party valuation trends from the MSAs in the Company's footprint 
in its estimate. The trend data is applied to the loan portfolios taking into account the age of the most recent valuation and geographic 
area.

The following table presents current LTV data for components of the residential first mortgage and home equity classes of 
the consumer portfolio segment. Current LTV data for the remaining loans in the portfolio is not available, primarily because some 
of the loans are serviced by others. Data may also not be available due to mergers and systems integrations. The amounts in the 
table represent the entire loan balance. For purposes of the table below, if the loan balance exceeds the current estimated collateral,     
the entire balance is included in the “Above 100%” category, regardless of the amount of collateral available to partially offset the 
shortfall. The balances in the "Above 100%" category as a percentage of the portfolio balances declined to 1 percent in the residential 
first mortgage portfolio and to 3 percent in the home equity portfolio at December 31, 2016.

Table 13—Estimated Current Loan to Value Ranges

December 31, 2016

December 31, 2015

Residential
First Mortgage

Home Equity

1st Lien

2nd Lien

Residential
First Mortgage

Home Equity

1st Lien

2nd Lien

(In millions)

$

$

139
1,675
11,090
536
13,440

$

$

82
371
6,248
99
6,800

$

$

235
677
2,814
161
3,887

$

$

267
1,703
10,288
553
12,811

$

$

127
497
5,965
107
6,696

$

$

417
886
2,785
194
4,282

Estimated current loan to value:

Above 100%
80% - 100%
Below 80%
Data not available

Indirect—Vehicles

Indirect-vehicles lending, which is lending initiated through third-party business partners, largely consists of loans made 
through automotive dealerships. This portfolio class increased $56 million from year-end 2015.  However, the balance is expected 
to  decrease  during  2017,  as  Regions  terminated  a  third-party  arrangement  during  the  fourth  quarter  of  2016  that  historically 
accounted for approximately half of the Company's production.

Indirect—Other Consumer

Indirect-other consumer lending represents other point of sale lending through third parties. This portfolio class increased 

$375 million from year-end 2015 primarily due to continued growth in new point-of-sale initiatives.

Consumer Credit Card

Consumer  credit  card  lending  represents  primarily  open-ended  variable  interest  rate  consumer  credit  card  loans. These 

balances increased $121 million from year-end 2015.

Other Consumer

Other consumer loans primarily include direct consumer loans, overdrafts and other revolving loans. Other consumer loans 

increased $85 million from year-end 2015.

Regions qualitatively considers factors such as periodic updates of FICO scores, unemployment, home prices, and geography 
as credit quality indicators for consumer loans. FICO scores are obtained at origination as part of Regions' formal underwriting 
process. Refreshed FICO scores are obtained by the Company quarterly for all revolving accounts and home equity lines of credit 
and semiannually for all other consumer loans. Residential first mortgage FICO scores are refreshed quarterly. The following 
tables present estimated current FICO score data for components of classes of the consumer portfolio segment. Current FICO data 
is not available for the remaining loans in the portfolio for various reasons; for example, if customers do not use sufficient credit, 
an updated score may not be available. Residential first mortgage and home equity balances with FICO scores below 620 were 5 
percent of the combined portfolios for December 31, 2016 compared to 6 percent at December 31, 2015.

64

 
 
 
Table of Contents 

Table 14—Estimated Current FICO Score Ranges

Below 620
620 - 680
681 - 720
Above 720
Data not available

Below 620
620 - 680
681 - 720
Above 720
Data not available

December 31, 2016

Residential
First Mortgage

1st Lien

2nd Lien

Home Equity

$

$

807
920
1,400
9,578
735
13,440

$

$

301
529
834
4,988
148
6,800

$

$

204
355
489
2,775
64
3,887

Indirect-
Vehicles

(In millions)
427
$
527
559
2,402
125
4,040

$

$

$

Indirect-
Other
Consumer

Consumer
Credit Card

Other
Consumer

19
94
141
382
284
920

$

$

71
206
271
647
1
1,196

$

$

82
162
222
597
62
1,125

December 31, 2015

Residential
First Mortgage

Home Equity

1st Lien

2nd Lien

Indirect(1)

Consumer
Credit Card

Other
Consumer

$

$

768
1,013
1,489
8,487
1,054
12,811

$

$

311
531
789
4,808
257
6,696

$

$

(In millions)
$
249
415
530
2,938
150
4,282

$

421
549
611
2,409
539
4,529

$

$

55
158
247
614
1
1,075

$

$

86
150
191
526
87
1,040

________
(1)  Amount represents both indirect-vehicles and indirect-other consumer portfolio classes.

Allowance for Credit Losses

The allowance for loan losses totaled $1.1 billion at both December 31, 2016 and December 31, 2015. Additionally, the 
allowance for loan losses as a percentage of net loans remained consistent between December 31, 2016 and December 31, 2015 
at 1.36 percent. Total allowance for loan losses for the direct energy portfolio was approximately 7 percent at December 31, 2016 
compared to approximately 6 percent at year-end 2015.

The increase in the provision for loan losses in 2016 compared to 2015 was primarily due to higher net charge-offs, including 
$37 million in 2016 energy charge-offs, and the increase in criticized and classified commercial loans, attributable primarily to 
downward risk rating migration in the energy portfolio.  This increase was offset by the impact of $2.0 billion in business services 
loan balance runoff, including $436 million in direct energy, and improvement in the risk profile of certain other loan classes.

Management expects that net loan charge-offs will be in the 0.35 percent to 0.50 percent range in 2017. Economic trends 
such as interest rates, unemployment, volatility in commodity prices and collateral valuations will impact the future levels of net 
charge-offs and may result in volatility during 2017. 

Details regarding the allowance and net charge-offs, including an analysis of activity from the previous year’s totals, are 

included in Table 15 “Allowance for Credit Losses.”

65

 
 
 
 
 
 
 
Table of Contents 

The table below summarizes activity in the allowance for credit losses for the years ended December 31:

Table 15—Allowance for Credit Losses

Allowance for loan losses at January 1

Loans charged-off:

Commercial and industrial

Commercial real estate mortgage—owner-occupied

Commercial real estate construction—owner-occupied

Commercial investor real estate mortgage

Commercial investor real estate construction

Residential first mortgage

Home equity

Indirect—vehicles

Indirect—other consumer

Consumer credit card

Other consumer

Recoveries of loans previously charged-off:

Commercial and industrial

Commercial real estate mortgage—owner-occupied

Commercial real estate construction—owner-occupied

Commercial investor real estate mortgage

Commercial investor real estate construction

Residential first mortgage

Home equity

Indirect—vehicles

Indirect—other consumer

Consumer credit card

Other consumer

Net charge-offs:

Commercial and industrial

Commercial real estate mortgage—owner-occupied

Commercial real estate construction—owner-occupied

Commercial investor real estate mortgage

Commercial investor real estate construction

Residential first mortgage

Home equity

Indirect—vehicles

Indirect—other consumer

Consumer credit card

Other consumer

Provision for loan losses

Allowance for loan losses at December 31

Reserve for unfunded credit commitments at January 1

Provision (credit) for unfunded credit losses

Reserve for unfunded credit commitments at December 31

Allowance for credit losses at December 31

2016

2015

2014

2013

2012

(Dollars in millions)

$

1,106

$

1,103

$

1,341

$

1,919

$

2,745

120

22

1

2

—

15

56

51

15

42

74

130

114

24

—

15

—

26

68

41

—

37

62

63

2

23

1

36

93

37

—

37

67

186

125

1

69

1

223

159

31

—

38

65

203

193

8

226

46

147

266

23

—

45

66

398

403

473

898

1,223

32

11

—

10

3

3

26

18

1

6

11

121

88

11

1

(8)

(3)

12

30

33

14

36

63

51

16

—

16

11

8

28

15

—

6

14

51

16

—

22

5

8

32

13

—

5

14

165

166

79

8

—

(1)

(11)

18

40

26

—

31

48

63

47

2

1

(4)

28

61

24

—

32

53

45

25

3

35

5

6

35

10

—

4

14

182

141

100

(2)

34

(4)

217

124

21

—

34

51

61

16

—

36

9

5

32

8

—

2

15

184

142

177

8

190

37

142

234

15

—

43

51

277

262

1,091

52

17

69

1,160

$

$

$

$

238

241

1,106

65

(13)

52

1,158

307

69

1,103

78

(13)

65

1,168

716

138

1,341

83

(5)

78

1,419

1,039

213

1,919

78

5

83

2,002

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

Loans, net of unearned income, outstanding at end of period

$ 80,095

$ 81,162

$ 77,307

$ 74,609

$ 73,995

Average loans, net of unearned income, outstanding for the period

$ 81,333

$ 79,634

$ 76,253

$ 74,924

$ 76,035

Ratios:

Allowance for loan losses to loans, net of unearned income

Allowance for loan losses to non-performing loans, excluding loans held for sale

Net charge-offs as percentage of average loans, net of unearned income

1.36%

1.10x

0.34%

1.36%

1.41x

0.30%

1.43%

1.33x

0.40%

1.80%

1.24x

0.96%

2.59%

1.14x

1.37%

66

 
 
Table of Contents 

Allocation of the allowance for loan losses by portfolio segment and class is summarized as follows:

Table 16—Allocation of the Allowance for Loan Losses

2016

2015

2014

2013

2012

Allocation
Amount

% Loans
in Each
Category

Allocation
Amount

% Loans
in Each
Category

Allocation
Amount

% Loans
in Each
Category

Allocation
Amount

% Loans
in Each
Category

Allocation
Amount

% Loans
in Each
Category

(Dollars in millions)

$

585

43.7% $

549

44.1% $

428

42.4% $

427

39.4% $

497

36.1%

161

8.6

200

9.3

214

10.7

271

12.8

342

13.6

7

753

54

31

85

68

45

39

15

45

41

0.4

52.7

5.1

3.0

8.1

16.8

13.3

5.0

1.2

1.5

1.4

9

758

69

28

97

77

67

33

5

40

29

0.5

53.9

5.3

3.3

8.6

15.8

13.5

4.9

0.7

1.3

1.3

12

654

122

28

150

93

90

41

3

46

26

0.5

53.6

6.0

2.8

8.8

15.9

14.1

4.7

0.3

1.3

1.3

13

711

210

26

236

119

160

39

3

43

30

0.4

52.6

7.1

1.9

9.0

16.3

15.1

4.1

0.3

1.3

1.3

8

847

424

45

469

254

252

20

2

45

30

0.4

50.1

9.2

1.2

10.4

17.5

16.0

3.2

0.3

1.2

1.3

253

39.2

251

37.5

299

37.6

394

38.4

603

39.5

$

1,091

100.0% $

1,106

100.0% $

1,103

100.0% $

1,341

100.0% $

1,919

100.0%

Commercial and
industrial

Commercial real
estate mortgage—
owner-occupied

Commercial real
estate construction—
owner-occupied

Total commercial

Commercial investor
real estate mortgage

Commercial investor
real estate
construction

Total investor real
estate

Residential first
mortgage

Home equity

Indirect—vehicles

Indirect—other
consumer

Consumer credit card

Other consumer

Total consumer

TROUBLED DEBT RESTRUCTURINGS (TDRs) 

TDRs are modified loans in which a concession is provided to a borrower experiencing financial difficulty. Residential first 
mortgage, home equity, indirect-vehicles, consumer credit card and other consumer TDRs are consumer loans modified under the 
CAP. Commercial and investor real estate loan modifications are not the result of a formal program, but represent situations where 
modifications were offered as a workout alternative. Renewals of classified commercial and investor real estate loans are considered 
to be TDRs, even if no reduction in interest rate is offered, if the existing terms are considered to be below market.

More detailed information regarding Regions’ TDRs is included in Note 6 “Allowance for Credit Losses” to the consolidated 
financial statements. The following table summarizes the loan balance and related allowance for accruing and non-accruing TDRs 
for the periods ending December 31:

67

 
 
 
Table of Contents 

Table 17—Troubled Debt Restructurings 

Accruing:

Commercial
Investor real estate
Residential first mortgage
Home equity
Indirect—vehicles
Consumer credit card
Other consumer

Non-accrual status or 90 days past due and still
accruing:

Commercial
Investor real estate
Residential first mortgage
Home equity

Total TDRs - Loans

TDRs- Held For Sale
Total TDRs

2016

2015

Loan
Balance

Allowance for
Loan Losses

Loan
Balance

Allowance for
Loan Losses

(In millions)

$

$

$

241
90
380
286
1
2
10
1,010

279
5
74
17
375
1,385

3
1,388

$

$

$

38
8
46
5
—
—
—
97

65
2
9
—
76
173

—
173

$

$

$

146
157
398
323
1
2
12
1,039

135
22
81
18
256
1,295

8
1,303

$

$

$

20
17
52
7
—
—
—
96

37
3
10
—
50
146

—
146

_________
Note: All loans listed in the table above are considered impaired under applicable accounting literature. 

The following table provides an analysis of the changes in commercial and investor real estate TDRs. TDRs with subsequent 
restructurings that meet the definition of a TDR are only reported as TDR inflows in the period they were first modified. Other 
than resolutions such as charge-offs, foreclosures, payments, sales and transfers to held for sale, Regions may remove loans from 
TDR classification, if the borrower's financial condition improves such that the borrower is no longer in financial difficulty, the 
loan has not had any forgiveness of principal or interest, and the loan is subsequently refinanced or restructured at market terms 
and qualifies as a new loan.

For  the  consumer  portfolio,  changes  in TDRs  are  primarily  due  to  inflows  from  CAP  modifications  and  outflows  from 
payments and charge-offs. Given the types of concessions currently being granted under the CAP, as detailed in Note 6 “Allowance 
for Credit Losses” to the consolidated financial statements, Regions does not expect that the market interest rate condition will be 
widely achieved. Therefore,  Regions expects consumer loans modified through CAP to continue to be identified as TDRs for the 
remaining term of the loan.

Table 18—Analysis of Changes in Commercial and Investor Real Estate TDRs 

Balance, beginning of period

Inflows
Outflows

Charge-offs
Foreclosure
Payments, sales and other (1)

Balance, end of period

2016

2015

Commercial

Investor
Real Estate

Commercial

Investor
Real Estate

(In millions)
179
27

$

—
—
(111)
95

$

$

344
186

(13)
(1)
(235)
281

$

357
57

(8)
(32)
(195)
179

$

$

$

281
497

(30)
—
(228)
520

$

68

 
 
 
 
Table of Contents 

_________
(1)  The  majority  of  this  category  consists  of  payments  and  sales.  "Other"  outflows  include  normal  amortization/accretion  of  loan  basis 
adjustments and loans transferred to held for sale. It also includes $35 million of commercial loans and $8 million of investor real estate 
loans refinanced or restructured as new loans and removed from TDR classification during 2016. During 2015, $44 million of commercial 
loans and $58 million of investor real estate loans were refinanced or restructured as new loans and removed from TDR classification.

NON-PERFORMING ASSETS

The following table presents non-performing assets as of December 31: 

Table 19—Non-Performing Assets

Non-performing loans:

Commercial and industrial

Commercial real estate mortgage—owner-occupied

Commercial real estate construction—owner-occupied

Total commercial

Commercial investor real estate mortgage

Commercial investor real estate construction

Total investor real estate

Residential first mortgage

Home equity

Total consumer

Total non-performing loans, excluding loans held for sale

Non-performing loans held for sale
Total non-performing loans(1)

Foreclosed properties

Total non-performing assets(1)

Accruing loans 90 days past due:

Commercial and industrial

Commercial real estate mortgage—owner-occupied

Total commercial

Commercial investor real estate mortgage

Total investor real estate

Residential first mortgage(2)
Home equity

Indirect—vehicles

Consumer credit card

Other consumer

Total consumer

Restructured loans not included in the categories above

Restructured loans held for sale not included in the categories above
Non-performing loans(1) to loans and non-performing loans held for sale
Non-performing assets(1) to loans, foreclosed properties and non-
performing loans held for sale

2016

2015

2014

2013

2012

(Dollars in millions)

$

$

$

$

$

$

623

210

3

836

17

—

17

50

92

142

995

13

1,008

90

1,098

6

2

8

—

—

99

33

10

15

5

$

$

$

325

268

2

595

31

—

31

63

93

156

782

38

820

100

920

9

3

12

4

4

113

59

9

12

4

252

238

3

493

123

2

125

109

102

211

829

38

867

124

991

7

5

12

3

3

122

63

7

12

3

$

$

$

257

303

17

577

238

10

248

146

111

257

1,082

82

1,164

136

1,300

6

6

12

6

6

142

75

5

12

4

$

$

$

409

439

14

862

457

20

477

214

128

342

1,681

89

1,770

149

1,919

19

6

25

11

11

220

87

3

14

3

162

170

1,010

1

$

$

$

197

213

1,039

1

$

$

$

207

222

1,260

1

$

$

$

238

256

1,676

545

$

$

$

327

363

2,789

—

$

$

$

1.26%

1.01%

1.12%

1.56%

2.39%

1.37%

1.13%

1.28%

1.74%

2.59%

_________
(1)  Excludes accruing loans 90 days past due.
(2)  Excludes residential first mortgage loans that are 100% guaranteed by the FHA and all guaranteed loans sold to the GNMA where Regions 
has the right but not the obligation to repurchase. Total 90 days or more past due guaranteed loans excluded were $113 million at December 31, 
2016, $107 million at December 31, 2015, $125 million at December 31, 2014, $106 million at December 31, 2013 and $87 million at 
December 31, 2012. 

69

 
 
Table of Contents 

Non-performing loans increased during 2016 primarily as a result of pressure on the energy lending portfolio as discussed 
in the "Portfolio Characteristics" section. Economic trends such as interest rates, unemployment, volatility in commodity prices 
and collateral valuations will impact the future level of non-performing assets. Circumstances related to individually large credits 
could also result in volatility throughout 2017.

Loans past due 90 days or more and still accruing, excluding government guaranteed loans, were $170 million at December 31, 

2016, a decrease from $213 million at December 31, 2015.

At  December 31,  2016,  Regions  had  approximately  $125  million  to  $200  million  of  potential  problem  commercial  and 
investor real estate loans that were not included in non-accrual loans, but for which management had concerns as to the ability of 
such borrowers to comply with their present loan repayment terms. This is a likely estimate of the amount of commercial and 
investor real estate loans that have the potential to migrate to non-accrual status in the next quarter.

In order to arrive at the estimate of potential problem loans, personnel from geographic regions forecast certain larger dollar 
loans that may potentially be downgraded to non-accrual at a future time, depending on the occurrence of future events. These 
personnel consider a variety of factors, including the borrower’s capacity and willingness to meet the contractual repayment terms, 
make principal curtailments or provide additional collateral when necessary, and provide current and complete financial information 
including  global  cash  flows,  contingent  liabilities  and  sources  of  liquidity.  Based  upon  the  consideration  of  these  factors,  a 
probability weighting is assigned to loans to reflect the potential for migration to the pool of potential problem loans during this 
specific time period. Additionally, for other loans (for example, smaller dollar loans), a trend analysis is incorporated to determine 
the  estimate  of  potential  future  downgrades.  Because  of  the  inherent  uncertainty  in  forecasting  future  events,  the  estimate  of 
potential problem loans ultimately represents the estimated aggregate dollar amounts of loans as opposed to an individual listing 
of loans.

The majority of the loans on which the potential problem loan estimate is based are considered criticized and classified. 
Detailed disclosures for substandard accrual loans (as well as other credit quality metrics) are included in Note 6 “Allowance for 
Credit Losses” to the consolidated financial statements.

The following table provides an analysis of non-accrual loans (excluding loans held for sale) by portfolio segment for the 

periods presented: 

Table 20—Analysis of Non-Accrual Loans

Balance at beginning of year

Additions

Net payments/other activity

Return to accrual
Charge-offs on non-accrual loans(2)
Transfers to held for sale(3)

Transfers to foreclosed properties

Sales

Balance at end of year

Balance at beginning of year

Additions

Net payments/other activity

Return to accrual
Charge-offs on non-accrual loans(2)
Transfers to held for sale(3)

Transfers to foreclosed properties

Sales

Balance at end of year

Non-Accrual Loans, Excluding Loans Held for Sale as of December 31, 2016

Commercial

Investor
Real Estate

Consumer(1)

Total

(In millions)

$

595

861

(341)

(87)

(136)

(46)

(4)

(6)

31

20

(17)

(13)

(2)

(1)

—

(1)

$

156

$

—

(12)

—

(1)

(1)

—

—

836

$

17

$

142

$

782

881

(370)

(100)

(139)

(48)

(4)

(7)

995

Non-Accrual Loans, Excluding Loans Held for Sale as of December 31, 2015

Commercial

Investor
Real Estate

Consumer(1)

Total

$

(In millions)

125

$

211

$

$

$

$

33

(53)

(20)

(15)

(6)

(33)

—

31

—

(53)

—

(1)

(1)

—

—

$

156

$

829

717

(342)

(149)

(164)

(66)

(40)

(3)

782

493

684

(236)

(129)

(148)

(59)

(7)

(3)

$

595

$

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________
(1)  All net activity within the consumer portfolio segment other than sales and transfers to held for sale (including related charge-offs) is included 

as a single net number within the net payments/other activity line.

(2)  Includes charge-offs on loans on non-accrual status and charge-offs taken upon sale and transfer of non-accrual loans to held for sale.
(3)  Transfers to held for sale are shown net of charge-offs of  $21 million and $51 million recorded upon transfer for the years ended December 31, 

2016 and 2015, respectively. 

Other Earning Assets

Other earning assets consist primarily of investments in FRB stock, FHLB stock, and operating lease assets. The balance at 
December 31, 2016 totaled $1.6 billion as compared to $1.7 billion at  December 31, 2015. The primary driver of the slight decrease  
between years was a decrease in operating lease assets.

Refer to Note 8 "Other Earning Assets" to the consolidated financial statements for additional information.

Premises and Equipment

Premises  and  equipment  at  December 31,  2016  decreased  $56  million  to  $2.1  billion  compared  to  year-end  2015. This 

decrease primarily resulted from depreciation expense on existing assets, combined with branch consolidation initiatives.

Goodwill

Goodwill totaled $4.9 billion for both December 31, 2016 and 2015 and was reallocated to the new reporting units during 
2016. Refer to the “Critical Accounting Policies” section earlier in this report for detailed discussions of the Company’s methodology 
for testing goodwill for impairment. Refer to Note 1 “Summary of Significant Accounting Policies” and Note 10 “Intangible 
Assets” to the consolidated financial statements for the methodologies and assumptions used in Step One of the goodwill impairment 
test and further details on the reallocation. Additionally, Note 1 “Summary of Significant Accounting Policies” to the consolidated 
financial statements includes information related to the fair value measurements of certain assets and liabilities and the valuation 
methodology of such measurements, which is also used for testing goodwill for impairment.

Residential Mortgage Servicing Rights at Fair Value

Residential MSRs increased approximately $72 million from December 31, 2015 to December 31, 2016. The year-over-year 
increase  is  primarily  due  to  purchases  of  the  rights  to  service  approximately  $8  billion  in  residential  mortgage  loans  for 
approximately $69 million, combined with additions resulting from loans sold during the year. These total additions exceeded the 
economic amortization associated with borrower repayments. An analysis of residential MSRs is presented in Note 7 “Servicing 
of Financial Assets” to the consolidated financial statements. 

Deposits

Regions competes with other banking and financial services companies for a share of the deposit market. Regions’ ability 
to compete in the deposit market depends heavily on the pricing of its deposits and how effectively the Company meets customers’ 
needs. Regions employs various means to meet those needs and enhance competitiveness, such as providing a high level of customer 
service, competitive pricing and providing convenient branch locations for its customers. Regions also serves customers through 
providing centralized, high-quality banking services and alternative product delivery channels such as mobile and internet banking.

Deposits are Regions’ primary source of funds, providing funding for 88 percent of average earning assets in 2016 and 90 
percent of average earning assets in 2015. Table 21 “Deposits” details year-over-year deposits on a period-ending basis.  Total 
deposits at December 31, 2016 increased approximately $605 million compared to year-end 2015 levels. The increase in deposits 
was primarily driven by increases in non-interest-bearing demand, savings and money market-domestic accounts. These increases 
were partially offset by declines in time deposits and interest-bearing transaction accounts.

Due to liquidity in the market, Regions has been able to steadily grow its low-cost customer deposits and therefore deposit 
costs have remained relatively consistent at 12 basis points for 2016, compared to 11 basis points for both 2015 and 2014. The 
following table summarizes deposits by category as of December 31:

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Table 21—Deposits

Non-interest-bearing demand
Savings
Interest-bearing transaction
Money market—domestic
Money market—foreign

Low-cost deposits

Time deposits

Customer deposits

Corporate treasury time deposits

2016

2015

(In millions)

2014

$

$

36,046
7,840
20,259
27,293
186
91,624
7,183
98,807
228
99,035

$

$

34,862
7,287
21,902
26,468
243
90,762
7,468
98,230
200
98,430

$

$

31,747
6,653
21,544
25,396
265
85,605
8,595
94,200
—
94,200

Within customer deposits, non-interest-bearing demand deposits increased $1.2 billion to $36.0 billion. Non-interest-bearing 
deposits accounted for approximately 36 percent of total deposits at year-end 2016 compared to 35 percent at year-end 2015. 
Savings  balances  increased  $553  million  to  $7.8  billion,  generally  reflecting  continued  consumer  savings  trends,  spurred  by 
economic uncertainty. Money market-domestic accounts increased $825 million to $27.3 billion. Money market-domestic accounts 
accounted for approximately 28 percent and 27 percent of total deposits at year-end 2016 and 2015, respectively.

Interest-bearing transaction accounts decreased $1.6 billion to $20.3 billion as a result of certain trust customer deposits, 
which require collateralization by securities, continuing to shift out of deposits and into other fee income-producing customer 
investments.

Included in customer time deposits are certificates of deposit and individual retirement accounts. The balance of customer 
time deposits decreased approximately 4 percent in 2016 to $7.2 billion compared to $7.5 billion in 2015. The decrease was 
primarily due to maturities with minimal reinvestment by customers as a result of the continued decline in interest rates offered 
on these products. Customer time deposits accounted for 7 percent of total deposits in 2016 compared to 8 percent in 2015. See 
Table 22 “Maturity of Time Deposits of $100,000 or More” for maturity information. 

During 2016, corporate treasury deposits remained at low levels as the Company continued to utilize customer-based funding 

and other sources. 

The sensitivity of Regions’ deposit rates to changes in market interest rates is reflected in Regions’ average interest rate paid 
on interest-bearing deposits. The rate paid on interest-bearing deposits increased slightly to 0.19 percent in 2016 compared to 0.17 
percent for both 2015 and 2014, driven by market interest rate increases that occurred in 2016. 

Table 22—Maturity of Time Deposits of $100,000 or More  

Time deposits of $100,000 or more, maturing in:

3 months or less
Over 3 through 6 months
Over 6 through 12 months
Over 12 months

Short-Term Borrowings

2016

2015

(In millions)

$

$

532
243
491
1,844
3,110

$

$

679
223
438
1,646
2,986

See  Note  12  “Short-Term  Borrowings”  to  the  consolidated  financial  statements  for  a  summary  of  these  borrowings  at 
December 31, 2016 and 2015. The levels of these borrowings can fluctuate depending on the Company’s funding needs and the 
sources utilized, as well as a result of customers’ activity. 

In the near term, Regions expects the use of wholesale unsecured borrowings for its funding needs to remain low. Short-
term secured borrowings, such as securities sold under agreements to repurchase and FHLB advances, are a core portion of Regions' 
funding strategy. 

The securities financing market and specifically short-term FHLB advances, however, continue to provide reliable funding 

at attractive rates. See the "Liquidity Risk" section for further detail of Regions' borrowing capacity with the FHLB.

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Long-Term Borrowings

Total long-term borrowings decreased approximately $586 million to $7.8 billion at December 31, 2016. The decrease was 
primarily the result of an approximately $1.0 billion decrease in the FHLB advances and the repurchase, through a tender offer, 
of approximately $649 million of the outstanding 2.00% senior notes due May 2018. Offsetting these decreases was the issuance 
of $1.1 billion of 3.20% senior notes. 

See Note 13 “Long-Term Borrowings” to the consolidated financial statements for further discussion and detailed listing of 

outstandings and rates.

Ratings

  Table 23 “Credit Ratings” reflects the debt ratings information of Regions Financial Corporation and Regions Bank by 
Standard and Poor's ("S&P"), Moody’s, Fitch and Dominion Bond Rating Service ("DBRS") as of December 31, 2016 and 2015.

Table 23—Credit Ratings 

Regions Financial Corporation
Senior unsecured debt
Subordinated debt

Regions Bank
Short-term
Long-term bank deposits
Long-term rating
Senior unsecured debt
Subordinated debt

Outlook

Regions Financial Corporation
Senior unsecured debt
Subordinated debt

Regions Bank
Short-term
Long-term bank deposits
Long-term rating
Senior unsecured debt
Subordinated debt

Outlook

_________
N/A - not applicable.

As of December 31, 2016

S&P

Moody’s

Fitch

DBRS

BBB
BBB-

A-2
N/A
BBB+
BBB+
BBB
Stable

Baa2
Baa2

P-1
A2
A2
Baa2
Baa2
Stable

BBB
BBB-

F2
BBB+
BBB
BBB
BBB-
Positive

BBBH
BBB

R-1L
AL
N/A
AL
BBBH
Stable

As of December 31, 2015

S&P

Moody’s

Fitch

DBRS

BBB
BBB-

A-2
N/A
BBB+
BBB+
BBB
Stable

Baa3
Baa3

P-2
A3
A3
Baa3
Baa3
Stable

BBB
BBB-

F2
BBB+
BBB
BBB
BBB-
Stable

BBB
BBBL

R-1L
BBBH
N/A
BBBH
BBB
Positive

On October 4, 2016, Fitch revised the outlook for Regions Financial Corporation to Positive from Stable, reflecting the 

Company’s capital and liquidity profile, improving earnings, and continued improvement in asset quality.

On  November  2,  2016,  Moody's  upgraded  the  senior  unsecured  and  subordinated  debt  ratings  of  Regions  Financial 
Corporation.   Further, Moody’s upgraded Regions Bank's long-term deposit, short-term deposit,  senior unsecured and subordinated 
debt ratings.  Following the upgrade, the outlook for the Company is Stable.  The upgrade is reflective of the Company's continued 
improvement in asset quality, sensitivity to asset concentrations in its loan portfolio, reduction in direct-energy loan exposure, and 
strong capital and liquidity profile. 

On December 9, 2016, DBRS upgraded the senior unsecured and subordinated debt ratings for Regions Financial Corporation. 
Further, DBRS upgraded Regions Bank’s long-term deposit, senior unsecured debt and subordinated debt ratings.  The trend for 
all ratings is Stable. The upgrade is reflective of the progress the Company has made improving its asset quality and reducing its 
risk profile, while improving core profitability.

On February 10, 2017, S&P revised the outlook for Regions Financial Corporation, and its subsidiary, Regions Bank to 
Positive from Stable, indicating a possible one-notch upgrade over the next two years.  The outlook upgrade is reflective of a 

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reduction in energy loan exposure and the expectation of manageable non-performing assets and net charge-off levels in 2017 
given improved energy prices and stability of economic trends in most of the Company’s major markets.  Furthermore, the outlook 
revision cited the Company’s conservative business growth strategies and improved risk management.

In  general,  ratings  agencies  base  their  ratings  on  many  quantitative  and  qualitative  factors,  including  capital  adequacy, 
liquidity, asset quality, business mix, probability of government support, and level and quality of earnings. Any downgrade in 
credit ratings by one or more ratings agencies may impact Regions in several ways, including, but not limited to, Regions’ access 
to the capital markets or short-term funding, borrowing cost and capacity, collateral requirements, and acceptability of its letters 
of credit, thereby potentially adversely impacting Regions’ financial condition and liquidity. See the “Risk Factors” section of this 
Annual Report on Form 10-K for more information.

A security rating is not a recommendation to buy, sell or hold securities, and the ratings are subject to revision or withdrawal 

at any time by the assigning rating agency. Each rating should be evaluated independently of any other rating.

Stockholders' Equity

Stockholders’ equity was $16.7 billion at December 31, 2016 as compared to $16.8 billion at December 31, 2015. During 
2016, net income increased stockholders’ equity by $1.2 billion, while cash dividends on common stock reduced stockholders' 
equity by $318 million and cash dividends on preferred stock reduced stockholder's equity by $64 million. Changes in accumulated 
other comprehensive income reduced stockholders' equity by $170 million, primarily due to the net change in the value of securities 
available for sale and derivative instruments. Common stock repurchased during 2016 reduced stockholders' equity by $839 million. 
These shares were immediately retired and therefore are not included in treasury stock.

On June 29, 2016, Regions received no objection from the Federal Reserve to its 2016 capital plan that was submitted as 
part of the CCAR  process. In addition to continuing the $0.065 quarterly common stock dividend, actions that Regions may 
undertake as outlined in its capital plan include the repurchase of up to $640 million in common shares. The capital plan also 
provides the potential for a dividend increase beginning in the second quarter of 2017, which is expected to be considered by the 
Board in early 2017. 

On July 14, 2016, Regions' Board authorized a new $640 million common stock repurchase plan, permitting repurchases 
from the beginning of the third quarter of 2016 through the second quarter of 2017. On October 12, 2016, Regions' Board authorized 
an  additional  $120  million  repurchase,  which  increases  the  total  amount  authorized  under  the  plan  to  $760  million. As  of 
December 31, 2016, Regions had repurchased approximately 46.5 million shares of common stock at a total cost of approximately 
$485 million under this plan. The Company continued to repurchase shares under this plan in the first quarter of 2017, and as of 
February 23, 2017, Regions had additional repurchases of approximately 10.2 million shares of common stock at a total cost of 
approximately $149.8 million. All of these shares were immediately retired upon repurchase and, therefore, will not be included 
in treasury stock.

Regions’ Board increased the annual dividend to $0.255 per common share for 2016, compared to $0.23 per common share 
for 2015 and $0.18 per common share for 2014. The Board also declared $64 million in cash dividends on preferred stock for both 
2016 and 2015, and $52 million for 2014. Prior to the first quarter of 2016, the Company was in a retained deficit position and 
common stock dividends were recorded as a reduction of additional paid-in capital, while preferred dividends were recorded as a 
reduction of preferred stock, including related surplus. During the first quarter of 2016, the Company achieved positive retained 
earnings and both common stock and preferred dividends were recorded as a reduction of retained earnings.

See Note 15 “Stockholders’ Equity and Accumulated Other Comprehensive Income (Loss)” to the consolidated financial 

statements for additional information.

REGULATORY REQUIREMENTS 

CAPITAL RULES

Regions and Regions Bank are required to comply with regulatory capital requirements established by Federal and State 
banking agencies. These regulatory capital requirements involve quantitative measures of assets, liabilities and certain off-balance 
sheet  items,  and  also  qualitative  judgments  by  the  regulators.  Failure  to  meet  minimum  capital  requirements  can  subject  the 
Company to a series of increasingly restrictive regulatory actions. See Note 14 "Regulatory Capital Requirements and Restrictions" 
to the consolidated financial statements for a tabular presentation of the applicable holding company and bank regulatory capital 
requirements.

In 2013, the Federal Reserve released its final rules detailing the U.S. implementation of the Basel III Rules. Under the Basel 
III Rules, Regions is designated as a standardized approach bank and, as such, began transitioning to the Basel III Rules in January 
2015 subject to a phase-in period extending to January 2019. When fully phased in, the Basel III Rules will increase capital 
requirements through higher minimum capital levels as well as through increases in risk-weights for certain exposures. Additionally, 
the Basel III Rules place greater emphasis on common equity. The Basel III Rules substantially revise the regulatory capital 
requirements applicable to BHCs and depository institutions, including Regions and Regions Bank. The Basel III Rules define 

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the components of capital and address other issues affecting the numerator in banking institutions' regulatory capital ratios. The 
Basel III Rules also address risk weights and other issues affecting the denominator in banking institutions' regulatory capital 
ratios to incorporate a more risk-sensitive approach. The Basel III Rules also implement the requirements of Section 939A of the 
Dodd-Frank Act to remove references to credit ratings from the federal banking agencies' rules. 

The Basel III Rules, among other things, (i) introduce a measure called CET1, (ii) specify that Tier 1 capital consists of CET1 
and “Additional Tier 1 capital” instruments meeting specified requirements, (iii) define CET1 narrowly by requiring that most 
deductions/adjustments to regulatory capital measures be made to CET1 and not to the other components of capital and (iv) expand 
the scope of the deductions/adjustments to capital as compared to prior regulations.

Under the Basel III Rules, the initial minimum capital ratios as of January 1, 2015 were as follows:

• 

• 

• 

4.5% CET1 to risk-weighted assets.

6.0% Tier 1 capital to risk-weighted assets.

8.0% Total capital to risk-weighted assets.

The Basel III Rules also introduce a new capital conservation buffer designed to absorb losses during periods of economic 
stress. The capital conservation buffer is on top of these minimum risk-weighted asset ratios. In addition, the Basel III Rules 
provide for a countercyclical capital buffer applicable only to advanced approach institutions. Currently the countercyclical capital 
buffer is not applicable to Regions or Regions Bank. The reportable capital conservation buffer is equal to the lowest difference 
between the three risk-based capital ratios less the applicable minimum required ratio.  Banking institutions with ratios that are  
above the minimum but below the combined capital conservation buffer and countercyclical capital buffer (when applicable) will 
face constraints on dividends, equity repurchases and compensation based on the amount of the shortfall. 

When fully phased in on January 1, 2019, the Basel III Rules will require Regions and Regions Bank to maintain an additional 
capital conservation buffer of 2.5% of CET1 to risk-weighted assets, effectively resulting in minimum ratios of (i) CET1 to risk-
weighted assets of at least 7%, (ii) Tier 1 capital to risk-weighted assets of at least 8.5%, and (iii) Total capital to risk-weighted 
assets of at least 10.5%. 

The Basel III Rules provide for a number of deductions from and adjustments to CET1. For example, goodwill and certain 
other intangible assets, as well as certain deferred tax assets are deducted. MSRs, certain other deferred tax assets and significant 
investments in non-consolidated financial entities are also deducted from CET1 to the extent that any one such category exceeds 
10% of CET1 or all such categories in the aggregate exceed 15% of CET1. Under the Basel III Rules, the effects of certain 
accumulated other comprehensive items are included; however, standardized approach banking organizations, including Regions 
and Regions Bank, may make a one-time permanent election to exclude these items. Regions and Regions Bank made this election 
in order to avoid significant variations in the level of capital depending upon the impact of interest rate fluctuations on the fair 
value of their securities portfolios.

Implementation of the deductions and other adjustments to CET1 began on January 1, 2015 and will be phased in over a 4-
year period (beginning at 40% on January 1, 2015 and an additional 20% per year thereafter). The implementation of the capital 
conservation buffer began on January 1, 2016 at the 0.625% level and be phased in over a 3-year period (increasing by that amount 
on each subsequent January 1, until it reaches 2.5% on January 1, 2019).

With respect to Regions Bank, the Basel III Rules also revise the prompt corrective action regulations pursuant to Section 
38  of  the  Federal  Deposit  Insurance Act,  by  (i)  introducing  a  CET1  ratio  requirement  at  each  level  (other  than  critically 
undercapitalized), with the required CET1 ratio being 6.5% for well-capitalized status; (ii) increasing the minimum Tier 1 capital 
ratio requirement for each category, with the required Tier 1 capital ratio for well-capitalized status being 8% (as compared to the 
previous 6%); and (iii) eliminating the provision that provides that a bank with a composite supervisory rating of 1 may have a 
3% leverage ratio and still be adequately capitalized. The Basel III Rules do not change the total capital requirement for any prompt 
corrective action category.

The Basel III Rules prescribe a standardized approach for risk weightings that expands the risk-weighting categories from 
the previous four Basel I-derived categories (0%, 20%, 50% and 100%) to a much larger and more risk-sensitive number of 
categories, depending on the nature of the assets, generally ranging from 0% for U.S. government and agency securities, to 1,250% 
for certain equity exposures, and resulting in higher risk weights for a variety of asset categories. Specific changes to the prior 
capital rules impacting Regions' determination of risk-weighted assets include, among other things:

•  Applying a 150% risk weight for certain high volatility commercial real estate acquisition, development and construction 

exposures (previously set at 100%).

•  Assigning a 150% risk weight to exposures (other than residential mortgage exposures) that are on non-accrual status or 

90 days or more past due (previously set at 100%).

• 

Providing for a 20% credit conversion factor for the unused portion of a loan commitment with an original maturity of 
less than one year that is not unconditionally cancellable (previously set at 0%). 

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•  Eliminating the previous 50% cap on the risk weight for derivative exposures.

•  Replacing the previous Ratings Based Approach for certain asset-backed securities with a SSFA, which results in risk 

weights ranging from 20% to 1,250% (previously ranged from 100% to 1,250%).

•  Effective January 1, 2018, applying a 250% risk weight to the portion of MSRs and certain deferred tax assets that are 

includible in capital (previously set at 100%).

In addition, the Basel III Rules also provide more advantageous risk weights for derivatives and repurchase-style transactions 
cleared through a qualifying central counterparty and increase the scope of eligible guarantors and eligible collateral for purposes 
of credit risk mitigation.

The Company’s estimated CET1 ratio on a fully phased-in basis as of December 31, 2016 was approximately 11.05% and 
therefore exceeded the Basel III minimum plus capital conservation buffer requirement of 7% for CET1. Because the Basel III 
capital calculations will not be fully phased in until 2019 and are not formally defined by GAAP, this measure is considered to be 
a non-GAAP financial measure, and other entities may calculate it differently than Regions’ disclosed calculation (see Table 2 
“GAAP to Non-GAAP Reconciliation” for further details).

LIQUIDITY COVERAGE RATIO 

The Federal Reserve, the OCC and the FDIC approved a final rule in 2014 implementing a minimum LCR requirement for 
certain large BHCs, savings and loan holding companies and depository institutions, and a less stringent LCR requirement (the 
"modified LCR") for other banking organizations, such as Regions, with $50 billion or more in total consolidated assets. The final 
rule imposes a monthly calculation requirement. As of January 1, 2017, the LCR calculation rule has been fully phased in. In 
December 2016, the Federal Reserve issued a final rule on the public disclosure of the LCR calculation that requires BHCs, such 
as Regions, to disclose publicly, on a quarterly basis, quantitative and qualitative information about certain components of its LCR 
beginning October 1, 2018.

At December 31, 2016, the Company was fully compliant with the LCR requirements. However, should the Company's cash 
position  or  investment  mix  change  in  the  future,  the  Company's  ability  to  meet  the  LCR  requirement  may  be  impacted,  and 
additional funding may need to be sourced to remain compliant.

See the “Supervision and Regulation—Liquidity Regulation” subsection of the “Business” section and the “Risk Factors” 

section for more information.

OFF-BALANCE SHEET ARRANGEMENTS

Regions  periodically  invests  in  various  limited  partnerships  that  sponsor  affordable  housing  projects,  which  are  funded 
through a combination of debt and equity. See Note 2 “Variable Interest Entities” to the consolidated financial statements for further 
discussion.

Regions' off-balance sheet credit risk includes obligations for loans sold with recourse, unfunded loan commitments, and 
letters of credit. See Note 7 "Servicing of Financial Assets" and Note 24 "Commitments, Contingencies and Guarantees" to the 
consolidated financial statements for further discussion.

EFFECTS OF INFLATION

The majority of assets and liabilities of a financial institution are monetary in nature; therefore, a financial institution differs 
greatly from most commercial and industrial companies, which have significant investments in fixed assets or inventories that are 
greatly impacted by inflation. However, inflation does have an important impact on the growth of total assets in the banking 
industry and the resulting need to increase equity capital at higher than normal rates in order to maintain an appropriate equity-
to-assets ratio. Inflation also affects other expenses that tend to rise during periods of general inflation.

Management believes the most significant potential impact of inflation on financial results is a direct result of Regions’ ability 
to manage the impact of changes in interest rates. Management attempts to maintain an essentially balanced position between rate-
sensitive assets and liabilities in order to minimize the impact of interest rate fluctuations on net interest income and other financing 
income. However, this goal can be difficult to completely achieve in times of rapidly changing rate structure and is one of many 
factors  considered  in  determining  the  Company’s  interest  rate  positioning. The  Company  is  moderately  asset  sensitive  as  of 
December 31, 2016. Refer to Table 24 “Interest Rate Sensitivity” for additional details on Regions’ interest rate sensitivity.

EFFECTS OF DEFLATION

A period of deflation would affect all industries, including financial institutions. Potentially, deflation could lead to lower 
profits, higher unemployment, lower production and deterioration in overall economic conditions. In addition, deflation could 
depress economic activity and impair bank earnings through increasing the value of debt while decreasing the value of collateral 
for loans. If the economy experienced a severe period of deflation, then it could depress loan demand, impair the ability of borrowers 
to repay loans and sharply reduce bank earnings.

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Management believes the most significant potential impact of deflation on financial results relates to Regions’ ability to 
maintain a sufficient amount of capital to cushion against future losses. However, the Company can utilize certain risk management 
tools to help it maintain its balance sheet strength even if a deflationary scenario were to develop.

RISK MANAGEMENT

Regions is exposed to various risks as part of the normal course of operations. The exposure to risk requires sound risk 
management  practices  that  comprise  an  integrated  and  comprehensive  set  of  programs  and  processes  that  apply  to  the  entire 
Company. Accordingly, Regions has established a risk management framework to manage risks and provide reasonable assurance 
of the achievement of the Company’s strategic objectives.

The primary risk exposures identified and managed through the Company’s risk management framework are market risk, 

liquidity risk, credit risk, operational risk, legal risk, compliance risk, reputational risk and strategic risk.

•  Market risk is the risk to Regions’ financial condition resulting from adverse movements in market rates or prices, 

such as interest rates, foreign exchange rates or equity prices. 

•  Liquidity risk is the potential that the Company will be unable to meet its obligations as they come due because of 
an inability to liquidate assets or obtain adequate funding (referred to as "funding liquidity risk") or the potential 
that it cannot easily unwind or offset specific exposures without significantly lowering market prices because of 
inadequate market depth or market disruptions ("market liquidity risk"). 

•  Credit risk is the risk that arises from the potential that a borrower or counterparty will fail to perform on an 

obligation. 

•  Operational risk is the risk of loss resulting from inadequate or failed internal processes, people, and systems or 

from external events.

•  Legal risk is the risk that arises from the potential that unenforceable contracts, lawsuits, or adverse judgments can 

disrupt or otherwise negatively affect the operations or condition of the Company. 

•  Compliance risk is the risk to current or anticipated earnings or capital arising from violations of laws, rules, or 
regulations,  or  from  non-conformance  with  prescribed  practices,  internal  policies  and  procedures,  or  ethical 
standards.

•  Reputational risk is the potential that negative publicity regarding Regions' business practices, whether true or not, 

will cause a decline in the customer base, costly litigation, or revenue reductions. 

• 

Strategic risk is the risk to current or anticipated earnings, capital, or franchise or enterprise value arising from 
adverse business decisions, poor implementation of business decisions, or lack of responsiveness to changes in the 
banking industry and operating environment.

Several of these primary risk exposures are expanded upon further within the remaining sections of Management's Discussion 

and Analysis.

Regions’ risk management framework outlines the Company’s approach for managing risk that includes the following four 

components:

•  Culture - A strong, collaborative risk culture ensures focus on risk in all activities and encourages the necessary 
mindset and behavior to enable effective risk management and promote sound risk-taking within the bounds of the 
Company’s risk appetite. Our risk culture requires that risks be promptly identified, escalated, and challenged; 
thereby, benefiting the overall performance of the Company.

•  Appetite - The Company's risk appetite statements define the types and levels of risk the Company is willing to take 

to achieve its objectives.

•  Process  -  Effective  risk  management  requires  sustainable  processes  and  tools  to  effectively  identify,  measure, 

mitigate, monitor, and report risk.

•  Governance - Governance serves as the foundation for comprehensive management of risks facing the Company. 
It outlines clear responsibility and accountability for managing, monitoring, escalating, and reporting both existing 
and emerging risks.

Clearly defined roles and responsibilities are critical to the effective management of risk and are central to the four components 
of the Company’s approach to risk management. Regions utilizes the Three Lines of Defense concept to clearly designate risk 
management activities within the Company.

• 

• 

1st Line of Defense activities provide for the identification, acceptance and ownership of risks.

2nd Line of Defense activities provide for objective oversight of the Company’s risk-taking activities and assessment 
of the Company’s aggregate risk levels.

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• 

3rd Line of Defense activities provide for independent reviews and assessments of risk management practices across 
the Company.

The Board provides the highest level of risk management governance. The principal risk management functions of the Board 
are to oversee processes for evaluating the adequacy of internal controls, risk management, financial reporting and compliance 
with laws and regulations. The Board has designated an Audit Committee of outside directors to focus on oversight of management's 
establishment and maintenance of appropriate disclosure controls and procedures over financial reporting. See the "Financial 
Disclosures and Internal Controls" section of Management's Discussion and Analysis for additional information.  The Board has 
also designated a Risk Committee of outside directors to focus on Regions’ overall risk profile. The Risk Committee annually 
approves an Enterprise Risk Appetite Statement that reflects core business principles and strategic vision by including quantitative 
limits and qualitative statements that are organized by risk type.  This statement is designed to be a high-level document that sets 
the tone for the Board’s risk appetite, which is the maximum amount of risk the Company is willing to accept in pursuit of its 
business objectives. By establishing boundaries around risk taking and business decisions, and by incorporating the needs and 
goals of its stockholders, regulators, customers and other stakeholders, the Company’s risk appetite is aligned with its strategic 
priorities and goals.

The Risk Management Group, led by the Company’s Chief Risk Officer, ensures the consistent application of Regions’ risk 
management approach within the structure of the Company’s operating, capital and strategic plans. The primary activities of the 
Risk Management Group include:

• 

• 

Interpreting internal and external signals that point to possible risk issues for the Company;

Identifying risks and determining which Company areas and/or products will be affected;

•  Ensuring there are mechanisms in place to specifically determine how risks will affect the Company as a whole and 

the individual area and or product;

•  Assisting business groups in analyzing trends and ensuring Company areas have appropriate risk identification and 

mitigation processes in place; and

•  Reviewing the limits, parameters, policies, and procedures in place to ensure the continued appropriateness of risk 

controls.

As part of its ongoing assessment process, the Risk Management Group makes recommendations to management and the 
Risk Committee of the Board regarding adjustments to these controls as conditions or risk tolerances change. In addition, the 
Internal Audit division provides an independent assessment of the Company’s internal control structure and related systems and 
processes.

Management, with the assistance of the Risk Management Group, follows a formal process for identifying, measuring and 
documenting key risks facing each business group and determining how those risks can be controlled or mitigated, as well as how 
the controls can be monitored to ensure they are effective. The Risk Committee receives reports from management to ensure 
operations are within the limits established by the Committee’s Enterprise Risk Appetite Statement.

Some of the more significant processes used by management to manage and control risks are described in the remainder of 

this report.  External factors beyond management’s control may result in losses despite the Risk Management Group’s efforts.

MARKET RISK—INTEREST RATE RISK  

Regions’ primary market risk is interest rate risk. This includes uncertainty with respect to absolute interest rate levels as 
well as relative interest rate levels, which are impacted by both the shape and the slope of the various yield curves that affect the 
financial products and services that the Company offers. To quantify this risk, Regions measures the change in its net interest 
income and other financing income in various interest rate scenarios compared to a base case scenario. Net interest income and 
other financing income sensitivity to market rate movements is a useful short-term indicator of Regions’ interest rate risk.

Sensitivity Measurement—Financial simulation models are Regions’ primary tools used to measure interest rate exposure. 
Using a wide range of sophisticated simulation techniques provides management with extensive information on the potential impact 
to net interest income and other financing income caused by changes in interest rates. Models are structured to simulate cash flows 
and accrual characteristics of Regions’ balance sheet. Assumptions are made about the direction and volatility of interest rates, the 
slope of the yield curve, and the changing composition of the balance sheet that result from both strategic plans and from customer 
behavior. Among the assumptions are expectations of balance sheet growth and composition, the pricing and maturity characteristics 
of existing business and the characteristics of future business. Interest rate-related risks are expressly considered, such as pricing 
spreads, the pricing of deposit accounts, prepayments and other option risks. Regions considers these factors, as well as the degree 
of certainty or uncertainty surrounding their future behavior.

The primary objective of asset/liability management at Regions is to coordinate balance sheet composition with interest rate 
risk management to sustain reasonable and stable net interest income and other financing income throughout various interest rate 
cycles. In computing interest rate sensitivity for measurement, Regions compares a set of alternative interest rate scenarios to the 

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results of a base case scenario based on “market forward rates.” The standard set of interest rate scenarios includes the traditional 
instantaneous parallel rate shifts of plus 100 and 200 basis points. While not presented, up-rate scenarios of greater magnitude are 
also analyzed. Regions prepares a minus 50 basis points scenario, as minus 100 and 200 basis points scenarios are of limited use 
in  the  current  rate  environment.  In  addition  to  parallel  curve  shifts,  multiple  curve  steepening  and  flattening  scenarios  are 
contemplated.  Regions includes simulations of gradual interest rate movements phased in over a six-month period that may more 
realistically mimic the speed of potential interest rate movements.

Exposure to Interest Rate Movements—As of December 31, 2016, Regions was moderately asset sensitive to both gradual 
and instantaneous parallel yield curve shifts as compared to the base case for the measurement horizon ending December 2017. 
The estimated exposure associated with the parallel yield curve shift of minus 50 basis points in the table below reflects the 
combined impacts of movements in short-term and long-term interest rates. The decline in short-term interest rates (such as the 
Fed Funds rate and the rate of Interest on Excess Reserves) will lead to a reduction of yield on assets and liabilities contractually 
tied to such rates. Recent Federal Funds increases have not resulted in higher deposit costs for Regions. Therefore, it is expected 
that declines in deposit costs will only partially offset the decline in asset yields. A reduction in long-term interest rates (such as 
intermediate to longer-term U.S. Treasuries, swap and mortgage rates) will drive yields lower on certain fixed rate, newly originated 
or renewed loans, reduce prospective yields on certain investment portfolio purchases, and increase amortization of premium 
expense on existing securities in the investment portfolio.

With respect to sensitivity to long-term interest rates, the balance sheet is estimated to be moderately asset sensitive. Current 
simulation models estimate that, as compared to the base case, net interest income and other financing income over a 12 month 
horizon would respond favorably by approximately $96 million if longer-term interest rates were to immediately and on a sustained 
basis exceed the base scenario by 100 basis points. Conversely, if longer-term interest rates were to immediately and on a sustained 
basis underperform the base case by 50 basis points, then net interest income and other financing income, as compared to the base 
case, would decline by approximately $54 million. Higher long-term rates experienced during the fourth quarter reduced the interest 
income sensitivity afforded by potential further extension of investment securities and the resulting impact on premium amortization. 
While the benefit of lower premium amortization will persist, incremental improvements will be smaller than observed through 
the recent market rate increase. Estimates may vary to the extent that long-term yield curve basis relationships change. The table 
below summarizes Regions' positioning in various parallel yield curve shifts (i.e. including both long-term and short-term interest 
rates). The scenarios are inclusive of all interest rate risk hedging activities.

Table 24—Interest Rate Sensitivity  

Gradual Change in Interest Rates

+ 200 basis points
+ 100 basis points
- 50 basis points

Instantaneous Change in Interest Rates

+ 200 basis points
+ 100 basis points
- 50 basis points

Estimated Annual Change
in Net Interest Income and 
Other Financing Income
December 31, 2016

(In millions)

$

$

219
127
(66)

222
152
(107)

As discussed above, the interest rate sensitivity analysis presented in Table 24 is informed by a variety of assumptions and 
estimates regarding the course of the balance sheet in both the baseline scenario as well as the scenarios of instantaneous and 
gradual shifts in the yield curve. Though there are many assumptions which affect the estimates for net interest income and other 
financing income, those pertaining to deposit pricing, deposit mix and overall balance sheet composition are particularly impactful. 
Given the uncertainties associated with interest rate increases following a prolonged period of low interest rates, management 
evaluates the impact to its sensitivity analysis of these key assumptions. Sensitivity calculations are hypothetical and should not 
be considered to be predictive of future results.

The Company’s baseline balance sheet growth assumptions include continued moderate loan and deposit growth reflecting 
management's best estimate. The behavior of deposits in response to changes in interest rate levels is largely informed by analyses 
of prior rate cycles, but with suitable adjustments based on management’s expectations in the current rate environment. In the + 
200 basis point gradual interest rate change scenario in Table 24, the total cumulative interest bearing deposit re-pricing sensitivity 
is expected to be approximately 60 percent of changes in short-term market rates (e.g. Fed Funds), as compared to approximately 
55 percent in the 2004 to 2007 historical timeframe. A 5 percentage point higher sensitivity than the 60 percent baseline would 
reduce 12 month net interest income and other financing income in the gradual +200 basis points scenario by approximately $74 

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million. While the estimates should be used as a guide, differences may result driven by the pace of rate changes, and other market 
and competitive factors.

Similarly, management assumes that the change in the mix of deposits in a rising rate environment versus the baseline balance 
sheet growth assumptions is informed by analyses of prior rate cycles. Management assumes that in rising rate scenarios, some 
shift from non-interest bearing to interest-bearing products will occur. The magnitude of the shift is rate dependent, but equates 
to approximately $3.5 billion over 12 months in the gradual +200 basis point scenario in Table 24. In the event this shift increased 
by an additional $3.0 billion over 12 months, the result would be a reduction of 12 month net interest income and other financing 
income in the gradual +200 basis points scenario by approximately $25 million. 

Interest rate movements may also have an impact on the value of Regions’ securities portfolio, which can directly impact 
the carrying value of stockholders’ equity. Regions from time to time may hedge these price movements with derivatives (as 
discussed below). 

Derivatives—Regions uses financial derivative instruments for management of interest rate sensitivity. ALCO, which consists 
of members of Regions’ senior management team, in its oversight role for the management of interest rate sensitivity, approves 
the use of derivatives in balance sheet hedging strategies. Derivatives are also used to offset the risks associated with customer 
derivatives, which include interest rate, credit and foreign exchange risks. The most common derivatives Regions employs are 
forward rate contracts, Eurodollar futures contracts, interest rate swaps, options on interest rate swaps, interest rate caps and floors, 
and forward sale commitments. 

Forward rate contracts are commitments to buy or sell financial instruments at a future date at a specified price or yield. A 
Eurodollar futures contract is a future on a Eurodollar deposit. Eurodollar futures contracts subject Regions to market risk associated 
with changes in interest rates. Because futures contracts are cash settled daily, there is minimal credit risk associated with Eurodollar 
futures. Interest rate swaps are contractual agreements typically entered into to exchange fixed for variable (or vice versa) streams 
of interest payments. The notional principal is not exchanged but is used as a reference for the size of interest settlements. Interest 
rate options are contracts that allow the buyer to purchase or sell a financial instrument at a predetermined price and time. Forward 
sale commitments are contractual obligations to sell market instruments at a future date for an already agreed-upon price. Foreign 
currency contracts involve the exchange of one currency for another on a specified date and at a specified rate. These contracts 
are executed on behalf of the Company's customers and are used by customers to manage fluctuations in foreign exchange rates. 
The Company is subject to the credit risk that another party will fail to perform.

Regions has made use of interest rate swaps in balance sheet hedging strategies to effectively convert a portion of its fixed-
rate funding position and available for sale securities portfolios to a variable-rate position and to effectively convert a portion of 
its variable-rate loan portfolios to fixed-rate. Regions also uses derivatives to economically manage interest rate and pricing risk 
associated with its mortgage origination business. In the period of time that elapses between the origination and sale of mortgage 
loans, changes in interest rates have the potential to cause a decline in the value of the loans in this held-for-sale portfolio. Futures 
contracts and forward sale commitments are used to protect the value of the loan pipeline and loans held for sale from changes in 
interest rates and pricing. 

The following table presents additional information about the interest rate swaps used by Regions to manage interest rate 

risk:

Table 25—Hedging Derivatives by Interest Rate Risk Management Strategy 

December 31, 2016

Estimated Fair Value

Weighted-Average

Notional
Amount

Gain

Loss

Maturity
(Years)

Receive
Rate

Pay Rate

(Dollars in millions)

Interest rate swaps:

Derivatives in fair value hedging relationships:

     Receive fixed/pay variable

     Receive variable/pay fixed

Derivatives in cash flow hedging relationships:

     Receive fixed/pay variable

$ 1,850

$

407

9,000

     Total derivatives designated as hedging instruments

$ 11,257

$

1

6

19

26

$

$

26

14

269

309

3.1

10.4

4.9

4.8

1.2%

0.8

1.3

1.3%

0.9%

2.5

0.7

0.8%

Regions manages the credit risk of these instruments in much the same way as it manages credit risk of the loan portfolios 
by  establishing  credit  limits  for  each  counterparty  and  through  collateral  agreements  for  dealer  transactions.  For  non-dealer 
transactions, the need for collateral is evaluated on an individual transaction basis and is primarily dependent on the financial 
strength of the counterparty. Credit risk is also reduced significantly by entering into legally enforceable master netting agreements. 

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When there is more than one transaction with a counterparty and there is a legally enforceable master netting agreement in place, 
the exposure represents the net of the gain and loss positions with and collateral received from and/or posted to that counterparty. 
The majority of interest rate derivatives traded by Regions are subject to mandatory clearing. The counterparty risk for cleared 
trades effectively moves from the executing broker to the clearinghouse allowing Regions to benefit from the risk mitigation 
controls  in  place  at  the  respective  clearinghouse.  The  “Credit  Risk”  section  in  this  report  contains  more  information  on  the 
management of credit risk.

Regions also uses derivatives to meet the needs of its customers. Interest rate swaps, interest rate options and foreign exchange 
forwards are the most common derivatives sold to customers. Other derivatives instruments with similar characteristics are used 
to hedge market risk and minimize volatility associated with this portfolio. Instruments used to service customers are held in the 
trading account, with changes in value recorded in the consolidated statements of income.

The primary objective of Regions’ hedging strategies is to mitigate the impact of interest rate changes, from an economic 
perspective, on net interest income and other financing income and the net present value of its balance sheet. The overall effectiveness 
of  these  hedging  strategies  is  subject  to  market  conditions,  the  quality  of  Regions’  execution,  the  accuracy  of  its  valuation 
assumptions, counterparty credit risk and changes in interest rates. See Note 21 “Derivative Financial Instruments and Hedging 
Activities” to the consolidated financial statements for a tabular summary of Regions’ year-end derivatives positions and further 
discussion.

Regions accounts for residential MSRs at fair market value with any changes to fair value being recorded within mortgage 
income.  Regions  enters  into  derivative  and  balance  sheet  transactions  to  economically  mitigate  the  impact  of  market  value 
fluctuations related to residential MSRs. Derivative instruments entered into in the future could be materially different from the 
current risk profile of Regions’ current portfolio.

MARKET RISK—PREPAYMENT RISK 

Regions, like most financial institutions, is subject to changing prepayment speeds on mortgage-related assets under different 
interest  rate  environments.  Prepayment  risk  is  a  significant  risk  to  earnings  and  specifically  to  net  interest  income  and  other 
financing income. For example, mortgage loans and other financial assets may be prepaid by a debtor, so that the debtor may 
refinance its obligations at lower rates. As loans and other financial assets prepay in a falling rate environment, Regions must 
reinvest these funds in lower-yielding assets. Prepayments of assets carrying higher rates reduce Regions’ interest income and 
overall asset yields. Conversely, in a rising rate environment, these assets will prepay at a slower rate, resulting in opportunity cost 
by not having the cash flow to reinvest at higher rates. Prepayment risk can also impact the value of securities and the carrying 
value of equity. Regions’ greatest exposures to prepayment risks primarily rest in its mortgage-backed securities portfolio, the 
mortgage fixed-rate loan portfolio and the residential MSR, all of which tend to be sensitive to interest rate movements. Each of 
these assets is also exposed to prepayment risk due to factors which are not necessarily the result of interest rates, but rather due 
to changes in policies or programs related, either directly or indirectly, to the U.S. Government's governance over certain lending 
and financing within the mortgage market. Such policies can work to either encourage or discourage financing dynamics and 
represent a risk that is extremely difficult to forecast and may be the result of non-economic factors. The Company attempts to 
monitor and manage such exposures within reasonable expectations while acknowledging all such risks cannot be foreseen or 
avoided. Further, Regions has prepayment risk that would be reflected in non-interest income in the form of servicing income on 
the residential MSR. Regions actively monitors prepayment exposure as part of its overall net interest income and other financing 
income forecasting and interest rate risk management. 

LIQUIDITY RISK

Liquidity is an important factor in the financial condition of Regions and affects Regions’ ability to meet the borrowing needs 
and deposit withdrawal requirements of its customers. In 2014, the Federal Reserve Board, the OCC and the FDIC released the 
final version of the liquidity coverage ratio rule, which is designed to ensure that financial institutions have the necessary assets 
on hand to withstand short-term liquidity disruptions. See the "Liquidity Coverage Ratio" discussion included in the "Regulatory  
Requirements" section of Management's Discussion and Analysis for additional information.

Regions  intends  to  fund  its  obligations  primarily  through  cash  generated  from  normal  operations.  In  addition  to  these 
obligations, Regions has obligations related to potential litigation contingencies. See Note 24 “Commitments, Contingencies and 
Guarantees” to the consolidated financial statements for additional discussion of the Company’s funding requirements.

Assets, consisting principally of loans and securities, are funded by customer deposits, borrowed funds and stockholders’ 
equity. Regions’ goal in liquidity management is to satisfy the cash flow requirements of depositors and borrowers, while at the 
same time meeting the Company’s cash flow needs. Having and using various sources of liquidity to satisfy the Company’s funding 
requirements is important.

In order to ensure an appropriate level of liquidity is maintained, Regions performs specific procedures including scenario 
analyses and stress testing at the bank, holding company, and affiliate levels. Regions' liquidity policy requires the holding company 
to maintain cash sufficient to cover the greater of (1) 18 months of debt service and other cash needs or (2) a minimum cash balance 
of $500 million. Compliance with the holding company cash requirements is reported to the Risk Committee of the Board on a 

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quarterly basis. Regions also has minimum liquidity requirements for the Bank and subsidiaries. The Bank's funding and contingency 
planning does not include any reliance on short-term unsecured sources. Risk limits are established within the Company's Liquidity 
Risk Oversight Committee and ALCO, which regularly reviews compliance with the established limits.

The securities portfolio is one of Regions’ primary sources of liquidity. Proceeds from maturities and principal and interest 
payments of securities provide a constant flow of funds available for cash needs (see Note 4 “Securities” to the consolidated 
financial statements). The agency guaranteed mortgage-backed securities portfolio is another source of liquidity in various secured 
borrowing capacities.

Maturities in the loan portfolio also provide a steady flow of funds. Additional funds are provided from payments on consumer 
loans and one-to-four family residential first mortgage loans. Regions’ liquidity is further enhanced by its relatively stable customer 
deposit base. Liquidity needs can also be met by borrowing funds in state and national money markets, although Regions does not 
currently rely on short-term unsecured wholesale market funding. 

The balance with the FRB is the primary component of the balance sheet line item, “interest-bearing deposits in other banks.” 
At December 31, 2016, Regions had approximately $3.6 billion in cash on deposit with the Federal Reserve, down approximately 
9 percent from 2015. The average balance held with the Federal Reserve was approximately $2.6 billion during both 2016 and 
2015.

Regions’ borrowing availability with the FRB as of December 31, 2016, based on assets pledged as collateral on that date, 

was $15.6 billion.

Regions’ financing arrangement with the FHLB adds additional flexibility in managing the Company's liquidity position. As 
of December 31, 2016, Regions’ outstanding balance of FHLB borrowings was $4.3 billion and its total borrowing capacity from 
the FHLB totaled approximately $16.4 billion. FHLB borrowing capacity is contingent on the amount of collateral pledged to the 
FHLB. Regions Bank pledged certain securities, commercial real estate mortgage loans, residential first mortgage loans on one-
to-four family dwellings and home equity lines of credit as collateral for the FHLB advances outstanding. Additionally, investment 
in  FHLB  stock  is  required  in  relation  to  the  level  of  outstanding  borrowings.  Refer  to  Note  8  "Other  Earning Assets"  to  the 
consolidated financial statements for additional information. The FHLB has been and is expected to continue to be a reliable and 
economical source of funding.

Regions maintains a shelf registration statement with the U.S. Securities and Exchange Commission that can be utilized by 
Regions to issue various debt and/or equity securities. Regions may also issue bank notes from time to time, either as part of a 
bank note program or as stand-alone issuances. Refer to Note 13 "Long-Term Borrowings" to the consolidated financial statements 
for additional information. 

Regions may, from time to time, consider opportunistically retiring outstanding issued securities, including subordinated 
debt in privately negotiated or open market transactions for cash or common shares. Regulatory approval would be required for 
retirement of some instruments.

Table 26—Contractual Obligations 

Regions' contractual obligations and expected payment dates are presented in the following table:

Less than 1
Year

1-3 Years

4-5 Years

More than 5
Years

Indeterminable
Maturity

Total

Payments Due By Period 

(1)

$

3,189

$

2,207

$

1,828

$

187

$

91,624

$

(In millions)

4,252

136

22

44

653

—

28

1,353

218

1,106

144

1,202

263

54

24

—

—

—

26

38

—

—

—

36

68

—

—

—

—

—

—

—

—

35

—

99,035

7,913

761

138

174

653

35

28

Deposits (2)
Long-term borrowings

Lease obligations

Purchase obligations
Benefit obligations (3)
Commitments to fund low 
income housing partnerships (4)
Unrecognized tax benefits (5)
Indemnification obligation (6)

$

8,324

$

3,856

$

3,142

$

1,756

$

91,659

$

108,737

_________
(1)  See  Note  24  “Commitments,  Contingencies  and  Guarantees”  to  the  consolidated  financial  statements  for  the  Company’s  commercial 

commitments at December 31, 2016.

(2)  Deposits  with  indeterminable maturity  include  non-interest  bearing  demand,  savings,  interest-bearing  transaction  accounts  and  money 

market accounts.

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(3)  Amounts only include obligations related to the unfunded non-qualified pension plan and postretirement health care plan.
(4)  Commitments to fund low income housing partnerships includes commitments to make future investments, short-term construction loans 
and letters of credit, as well as the funded portions of these loans and letters of credit. All of these items are short-term in nature and the 
majority do not have defined maturity dates. Therefore, they have all been considered due on demand, maturing one year or less. See Note 
2 "Variable Interest Entities" to the consolidated financial statements for additional information.

(5)  Includes liabilities for unrecognized tax benefits of $31 million and tax-related interest and penalties of $4 million. See Note 20 “Income 

Taxes” to the consolidated financial statements.

(6)  See Note 24 “Commitments, Contingencies and Guarantees” to the consolidated financial statements for a description of the indemnification 

obligation to Raymond James, and the rationale for the expected payment timeframe.

CREDIT RISK

Regions’ objective regarding credit risk is to maintain a high-quality credit portfolio that provides for stable credit costs with 
acceptable volatility through an economic cycle. Regions has various processes to manage credit risk as described below. In order 
to assess the risk profile of the loan portfolio, Regions considers risk factors within the loan portfolio segments and classes, the 
current  U.S.  economic  environment  and  that  of  its  primary  banking  markets,  as  well  as  counterparty  risk.  See  the  "Portfolio 
Characteristics" section found earlier in this report for further information regarding the loan portfolio. See further discussion of 
the current U.S. economic environment and counterparty risk below. 

Management Process

Credit risk is managed by maintaining a sound credit risk culture, throughout all lines of defense, which ensures that the 
levels and types of risk taken are aligned with Regions' credit risk appetite.  The credit quality of borrowers and counterparties 
has a significant impact on Regions' earnings; however, the nature of the risk differs by each of the defined businesses which 
engage in multiple forms of commercial, investor real estate and consumer lending.  Regions categorizes the credit risks it faces 
by asset quality, counterparty exposure, and diversification levels which provides a structure to assess credit risk and guides credit 
decision-making.  Credit policies, another key component of Regions' culture, are designed and adjusted, as needed, to promote 
sound credit risk management.  These policies guide lending activities in a manner consistent with our strategy and provide a 
framework for achieving asset quality and earnings objectives.  

Effective credit risk management requires coordinated identification, measurement, mitigation, monitoring and reporting of 
credit risk exposure, credit quality, and emerging risk trends.  Accordingly, Regions has implemented a credit risk governance 
structure that provides oversight from the Board to the organizational units in order to maintain open channels of communication.

Occasionally, borrowers and counterparties do not fulfill their obligations and Regions must take steps to mitigate and manage 
losses.  Teams are in place to appropriately identify and manage nonperforming loans, collections, loan modifications, and loss 
mitigation efforts.  Regions maintains an allowance that management considers adequate to absorb losses inherent in the portfolio.

For  a  discussion  of  the  process  and  methodology  used  to  calculate  the  allowance for  credit  losses  refer  to  the  “Critical 
Accounting Estimates and Related Policies” section found earlier in this report, and Note 1 “Summary of Significant Accounting 
Policies” and Note 6 “Allowance for Credit Losses” to the consolidated financial statements. Details regarding the allowance for 
credit losses, including an analysis of activity from the previous year’s total, are included in Table 15 “Allowance for Credit 
Losses.” Also, refer to Table 16 “Allocation of the Allowance for Loan Losses” for details pertaining to management’s allocation 
of the allowance for loan losses to each loan category.

Responsibility and accountability for effectively managing all risks, including credit risk, in the various business units lies 
with the first line of defense.  Credit Risk Management, in the second line of defense, oversees, assesses and effectively challenges 
the risk-taking activities of the first line of defense.  Finally, Credit Risk Review provides ongoing oversight, as a third line of 
defense function, of the credit portfolios to ensure Regions’ activities, and controls, are appropriate for the size, complexity and 
risk profile of the Company.

Economic Environment in Regions’ Banking Markets 

One of the primary factors influencing the credit performance of Regions’ loan portfolio is the overall economic environment 
in the U.S. and the primary markets in which it operates. Preliminary data shows the U.S. economy grew at a rate of just 1.5 percent 
in 2016, down from 2.6 percent in 2015 and below the average 2.1 percent annual growth realized since the end of the 2007 to 
2009 recession. Growth over the first half of 2016 was notably slow, due to weakness in business investment and residential fixed 
investment and the continuation of a persistent inventory correction. Growth picked up considerably in the third quarter of 2016, 
with real GDP growth of 3.5 percent, and fourth quarter growth was approximately 2.0 percent (annualized rates). Consumer 
spending was again the key driver of overall economic growth in 2016. According to preliminary data, private domestic demand 
grew at a rate of 2.3 percent in 2016, after adjusting for inflation.

Business investment spending was a persistent drag on top-line growth in 2016, as was also the case in 2015. One key 
difference, however, is that while in 2015 weakness in business investment spending was mainly a function of sharp cutbacks in 
energy-related investments, the weakness was more broad-based in 2016. In an environment of persistently slow top-line growth 
and an already considerable degree of idle industrial capacity, companies had little incentive to undertake capital investment in 

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2016. Weak business investment spending in turn contributed to generally weak conditions in manufacturing in 2016, with the 
exception of automotive and automotive parts manufacturers. Additionally, domestic manufacturing was also impacted by a soft 
global growth environment that resulted in U.S. exports of goods being basically unchanged from 2015.

In contrast, another year of steadily improving labor market conditions led to solid growth in inflation adjusted personal 
income that, in turn, supported growth in consumer spending. In addition to improved labor market conditions, U.S. consumers 
also benefitted from low interest rates, low inflation, and rising household net worth. Consumers responded by not only increasing 
discretionary spending, but also by building up savings and paying down debt. Household balance sheets ended 2016 in better 
condition than has been the case for several years. 

Over the course of 2016 there was considerable volatility in financial markets, both in the U.S. and abroad. Early in 2016, 
fears that growth in the Chinese economy would slow sharply and perhaps touch off broad based deflation led to a decline in long-
term U.S. interest rates. In the aftermath of the Brexit vote in late June, long-term U.S. interest rates fell even more sharply, with 
yields on 10-year U.S. Treasury notes falling below 1.4 percent. Following the November elections, however, long-term interest 
rates jumped dramatically and closed the year at just under 2.5 percent with short-term rates rising by a lesser extent. Expectations 
that both growth and inflation would be faster than has been the case in recent years pushed market interest rates and the exchange 
value of the U.S. dollar sharply higher.

The FOMC raised the mid-point of the Fed funds rate target range by 25 basis points in December, making 2016 the second 
consecutive year in which the FOMC raised the target range mid-point only once. Given the uncertainty around the path of the 
U.S. economy, a soft global growth environment, and inflation remaining below their 2.0 percent target rate, the FOMC had the 
latitude to remain patient on removing monetary accommodation. Currently, however, the FOMC has less latitude to remain patient 
and the “dot plot” released in conjunction with their December 2016 meeting implied three 25-basis point hikes in the Fed funds 
rate target range mid-point in 2017, one more than had been implied in the prior edition of the dot plot released in conjunction 
with the September 2016 FOMC meeting.

Differentials in rates of economic growth and central bank policy paths could be a source of persistent upward pressure on 
the exchange value of the U.S. dollar in 2017. Further dollar appreciation would act as a drag on growth in U.S. exports and on 
U.S. corporate profits, and would put further downward pressure on prices of imported goods, thereby making it harder for the 
FOMC to hit their inflation target. These differentials could also be a source of persistent volatility in global financial markets in 
2017 that could result in sharp swings in asset prices, market interest rates, and exchange rates around a fairly stable mean. As 
such, while Regions looks for moderate increases in long-term U.S. interest rates in 2017, a considerable degree of volatility and 
sharp swings, in either direction, that ultimately will not be sustained is expected. 

The FOMC is currently trying to assess what significant changes to fiscal, regulatory, and trade policy will alter the course 
of the U.S. economy, and to a lesser extent the global economy, in 2017.  With no specific policy proposals yet on the table, it is 
not possible to quantify the effects on economic growth and Regions’ baseline forecast for 2017 continues to call for real GDP 
growth of 2.1 percent. Consumer spending and housing, single family housing in particular, are expected to be the primary drivers 
for growth in 2017. Based on the likely contours of changes to policy in 2017, however, potential upside risks to a baseline outlook 
from  fiscal  and  regulatory  policy  and  potential  downside  risks  from  trade  policy  exist.  Business  investment  spending  and 
government spending are two areas that may have the most upside potential, while exports, and by extension manufacturing, may 
have the most downside potential. It should be noted that the outlook for housing would be less favorable should we see continued 
increases in mortgage interest rates occur following the increases already seen after the November elections. On the whole, Regions 
believes the potential upside risks to growth outweigh the potential downside risks to growth.

That said, Regions thinks many analysts are discounting the likelihood that the policy changes that ultimately emerge from 
the legislative process will be less impactful than what was discussed during the course of the Presidential campaign, and also 
believes the legislative process may take longer than many analysts seem to be expecting. As such, Regions does not expect 
meaningful impacts on economic growth until the fourth quarter of 2017, meaning growth for the year is not likely to stray far 
from its baseline forecast. Regions does, however, see more upside potential for growth in 2018.

Within the Regions footprint, rates of job, income, and overall economic growth have been and are expected to remain broadly 
consistent with those seen nationally. There are, however, differences in rates of growth among the individual states and metropolitan 
areas across the footprint. Markets with exposure to energy and trade underperformed in 2016, as was the case in 2015, though 
by year-end some firming in crude oil prices brought some relief to those markets with heavy energy exposure. Should the U.S. 
economy and the global economy evolve as expected in 2017, energy prices should remain fairly stable. However, should trade 
policy evolve along the lines discussed during the Presidential campaign, those markets with heavy exposure to trade could suffer 
from lower export and import volumes, and in turn diminished shipping volumes would take a toll on domestic transportation 
operations. Those markets which are larger and more economically diverse and boast demographic trends have been and are 
expected to remain among the better performing markets within Regions' footprint. Housing market activity appears to be picking 
up at a steady pace within Regions' footprint. As is the case for the U.S. as a whole, multi-family construction has rebounded far 
more rapidly than has single family construction. Over the course of 2017, it is expected single family construction will take on 
a larger role while multi-family construction will begin to recede from cyclical peaks as there is a considerable degree of supply 
in the pipeline. Further increases in mortgage interest rates could alter both the outlook for overall residential construction and the 

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mix between single family and multi-family construction. As has been the case nationally, house price appreciation in Regions’ 
larger metro area markets picked up notably over the course of 2016, but a slower pace of price appreciation in 2017 is expected. 

In summation, real GDP growth is expected to be in the 2.0 percent to 2.5 percent range for 2017 and 2018 but at present 
upside risks to a baseline outlook depending on the evolution of economic and regulatory policy exist in the coming months. The 
global growth outlook remains uneven and uncertain and this could be a source of volatility in global financial markets in 2017 
even if there is limited economic impact in the U.S. The FOMC will face a new set of challenges in 2017, given the potential shifts 
in fiscal, regulatory, and trade policy, and as such greater scope for not only more aggressive action on the part of the FOMC than 
has been the case in recent years, but also for policy decisions that could add to volatility in global financial markets may be seen.

Counterparty Risk

Counterparty risk within Regions Bank is the risk that the counterparty to a transaction or contract could be unable or unwilling 
to fulfill its contractual or legal obligations. Exposure may be to a financial institution (such as commercial banks, insurance 
companies, broker dealers, etc.) or a corporate client. 

Regions has a centralized approach to approval, management, and monitoring of counterparty exposure. Counterparty Risk 
Management, housed within Capital Markets Risk Management, is responsible for the independent credit risk management of 
financial institution counterparties and their affiliates.  Market Risk Management is responsible for the suitability, measurement, 
and stress testing of counterparty exposures.  Business Services Credit is responsible for the independent credit risk management 
of client side counterparties.

Financial institution exposure may result from a variety of transaction types generated in one or more departments of the 
Company.  Exposure limits are established to manage the exposure generated by various areas of the Company. Counterparty client 
credit risk arises when Regions sells a risk management product to hedge risks in the client’s business. Exposures to counterparties 
are aggregated across departments and regularly reported to senior management.

INFORMATION SECURITY RISK

 Regions faces a variety of operational risks, including information security risks. Information security risks such as evolving 
and adaptive cyber-attacks, regularly conducted against Regions and other large financial institutions to compromise or disable 
information systems, have generally increased in recent years. This trend is expected to continue for a number of reasons, including 
the proliferation of new technologies, the use of mobile devices, more financial transactions conducted online, and the increased 
sophistication and activities of organized crime, hackers, terrorists, nation-states, activists and other external parties or fraud on 
the part of employees.

Regions spends significant resources to identify and mitigate threats to the confidentiality, availability and integrity of its 
information systems. Regions regularly assesses the threats and vulnerabilities to its environment so it can update and maintain 
its systems and controls to effectively mitigate these risks. Layered security controls are designed to complement each other to 
protect customer information and transactions. Regions will continue to commit the resources necessary to mitigate these growing 
cyber risks, as well as continue to develop and enhance controls, processes and technology to protect its systems from attacks or 
unauthorized access. In addition, Regions maintains a strong commitment to a comprehensive risk management program that 
includes oversight of third-party relationships involving vendors. The Board, through its various committees, is briefed at least 
quarterly on information security matters.

Regions participates in information sharing organizations such as FS-ISAC, to gather and share information amongst peer 
banks and other financial institutions to better prepare and protect its information systems from attack. FS-ISAC is a nonprofit 
organization whose objective is to protect the financial services sector against cyber and physical threats and risk. It acts as a 
trusted third party that provides anonymity to allow members to submit threat, vulnerability and incident information in a non-
attributable and trusted manner so information that would normally not be shared is instead made available for the greater good 
of the membership. In addition to FS-ISAC, Regions is a member of BITS, the technology arm of the Financial Services Roundtable. 
BITS serves the financial community and its members by providing industry best practices on a variety of security and fraud topics.

Regions has contracts with vendors to provide denial of service mitigation. These vendors have also continued to commit 
the necessary resources to support Regions in the event of an attack. Even though Regions devotes significant resources to combat 
cyber security risks, there is no guarantee that these measures will provide absolute security. As an additional security measure, 
Regions has placed a computer forensics firm and an industry-leading consulting firm on retainer in case of a breach event.

Even if Regions successfully prevents data breaches to its own networks, the Company may still incur losses that result from 
customers' account information obtained through breaches of retailers' networks where customers have transacted business. The 
fraud losses, as well as the costs of investigations and re-issuing new customer cards impact Regions' financial results. In addition, 
Regions  also  relies  on  some  vendors  to  provide  certain  components  of  its  business  infrastructure,  which  may  also  increase 
information security risk.

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REGULATORY RISK

In 2014, the Federal Reserve Bank of Atlanta began a regularly scheduled CRA examination of Regions Bank covering 2012 
and 2013 performance. This review included, among other things, a review of Regions Bank's previously disclosed public consent 
orders. As a result of the examination, the results of which were communicated during the fourth quarter of 2015, Regions Bank 
received "High Satisfactory" ratings on its CRA components, but its overall CRA rating was downgraded from "Satisfactory" to 
“Needs to Improve.” The downgrade was attributed to the matters underlying Regions Bank’s April 2015 public consent order 
with the CFPB related to overdrafts and Regulation E. Regions Bank had self-reported these matters and provided remuneration 
to affected customers during 2011 and 2012. This downgrade imposed restrictions on the Company's ability to undertake certain 
activities, including mergers and acquisitions of insured depository institutions and applications to open branches or certain other 
facilities until such time as the rating was improved. On December 19, 2016, the Federal Reserve Bank of Atlanta informed Regions 
that the Company's overall CRA rating had been reinstated from "Needs to Improve" to "Satisfactory" and this regulatory issue is 
resolved.  Further, Regions continued to receive a "High Satisfactory" rating on the lending, investment and service portions of 
the Company's most recent CRA review.

FINANCIAL DISCLOSURE AND INTERNAL CONTROLS

Regions has always maintained internal controls over financial reporting, which generally include those controls relating to 
the preparation of the consolidated financial statements in conformity with GAAP. Regions’ process for evaluating internal controls 
over financial reporting starts with understanding the risks facing each of its functions and areas, how those risks are controlled 
or mitigated, and how management monitors those controls to ensure that they are in place and effective. These risks, control 
procedures and monitoring tools are documented in a standard format. This format not only documents the internal control structures 
over all significant accounts, but also places responsibility on management for establishing feedback mechanisms to ensure that 
controls are effective.

Regions has also established processes to ensure appropriate disclosure controls and procedures are maintained. These controls 
and procedures as defined by the SEC are generally designed to ensure that financial and non-financial information required to be 
disclosed in reports filed with the SEC is reported within the time periods specified in the SEC’s rules and forms, and that such 
information is communicated to management, including the CEO and CFO, as appropriate, to allow timely decisions regarding 
required disclosure.

Regions’ Disclosure Review Committee, which includes representatives from the legal, risk management, accounting, investor 
relations,  and  treasury  departments,  meets  quarterly  to  review  recent  internal  and  external  events  to  determine  whether  all 
appropriate disclosures have been made in reports filed with the SEC. In addition, the CEO and CFO meet quarterly with the SEC 
Filings Review Committee, which includes senior representatives from accounting, legal, risk management, treasury, and the 
business groups. The SEC Filings Review Committee provides a forum in which senior executives disclose to the CEO and CFO 
any known significant deficiencies or material weaknesses in Regions’ internal controls over financial reporting, and provide 
reasonable assurance that the financial statements and other contents of the Company’s Form 10-K and 10-Q filings are accurate, 
complete and timely. As part of this process, certifications of internal control effectiveness are obtained from Regions’ associates  
who are responsible for maintaining and monitoring effective internal controls over financial reporting. These certifications are 
reviewed and presented to the CEO and CFO as support of the Company’s assessment of internal controls over financial reporting. 
The Form 10-K is presented to the Audit Committee of the Board of Directors for approval, and the Forms 10-Q are reviewed by 
the Audit Committee. Financial results and other financial information are also reviewed with the Audit Committee on a quarterly 
basis.

As required by Sections 302 and 906 of the Sarbanes-Oxley Act of 2002, the CEO and the CFO review and make certifications 
regarding the accuracy of Regions’ periodic public reports filed with the SEC, as well as the effectiveness of disclosure controls 
and procedures and internal controls over financial reporting. With the assistance of the financial review committees noted in the 
previous paragraph, Regions will continue to assess and monitor disclosure controls and procedures and internal controls over 
financial reporting, and will make refinements as necessary.

COMPARISON OF 2015 WITH 2014—CONTINUING OPERATIONS

Regions reported net income available to common shareholders of $1.1 billion, or $0.76 per diluted common share, in 2015
compared to $0.79 per diluted share in 2014. Regions reported income from continuing operations available to common shareholders 
of $1.0 billion, or $0.76 per diluted common share, in 2015 compared to $1.1 billion, or $0.78 per diluted share, in 2014. 

Net interest income and other financing income from continuing operations was $3.3 billion in both 2015 and 2014. The net 
interest margin from continuing operations (taxable-equivalent basis) was 3.13 percent in 2015, compared to 3.21 percent during 
2014. The margin decline was driven primarily by decreases in yields on earning assets exceeding the decline in funding costs. 

Non-interest income from continuing operations increased $168 million to $2.1 billion in 2015 compared to 2014. The year-
over-year increase was due to an increase in insurance proceeds, capital markets fee income and other and card and ATM fees. 
See Table 5 "Non-Interest Income from Continuing Operations" for additional information.

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In 2015, insurance proceeds increased $91 million compared to 2014. The increase was primarily driven by the settlement 

of the previously disclosed and accrued 2010 class action lawsuit. 

Capital markets fee income and other  increased $31 million in 2015 compared to 2014. The increase was primarily related 
to increased securities underwriting and placement fees and loan syndication fees. Mergers and acquisitions advisory fees, which 
were derived from the purchase of BlackArch Partners, also contributed to the increase.

Card and ATM fees increased $30 million in 2015 compared to 2014. The increase was a result of increased checking accounts, 
as well as increased transactions in part by the continued migration of transactions from cash and checks to cards.  Additionally, 
the increase in active credit cards generated greater purchase activity resulting in higher interchange income. 

Non-interest expense from continuing operations increased $175 million in 2015 compared to 2014. Increases in non-interest 
expense in 2015 included increases in branch consolidation, property and equipment charges and FDIC insurance assessments, as 
well as losses on early extinguishment of debt. These increases were offset by decreases in professional, legal and regulatory 
expenses, net occupancy expense, salaries and employee benefits and a 2014 gain on the sale of TDRs held for sale that did not 
repeat. See Table 6 “Non-Interest Expense from Continuing Operations” for additional information.

Branch consolidation, property and equipment charges increased $40 million in 2015 as compared to 2014.  The increase 
was due to additional charges related to the transfer of land previously held for branch expansion, to held for sale based on changes 
in management’s intent, as management identified certain parcels of land that were no longer intended to be developed.  This 
increase also included write-offs and depreciation for closed branches.

 FDIC insurance assessments increased $30 million in 2015 as compared to 2014. The increase is primarily due to a $23 

million adjustment to prior assessments recorded during the third quarter of 2015 that exceeded the benefit of refunds of 
previously incurred fees recognized in prior quarters. 

During 2015, the Company incurred $43 million in early extinguishment charges, related to the redemption of certain 

subordinated debt. 

Professional, legal, and regulatory expenses decreased $98 million in 2015 as compared to 2014. The Company recorded 
$50 million and $100 million of contingent legal expenses in 2015 and 2014, respectively, related to previously disclosed matters. 
The 2014 accruals were settled in 2015 for $2 million less than originally estimated, and a corresponding recovery was recorded. 
Excluding these items, professional, legal, and regulatory expenses decreased $46 million during 2015 compared to 2014 primarily 
due to lower consulting fees and lower legal fees resulting from a declining case load as well as legal fee recoveries. 

Net occupancy expense decreased 2 percent to $361 million in 2015 as compared to 2014. 

Total salaries and employee benefits increased $73 million, or 4 percent, in 2015. The increase is primarily due to 

increases in base salaries, as well as expenses from liabilities held for employee benefit purposes. Higher pension, health 
insurance, severance expenses and higher incentives. Headcount increased from 23,723 at December 31, 2014 to 23,916 at 
December 31, 2015.

During the fourth quarter of 2013, Regions transferred certain residential first mortgage loans classified as TDRs to loans 

held for sale. These loans were sold during the first quarter of 2014, resulting in a $35 million net gain.

Outside  services  increased  $18  million  in  2015  as  compared  to  2014,  primarily  due  to  increases  in  certain  fees  paid  in 
connection with revenue growth as well as increased servicing costs related to continued purchases of indirect loans from third 
parties. 

The Company’s income tax expense for 2015 was $455 million compared to $548 million in 2014, resulting in an effective 
tax rate of 29.7 percent and 32.6 percent, respectively.  The decrease in the effective tax rate was driven primarily by audit settlements 
reached with the IRS and certain state taxing authorities, tax benefits related to state deferred taxes and lower pre-tax income.

At December 31, 2015, the allowance for loan losses totaled $1.1 billion or 1.36 percent of total loans, net of unearned 
income compared to $1.1 billion or 1.43 percent at December 31, 2014. Net charge-offs totaled $238 million, or 0.30 percent of 
average loans in 2015 compared to $307 million, or 0.40 percent of average loans in 2014. Net charge-offs were lower across most 
major categories when comparing 2015 to 2014 primarily due to fundamental improvement in credit performance. During 2015, 
the provision for loan losses was $241 million as compared to $69 million in 2014. Non-performing assets decreased from $991 
million at December 31, 2014, to $920 million at December 31, 2015, which reflected management’s continuing efforts to work 
through problem assets and reduce the riskiest exposures.

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Table 27—Quarterly Results of Operations

2016

2015

Fourth
Quarter

Third
Quarter

Second
Quarter

First
Quarter

Fourth
Quarter

Third
Quarter

Second
Quarter

First
Quarter

(In millions, except per share data)

Total interest income, including other financing income

$

957

$

942

$

952

$

963

$

933

$

901

$

883

$

886

Total interest expense and depreciation expense on operating
lease assets

Net interest income and other financing income

Provision for loan losses

Net interest income and other financing income after
provision for loan losses

Total non-interest income, excluding securities gains (losses),
net

Securities gains (losses), net

Total non-interest expense

Income from continuing operations before income taxes

Income tax expense

Income from continuing operations

Discontinued operations:

Income (loss) from discontinued operations before income
taxes

Income tax expense (benefit)

Income (loss) from discontinued operations, net of tax

Net income

Income from continuing operations available to common
shareholders

Net income available to common shareholders
Earnings per common share from continuing operations: (1)

Basic

Diluted

Earnings per common share: (1)

Basic

Diluted

Cash dividends declared per common share
Market price: (2)

High

Low

104

853

48

805

517

5

899

428

134

294

1

—

1

295

278

279

0.23

0.23

0.23

0.23

$

$

$

$

$

107

835

29

806

599

—

934

471

152

319

2

1

1

320

303

304

0.24

0.24

0.24

0.24

$

$

$

$

$

104

848

72

776

520

6

915

387

115

272

5

2

3

275

256

259

0.20

0.20

0.20

0.20

$

$

$

$

$

$

$

$

$

$

0.065

0.065

0.065

$ 14.73

$ 10.08

$ 10.00

$

9.78

7.80

7.53

101

862

113

749

511

(5)

869

386

113

273

—

—

—

273

257

257

0.20

0.20

0.20

0.20

0.06

9.51

7.00

97

836

69

767

503

11

873

408

120

288

(6)

(3)

(3)

285

272

269

0.21

0.21

0.21

0.21

0.06

$

$

$

$

$

65

836

60

776

490

7

895

378

116

262

(6)

(2)

(4)

258

246

242

0.19

0.19

0.18

0.18

0.06

$

$

$

$

$

63

820

63

757

584

6

934

413

124

289

(6)

(2)

(4)

285

273

269

0.20

0.20

0.20

0.20

0.06

$

$

$

$

$

71

815

49

766

465

5

905

331

95

236

(4)

(2)

(2)

234

220

218

0.16

0.16

0.16

0.16

0.05

$

$

$

$

$

$ 10.28

$ 10.87

$ 10.82

$ 10.68

8.54

8.74

9.28

8.59

________
(1)  Quarterly amounts may not add to year-to-date amounts due to rounding.
(2)  High and low market prices are based on intraday sales prices.

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Item 8.  Financial Statements and Supplementary Data

REPORT OF MANAGEMENT ON INTERNAL CONTROL OVER FINANCIAL REPORTING

We, as members of the Management of Regions Financial Corporation and subsidiaries (the “Company”), are responsible 
for establishing and maintaining effective internal control over financial reporting. Regions’ internal control system was designed 
to  provide  reasonable  assurance  to  the  Company’s  management  and  Board  of  Directors  regarding  the  preparation  and  fair 
presentation of the Company’s financial statements for external purposes in accordance with U.S. generally accepted accounting 
principles.  Internal  control  over  financial  reporting  includes  self-monitoring  mechanisms,  and  actions  are  taken  to  correct 
deficiencies as they are identified.

All  internal  controls  systems,  no  matter  how  well  designed,  have  inherent  limitations  and  may  not  prevent  or  detect 
misstatements  in  the  Company’s  financial  statements,  including  the  possibility  of  circumvention  or  overriding  of  controls. 
Therefore, even those systems determined to be effective can provide only reasonable assurance with respect to financial statement 
preparation and presentation. Also, 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.

Regions’ management assessed the effectiveness of the Company’s internal control over financial reporting as of December 
31, 2016. In making this assessment, we used the criteria set forth by the Committee of Sponsoring Organizations of the Treadway 
Commission (“COSO”) in its 2013 Internal Control—Integrated Framework. Based on our assessment, we believe and assert that, 
as of December 31, 2016, the Company’s internal control over financial reporting is effective based on those criteria.

Regions’ independent registered public accounting firm has issued an audit report on the effectiveness of the Company’s 

internal control over financial reporting. This report appears on the following page.

REGIONS FINANCIAL CORPORATION

by

by

/S/    O. B. GRAYSON HALL, JR.        

O. B. Grayson Hall, Jr.
President and Chief Executive Officer

/S/    DAVID J. TURNER, JR.        

David J. Turner, Jr.
Chief Financial Officer

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REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

THE BOARD OF DIRECTORS AND STOCKHOLDERS OF REGIONS FINANCIAL CORPORATION

We have audited Regions Financial Corporation and subsidiaries’ internal control over financial reporting as of December 31, 
2016, based on criteria established in Internal Control-Integrated Framework issued by the Committee of Sponsoring Organizations 
of the Treadway Commission (2013 framework) (the COSO criteria). Regions Financial Corporation and subsidiaries' management 
is responsible for maintaining effective internal control over financial reporting, and for its assessment of the effectiveness of 
internal control over financial reporting included in the accompanying Report of Management on Internal Control over Financial 
Reporting. Our responsibility is to express an opinion on the Company’s internal control over financial reporting based on our 
audit. 

We conducted our audit in accordance with the standards of the Public Company Accounting Oversight Board (United States). 
Those standards require that we plan and perform the audit to obtain reasonable assurance about whether effective internal control 
over financial reporting was maintained in all material respects. Our audit included obtaining an understanding of internal control 
over  financial  reporting,  assessing  the  risk  that  a  material  weakness  exists,  testing  and  evaluating  the  design  and  operating 
effectiveness of internal control based on the assessed risk, and performing such other procedures as we considered necessary in 
the circumstances. We believe that our audit provides a reasonable basis for our opinion. 

A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the 
reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally 
accepted accounting principles. A company’s internal control over financial reporting includes those policies and procedures that 
(1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions 
of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation 
of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the 
company are being made only in accordance with authorizations of management and directors of the company; and (3) 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. Also, 
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. 

In our opinion, Regions Financial Corporation and subsidiaries maintained, in all material respects, effective internal control 

over financial reporting as of December 31, 2016, based on the COSO criteria. 

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States), 
the consolidated balance sheets of Regions Financial Corporation and subsidiaries as of December 31, 2016 and 2015, and the 
related consolidated statements of income, comprehensive income, changes in stockholders’ equity, and cash flows for each of the 
three years in the period ended December 31, 2016 of Regions Financial Corporation and subsidiaries and our report dated February 
24, 2017, expressed an unqualified opinion thereon. 

Birmingham, Alabama

February 24, 2017

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REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

THE BOARD OF DIRECTORS AND STOCKHOLDERS OF REGIONS FINANCIAL CORPORATION

We have audited the accompanying consolidated balance sheets of Regions Financial Corporation and subsidiaries as of 
December 31, 2016 and 2015, and the related consolidated statements of income, comprehensive income, changes in stockholders’ 
equity, and cash flows for each of the three years in the period ended December 31, 2016. These financial statements are the 
responsibility of the Company’s management. Our responsibility is to express an opinion on these financial statements based on 
our audits. 

We conducted our audits in accordance with the standards of the Public Company Accounting Oversight Board (United 
States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial 
statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and 
disclosures in the financial statements. An audit also includes assessing the accounting principles used and significant estimates 
made by management, as well as evaluating the overall financial statement presentation. We believe that our audits provide a 
reasonable basis for our opinion. 

In our opinion, the financial statements referred to above present fairly, in all material respects, the consolidated financial 
position of Regions Financial Corporation and subsidiaries at December 31, 2016 and 2015, and the consolidated results of their 
operations and their cash flows for each of the three years in the period ended December 31, 2016, in conformity with U.S. generally 
accepted accounting principles. 

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States), 
Regions Financial Corporation and subsidiaries' internal control over financial reporting as of December 31, 2016, based on criteria 
established in Internal Control-Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway 
Commission (2013 framework) and our report dated February 24, 2017, expressed an unqualified opinion thereon.

Birmingham, Alabama

February 24, 2017

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REGIONS FINANCIAL CORPORATION AND SUBSIDIARIES

CONSOLIDATED BALANCE SHEETS

$

$

$

December 31

2016

2015

(In millions, except share data)

$

1,853

3,583

15

124

1,362

23,781

718

80,095

(1,091)

79,004

1,644

2,096

319

4,904

324

221

6,020

125,968

$

36,046

$

62,989

99,035

—

—

7,763

7,763

2,506

1,382

3,932

—

143

1,946

22,710

448

81,162

(1,106)

80,056

1,652

2,152

319

4,878

252

259

5,921

126,050

34,862

63,568

98,430

10

10

8,349

8,359

2,417

109,304

109,206

820

13

17,092

666

(1,377)

(550)

16,664

820

13

17,883

(115)

(1,377)

(380)

16,844

$

125,968

$

126,050

Cash and due from banks

Interest-bearing deposits in other banks

Assets

Federal funds sold and securities purchased under agreements to resell

Trading account securities

Securities held to maturity (estimated fair value of $1,369 and $1,969, respectively)

Securities available for sale

Loans held for sale (includes $447 and $353 measured at fair value, respectively)

Loans, net of unearned income

Allowance for loan losses

Net loans

Other earning assets

Premises and equipment, net

Interest receivable

Goodwill

Residential mortgage servicing rights at fair value

Other identifiable intangible assets

Liabilities and Stockholders’ Equity

Other assets

Total assets

Deposits:

Non-interest-bearing

Interest-bearing

Total deposits

Borrowed funds:

Short-term borrowings:

Other short-term borrowings

Total short-term borrowings

Long-term borrowings

Total borrowed funds

Other liabilities

Total liabilities

Stockholders’ equity:

Preferred stock, authorized 10 million shares, par value $1.00 per share

Non-cumulative perpetual, liquidation preference $1,000.00 per share, including related surplus, net

of issuance costs; issued—1,000,000 shares

Common stock, authorized 3 billion shares, par value $.01 per share:

Issued including treasury stock—1,255,839,866 and 1,338,591,703 shares, respectively

Additional paid-in capital

Retained earnings (deficit)

Treasury stock, at cost—41,259,319 and 41,261,018 shares, respectively

Accumulated other comprehensive income (loss), net

Total stockholders’ equity

Total liabilities and stockholders’ equity

See notes to consolidated financial statements.

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REGIONS FINANCIAL CORPORATION AND SUBSIDIARIES

CONSOLIDATED STATEMENTS OF INCOME

Interest income, including other financing income on:

Loans, including fees

Securities - taxable

Loans held for sale

Trading account securities

Other earning assets

Operating lease assets

Total interest income, including other financing income

Interest expense on:

Deposits

Short-term borrowings

Long-term borrowings

Total interest expense

Depreciation expense on operating lease assets

Total interest expense and depreciation expense on operating lease assets

Net interest income and other financing income

Provision for loan losses

Net interest income and other financing income after provision for loan losses

Non-interest income:

Service charges on deposit accounts

Card and ATM fees

Investment management and trust fee income

Mortgage income

Securities gains (losses), net

Other

Total non-interest income

Non-interest expense:

Salaries and employee benefits

Net occupancy expense

Furniture and equipment expense

Other

Total non-interest expense

Income from continuing operations before income taxes

Income tax expense

Income from continuing operations

Discontinued operations:

Income (loss) from discontinued operations before income taxes

Income tax expense (benefit)

Income (loss) from discontinued operations, net of tax

Net income

Net income from continuing operations available to common shareholders

Net income available to common shareholders

Weighted-average number of shares outstanding:

Basic

Diluted

Earnings per common share from continuing operations:

Basic
Diluted

Earnings per common share:

Basic

Diluted

Cash dividends declared per common share

Year Ended December 31

2016

2015

2014

(In millions, except per share data)

$

3,066

$

2,942

$

566

16

5

36

125

3,814

117

—

196

313

103

416

3,398

262

3,136

664

402

213

173

6

695

2,153

1,913

348

317

1,039

3,617

1,672

514

1,158

8

3

5

1,163

1,094

1,099

1,255

1,261

0.87
0.87

0.87

0.87

0.255

$

$

$

$

$

$

$

$

$

$

564

16

5

43

33

2,941

584

22

3

39

—

3,603

3,589

109

1

158

268

28

296

3,307

241

3,066

662

364

202

162

29

652

2,071

1,883

361

303

1,060

3,607

1,530

455

1,075

(22)

(9)

(13)

1,062

1,011

998

1,325

1,334

0.76
0.76

0.75

0.75

0.23

$

$

$

$

$

105

2

202

309

—

309

3,280

69

3,211

695

334

193

149

27

505

1,903

1,810

368

287

967

3,432

1,682

548

1,134

21

8

13

1,147

1,082

1,095

1,375

1,387

0.79
0.78

0.80

0.79

0.18

See notes to consolidated financial statements.

93

 
 
 
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REGIONS FINANCIAL CORPORATION AND SUBSIDIARIES

CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME 

Year Ended December 31

2016

$

1,163

2015
(In millions)
1,062
$

2014

$

1,147

—

(14)

14

(92)

4

(96)

25

89

(64)

(46)

(22)

(24)

—

(8)

8

(166)

19

(185)

137

95

42

(38)

(31)

(7)

(142)

—

(9)

9

214

17

197

96

78

18

(159)

(16)

(143)

81

920

$

1,228

Net income

Other comprehensive income (loss), net of tax:

Unrealized losses on securities transferred to held to maturity:

Unrealized losses on securities transferred to held to maturity during the period (net of zero,
zero and zero tax effect, respectively)
Less: reclassification adjustments for amortization of unrealized losses on securities
transferred to held to maturity (net of ($8), ($6) and ($5) tax effect, respectively)
Net change in unrealized losses on securities transferred to held to maturity, net of tax

Unrealized gains (losses) on securities available for sale:

Unrealized holding gains (losses) arising during the period (net of ($57), ($103) and $131 tax
effect, respectively)

Less: reclassification adjustments for securities gains (losses) realized in net income (net of $2,
$10 and $10 tax effect, respectively)
Net change in unrealized gains (losses) on securities available for sale, net of tax

Unrealized gains (losses) on derivative instruments designated as cash flow hedges:

Unrealized holding gains (losses) on derivatives arising during the period (net of $15, $82 and
$60 tax effect, respectively)

Less: reclassification adjustments for gains (losses) on derivative instruments realized in net
income (net of $54, $58 and $48 tax effect, respectively)
Net change in unrealized gains (losses) on derivative instruments, net of tax

Defined benefit pension plans and other post employment benefits:

Net actuarial gains (losses) arising during the period (net of ($27), ($21) and ($97) tax effect,
respectively)

Less: reclassification adjustments for amortization of actuarial loss and prior service cost
realized in net income (net of ($12), ($17) and ($9) tax effect, respectively)
Net change from defined benefit pension plans and other post employment benefits, net of tax

Other comprehensive income (loss), net of tax

Comprehensive income

(170)

993

$

$

See notes to consolidated financial statements.

94

 
 
 
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REGIONS FINANCIAL CORPORATION AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF CHANGES IN STOCKHOLDERS’ EQUITY

Preferred Stock

Common Stock

Shares

Amount

Shares

Amount

Additional
Paid-In
Capital

Retained
Earnings
(Deficit)

Treasury
Stock,
At Cost

(In millions, except per share data)

Accumulated
Other
Comprehensive
Income (Loss), 
Net

Total

BALANCE AT JANUARY 1, 2014

Net income

Amortization of unrealized losses on securities
transferred to held to maturity, net of tax

Net change in unrealized gains and losses on
securities available for sale, net of tax and
reclassification adjustment

Net change in unrealized gains and losses on
derivative instruments, net of tax and
reclassification adjustment

Net change from employee benefit plans, net of
tax

Cash dividends declared—$0.18 per share

Preferred stock dividends

Preferred stock transactions:

Net proceeds from issuance of 500 thousand
shares of Series B, fixed to floating rate, non-
cumulative perpetual preferred stock, including
related surplus

Common stock transactions:

Impact of share repurchase

Impact of stock transactions under
compensation plans, net and other

BALANCE AT DECEMBER 31, 2014

Net income

Amortization of unrealized losses on securities
transferred to held to maturity, net of tax

Net change in unrealized gains and losses on
securities available for sale, net of tax and
reclassification adjustment

Net change in unrealized gains and losses on
derivative instruments, net of tax and
reclassification adjustment

Net change from employee benefit plans, net of
tax

Cash dividends declared—$0.23 per share

Preferred stock dividends

Common stock transactions:

Impact of share repurchase

Impact of stock transactions under
compensation plans, net and other

BALANCE AT DECEMBER 31, 2015

1

—

—

—

—

—

—

—

—

—

—

1

—

—

—

—

—

—

—

—

—

1

14

—

—

—

—

—

—

—

—

—

—

14

—

—

—

—

—

—

—

—

13

$ 19,216

$ (2,324) $ (1,377) $

(319) $15,660

—

—

—

—

—

(247)

—

—

(256)

54

1,147

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

9

1,147

9

197

197

18

18

(143)

—

—

(143)

(247)

(52)

—

—

—

486

(256)

54

$ 18,767

$ (1,177) $ (1,377) $

(238) $16,873

—

—

—

—

—

(304)

—

42

1,062

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

8

1,062

8

(185)

(185)

42

(7)

—

—

—

—

42

(7)

(304)

(64)

(623)

42

$ 17,883

$

(115) $ (1,377) $

(380) $16,844

(63)

(1)

(622)

$

450

1,378

$

—

—

—

—

—

—

(52)

—

—

—

—

—

—

—

486

—

—

—

(26)

2

$

884

1,354

$

—

—

—

—

—

—

(64)

—

—

—

—

—

—

—

—

—

6

$

820

1,297

$

95

 
 
 
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REGIONS FINANCIAL CORPORATION AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF CHANGES IN STOCKHOLDERS’ EQUITY—Continued

Preferred Stock

Common Stock

Shares

Amount

Shares

Amount

Additional
Paid-In
Capital

Retained
Earnings
(Deficit)

Treasury
Stock,
At Cost

(In millions, except per share data)

Net income

Amortization of unrealized losses on securities
transferred to held to maturity, net of tax

Net change in unrealized gains and losses on
securities available for sale, net of tax and
reclassification adjustment

Net change in unrealized gains and losses on
derivative instruments, net of tax and
reclassification adjustment

Net change from employee benefit plans, net of
tax

Cash dividends declared—$0.255 per share

Preferred stock dividends

Common stock transactions:

Impact of share repurchase

Impact of stock transactions under
compensation plans, net and other

BALANCE AT DECEMBER 31, 2016

—

—

—

—

—

—

—

—

—

1

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

(89)

6

$

820

1,214

$

—

—

—

—

—

—

—

—

—

13

—

—

—

—

—

—

—

(839)

48

1,163

—

—

—

—

(318)

(64)

—

—

—

—

—

—

—

—

—

—

—

Accumulated
Other
Comprehensive
Income (Loss), 
Net

—

14

Total

1,163

14

(96)

(96)

(64)

(24)

—

—

—

—

(64)

(24)

(318)

(64)

(839)

48

$ 17,092

$

666

$ (1,377) $

(550) $16,664

See notes to consolidated financial statements.

96

 
 
 
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REGIONS FINANCIAL CORPORATION AND SUBSIDIARIES

CONSOLIDATED STATEMENTS OF CASH FLOWS

Operating activities:

Net income

Adjustments to reconcile net income to net cash from operating activities:

Provision for loan losses

Depreciation, amortization and accretion, net

Securities (gains) losses, net

Deferred income tax expense

Originations and purchases of loans held for sale

Proceeds from sales of loans held for sale

Gain on TDRs held for sale, net

(Gain) loss on sale of loans, net

(Gain) loss on early extinguishment of debt

Net change in operating assets and liabilities:

Trading account securities

Other earning assets

Interest receivable and other assets

Other liabilities

Other

Net cash from operating activities

Investing activities:

Proceeds from maturities of securities held to maturity

Proceeds from sales of securities available for sale

Proceeds from maturities of securities available for sale

Purchases of securities available for sale

Proceeds from sales of loans

Purchases of loans

Purchases of mortgage servicing rights

Net change in loans

Net purchases of other assets

Net cash from investing activities

Financing activities:

Net change in deposits

Net change in short-term borrowings

Proceeds from long-term borrowings

Payments on long-term borrowings

Cash dividends on common stock

Cash dividends on preferred stock

Net proceeds from issuance of preferred stock

Repurchase of common stock

Other

Net cash from financing activities

Net change in cash and cash equivalents

Cash and cash equivalents at beginning of year

Cash and cash equivalents at end of year

Year Ended December 31

2016

2015

2014

(In millions)

$

1,163

$

1,062

$

1,147

262

574

(6)

67

(3,756)

3,700

—

(124)

14

19

(95)

(219)

189

166

1,954

591

1,965

4,420

(7,874)

182

(985)

(64)

1,339

(205)

(631)

605

(10)

3,357

(3,916)

(317)

(64)

—

(839)

(2)

(1,186)

137

5,314

241

523

(29)

201

(2,560)

2,755

—

(87)

43

(37)

(200)

12

(449)

97

1,572

229

3,138

3,890

(7,819)

76

(1,127)

(4)

(4,138)

(369)

(6,124)

4,230

(2,243)

5,996

(1,142)

(304)

(64)

—

(623)

12

5,862

1,310

4,004

69

523

(27)

196

(2,506)

2,589

(35)

(108)

—

5

29

(179)

421

(17)

2,107

178

1,637

3,207

(5,872)

696

(1,077)

(21)

(2,287)

(242)

(3,781)

1,747

71

—

(1,350)

(247)

(52)

486

(256)

6

405

(1,269)

5,273

4,004

See notes to consolidated financial statements.

$

5,451

$

5,314

$

97

 
 
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REGIONS FINANCIAL CORPORATION AND SUBSIDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES 

Regions Financial Corporation (“Regions” or the “Company”) provides a full range of banking and bank-related services to 
individual and corporate customers through its subsidiaries and branch offices located primarily in Alabama, Arkansas, Florida, 
Georgia,  Illinois,  Indiana,  Iowa,  Kentucky,  Louisiana,  Mississippi,  Missouri,  North  Carolina,  South  Carolina, Tennessee,  and 
Texas. The Company is subject to competition from other financial institutions, is subject to the regulations of certain government 
agencies and undergoes periodic examinations by certain of those regulatory authorities.

The  accounting  and  reporting  policies  of  Regions  and  the  methods  of  applying  those  policies  that  materially  affect  the 
consolidated financial statements conform with accounting principles generally accepted in the United States (“GAAP”) and with 
general financial services industry practices. In preparing the financial statements, management is required to make estimates and 
assumptions that affect the reported amounts of assets and liabilities as of the balance sheet dates and revenues and expenses for 
the periods presented. Actual results could differ from the estimates and assumptions used in the consolidated financial statements 
including, but not limited to, the estimates and assumptions related to the allowance for credit losses, fair value measurements, 
intangibles, residential MSRs and income taxes. 

Regions has evaluated all subsequent events for potential recognition and disclosure through the filing date of this Annual 

Report on Form 10-K.

Certain amounts in prior period financial statements have been reclassified to conform to the current period presentation, 
except as otherwise noted. These reclassifications are immaterial and have no effect on net income, comprehensive income (loss), 
total assets or total stockholders’ equity as previously reported.

BASIS OF PRESENTATION AND PRINCIPLES OF CONSOLIDATION

The  consolidated  financial  statements  include  the  accounts  of  Regions,  its  subsidiaries  and  certain  VIEs.  Significant 
intercompany balances and transactions have been eliminated. Regions considers a voting rights entity to be a subsidiary and 
consolidates it if Regions has a controlling financial interest in the entity. VIEs are consolidated if Regions has the power to direct 
the activities of the VIE that significantly impact financial performance and has the obligation to absorb losses or the right to 
receive benefits that could potentially be significant to the VIE (i.e., Regions is the primary beneficiary). The determination of 
whether Regions is the primary beneficiary of a VIE is reassessed on an ongoing basis. Investments in companies which are not 
VIEs but in which Regions has significant influence over the operating and financing decisions, are accounted for using the equity 
method of accounting. Investments in VIEs, where Regions is not the primary beneficiary of a VIE, are accounted for using either 
the proportional amortization method or the equity method of accounting. These investments are included in other assets in the 
consolidated balance sheets. The maximum potential exposure to losses relative to investments in VIEs is generally limited to the 
sum  of  the  outstanding  balance,  future  funding  commitments  and  any  related  loans  to  the  entity.  Loans  to  these  entities  are 
underwritten in substantially the same manner as are other loans and are generally secured. Refer to Note 2 for additional disclosures 
regarding Regions’ significant VIEs.

Unconsolidated equity investments that do not meet the criteria to be accounted for under the equity method are accounted 
for under the cost method. Cost method investments are included in other assets in the consolidated balance sheets and dividends 
received  or  receivable  from  these  investments  are  included  as  a  component  of  other  non-interest  income  in  the  consolidated 
statements of income.

DISCONTINUED OPERATIONS

On January 11, 2012, Regions entered into an agreement to sell Morgan Keegan and related affiliates. The transaction closed 
on April 2, 2012. Results of operations for the entities sold are presented separately as discontinued operations for all periods 
presented on the consolidated statements of income. Other expenses related to the transaction are also included in discontinued 
operations. See Note 3 and Note 24 for further discussion.

CASH EQUIVALENTS AND CASH FLOWS

Cash equivalents represent assets that can be converted into cash immediately.  At Regions, these assets include cash and 
due from banks, interest-bearing deposits in other banks, and federal funds sold and securities purchased under agreements to 
resell. Cash flows from loans, either originated or acquired, are classified at that time according to management’s intent to either 
sell or hold the loan for the foreseeable future. When management’s intent is to sell the loan, the cash flows of that loan are presented 
as operating cash flows. When management’s intent is to hold the loan for the foreseeable future, the cash flows of that loan are 
presented as investing cash flows.

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Table of Contents 

The following table summarizes supplemental cash flow information for the years ended December 31: 

Cash paid during the period for:

Interest on deposits and borrowings
Income taxes, net

Non-cash transfers:

Operating leases transferred from loans
Loans held for sale and loans transferred to other real estate
Loans transferred to loans held for sale
Loans held for sale transferred to loans
Properties transferred to held for sale

2016

2015

(In millions)

2014

$

$

299
314

—
100
247
5
53

$

268
129

879
156
69
3
38

314
296

—
125
101
4
8

SECURITIES PURCHASED UNDER AGREEMENTS TO RESELL AND SECURITIES SOLD UNDER AGREEMENTS 
TO REPURCHASE

Securities purchased under agreements to resell and securities sold under agreements to repurchase are treated as collateralized 
financing transactions. It is Regions’ policy to take possession of securities purchased under resell agreements either through direct 
delivery or a tri-party agreement.

TRADING ACCOUNT SECURITIES 

Trading account securities, which are primarily held for employee benefit purposes as a funding mechanism for related 
liabilities, consist of debt and marketable equity securities and are carried at estimated fair value. See the “Fair Value Measurements” 
section below for discussion of determining fair value. Gains and losses, both realized and unrealized, are included in other non-
interest income. 

SECURITIES

Management determines the appropriate accounting classification of debt and equity securities at the time of purchase, based 
on intent, and periodically re-evaluates such designations. Debt securities are classified as securities held to maturity when the 
Company has the intent and ability to hold the securities to maturity. Securities held to maturity are presented at amortized cost. 
Debt securities not classified as securities held to maturity or trading account securities, and marketable equity securities not 
classified as trading account securities are classified as securities available for sale. Securities available for sale are presented at 
estimated fair value with changes in unrealized gains and losses, net of taxes, reported as a component of accumulated other 
comprehensive income (loss). See the “Fair Value Measurements” section below for discussion of determining fair value.

The amortized cost of debt securities classified as securities held to maturity and securities available for sale is adjusted for 
amortization of premiums and accretion of discounts to maturity, or in the case of mortgage-backed securities, over the estimated 
life of the security, using the interest method. Such amortization or accretion is included in interest income on securities. Realized 
gains and losses are included in net securities gains (losses). The cost of securities sold is based on the specific identification 
method.

The Company reviews its securities portfolio on a regular basis to determine if there are any conditions indicating that a 
security has other-than-temporary impairment. Factors considered in this determination include the length of time and the extent 
to which the market value has been below cost for equity securities.  For debt securities, factors include the credit standing of the 
issuer, whether the Company expects to receive all scheduled principal and interest payments, Regions’ intent to sell and whether 
it is more likely than not that the Company will have to sell the security before its market value recovers. For debt securities, 
activity related to the credit loss component of other-than-temporary impairment is recognized in earnings as part of net securities 
gains (losses). Additionally, the Company recognizes impairment of available for sale equity securities when the cost basis is above 
the highest traded price within the past six months; the cost basis of the securities is adjusted to current estimated fair value with 
the entire offset recorded in the statement of income. Refer to Note 4 for further detail and information on securities.

LOANS HELD FOR SALE

Regions’ loans held for sale include commercial loans, investor real estate loans and residential real estate mortgage loans. 
Loans held for sale are recorded at either estimated fair value, if the fair value option is elected, or the lower of cost or estimated 
fair value.  Regions has elected to account for residential real estate mortgages originated with the intent to sell at fair value.  Intent 
is established for these conforming residential real estate mortgage loans when Regions enters into an interest rate lock commitment.   
Gains and losses on these residential mortgage loans held for sale for which the fair value option has been elected are included in 
mortgage income.  Certain commercial mortgage loans held for sale where management has elected the fair value option are 

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recorded at fair value.  Gains and losses on commercial mortgage loans held for sale for which the fair value option has been 
elected are included in capital markets fee income and other. Regions also transfers certain commercial, investor real estate, and 
residential real estate mortgage portfolio loans to held for sale when management has the intent to sell in the near term.  These 
held for sale loans are recorded at the lower of cost or estimated fair value.  At the time of transfer, write-downs on the loans are 
recorded as charge-offs and a new cost basis is established.  Any subsequent lower of cost or market adjustment is determined on 
an individual loan basis and is recognized in other non-interest expense.  Gains and losses on the sale of non-performing commercial 
and investor real estate loans are included in other non-interest expense when realized as such amounts are viewed as credit costs.  
Gains and losses on sales of performing loans are included in non-interest income. See the “Fair Value Measurements” section 
below for discussion of determining estimated fair value.

LOANS

Loans that management has the intent and ability to hold for the foreseeable future or until maturity or payoff are considered 
loans held for investment (or portfolio loans). Loans held for investment are carried at the principal amount outstanding, net of 
premiums, discounts, unearned income and deferred loan fees and costs. Regions' loan balance is comprised of commercial, investor 
real estate and consumer loans. Interest income on all types of loans is accrued based on the contractual interest rate and the 
principal amount outstanding using methods that approximate the interest method, except for those loans classified as non-accrual. 
Premiums and discounts on purchased loans and non-refundable loan origination and commitment fees, net of direct costs of 
originating or acquiring loans, are deferred and recognized over the estimated lives of the related loans as an adjustment to the 
loans’ constant effective yield, which is included in interest income on loans. See Note 5 for further detail and information on 
loans.

Regions engages in both direct and leveraged lease financing. The net investment in direct financing leases is the sum of all 
minimum lease payments and estimated residual values, less unearned income. Unearned income is recognized over the terms of 
the leases to produce a constant effective, or level, yield. The net investment in leveraged leases is the sum of all lease payments 
(less non-recourse debt payments) and estimated residual values, less unearned income. Income from leveraged leases is recognized 
over the term of the leases based on the unrecovered equity investment.

Regions determines past due or delinquency status of a loan based on contractual payment terms.  

Commercial and investor real estate loans are placed on non-accrual if any of the following conditions occur: 1) collection 
in full of contractual principal and interest is no longer reasonably assured (even if current as to payment status), 2) a partial charge-
off has occurred, unless the loan has been brought current under its contractual terms (original or restructured terms) and the full 
originally contracted principal and interest is considered to be fully collectible, or 3) the loan is delinquent on any principal or 
interest for 90 days or more unless the obligation is secured by collateral having a net realizable value (estimated fair value less 
costs to sell) sufficient to fully discharge the obligation and the loan is in the legal process of  collection. Factors considered 
regarding full collection include assessment of changes in borrower’s cash flow, valuation of underlying collateral, ability and 
willingness of guarantors to provide credit support, and other conditions.  Charge-offs on commercial and investor real estate loans 
are primarily based on the facts and circumstances of the individual loan and occur when available information confirms the loan 
is not or will not be fully collectible. Factors considered in making these determinations are the borrower’s and any guarantor’s 
ability and willingness to pay, the status of the account in bankruptcy court (if applicable), and collateral value. Commercial and 
investor real estate loan relationships of $250,000 or less are subject to charge-off or charge down to net realizable value at 180
days past due, based on collateral value.

Non-accrual and charge-off decisions for consumer loans are dictated by the FFIEC's Uniform Retail Credit Classification 
and Account Management Policy which establishes standards for the classification and treatment of consumer loans. The charge-
off process drives consumer non-accrual status as follows. If a consumer loan secured by real estate in a first lien position (residential 
first mortgage or home equity) becomes 180 days past due, Regions evaluates the loan for non-accrual status and potential charge-
off based on net loan to value exposure. For home equity loans in a second lien position, the evaluation is performed at 120 days 
past due. If a loan is secured by collateral having a net realizable value sufficient to fully discharge the obligation, then a partial 
write-down is not necessary and the loan remains on accrual status, provided it is in the process of legal collection. If a partial 
charge-off is necessary as a result of the evaluation, then the remaining balance is placed on non-accrual. Consumer loans not 
secured by real estate are generally charged-off in full at either 120 days past due for closed-end loans, 180 days past due for open-
end loans other than credit cards or the end of the month in which the loan becomes 180 days past due for credit cards.

When loans are placed on non-accrual status, the accrual of interest, amortization of loan premium, accretion of loan discount 
and amortization/accretion of deferred net loan fees/costs are discontinued. When a commercial or investor real estate loan is 
placed on non-accrual status, uncollected interest accrued in the current year is reversed and charged to interest income. Uncollected 
interest accrued from prior years on commercial and investor real estate loans placed on non-accrual status in the current year is 
charged against the allowance for loan losses. When a consumer loan is placed on non-accrual status, all uncollected interest 
accrued is reversed and charged to interest income due to immateriality. Interest collections on commercial and investor real estate 
non-accrual loans are applied as principal reductions. Interest collections on consumer loans are recorded using the cash basis, 
due to immateriality.

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All loans on non-accrual status may be returned to accrual status and interest accrual resumed if  all of the following conditions 
are met: 1) the loan is brought contractually current as to both principal and interest, 2) future payments are reasonably expected 
to continue being received in accordance with the terms of the loan and repayment ability can be reasonably demonstrated, and 
3) the loan has been performing for at least six months.

ALLOWANCE FOR CREDIT LOSSES

Regions' allowance for credit losses (“allowance”) consists of two components: the allowance for loan losses, which is 
recorded as a contra-asset to loans, and the reserve for unfunded credit commitments, which is recorded in other liabilities. The 
allowance is reduced by actual losses (charge-offs) and increased by recoveries, if any. Regions charges losses against the allowance 
in the period the loss is confirmed. All adjustments to the allowance for loan losses are charged directly to expense through the 
provision for loan losses. All adjustments to the reserve for unfunded credit commitments are recorded in other non-interest expense.

The allowance is maintained at a level believed appropriate by management to absorb probable credit losses inherent in the 
loan and unfunded credit commitment portfolios in accordance with GAAP and regulatory guidelines. Management’s determination 
of the appropriateness of the allowance is a quarterly process and is based on an evaluation and rating of the loan portfolio segments, 
historical loan loss experience, current economic conditions, collateral values securing loans, levels of problem loans, volume, 
growth, quality and composition of the loan portfolio, regulatory guidance, and other relevant factors. Changes in any of these, or 
other factors, or the availability of new information, could require that the allowance be adjusted in future periods. Actual losses 
could vary from management’s estimates. Management attributes portions of the allowance to loans that it evaluates and determines 
to be impaired and to groups of loans that it evaluates collectively. However, the entire allowance is available to cover all charge-
offs that arise from the loan portfolio.

CALCULATION OF ALLOWANCE FOR CREDIT LOSSES

Commercial and Investor Real Estate Components

Impaired Loans

Loans deemed to be impaired include non-accrual loans, excluding consumer loans, and all TDRs. Regions considers the 
current value of collateral, credit quality of any guarantees, guarantor’s liquidity and willingness to repay, the loan structure, and 
other factors when evaluating whether an individual loan is impaired.  Other factors may include the industry and geographic 
region of the borrower, size and financial condition of the borrower, cash flow and leverage of the borrower and Regions’ evaluation 
of the borrower’s management. For non-accrual commercial and investor real estate loans (including TDRs) equal to or greater 
than $2.5 million, the allowance for loan losses is based on a note-level evaluation considering the facts and circumstances specific 
to each borrower. For these loans, Regions measures the level of impairment based on the present value of the estimated cash 
flows, the estimated value of the collateral or, if available, the observable market price. Regions generally uses the estimated cash 
flow method to measure impairment. For commercial and investor real estate accruing TDRs and all non-accruing loans less than 
$2.5 million, the allowance for loan losses is based on a discounted cash flow analysis performed at the note level, where estimated 
projected cash flows reflect credit losses based on statistical information (including historical default information) derived from 
loans with similar risk characteristics (e.g., credit quality indicator and product type) using PDs and LGDs as described in the 
following paragraph. 

Non-Impaired Loans

For all other commercial and investor real estate loans, the allowance for loan losses is calculated at a pool level based on 
credit quality indicators and product type. Statistically determined PDs and LGDs are calculated based on historical default and 
loss information for similar loans. The historical default and loss information is measured over a relevant period for each loan 
pool. The pool level allowance is calculated using the PD and LGD estimates and is adjusted as appropriate based on additional 
analysis of long-term average loss experience compared to previously forecasted losses, external loss data and other risks identified 
from current economic conditions and credit quality trends. Various one year PD measurements are used in conjunction with life-
of-loan LGD measurements to estimate incurred losses.  As a result, losses are effectively covered over a two to three year period 
for loans that are currently in default and those estimated to default within the next twelve months.

Consumer Components

For consumer loans, the classes are segmented into pools of loans with similar risk characteristics. For most consumer loan 
pools, historical losses are the primary factor in establishing the allowance allocated to each pool. The twelve month loss rate is 
the basis for the allocation and it may be adjusted based on deteriorating trends, portfolio growth, or other factors determined by 
management to be relevant.

The allowance for loan losses for the residential first mortgage non-TDR pool is calculated based on a twelve-month historical 
loss rate segmented based on the following risk characteristics: past due and accrual status and further by geography, property use 
and  amortization  type  for  accruing,  non-past  due  loans. The  allowance  for  loan  losses  for  residential  first  mortgage TDRs  is 
calculated based on a discounted cash flow analysis on pools of homogeneous loans. Cash flows are projected using the restructured 
terms and then discounted at the original note rate. The projected cash flows assume a default rate, which is based on historical 

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performance of residential first mortgage TDRs. The allowance for loan losses for the home equity pool is calculated based on a 
twelve-month historical loss rate segmented based on the following risk characteristics: lien position, TDR status, geography, non-
accrual and past due status, and refreshed FICO scores for accruing, non-past due loans.

Qualitative Factors

While  quantitative  allowance  methodologies  strive  to  reflect  all  risk  factors,  any  estimate  involves  assumptions  and 
uncertainties resulting in some level of imprecision. Imprecision exists in the estimation process due to the inherent time lag of 
obtaining information and variations between estimates and actual outcomes. Regions adjusts the allowance in consideration of  
quantitative and qualitative factors which may not be directly measured in the note-level or pooled calculations, including, but not 
limited to:

•  Credit quality trends,

•  Loss experience in particular portfolios,

•  Macroeconomic factors such as unemployment, real estate prices, or commodity pricing volatility,

•  Changes in risk selection and underwriting standards,

• 

Shifts in credit quality of consumer customers which is not yet reflected in the historical data.

Reserve for Unfunded Credit Commitments

In order to estimate a reserve for unfunded commitments, Regions uses a process consistent with that used in developing the 
allowance for loan losses. The reserve is based on an EAD multiplied by a PD multiplied by an LGD. The EAD is estimated based 
on an analysis of historical funding patterns for defaulted loans in various categories. The PD and LGD align with the statistically-
calculated parameters used to calculate the allowance for loan losses for various pools, which are based on credit quality indicators 
and product type. The methodology applies to commercial and investor real estate credit commitments and standby letters of credit 
that are not unconditionally cancellable.

Refer to Note 6 for further discussion regarding the calculation of the allowance for credit losses.

TROUBLED DEBT RESTRUCTURINGS (TDRs)

TDRs are loans in which the borrower is experiencing financial difficulty at the time of restructuring, and Regions has granted 
a concession to the borrower. TDRs are undertaken in order to improve the likelihood of recovery on the loan and may take the 
form of modifications made with the stated interest rate lower than the current market rate for new debt with similar risk, other 
modifications to the structure of the loan that fall outside of normal underwriting policies and procedures, or in limited circumstances 
forgiveness of principal and/or interest. TDRs can involve loans remaining on non-accrual, moving to non-accrual, or continuing 
on accrual status, depending on the individual facts and circumstances of the borrower. TDRs are subject to policies governing 
accrual/non-accrual evaluation consistent with all other loans of the same product type as discussed in the “Loans” section above. 
All loans with the TDR designation are considered to be impaired, even if they are accruing. See the “Calculation of Allowance 
For Credit Losses” section above for Regions’ allowance for loan losses methodology related to TDRs.

The CAP was designed to evaluate potential consumer loan participants as early as possible in the life cycle of the troubled 
loan (as described in Note 6). Many of the modifications are finalized without the borrower ever reaching the applicable number 
of  days  past  due,  and  therefore  the  loan  may  never  be  placed  on  non-accrual. Accordingly,  given  the  positive  impact  of  the 
restructuring on the likelihood of recovery of cash flows due under the modified terms, accrual status continues to be appropriate 
for these loans.

OTHER EARNING ASSETS

Other earning assets consist primarily of investments in FRB stock, FHLB stock, and operating lease assets. See Note 8 for 

additional information. 

INVESTMENTS IN FEDERAL RESERVE BANK AND FEDERAL HOME LOAN BANK STOCK

Stock ownership in the FRB and FHLB is a requirement for all banks seeking membership into and access to the services 

provided by these banking systems. These shares are accounted for at amortized cost, which approximates fair value. 

INVESTMENTS IN OPERATING LEASES

Investments  in  operating  leases  represent  the  assets  underlying  the  related  lease  contracts  and  are  reported  at  cost,  less 
accumulated depreciation and net of origination fees and costs. Depreciation on these assets is generally provided on a straight-
line basis over the lease term down to an estimated residual value. Regions periodically evaluates its depreciation rate for leased 
assets based on projected residual values and adjusts depreciation expense over the remaining life of the lease if deemed appropriate. 
Regions also evaluates the current value of the operating lease assets and tests for impairment when indicators of impairment are 
present. Income from operating lease assets includes lease origination fees, net of lease origination costs, and is recognized as 
operating lease revenue on a straight line basis over the scheduled lease term. The accrual of revenue on operating leases is generally 

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discontinued at the time an account is determined to be uncollectible. Operating lease revenue and the depreciation expense on 
the related operating lease assets are included as components of net interest income and other financing income on the consolidated 
statements of income. When a leased asset is returned, its remaining value is reclassified from other earning assets to other assets 
and recorded at the lower of cost or estimated fair value, less costs to sell, on Regions' consolidated balance sheet. Impairment of 
the operating lease asset, as well as residual value gains and losses at the end of the lease term are recorded through other non-
interest income.

PREMISES AND EQUIPMENT

Premises and equipment are stated at cost, less accumulated depreciation and amortization, as applicable. Land is carried at 
cost. Depreciation expense is computed using the straight-line method over the estimated useful lives of the assets. Leasehold 
improvements are amortized using the straight-line method over the estimated useful lives of the improvements (or the terms of 
the leases, if shorter). Generally, premises and leasehold improvements are depreciated or amortized over 7-40 years. Furniture 
and equipment are generally depreciated or amortized over 3-10 years. Premises and equipment are evaluated for impairment 
whenever events or circumstances indicate that the carrying value of the asset may not be recoverable. Maintenance and repairs 
are charged to non-interest expense in the consolidated statements of income. Improvements that extend the useful life of the asset 
are capitalized to the carrying value and depreciated. See Note 9 for detail of premises and equipment.

Regions enters into lease transactions for the right to use assets. These leases vary in term and, from time to time, include 
incentives and/or rent escalations. Examples of incentives include periods of “free” rent and leasehold improvement incentives. 
Regions recognizes incentives and escalations on a straight-line basis over the lease term as a reduction of or increase to rent 
expense, as applicable, within net occupancy expense in the consolidated statements of income.

INTANGIBLE ASSETS

Intangible assets include goodwill, which is the excess of cost over the fair value of net assets of acquired businesses, and 
other identifiable intangible assets. Other identifiable intangible assets primarily include the following: 1) core deposit intangible 
assets, which are amounts recorded related to the value of acquired indeterminate maturity deposits, 2) amounts capitalized related 
to the value of acquired customer relationships, 3) amounts recorded related to employment agreements with certain individuals 
of acquired entities, and 4) the Fannie Mae DUS license. Core deposit intangibles and certain other identifiable intangibles are 
amortized on an accelerated basis over their expected useful lives.

The  Company’s  goodwill  is  tested  for  impairment  on  an  annual  basis  in  the  fourth  quarter,  or  more  often  if  events  or 
circumstances indicate that there may be impairment. Regions assesses the following indicators of goodwill impairment for each 
reporting period:

•  Recent operating performance,

•  Changes in market capitalization,

•  Regulatory actions and assessments,

•  Changes in the business climate (including legislation, legal factors and competition),

•  Company-specific factors (including changes in key personnel, asset impairments, and business dispositions), and

•  Trends in the banking industry.

Adverse changes in the economic environment, declining operations, or other factors could result in a decline in the implied 
estimated fair value of goodwill. A goodwill impairment test includes two steps. Step One, used to identify potential impairment, 
compares the estimated fair value of a reporting unit with its carrying amount, including goodwill. If the estimated fair value of a 
reporting unit exceeds its carrying amount, goodwill of the reporting unit is considered not impaired. If the carrying amount of a 
reporting unit exceeds its estimated fair value, the second step of the goodwill impairment test is performed to measure the amount 
of impairment loss, if any. Step Two of the goodwill impairment test compares the implied estimated fair value of reporting unit 
goodwill with the carrying amount of that goodwill. If the carrying amount of goodwill for that reporting unit exceeds the implied 
estimated fair value of that unit’s goodwill, an impairment loss is recognized in other non-interest expense in an amount equal to 
that excess.

For purposes of performing Step One of the goodwill impairment test, Regions uses both income and market approaches to 
value its reporting units. The income approach, which is the primary valuation approach, consists of discounting projected long-
term future cash flows, which are derived from internal forecasts and economic expectations for the respective reporting units. 
The significant inputs to the income approach include expected future cash flows, the long-term target equity ratios, and the discount 
rate.

Regions utilizes the CAPM in order to derive the base discount rate. The inputs to the CAPM include the 20-year risk-free 
rate, 5-year beta for a select peer set, and the market risk premium, all based on published data. To determine the estimated cost 
of equity for each reporting unit, a size premium is added (also based on a published source) as well as a company-specific risk 
premium (based on business model and market perception of risk) to the base discount rate.

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Regions uses both the GCM and the GTM as its market approaches. The GCM applies a value multiplier derived from each 
reporting unit’s peer group to tangible book value (for Corporate Bank and Consumer Bank) or price to earnings ratio (for Wealth 
Management) and an implied control premium to each reporting unit. The control premium is evaluated and compared to similar 
financial services transactions considering the absolute and relative potential revenue synergies and cost savings. The GTM applies 
a value multiplier to a financial metric of each reporting unit based on comparable observed purchase transactions in the financial 
services industry for the reporting unit (where available).

For purposes of performing Step Two of the goodwill impairment test, if applicable, Regions compares the implied estimated 
fair value of the reporting unit goodwill with the carrying amount of that goodwill. In order to determine the implied estimated 
fair value, a full purchase price allocation would be performed in the same manner as if a business combination had occurred. As 
part of the Step Two analysis, Regions estimates the fair value of all of the assets and liabilities of the reporting unit, including 
unrecognized assets and liabilities. The related valuation methodologies for certain material financial assets and liabilities are 
discussed in the “Fair Value Measurements” section below.

Other identifiable intangible assets, primarily core deposit intangibles, purchased credit card relationships and other acquired 
customer relationships, are reviewed at least annually (usually in the fourth quarter) for events or circumstances that could impact 
the recoverability of the intangible asset. These events could include loss of core deposits, significant losses of credit card or other 
types of acquired customer accounts and/or balances, increased competition or adverse changes in the economy. To the extent 
other identifiable intangible assets are deemed unrecoverable, impairment losses are recorded in other non-interest expense and 
reduce the carrying amount of the asset.

Refer to Note 10 for further detail and discussion of the results of the goodwill and other identifiable intangibles impairment 

tests.

ACCOUNTING FOR TRANSFERS AND SERVICING OF FINANCIAL ASSETS

Regions accounts for transfers of financial assets as sales when control over the transferred assets is surrendered. Control is 
generally  considered  to  have  been  surrendered  when  1) the  transferred  assets  are  legally  isolated  from  the  Company  or  its 
consolidated affiliates, even in bankruptcy or other receivership, 2) the transferee has the right to pledge or exchange the assets 
with no conditions that constrain the transferee and provide more than a trivial benefit to the Company, and 3) the Company does 
not maintain the obligation or unilateral ability to reclaim or repurchase the assets. If these sale criteria are met, the transferred 
assets are removed from the Company’s balance sheet and a gain or loss on sale is recognized. If not met, the transfer is recorded 
as a secured borrowing, and the assets remain on the Company’s balance sheet, the proceeds from the transaction are recognized 
as a liability, and gain or loss on sale is deferred until the sale criterion are achieved.

Regions has elected to account for its residential MSRs using the fair value measurement method. Under the fair value 
measurement method, residential MSRs are measured at estimated fair value each period with changes in fair value recorded as a 
component of mortgage income.  The fair value of residential MSRs is calculated using various assumptions including future cash 
flows, market discount rates, expected prepayment rates, servicing costs and other factors. A significant change in prepayments 
of residential mortgages in the servicing portfolio could result in significant valuation adjustments, thus creating potential volatility 
in the carrying amount of residential MSRs. The valuation method relies on an OAS to consider prepayment risk and equate the 
asset's discounted cash flows to its market price. See the “Fair Value Measurements” section below for additional discussion 
regarding determination of fair value.

Regions is a Fannie Mae DUS lender. The Fannie Mae DUS program provides liquidity to the multi-family housing market. 
Regions' related commercial MSRs are recorded in other assets on the consolidated balance sheets at the lower of cost or estimated 
fair value and are amortized in proportion to, and over the estimated period that net servicing income is expected to be received 
based on projections of the amount and timing of estimated future net cash flows. The amount and timing of estimated future net 
cash flows are updated based on actual results and updated projections. Regions periodically evaluates its commercial MSRs for 
impairment. Regions has a one-third loss share guarantee associated with the majority of the DUS servicing portfolio. The other 
two-thirds loss share guarantee is retained by Fannie Mae. The estimated fair value of the loss share guarantee is recorded in other 
liabilities on the consolidated balance sheets.

Refer to Note 7 for further information on servicing of financial assets.

FORECLOSED PROPERTY AND OTHER REAL ESTATE

Other real estate and certain other assets acquired in satisfaction of indebtedness (“foreclosure”) are carried in other assets 
at the lower of the recorded investment in the loan or estimated fair value less estimated costs to sell the property. At the date of 
transfer from the loan portfolio, if the recorded investment in the loan exceeds the property’s estimated fair value less estimated 
costs to sell, a write-down is recorded against the allowance. Regions allows a period of up to 60 days after the date of transfer to 
record finalized write-downs as charge-offs against the allowance in order to properly accumulate all related invoices and updated 
valuation information, if necessary. Subsequent to transfer, Regions obtains valuations from professional valuation experts and/
or third party appraisers on at least an annual basis. See the “Fair Value Measurements” section below for additional discussion 
regarding determination of fair value. Subsequent to transfer and the additional 60 days, any further write-downs are recorded as 

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other non-interest expense. Gain or loss on the sale of foreclosed property and other real estate is included in other non-interest 
expense. At December 31, 2016 and 2015, the carrying values of foreclosed properties were immaterial.

From time to time, assets classified as premises and equipment are transferred to held for sale for various reasons. These 
assets are carried in other assets at the lower of the recorded investment in the asset or estimated fair value less estimated cost to 
sell based upon the property’s appraised value at the date of transfer. Any write-downs of property held for sale are recorded as 
other non-interest expense. 

DERIVATIVE FINANCIAL INSTRUMENTS AND HEDGING ACTIVITIES

The Company enters into derivative financial instruments to manage interest rate risk, facilitate asset/liability management 
strategies and manage other exposures. These instruments primarily include interest rate swaps, options on interest rate swaps, 
options  including  interest  rate  caps  and  floors,  Eurodollar  futures,  forward  rate  contracts  and  forward  sale  commitments. All 
derivative financial instruments are recognized on the consolidated balance sheets as other assets or other liabilities, as applicable, 
at  estimated  fair  value.  Regions  enters  into  master  netting  agreements  with  counterparties  and/or  requires  collateral  to  cover 
exposures. In at least some cases, counterparties post collateral at a zero threshold regardless of credit rating. The majority of 
interest  rate  derivatives  traded  by  Regions  with  dealing  counterparties  are  subject  to  mandatory  clearing  through  a  central 
clearinghouse. The counterparty risk for cleared trades effectively moves from the executing broker to the clearinghouse allowing 
Regions to benefit from the risk mitigation controls in place at the respective clearinghouse.

Interest rate swaps are agreements to exchange interest payments based upon notional amounts. Interest rate swaps subject 
Regions to market risk associated with changes in interest rates, changes in interest rate volatility as well as the credit risk that the 
counterparty will fail to perform. Option contracts involve rights to buy or sell financial instruments on a specified date or over a 
period at a specified price. These rights do not have to be exercised. Some option contracts such as interest rate floors, involve the 
exchange of cash based on changes in specified indices. Interest rate floors are contracts to hedge interest rate declines based on 
a notional amount, generally associated with a principal balance at risk. Interest rate floors subject Regions to market risk associated 
with changes in interest rates, changes in interest rate volatility, as well as the credit risk that the counterparty will fail to perform. 
Forward rate contracts are commitments to buy or sell financial instruments at a future date at a specified price or yield. Regions 
primarily enters into forward rate contracts on marketable instruments, which expose Regions to market risk associated with 
changes in the value of the underlying financial instrument, as well as the credit risk that the counterparty will fail to perform. 
Eurodollar futures are futures contracts on Eurodollar deposits. Eurodollar futures subject Regions to market risk associated with 
changes in interest rates. Because futures contracts are cash settled daily through a margining process in an exchange, there is 
minimal credit risk associated with Eurodollar futures. Forward sale commitments are sales of securities at a specified price at a 
future date. Forward sale commitments subject Regions to market risk associated with changes in market value, as well as the 
credit risk that the counterparty will fail to perform.

The Company elects to account for certain derivative financial instruments as accounting hedges which, based on the exposure 

being hedged, are either fair value or cash flow hedges.

Fair value hedge relationships mitigate exposure to the change in fair value of an asset, liability or firm commitment. Under 
the fair value hedging model, gains or losses attributable to the change in fair value of the derivative instrument, as well as the 
gains and losses attributable to the change in fair value of the hedged item, are recognized in other non-interest expense in the 
period in which the change in fair value occurs. Hedge ineffectiveness is recognized as other non-interest expense to the extent 
the changes in fair value of the derivative do not offset the changes in fair value of the hedged item. The corresponding adjustment 
to the hedged asset or liability is included in the basis of the hedged item, while the corresponding change in the fair value of the 
derivative instrument is recorded as an adjustment to other assets or other liabilities, as applicable.

Cash flow hedge relationships mitigate exposure to the variability of future cash flows or other forecasted transactions. For 
cash flow hedge relationships, the effective portion of the gain or loss related to the derivative instrument is recognized as a 
component of accumulated other comprehensive income (loss). Ineffectiveness is measured by comparing the change in fair value 
of the respective derivative instrument and the change in fair value of a “perfectly effective” hypothetical derivative instrument. 
Ineffectiveness will be recognized in earnings only if it results from an overhedge (i.e. the change in the value of the derivative 
exceeds the change related to the hedged exposure). The ineffective portion of the gain or loss related to the derivative instrument, 
if any, is recognized in earnings as other non-interest expense during the period of change. Amounts recorded in accumulated other 
comprehensive income (loss) are recognized in earnings in the period or periods during which the hedged item impacts earnings.

The Company formally documents all hedging relationships, as well as its risk management objective and strategy for entering 
into various hedge transactions. The Company performs periodic assessments to determine whether the hedging relationship has 
been highly effective in offsetting changes in fair values or cash flows of hedged items and whether the relationship is expected 
to continue to be highly effective in the future.

When a hedge is terminated or hedge accounting is discontinued because the hedged item no longer meets the definition of 
a firm commitment, or because it is probable that the forecasted transaction will not occur, the derivative will continue to be 
recorded as an other asset or other liability in the consolidated balance sheets at its estimated fair value, with changes in fair value 
recognized in capital markets fee income or other. Any asset or liability that was recorded pursuant to recognition of the firm 

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commitment is removed from the consolidated balance sheets and recognized in other non-interest expense. Gains and losses that 
were unrecognized and accumulated in accumulated other comprehensive income (loss) pursuant to the hedge of a forecasted 
transaction are recognized immediately in other non-interest expense.

Derivative contracts for which the Company has not elected to apply hedge accounting are classified as other assets or 
liabilities with gains and losses related to the change in fair value recognized in capital markets fee income and other or mortgage 
income, as applicable, in the statements of income during the period. These positions, as well as non-derivative instruments, are 
used to mitigate economic and accounting volatility related to customer derivative transactions, the mortgage pipeline and the fair 
value of residential MSRs.

Regions enters into interest rate lock commitments, which are commitments to originate mortgage loans whereby the interest 
rate on the loan is determined prior to funding and the customers have locked into that interest rate. Accordingly, such commitments 
are recorded at estimated fair value with changes in fair value recorded in mortgage income or capital markets fee income and 
other, as applicable. Regions also has corresponding forward sale commitments related to these interest rate lock commitments, 
which are recorded at estimated fair value with changes in fair value recorded in mortgage income or capital markets fee income 
and other, as applicable. See the “Fair Value Measurements” section below for additional information related to the valuation of 
interest rate lock commitments.

Regions enters into various derivative agreements with customers desiring protection from possible future market fluctuations. 
Regions manages the market risk associated with these derivative agreements in a trading portfolio. The contracts in this portfolio 
for which the Company has elected not to apply hedge accounting are marked-to-market through earnings and included in other 
assets and other liabilities.

Concurrent with the election to use fair value measurement for residential MSRs, Regions began using various derivative 
instruments to mitigate the impact of changes in the fair value of residential MSRs in the statements of income. This effort may 
involve  the  use  of  various  derivative  instruments,  including,  but  not  limited  to,  forwards,  futures,  swaps  and  options. These 
derivatives are carried at estimated fair value, with changes in fair value reported in mortgage income.

Refer to Note 21 for further discussion and details of derivative financial instruments and hedging activities.

INCOME TAXES

The Company accounts for income taxes using the asset and liability method, which requires the recognition of deferred tax 
assets and liabilities for expected future tax consequences. Under this method, deferred tax assets and liabilities are determined 
by applying the federal and state tax rates to the differences between financial statement carrying amounts and the corresponding 
tax bases of assets and liabilities. Deferred tax assets are also recorded for any tax attributes, such as tax credit and net operating 
loss  carryforwards. The  net  balance  of  deferred  tax  assets  and  liabilities  is  reported  in  other  assets  or  other  liabilities  in  the 
consolidated balance sheets, as appropriate. Any effect of a change in federal and state tax rates on deferred tax assets and liabilities 
is recognized in income tax expense in the period that includes the enactment date. The Company reflects the expected amount of 
income tax to be paid or refunded during the year as current income tax expense or benefit, as applicable.

The Company evaluates the realization of deferred tax assets based on all positive and negative evidence available at the 
balance sheet date. Realization of deferred tax assets is based on the Company’s judgments about relevant factors affecting their 
realization, including taxable income within any applicable carryback periods, future projected taxable income, reversal of taxable 
temporary differences and other tax-planning strategies to maximize realization of the deferred tax assets. A valuation allowance 
is recorded for any deferred tax assets that are not more-likely-than-not to be realized.

Income tax benefits generated from uncertain tax positions are accounted for using the recognition and cumulative-probability 
measurement  thresholds.  Based  on  the  technical  merits,  if  a  tax  benefit  is  not  more-likely-than-not  of  being  sustained  upon 
examination, the Company records a liability for the recognized income tax benefit. If a tax benefit is more-likely-than-not of 
being sustained based on the technical merits, the Company utilizes the cumulative probability measurement and records an income 
tax benefit equivalent to the largest amount of tax benefit that is greater than 50 percent likely to be realized upon ultimate settlement 
with a taxing authority. The Company recognizes interest expense, interest income and penalties related to unrecognized tax benefits 
within current income tax expense.

The Company applies the proportional amortization method in accounting for its qualified affordable housing investments. 

This method recognizes the amortized cost of the investment as a component of income tax expense.

The deferral method of accounting is used for investments that generate investment tax credits. Under this method, the 

investment tax credits are recognized as a reduction of the related asset.

Refer to Note 20 for further discussion regarding income taxes.

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TREASURY STOCK AND SHARE REPURCHASES

The purchase of the Company’s common stock is recorded at cost. At the date of repurchase, stockholders' equity is reduced 
by the repurchase price. Upon retirement, or upon purchase for constructive retirement, treasury stock would be reduced by the 
cost of such stock with the excess of repurchase price over par or stated value recorded in additional paid-in capital. If the Company 
subsequently reissues treasury shares, treasury stock is reduced by the cost of such stock with differences recorded in additional 
paid-in capital or retained earnings, as applicable.

Pursuant to recent share repurchase programs, shares repurchased were immediately retired, and therefore were not included 
in treasury stock. The Company's policy related to these share repurchases is to reduce its common stock based on the par value 
of the shares repurchased and to reduce its additional paid-in capital for the excess of the repurchase price over the par value.

SHARE-BASED PAYMENTS 

Regions sponsors stock plans which most commonly include restricted stock (i.e., unvested common stock), restricted stock 
units, performance stock units and stock options. The Company accounts for share-based payments under the fair value recognition 
provisions whereby compensation cost is measured based on the estimated fair value of the award at the grant date and is recognized 
in the consolidated financial statements on a straight-line basis over the requisite service period for service-based awards. The fair 
value of restricted stock, restricted stock units or performance stock units is determined based on the closing price of Regions 
common stock on the date of grant. Historical data is also used to estimate future employee attrition, which is considered in 
calculating estimated forfeitures. Estimated forfeitures are adjusted when actual forfeitures differ from estimates, resulting in the 
recognition of compensation cost only for awards that vest.  The effect of a change in estimated forfeitures is recognized through 
a cumulative catch-up adjustment that is included in compensation cost in the period of the change in estimate.  The fair value of 
stock options where vesting is based on service is estimated at the date of grant using a Black-Scholes option pricing model and 
related assumptions. As compensation cost is recognized, a deferred tax asset is recorded that represents an estimate of the future 
tax deduction from exercise or release of restrictions.  At the time the share-based awards are exercised, cancelled, have expired, 
or restrictions are released, the Company may be required to recognize an adjustment to tax expense depending on the market 
price of the Company’s common stock.

See Note 17 for further discussion and details of share-based payments.

EMPLOYEE BENEFIT PLANS

Regions uses an expected long-term rate of return applied to the fair market value of assets as of the beginning of the year 
and the expected cash flows during the year for calculating the expected investment return on all pension plan assets.  At a minimum, 
amortization of the net gain or loss included in accumulated other comprehensive income resulting from experience different from 
that assumed and from changes in assumptions is included as a component of net periodic benefit cost if, as of the beginning of 
the year, that net gain or loss exceeds 10 percent of the greater of the projected benefit obligation or the market value of plan assets.  
If amortization is required, the minimum amortization is that excess divided by the average remaining service period of active 
participating employees expected to receive benefits under the plans.  Regions uses a third-party actuary to compute the remaining 
service  period  of  active  participating  employees.   This  period  reflects  expected  turnover,  pre-retirement  mortality,  and  other 
applicable employee demographics.

REVENUE RECOGNITION

The largest source of revenue for Regions is interest income. Interest income is recognized using the interest method driven 
by nondiscretionary formulas based on written contracts, such as loan agreements or securities contracts. Credit and mortgage-
related fees, including letter of credit fees, servicing fees, and fees related to debit and credit cards are recognized in non-interest 
income when earned. Regions recognizes commission revenue and exchange and clearance fees on a trade-date basis. Other types 
of non-interest revenues, such as service charges on deposits, interchange income on credit cards, trust revenues and capital markets 
fee  income  are  accrued  and  recognized  into  income  as  services  are  provided  and  the  amount  of  fees  earned  are  reasonably 
determinable.

PER SHARE AMOUNTS

Earnings per common share is calculated by dividing net income available to common shareholders by the weighted-average 
number of common shares outstanding during the period. Diluted earnings per common share is calculated by dividing net income 
available to common shareholders by the weighted-average number of common shares outstanding during the period, plus the 
effect of outstanding stock options and stock performance awards if dilutive. Refer to Note 16 for additional information.

FAIR VALUE MEASUREMENTS

Fair value guidance establishes a framework for using fair value to measure assets and liabilities and defines fair value as 
the price that would be received to sell an asset or paid to transfer a liability (an exit price) as opposed to the price that would be 
paid to acquire the asset or received to assume the liability (an entry price). A fair value measure should reflect the assumptions 
that market participants would use in pricing the asset or liability, including the assumptions about the risk inherent in a particular 
valuation technique, the effect of a restriction on the sale or use of an asset and the risk of nonperformance. Required disclosures 

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include stratification of balance sheet amounts measured at fair value based on inputs the Company uses to derive fair value 
measurements. These strata include:

•  Level 1 valuations, where the valuation is based on quoted market prices for identical assets or liabilities traded in active 

markets (which include exchanges and over-the-counter markets with sufficient volume),

•  Level 2 valuations, where the valuation is based on quoted market prices for similar instruments traded 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, and

•  Level 3 valuations, where the valuation is generated from model-based techniques that use significant assumptions not 
observable in the market, but observable based on Company-specific data. These unobservable assumptions reflect the 
Company’s own estimates for assumptions that market participants would use in pricing the asset or liability. Valuation 
techniques typically include option pricing models, discounted cash flow models and similar techniques, but may also 
include the use of market prices of assets or liabilities that are not directly comparable to the subject asset or liability.

ITEMS MEASURED AT FAIR VALUE ON A RECURRING BASIS

Trading account securities, securities available for sale, certain mortgage loans held for sale, residential MSRs, derivative 
assets and derivative liabilities are recorded at fair value on a recurring basis. Below is a description of valuation methodologies 
for these assets and liabilities.

Trading account securities and securities available for sale consist of U.S. Treasuries, obligations of states and political 

subdivisions, mortgage-backed securities (including agency securities), other debt securities and equity securities.

•  U.S. Treasuries are valued based on quoted market prices of identical assets on active exchanges. Pricing received for 
U.S. Treasuries from third-party services is based on a market approach using dealer quotes from multiple active market 
makers and real-time trading systems. These valuations are Level 1 measurements.

•  Mortgage-backed securities are valued primarily using data from third-party pricing services for similar securities as 
applicable. Pricing from these third-party services is generally based on a market approach using observable inputs such 
as benchmark yields, reported trades, broker/dealer quotes, benchmark securities, TBA prices, issuer spreads, bids and 
offers,  monthly  payment  information,  and  collateral  performance,  as  applicable.  These  valuations  are  Level  2 
measurements. Where such comparable data is not available, the Company develops valuations based on assumptions 
that are not readily observable in the market place; these valuations are Level 3 measurements.

•  Obligations of states and political subdivisions are generally based on data from third-party pricing services. The valuations 
are based on a market approach using observable inputs such as benchmark yields, MSRB reported trades, material event 
notices and new issue data. These valuations are Level 2 measurements. Where such comparable data is not available, 
the Company develops valuations based on assumptions that are not readily observable in the market place; these valuations 
are Level 3 measurements. 

•  Other debt securities are valued based on Level 1, 2 and 3 measurements, depending on pricing methodology selected 
and are valued primarily using data from third-party pricing services. Pricing from these third-party services is generally 
based on a market approach using observable inputs such as benchmark yields, reported trades, broker/dealer quotes, 
issuer spreads, benchmark securities, bids and offers, and TRACE reported trades.

•  Equity securities are valued based on quoted market prices of identical assets on active exchanges; these valuations are 

Level 1 measurements.

Regions’  trading  account  securities  and  the  majority  of  securities  available  for  sale  are  valued  using  third-party  pricing 
services. To validate pricing related to investment securities held in the trading account securities portfolios, pricing received from 
third-party pricing services is compared to available market data for reasonableness and/or pricing information from other third-
party pricing services.

To validate pricing related to liquid investment securities, which represent the vast majority of the available for sale portfolio 
(e.g., mortgage-backed securities), Regions compares price changes received from the third-party pricing service to overall changes 
in market factors in order to validate the pricing received. To validate pricing received on less liquid investment securities in the 
available  for  sale  portfolio,  Regions  receives  pricing  from  third-party  brokers/dealers  on  a  sample  of  securities  that  are  then 
compared to the pricing received. The pricing service uses standard observable inputs when available, for example: benchmark 
yields, reported trades, broker-dealer quotes, issuer spreads, benchmark securities, and bids and offers, among others. For certain 
security types, additional inputs may be used, or some inputs may not be applicable. It is not customary for Regions to adjust the 
pricing received for the available for sale portfolio. In the event that prices are adjusted, Regions classifies the measurement as a 
Level 3 measurement.

Mortgage loans held for sale consist of residential first mortgage loans and commercial mortgages held for sale.  The 
residential first mortgage loans held for sale are valued based on traded market prices of similar assets where available and/or 
discounted  cash  flows  at  market  interest  rates,  adjusted  for  securitization  activities  that  include  servicing  value  and  market 

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conditions, a Level 2 measurement. The commercial mortgage loans held for sale are valued based on traded market prices for 
comparable commercial mortgage-backed securitizations, into which the loans will be placed, adjusted for movements of interest 
rates and credit spreads, a Level 3 measurement due to the unobservable inputs included in the credit spreads for bonds in commercial 
mortgage-backed securitizations.  Regions has elected to measure certain residential and commercial mortgage loans held for sale 
at fair value by applying the fair value option (see additional discussion under the “Fair Value Option” section in Note 22).

Residential  mortgage  servicing  rights  are  valued  using  an  option-adjusted  spread  valuation  approach,  a  Level  3 
measurement.  The  underlying  assumptions  and  estimated  values  are  corroborated  at  least  quarterly  by  values  received  from 
independent third parties. See Note 7 for information regarding the servicing of financial assets and additional details regarding 
the assumptions relevant to this valuation.

Derivative assets and liabilities, which primarily consist of interest rate, foreign exchange, and commodity contracts that 
include forwards, futures, options and swaps, are included in other assets and other liabilities (as applicable) on the consolidated 
balance sheets. Interest rate swaps are predominantly traded in over-the-counter markets and, as such, values are determined using 
widely accepted discounted cash flow models, which are Level 2 measurements. These discounted cash flow models use projections 
of future cash payments/receipts that are discounted at an appropriate index rate. During 2016, Regions began utilizing OIS curves 
as fair value measurement inputs for the valuation of interest rate and commodity derivatives. The assumed cash flows are sourced 
from an assumed yield curve, which is consistent with industry standards and conventions. These valuations are adjusted for the 
unsecured credit risk at the reporting date, which considers collateral posted and the impact of master netting agreements. For 
options and futures contracts traded in over-the-counter markets, values are determined using discounted cash flow analyses and 
option pricing models based on market rates and volatilities, which are Level 2 measurements. Interest rate lock commitments on 
loans  intended  for  sale  and  risk  participations  categorized  as  credit  derivatives  are  valued  using  option  pricing  models  that 
incorporate significant unobservable inputs, and therefore are Level 3 measurements.

ITEMS MEASURED AT FAIR VALUE ON A NON-RECURRING BASIS

From time to time, certain assets may be recorded at fair value on a non-recurring basis. These non-recurring fair value 
adjustments typically are a result of the application of lower of cost or fair value accounting or a write-down occurring during the 
period. For example, if the fair value of an asset in these categories falls below its cost basis, it is considered to be at fair value at 
the end of the period of the adjustment. In periods where there is no adjustment, the asset is generally not considered to be at fair 
value. The following is a description of the valuation methodologies used for assets measured at fair value on a non-recurring 
basis.

Foreclosed property and other real estate is carried in other assets at the lower of the recorded investment in the loan or 
fair value less estimated costs to sell the property. The fair value for foreclosed property that is based on either observable transactions 
of similar instruments or formally committed sale prices is classified as a Level 2 measurement. If no formally committed sale 
price is  available, Regions  also obtains valuations from  professional valuation experts and/or third  party appraisers. Updated 
valuations are obtained on at least an annual basis. Foreclosed property exceeding established dollar thresholds is valued based 
on appraisals. Appraisals are performed by third-parties with appropriate professional certifications and conform to generally 
accepted appraisal standards as evidenced by the Uniform Standards of Professional Appraisal Practice. Regions’ policies related 
to appraisals conform to regulations established by the Financial Institutions Reform, Recovery and Enforcement Act of 1989 and 
other  regulatory  guidance.  Professional  valuations  are  considered  Level  2  measurements  because  they  are  based  largely  on 
observable inputs. Regions has a centralized appraisal review function that is responsible for reviewing appraisals for compliance 
with banking regulations and guidelines as well as appraisal standards. Based on these reviews, Regions may make adjustments 
to the market value conclusions determined in the appraisals of real estate (either as other real estate or loans held for sale) when 
the appraisal review function determines that the valuation is based on inappropriate assumptions or where the conclusion is not 
sufficiently supported by the market data presented in the appraisal. Adjustments to the market value conclusions are discussed 
with the professional valuation experts and/or third-party appraisers; the magnitude of the adjustments that are not mutually agreed 
upon is insignificant. In either event, adjustments, if made, must be based on sufficient information available to support an alternate 
opinion of market value. An estimated standard discount factor, which is updated at least annually, is applied to the appraisal 
amount for certain commercial and investor real estate properties when the recorded investment in the loan is transferred into 
foreclosed property. Internally adjusted valuations are considered Level 3 measurements as management uses assumptions that 
may not be observable in the market. These non-recurring fair value measurements are typically recorded on the date an updated 
offered quote, appraisal, or third-party valuation is received.

Loans held for sale for which the fair value option has not been elected are recorded at the lower of cost or fair value and 
therefore are reported at fair value on a non-recurring basis. The fair values for commercial loans held for sale that are based on 
formally committed loan sale prices or valuations performed using observable inputs are classified as a Level 2 measurement. If 
no formally committed sales price is available, a professional valuation is obtained, consistent with the process described above 
for foreclosed property and other real estate.

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FAIR VALUE OF FINANCIAL INSTRUMENTS

The following methods and assumptions were used by the Company in estimating fair values of financial instruments that 

are not disclosed above:

Cash and cash equivalents: The carrying amounts reported in the consolidated balance sheets and cash flows approximate 
the estimated fair values. Because these amounts generally relate to either currency or highly liquid assets, these are considered 
Level 1 valuations.

Securities  held  to  maturity:  The  fair  values  of  securities  held  to  maturity  are  estimated  in  the  same  manner  as  the 

corresponding securities available for sale, which are measured at fair value on a recurring basis.

Loans, (excluding capital leases), net of unearned income and allowance for loan losses: A discounted cash flow method 
under the income approach is utilized to estimate the fair value of the loan portfolio. The discounted cash flow method relies upon 
assumptions about the amount and timing of scheduled principal and interest payments, principal prepayments, and estimates of 
principal defaults, loss given default, and current market interest rates (excluding credit). The loan portfolio is aggregated into 
categories based on loan type and credit quality. For each loan category, weighted average statistics, such as coupon rate, age, and 
remaining term are calculated. These are Level 3 valuations.

Other  earning  assets  (excluding  operating  leases): The  carrying  amounts  reported  in  the  consolidated  balance  sheets 
approximate the estimated fair values. While these instruments are not actively traded in the market, the majority of the inputs 
required to value them are actively quoted and can be validated through external sources. Accordingly, these are Level 2 valuations.

Deposits: The fair value of non-interest-bearing demand accounts, interest-bearing transaction accounts, savings accounts, 
money market accounts and certain other time deposit accounts is the amount payable on demand at the reporting date (i.e., the 
carrying amount). Fair values for certificates of deposit are estimated by using discounted cash flow analyses, based on market 
spreads to benchmark rates. These are Level 2 valuations.

Short-term and long-term borrowings: The carrying amounts of short-term borrowings reported in the consolidated balance 
sheets approximate the estimated fair values, and are considered Level 2 measurements as similar instruments are traded in active 
markets. The fair values of certain long-term borrowings are estimated using quoted market prices of identical instruments in 
active markets and are considered Level 1 measurements. The fair values of certain long term borrowings are estimated using 
quoted market prices of identical instruments in non-active markets and are considered Level 2 valuations. Otherwise, valuations 
are based on non-binding broker quotes and are considered Level 3 valuations.

Loan commitments and letters of credit: The estimated fair values for these off-balance sheet instruments are based on 
probabilities of funding to project future loan fundings, which are discounted using the loan methodology described above. The 
premiums/discounts are adjusted for the time value of money over the average remaining life of the commitments and the opportunity 
cost associated with regulatory requirements. Because the probabilities of funding and loan valuations are not observable in the 
market and are considered Company specific inputs, these are Level 3 valuations.

Indemnification obligation: The estimated fair value of the indemnification obligation was determined through the use of 
a present value calculation that takes into account the future cash flows that a market participant would expect to receive from 
holding the indemnification liability as an asset. Regions performed a probability-weighted cash flow analysis and discounted the 
result at a credit-adjusted risk free rate. Because the future cash flows and probability weights are Company-specific inputs, this 
is a Level 3 valuation. See Note 24 for further information regarding the indemnification obligation.

See Note 22 for additional information related to fair value measurements.

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RECENT ACCOUNTING PRONOUNCEMENTS AND ACCOUNTING CHANGES

The  following  table  provides  a  brief  description  of  accounting  standards  that  could  have  a  material  impact  to  Regions’ 

consolidated financial statements upon adoption.

Standard

Description

Required Date
of Adoption

Effect on Regions' financial statements or other
significant matters

Standards Adopted (or partially adopted) in 2016
ASU 2015-02,
Amendments to
Consolidation
Analysis

This ASU amends Topic 810, Consolidation, and 
eliminates the consolidation model created specifically for 
limited partnerships and creates a single model for 
evaluating consolidation of legal entities.  This ASU may 
be adopted either retrospectively or on a modified 
retrospective basis.
This ASU amends Subtopic 835-30, Interest-Imputation of 
Interest, and requires entities to present debt issuance costs 
related to a recognized liability as a direct deduction from 
the carrying amount of the debt liability. This ASU should 
be adopted retrospectively. 

January 1, 2016

Early adoption is 
permitted.

Adopted on a modified-retrospective basis January 1, 
2016.

No material impact.

January 1, 2016

Adopted January 1, 2016.

Early adoption is
permitted.

Because the impact of this guidance was not material to 
prior periods, retrospective application and the related 
disclosures were not necessary for Regions.

ASU 2015-03,
Simplifying the
Presentation of
Debt Issuance
Costs

ASU 2015-05,
Customer’s
Accounting for
Fees Paid in a
Cloud
Computing
Arrangement

ASU 2015-07,
Disclosures for
Investments in
Certain Entities
That Calculate
Net Asset Value
per Share (or Its
Equivalent)

ASU 2015-12,
(Part I) Fully
Benefit-
Responsive
Investment
Contracts, (Part
II) Plan
Investment
Disclosures, and
(Part III)
Measurement
Date Practical
Expedient

This ASU amends Subtopic 350-40, Intangibles-Goodwill 
and Other- Internal Use Software, and provides guidance 
on how customers should evaluate whether such 
arrangements contain a software license that should be 
accounted for separately.  This ASU may be adopted either 
retrospectively or prospectively.  

January 1, 2016

Adopted on a prospective basis January 1, 2016.

Early adoption is
permitted.

No material impact.

This ASU amends Topic 820, Fair Value Measurement, 
removes the requirement to categorize within the fair value 
hierarchy all investments for which fair value is measured 
using the net asset value per share practical expedient 
pursuant to previous guidance. This ASU should be 
adopted retrospectively. 

January 1, 2016

Adopted January 1, 2016.

Early adoption is
permitted.

No material impact.

January 1, 2016

Adopted January 1, 2016.

No material impact.

Early adoption is
permitted for any
of the three parts
individually.

This ASU amends Topic 960, Plan Accounting: Defined 
Benefit Pension Plans, Topic 962, Defined Contribution 
Pension Plans, and Topic 965, Health and Welfare Benefit 
Plans.  The guidance provides three parts to simplify the 
process. Part I notes that fully benefit-responsive 
investment contracts will be measured, presented and 
disclosed only at contract value, and plans are no longer 
required to reconcile contract value to fair value. Part II 
simplifies the disclosure of plan investments.  Part III 
allows a measurement date practical expedient and permits 
plans to measure investments and investment-related 
accounts as of a month-end that is closest to the plan’s 
fiscal year-end when the fiscal year-end does not coincide 
with a month-end. Parts I and II of the ASU should be 
adopted on a retrospective basis and Part III of the ASU 
should be adopted prospectively.

ASU 2015-16,
Simplifying the
Accounting for
Measurement-
Period
Adjustments

This ASU amends Topic 805, Business Combinations, and 
eliminates the requirement for an acquirer in a business 
combination to account for measurement-period 
adjustments retrospectively. Instead acquirers will 
recognize measurement-period adjustments during the 
period in which they determine the amounts.  This ASU 
should be adopted prospectively.

January 1, 2016

Adopted January 1, 2016.

Early adoption is
permitted.

No material impact.

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Standard

Description

Required Date
of Adoption

Effect on Regions' financial statements or other
significant matters

Standards Not Yet Adopted
ASU 2014-09, 
Revenue from 
Contracts with 
Customers

This ASU supersedes the revenue recognition requirements 
in ASC Topic 605, Revenue Recognition, and most 
industry-specific guidance throughout the Industry topics 
of the Codification.  The core principle of the ASU is that 
an entity should recognize revenue to depict the transfer of 
promised goods or services to customers in an amount that 
reflects the consideration to which the entity expects to be 
entitled in exchange for those goods or services.  The ASU 
may be adopted either retrospectively or on a modified 
retrospective basis.

January 1, 2018 

Early adoption is 
permitted 
beginning 
January 1, 2017.

Regions has established a revenue recognition standard
implementation team, led by the Corporate Controller’s
group with assistance from the various lines of business
and finance management to evaluate the potential impact
of adopting this guidance. The implementation team has
substantially completed the initial scoping and
determined that approximately $1.7 billion of 2016 non-
interest income would be within the scope of the new
revenue recognition standard, when adopted. Non-
interest income streams that are out of scope of the new
standard include mortgage income, securities gains
(losses), bank-owned life insurance and certain other
components within non-interest income. The
implementation team has also substantially completed its
evaluation of service charges on deposit accounts and has
determined that changes in revenue recognition for those
contracts are not expected to result in a material impact
to Regions upon adoption. The implementation team is
currently reviewing contracts related to card and ATM
fees, investment management and trust fees, insurance
commissions and fees, investment services fees and
capital markets fees. The review of the remaining
contracts is expected to be completed in early 2017. In
addition to potential timing issues for revenue
recognition under the new standard, Regions is still
evaluating the standard’s guidance for assessment of
gross versus net reporting of revenues and expenses
related to certain arrangements such as card interchange
fees. The implementation team is also in process of
developing additional quantitative and qualitative
disclosures that may be required upon the adoption of the
new revenue recognition standard.

Regions is evaluating the impact upon adoption; 
however, the impact is not expected to be material. 
Regions does not plan to early adopt.

ASU 2015-14, 
Deferral of the 
Effective Date

ASU 2016-08, 
Principal versus 
Agent 
Considerations

ASU 2016-10, 
Identifying 
Performance 
Obligations and 
Licensing

ASU 2016-12, 
Narrow-Scope 
Improvements 
and Practical 
Expedience

ASU 2016-20, 
Technical 
Corrections and 
Improvements to 
Topic 606, 
Revenue from 
Contracts with 
Customers

ASU 2016-01,
Recognition and
Measurement of
Financial Assets
and Liabilities

This ASU amends ASC Topic 825, Financial Instruments-
Overall, and addresses certain aspects of recognition, 
measurement, presentation, and disclosure of financial 
instruments.  The main provisions require investments in 
equity securities to be measured at fair value with changes 
in the fair value recognized through net income (except for 
those accounted for under the equity method of accounting 
or those that result in consolidation of the investee) 
requires public business entities (PBEs) to use the exit 
price notion when measuring the fair value of financial 
instruments for disclosure purposes and requires an entity 
to present separately in other comprehensive income, the 
portion of the total change in the fair value of a liability 
resulting from a change in the instrument-specific credit 
risk when the entity has elected to measure the liability at 
fair value. Except for disclosure requirements that will be 
adopted prospectively, the ASU must be adopted on a 
modified retrospective basis.

January 1, 2018 

Early adoption 
permitted 
beginning 
January 1, 2016 
or 2017 for the 
amendment 
related to 
separate 
presentation in 
other 
comprehensive 
income.  

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Standard

Description

Required Date
of Adoption

Effect on Regions' financial statements or other
significant matters

Standards Not Yet Adopted (continued)
ASU 2016-02,
Leases

This ASU creates ASU Topic 842, Leases, and supersedes 
Topic 840, Leases.  The new guidance requires lessees to 
record a right-of-use asset and a corresponding liability 
equal to the present value of future rental payments on 
their balance sheets for all leases with a term greater than 
one year.  There are not significant changes to lessor 
accounting; however, there were certain improvements 
made to align lessor accounting with the lessee accounting 
model and Topic 606, Revenue from Contracts with 
Customers.  This guidance expands both quantitative and 
qualitative required disclosures.  This ASU should be 
adopted on a modified retrospective basis.

January 1, 2019

Early adoption is 
permitted.

This ASU supersedes the lease accounting requirements 
in Topic 840, Leases. Regions has established a leasing 
standard implementation team comprised of the 
Corporate Controller’s group, Corporate Real Estate and 
other business and finance management to plan and 
execute the adoption of the new leasing standard.  The 
implementation team has substantially completed the 
identification of Regions’ leases that will need to be 
measured and reported as a right-of-use asset and 
corresponding liability for future rental payments.  The 
implementation team is currently working with a lease 
administration vendor to set up and test the accounting 
for the lease contracts on the lease administration system. 
Based on the December 31, 2016 lease portfolio, Regions 
has approximately $761 million of future lease 
obligations that would be measured and recognized when 
the new guidance is adopted (refer to Note 24). While 
this amount represents a large majority of the leases that 
are within the scope of the new leasing standard, the 
implementation team will continue reviewing service 
contracts up through the effective date and may identify 
additional leases embedded in those arrangements that 
will be within the scope of the new standard. Between 
now and January 1, 2019, Regions will likely have 
changes to the lease portfolio as the Company continues 
to evaluate and execute branch and occupancy 
optimization initiatives. In addition to final determination 
of the lease portfolio at the effective date, the initial 
measurement of the right-of-use asset and the 
corresponding liability will be affected by certain key 
assumptions such as expectations of renewals or 
extensions and the interest rate to be used to discount the 
future lease obligations. Up through the date of adoption, 
the evaluation of the impact of the standard will be 
adjusted based on new leases that are executed, leases 
that are terminated prior to the effective date, and any 
leases with changes to key assumptions or expectations 
such as renewals and extensions, and discount rates. 
While there will be some changes to income statement 
classification, the implementation team does not expect 
the adoption of the standard to have a material impact to 
pre-tax income.  Regions does not anticipate early 
adoption of the new standard.

ASU 2016-05,
Effect of
Derivative
Contract
Novations on
Existing Hedge
Accounting
Relationships

ASU 2016-06,
Contingent Put
and Call Options
in Debt
Instruments

ASU 2016-07,
Simplifying the
Transition to the
Equity Method
of Accounting

ASU 2016-09,
Improvements to
Employee Share-
Based Payment
Accounting

The ASU amends Topic 815, Derivatives and Hedging, 
and addresses how a change in the counterparty to a 
derivative contract affects a hedging relationship.  The 
ASU may be adopted either prospectively or on a modified 
retrospective basis.   

January 1, 2017

Regions believes the adoption of this guidance will not 
have a material impact.

The ASU amends Topic 815, Derivatives and Hedging, 
and clarifies that entities should solely use the four-step 
decision sequence described in current derivatives 
accounting guidance. This sequence should be used when 
assessing whether contingent exercise provisions 
associated with a put or call option are clearly and closely 
related to their debt hosts. The ASU should be adopted on 
a modified retrospective basis.

The ASU amends Topic 323, Investments- Equity Method 
and Joint Ventures, and eliminates the requirement for an 
investor to retrospectively apply the equity method to 
investments when its ownership interest (or degree of 
influence in an investee) increases to a level that triggers 
the equity method of accounting. This ASU should be 
adopted prospectively. 

This ASU amends Topic 718, Stock Compensation, and 
intends to improve and simplify accounting for employee 
shared-based payments. The amendments update the 
accounting for income taxes, forfeitures, and statutory tax 
withholding requirements, as well as classification in the 
statement of cash flows.  The transition method of 
accounting application (i.e. prospective, retrospective or 
modified retrospective application) differs by amendment 
and is defined in the guidance.

January 1, 2017

Regions believes the adoption of this guidance will not 
have a material impact.

January 1, 2017

Regions believes the adoption of this guidance will not
have a material impact.

January 1, 2017

Regions believes the adoption of this guidance will not
have a material impact.

113

Table of Contents 

Standard

Description

Required Date
of Adoption

Effect on Regions' financial statements or other
significant matters

Standards Not Yet Adopted (continued)
ASU 2016-13,
Measurement of
Credit Losses on
Financial
Instruments

This ASU amends Topic 326, Financial Instruments- 
Credit Losses to replace the current incurred loss 
accounting model with a current expected credit loss 
approach (CECL) for financial instruments measured at 
amortized cost and other commitments to extend credit.  
The amendments require entities to consider all available 
relevant information when estimating current expected 
credit losses, including details about past events, current 
conditions, and reasonable and supportable forecasts.  The 
resulting allowance for credit losses is to reflect the portion 
of the amortized cost basis that the entity does not expect 
to collect.  The amendments also eliminate the current 
accounting model for purchased credit impaired loans and 
debt securities. Additional quantitative and qualitative 
disclosures are required upon adoption.  

While the CECL model does not apply to AFS debt 
securities, the ASU does require entities to now record an 
allowance when recognizing credit losses for AFS 
securities, rather than reduce the amortized cost of the 
securities by direct write-offs.  

The ASU should be adopted on a modified retrospective 
basis.  Entities that have loans accounted for under ASC 
310-30 at the time of adoption should prospectively apply 
the guidance in this amendment for purchase credit 
deteriorated assets. 

This ASU amends Topic 230, Statement of Cash Flows, 
and provides clarification with respect to classification 
within the statement on cash flows where current guidance 
is unclear or silent.  The ASU should be adopted 
retrospectively.  

This ASU amends Topic 810, Consolidation, and 
prescribes that when determining whether a single decision 
maker is the primary beneficiary of a variable interest 
entity (VIE), a single decision maker will no longer be 
required to consider indirect interests held through related 
parties that are under common control with the single 
decision maker to be the equivalent of direct interests in 
their entirety. Entities that have not adopted ASU 2015-02 
are required to adopt the amendments in this ASU at the 
same time they adopt ASC 2015-02 and should apply the 
same transition method elected for the application of ASU 
2015-02.  Entities that have already adopted ASU 2015-02 
should apply the amendments in this ASU retrospectively 
to the same periods ASU 2015-02 were initially applied. 

ASU 2016-15,
Classification of
Certain Cash
Receipts and
Cash Payments

ASU 2016-17, 
Interest Held 
through Related 
Parties That Are 
Under Common 
Control

January 1, 2020 

Early adoption 
permitted 
beginning 
January 1, 2019

Regions has formed a cross-functional implementation 
team co-led by Finance and Risk Management.  The 
implementation team has developed a high-level project 
plan and is staying informed about the broader industry’s 
perspective and insights, delivering educational and 
awareness sessions across the Company, identifying and 
researching key decision points, and evaluating the 
financial and operational implications of adoption. 

January 1, 2018

Early adoption is 
permitted.

Regions is evaluating the impact upon adoption;
however, the impact is not expected to be material.
Regions does not plan to early adopt.

January 1, 2017

Early adoption is 
permitted.

Regions is evaluating the impact upon adoption; 
however, the impact is not expected to be material. 
Regions does not plan to early adopt.

ASU 2017-01,
Clarifying the
Definition of a
Business

This ASU amends Topic 805, Business Combinations, and 
provides additional accounting guidance to better 
determine when a set of assets and activities is a business. 
The ASU should be adopted prospectively.   

ASU 2017-04,
Simplifying the
Test for
Goodwill
Impairment

This ASU amends Topic 350, Intangibles-Goodwill and 
Other, and eliminates Step 2 from the goodwill impairment 
test. 

January 1, 2018

Early adoption is 
permitted for 
certain 
transactions as 
described in 
guidance.

January 1, 2020

Early adoption is 
permitted.

Regions is evaluating the impact upon adoption; 
however, the impact is not expected to be material. 

Regions believes the adoption of this guidance will not 
have a material impact.  Regions does not plan to early 
adopt. 

114

NOTE 2. VARIABLE INTEREST ENTITIES

Regions is involved in various entities that are considered to be VIEs, as defined by authoritative accounting literature. 
Generally, a VIE is a corporation, partnership, trust or other legal structure that either does not have equity investors with substantive 
voting rights or has equity investors that do not provide sufficient financial resources for the entity to support its activities. The 
following discusses the VIEs in which Regions has a significant interest.

Regions  periodically  invests  in  various  limited  partnerships  that  sponsor  affordable  housing  projects,  which  are  funded 
through  a  combination  of  debt  and  equity.  These  partnerships  meet  the  definition  of  a  VIE.  Regions  uses  the  proportional 
amortization method for these investments. Due to the nature of the management activities of the general partner, Regions is not 
the primary beneficiary of these partnerships and accounts for these investments in other assets on the consolidated balance sheets.  
See Note 1 for additional details.

Regions reports its equity share of affordable housing partnership gains and losses as an adjustment to non-interest income. 
Regions reports its commitments to make future investments in other liabilities on the consolidated balance sheets. The Company 
also receives tax credits, which are reported as a reduction of income tax expense (or increase to income tax benefit) related to 
these transactions. Additionally, Regions has short-term construction loans or letters of credit commitments with certain limited 
partnerships. The funded portion of the short-term loans and letters of credit is classified as commercial and industrial loans or 
investor real estate construction loans, as applicable, in Note 5. Regions also has long-term mortgage loans with certain limited 
partnerships. These long-term loans are classified as investor real estate mortgage loans in Note 5.

The Company recognized $117 million and $103 million in amortization expense and $130 million and $118 million of tax 
credits related to investments in qualified affordable housing projects utilizing the proportional amortization method during 2016 
and 2015, respectively. The Company also recognized $37 million and $32 million of other tax benefits related to these investments 
during 2016 and 2015, respectively.

A summary of Regions’ proportional amortization method investments, equity method investments and related loans and 

letters of credit, representing Regions’ maximum exposure to loss as of December 31 is as follows: 

Proportional amortization method investments included in other assets
Equity method investments included in other assets
Unfunded commitments included in other liabilities
Short-term construction loans and letters of credit commitments
Funded portion of short-term loans and letters of credit

2016

2015

(In millions)

$

$

1,013
21
301
249
103

891
26
285
266
139

During 2016, Regions became a syndicator of affordable housing investments. In these syndication transactions, Regions 
creates affordable housing funds in which a subsidiary is the general partner or managing member and sells limited partnership 
interests to third parties. Regions' general partner or managing member interest represents an insignificant interest in the affordable 
housing fund.  Regions generates revenue from the syndication of these funds and also asset management revenue by managing 
the funds. The affordable housing funds meet the definition of a VIE. The primary benefits are the rights to receive tax credits and 
other tax benefits, which are transferred to the third party investors. As Regions is not the primary beneficiary and does not have 
a significant interest, these investments are not consolidated. At December 31, 2016, the value of Regions’ general partnership 
interest in affordable housing investments is immaterial.  Affordable housing investments that the Company intends to syndicate 
but have not yet syndicated as of December 31, 2016 are not VIEs and are accounted for within other assets at the lower of cost 
or fair value totaling approximately $8 million. 

115

 
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NOTE 3. DISCONTINUED OPERATIONS

On  January 11,  2012,  Regions  entered  into  a  stock  purchase  agreement  to  sell  Morgan  Keegan  and  related  affiliates  to 
Raymond James. The transaction closed on April 2, 2012. Regions Investment Management, Inc. (formerly known as Morgan 
Asset Management, Inc.) and Regions Trust were not included in the sale. In connection with the closing of the sale, Regions 
agreed to indemnify Raymond James for all litigation matters related to pre-closing activities.  See Note 24 for related disclosure.

The following table represents the condensed results of operations for discontinued operations:

Non-interest income:

Insurance proceeds

Total non-interest income

Non-interest expense:

Professional and legal expenses
Other

Total non-interest expense

Income (loss) from discontinued operations before income taxes
Income tax expense (benefit)
Income (loss) from discontinued operations, net of tax
Earnings (loss) per common share from discontinued operations:

Basic
Diluted

NOTE 4. SECURITIES 

Year Ended December 31

2016

2015

2014

(In millions, except per share data)

$

$

$
$

— $
—

(9)
1
(8)
8
3
5

0.00
0.00

$

$
$

— $
—

21
1
22
(22)
(9)
(13) $

19
19

(3)
1
(2)
21
8
13

(0.01) $
(0.01) $

0.01
0.01

The amortized cost, gross unrealized gains and losses, and estimated fair value of securities held to maturity and securities 

available for sale are as follows:

December 31, 2016

Recognized in OCI (1)

Gross
Unrealized
Gains

Gross
Unrealized
Losses

Amortized
Cost

Not recognized in OCI

Gross
Unrealized
Gains

Gross
Unrealized
Losses

Estimated
Fair
Value

Carrying
Value

(In millions)

Securities held to maturity:

Mortgage-backed securities:

Residential agency

Commercial agency

Securities available for sale:

U.S. Treasury securities

Federal agency securities

$

$

$

Obligations of states and political subdivisions

Mortgage-backed securities:

Residential agency

Residential non-agency

Commercial agency

Commercial non-agency

Corporate and other debt securities

Equity securities

303

$

35

1

17,531

4

3,486

1,124

1,272

194
23,950

$

$

1,249

167

1,416

$

$

— $

(49) $

—

(5)

— $

(54) $

1,200

162

1,362

$

$

12

—

12

$

$

(3) $

(2)

(5) $

1,209

160

1,369

$

$

303

35

1

17,371

4

3,463

1,129

1,274

201
23,781

$

(1) $

—

—

303

35

1

(255)

17,371

—

(32)

(3)

(17)

4

3,463

1,129

1,274

—
(308) $

201
23,781

1

—

—

95

—

9

8

19

7
139

$

116

 
 
 
 
 
 
 
Table of Contents 

December 31, 2015

Recognized in OCI (1)

Gross
Unrealized
Gains

Gross
Unrealized
Losses

Amortized
Cost

Not recognized in OCI

Gross
Unrealized
Gains

Gross
Unrealized
Losses

Estimated
Fair
Value

Carrying
Value

(In millions)

$

$

$

Securities held to maturity:

U.S. Treasury securities

Federal agency securities

Mortgage-backed securities:

Residential agency

Commercial agency

Securities available for sale:

U.S. Treasury securities

Federal agency securities

Obligations of states and political subdivisions

Mortgage-backed securities:

Residential agency

Residential non-agency

Commercial agency

Commercial non-agency

Corporate and other debt securities

Equity securities

1

$

— $

— $

1

$

— $

— $

350

1,490

181

—

—

—

(10)

(61)

(5)

340

1,429

176

2,022

$

— $

(76) $

1,946

$

9

18

—

27

$

228

219

1

1

—

—

16,003

149

5

3,033

1,245

1,718

272

—

10

3

12

10

$

(1) $

(1)

—

(90)

—

(25)

(17)

(63)

(2)

228

218

1

16,062

5

3,018

1,231

1,667

280

1

349

1,445

174

—

(2)

(2)

$

(4) $

1,969

$

228

218

1

16,062

5

3,018

1,231

1,667

280

$

22,724

$

185

$

(199) $

22,710

$

22,710

_________
(1)  The gross unrealized losses recognized in OCI on held to maturity securities resulted from a transfer of available for sale securities to 

held to maturity in the second quarter of 2013.

Securities with carrying values of $11.6 billion and $11.9 billion at December 31, 2016 and 2015, respectively, were 
pledged to secure public funds trading positions, trust deposits and certain borrowing arrangements. Included within total pledged 
securities is approximately $50 million of encumbered U.S. Treasury securities at both December 31, 2016 and 2015. 

The amortized cost and estimated fair value of securities held to maturity and securities available for sale at December 31, 
2016, by contractual maturity, are shown below. Expected maturities will differ from contractual maturities because borrowers 
may have the right to call or prepay obligations with or without call or prepayment penalties.

117

 
 
 
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Securities held to maturity:

Mortgage-backed securities:

Residential agency
Commercial agency

Securities available for sale:
Due in one year or less
Due after one year through five years
Due after five years through ten years
Due after ten years
Mortgage-backed securities:

Residential agency
Residential non-agency
Commercial agency
Commercial non-agency

Equity securities

Amortized
Cost

Estimated
Fair Value

(In millions)

$

$

$

$

1,249
167
1,416

74
581
719
237

17,531
4
3,486
1,124
194
23,950

$

$

$

$

1,209
160
1,369

74
586
720
233

17,371
4
3,463
1,129
201
23,781

The following tables present gross unrealized losses and the related estimated fair value of securities held to maturity and 
securities available for sale at December 31, 2016 and 2015. For securities transferred to held to maturity from available for 
sale, the analysis in the tables below is comparing the securities' original amortized cost to its current estimated fair value. These 
securities are segregated between investments that have been in a continuous unrealized loss position for less than twelve months 
and for twelve months or more.

Securities held to maturity:

Mortgage-backed securities:

Residential agency
Commercial agency

Securities available for sale:
U.S. Treasury securities
Mortgage-backed securities:

Residential agency
Commercial agency
Commercial non-agency

All other securities

December 31, 2016

Less Than Twelve Months

Twelve Months or More

Total

Estimated
Fair
Value

Gross
Unrealized
Losses

Estimated
Fair
Value

Gross
Unrealized
Losses

Estimated
Fair
Value

Gross
Unrealized
Losses

(In millions)

$

$

$

$

850
—
850

$

$

(26) $
—
(26) $

359
160
519

$

$

(14) $
(7)
(21) $

1,209
160
1,369

$

$

(40)
(7)
(47)

112

$

(1) $

18

$

— $

130

$

(1)

12,071
2,199
402
382
15,166

$

(245)
(31)
(2)
(6)
(285) $

570
45
176
218
1,027

$

(10)
(1)
(1)
(11)
(23) $

12,641
2,244
578
600
16,193

$

(255)
(32)
(3)
(17)
(308)  

118

 
 
 
 
 
Table of Contents 

Securities held to maturity:
Federal agency securities
Mortgage-backed securities:

Residential agency
Commercial agency

Securities available for sale:
U.S. Treasury securities
Federal agency securities
Mortgage-backed securities:

Residential agency
Residential non-agency
Commercial agency
Commercial non-agency

All other securities

December 31, 2015

Less Than Twelve Months

Twelve Months or More

Total

Estimated
Fair
Value

Gross
Unrealized
Losses

Estimated
Fair
Value

Gross
Unrealized
Losses

Estimated
Fair
Value

Gross
Unrealized
Losses

(In millions)

$

$

$

$

198

$

(1) $

— $

— $

198

$

(1)

322
—
520

59
74

8,037
3
1,695
684
805
11,357

$

$

$

(7)
—
(8) $

1,121
174
1,295

(1) $
—

8
7

(73)
—
(20)
(12)
(36)
(142) $

791
—
273
264
307
1,650

$

$

$

(38)
(7)
(45) $

1,443
174
1,815

— $
—

(17)
—
(5)
(6)
(29)
(57) $

67
81

8,828
3
1,968
948
1,112
13,007

$

$

$

(45)
(7)
(53)

(1)
—

(90)
—
(25)
(18)
(65)
(199)

The number of individual securities in an unrealized loss position in the tables above increased from 1,081 at December 31, 
2015 to 1,613 at December 31, 2016. The increase in the number of securities and the total amount of unrealized losses was 
primarily due to changes in market interest rates. In instances where an unrealized loss existed, there was no indication of an 
adverse change in credit on the underlying positions in the tables above.  As it relates to these positions, management believes 
no individual unrealized loss, other than those discussed below, represented an other-than-temporary impairment as of those 
dates. The Company does not intend to sell, and it is not more likely than not that the Company will be required to sell, the 
positions before the recovery of their amortized cost basis, which may be at maturity.

As part of the Company's normal process for evaluating other-than-temporary impairments, management did identify a 
limited number of positions where an other-than-temporary impairment was believed to exist during 2016. Such impairments 
were related to available-for-sale securities with current market values below the highest traded price in the last six months, and  
debt securities for which the decision to sell was made. Total impairments in 2016 were $2 million, and have been reflected as 
a reduction of net securities gains on the consolidated statements of income.

Gross realized gains and gross realized losses on sales of securities available for sale, as well as other-than-temporary 
impairment losses, for years ended December 31 are shown in the table below. The cost of securities sold is based on the specific 
identification method.

Gross realized gains
Gross realized losses
OTTI

Securities gains, net

2016

2015

(In millions)

2014

$

$

36
(28)
(2)
6

$

$

44
(8)
(7)
29

$

$

38
(8)
(3)
27

119

 
 
 
 
 
 
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NOTE 5. LOANS

The following table presents the distribution of Regions' loan portfolio by segment and class, net of unearned income as of 

December 31:

Commercial and industrial

Commercial real estate mortgage—owner-occupied

Commercial real estate construction—owner-occupied

Total commercial

Commercial investor real estate mortgage

Commercial investor real estate construction

Total investor real estate

Residential first mortgage

Home equity

Indirect—vehicles

Indirect—other consumer

Consumer credit card

Other consumer

Total consumer

2016

2015

(In millions)

$

35,012

$

6,867

334

42,213

4,087

2,387

6,474

13,440

10,687

4,040

920

1,196

1,125

31,408

35,821

7,538

423

43,782

4,255

2,692

6,947

12,811

10,978

3,984

545

1,075

1,040

30,433

Total loans, net of unearned income (1)
_________
(1)  Loans are presented net of unearned income, unamortized discounts and premiums and net deferred loan costs of $141 million and $317 

80,095

81,162

$

$

million at December 31, 2016 and 2015, respectively. 

During 2016 and 2015, Regions purchased approximately $985 million and $1.1 billion, respectively, in indirect-vehicles 

and indirect-other consumer loans from a third party. 

The following tables include details regarding Regions’ investment in leveraged leases included within the commercial and 

industrial loan portfolio class as of and for the years ended December 31:

Rentals receivable
Estimated residuals on leveraged leases
Unearned income on leveraged leases

2016

2015

$

$

(In millions)
303
203
184

2016

2015

(In millions)

2014

Pre-tax income from leveraged leases
Income tax expense on income from leveraged leases

$

$

28
31

$

34
33

326
240
248

38
33

The income above does not include leveraged lease termination gains of $8 million, $8 million and $10 million with related 
income tax expense of  $11 million,  less than $1 million and $10 million for the years ended December 31, 2016, 2015 and 2014, 
respectively.

At December 31, 2016, $19.8 billion in securities and net eligible loans held by Regions were pledged to secure current and 
potential borrowings from the FHLB. At December 31, 2016, an additional $22.3 billion in net eligible loans held by Regions 
were pledged to the Federal Reserve Bank for potential borrowings.

120

 
 
 
Table of Contents 

NOTE 6. ALLOWANCE FOR CREDIT LOSSES 

Regions determines the appropriate level of the allowance on a quarterly basis.  The methodology is described in Note 1 

"Summary of Significant Accounting Policies." 

ROLLFORWARD OF ALLOWANCE FOR CREDIT LOSSES

The following tables present analyses of the allowance by portfolio segment for the years ended December 31, 2016, 2015
and 2014. The total allowance for loan losses and the related loan portfolio ending balances are then disaggregated to detail the 
amounts derived through individual evaluation and collective evaluation for impairment. The allowance for loan losses related to 
individually evaluated loans is attributable to reserves for non-accrual commercial and investor real estate loans and all TDRs. 
The allowance for loan losses and the loan portfolio ending balances related to collectively evaluated loans is attributable to the 
remainder of the portfolio.

Commercial

Investor Real
Estate

Consumer

Total

2016

Allowance for loan losses, January 1, 2016

Provision (credit) for loan losses

Loan losses:

Charge-offs

Recoveries

Net loan losses

Allowance for loan losses, December 31, 2016

Reserve for unfunded credit commitments, January 1, 2016

Provision (credit) for unfunded credit losses

Reserve for unfunded credit commitments, December 31, 2016

Allowance for credit losses, December 31, 2016

Portion of ending allowance for loan losses:

Individually evaluated for impairment

Collectively evaluated for impairment

Total allowance for loan losses

Portion of loan portfolio ending balance:

Individually evaluated for impairment

Collectively evaluated for impairment

Total loans evaluated for impairment

$

$

$

$

$

$

758

$

95

(143)

43

(100)

753

47

17

64

817

231

522

753

1,069

41,144

42,213

$

$

$

$

$

(In millions)

97

$

(23)

$

251

190

(2)

13

11

85

5

—

5

90

13

72

85

107

6,367

6,474

$

$

$

$

$

(253)

65

(188)

253

—

—

—

253

60

193

253

770

30,638

31,408

$

$

$

$

$

1,106

262

(398)

121

(277)

1,091

52

17

69

1,160

304

787

1,091

1,946

78,149

80,095

121

 
 
 
Table of Contents 

Allowance for loan losses, January 1, 2015

Provision (credit) for loan losses

Loan losses:

Charge-offs

Recoveries

Net loan losses

Allowance for loan losses, December 31, 2015

Reserve for unfunded credit commitments, January 1, 2015

Provision (credit) for unfunded credit losses

Reserve for unfunded credit commitments, December 31, 2015

Allowance for credit losses, December 31, 2015

Portion of ending allowance for loan losses:

Individually evaluated for impairment

Collectively evaluated for impairment

Total allowance for loan losses

Portion of loan portfolio ending balance:

Individually evaluated for impairment

Collectively evaluated for impairment

Total loans evaluated for impairment

Allowance for loan losses, January 1, 2014

Provision (credit) for loan losses

Loan losses:

Charge-offs

Recoveries

Net loan losses

Allowance for loan losses, December 31, 2014

Reserve for unfunded credit commitments, January 1, 2014

Provision (credit) for unfunded credit losses

Reserve for unfunded credit commitments, December 31, 2014

Allowance for credit losses, December 31, 2014

Portion of ending allowance for loan losses:

Individually evaluated for impairment

Collectively evaluated for impairment

Total allowance for loan losses

Portion of loan portfolio ending balance:

Individually evaluated for impairment

Collectively evaluated for impairment

Total loans evaluated for impairment

$

$

$

$

$

$

$

$

$

$

$

$

Commercial

Investor Real
Estate

Consumer

Total

2015

$

654

191

(154)

67

(87)

758

57

(10)

47

805

189

569

758

743

43,039

43,782

$

$

$

$

$

(In millions)

150

$

(65)

$

299

115

(234)

71

(163)

251

—

—

—

251

68

183

251

835

29,598

30,433

$

$

$

$

$

(15)

27

12

97

8

(3)

5

102

26

71

97

191

6,756

6,947

$

$

$

$

$

2014

Commercial

Investor Real
Estate

Consumer

Total

711

$

55

(179)

67

(112)

654

63

(6)

57

711

186

468

654

742

40,660

41,402

$

$

$

$

$

(In millions)

236

$

(89)

$

394

103

(24)

27

3

150

12

(4)

8

158

65

85

150

417

6,396

6,813

$

$

$

$

$

(270)

72

(198)

299

3

(3)

—

299

78

221

299

856

28,236

29,092

$

$

$

$

$

1,103

241

(403)

165

(238)

1,106

65

(13)

52

1,158

283

823

1,106

1,769

79,393

81,162

1,341

69

(473)

166

(307)

1,103

78

(13)

65

1,168

329

774

1,103

2,015

75,292

77,307

PORTFOLIO SEGMENT RISK FACTORS

The following describe the risk characteristics relevant to each of the portfolio segments.

Commercial—The commercial loan portfolio segment includes commercial and industrial loans to commercial customers 
for  use  in  normal  business  operations  to  finance  working  capital  needs,  equipment  purchases  or  other  expansion  projects. 
Commercial also includes owner-occupied commercial real estate mortgage loans to operating businesses, which are loans for 

122

 
 
 
 
 
 
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long-term  financing  of  land  and  buildings,  and  are  repaid  by  cash  flow  generated  by  business  operations.  Owner-occupied 
construction loans are made to commercial businesses for the development of land or construction of a building where the repayment 
is  derived  from  revenues  generated  from  the  business  of  the  borrower.  Collection  risk  in  this  portfolio  is  driven  by  the 
creditworthiness of underlying borrowers, particularly cash flow from customers’ business operations, and the sensitivity to market 
fluctuations in commodity prices.

Investor Real Estate—Loans for real estate development are repaid through cash flow related to the operation, sale or refinance 
of the property. This portfolio segment includes extensions of credit to real estate developers or investors where repayment is 
dependent on the sale of real estate or income generated from the real estate collateral. A portion of Regions’ investor real estate 
portfolio  segment  consists  of  loans  secured  by  residential  product  types  (land,  single-family  and  condominium  loans)  within 
Regions’ markets. Additionally, these loans are made to finance income-producing properties such as apartment buildings, office 
and industrial buildings, and retail shopping centers. Loans in this portfolio segment are particularly sensitive to the valuation of 
real estate.

Consumer—The consumer loan portfolio segment includes residential first mortgage, home equity, indirect-vehicles, indirect-
other consumer, consumer credit card, and other consumer loans. Residential first mortgage loans represent loans to consumers 
to finance a residence. These loans are typically financed over a  15 to 30 year term and, in most cases, are extended to borrowers 
to finance their primary residence. Home equity lending includes both home equity loans and lines of credit. This type of lending, 
which is secured by a first or second mortgage on the borrower’s residence, allows customers to borrow against the equity in their 
home. Real estate market values as of the time the loan or line is secured directly affect the amount of credit extended and, in 
addition, changes in these values impact the depth of potential losses. Indirect-vehicles lending, which is lending initiated through 
third-party business partners, largely consists of loans made through automotive dealerships. Indirect-other consumer lending 
represents other point of sale lending through third parties. Consumer credit card includes Regions branded consumer credit card 
accounts. Other consumer loans include other revolving consumer accounts, direct consumer loans, and overdrafts. Loans in this 
portfolio segment are sensitive to unemployment and other key consumer economic measures. 

CREDIT QUALITY INDICATORS

 Commercial and investor real estate loan portfolio segments are detailed by categories related to underlying credit quality 
and probability of default. Regions assigns these categories at loan origination and reviews the relationship utilizing a risk-based 
approach on, at minimum, an annual basis or at any time management becomes aware of information affecting the borrowers' 
ability to fulfill their obligations. Both quantitative and qualitative factors are considered in this review process. These categories 
are utilized to develop the associated allowance.

• 

• 

• 

Pass—includes obligations where the probability of default is considered low;

Special Mention—includes obligations that have potential weakness that may, if not reversed or corrected, weaken 
the credit or inadequately protect the Company’s position at some future date. Obligations in this category may also 
be subject to economic or market conditions that may, in the future, have an adverse effect on debt service ability;

Substandard Accrual—includes  obligations  that  exhibit  a  well-defined  weakness  that  presently  jeopardizes  debt 
repayment, even though they are currently performing. These obligations are characterized by the distinct possibility 
that the Company may incur a loss in the future if these weaknesses are not corrected;

•  Non-accrual—includes obligations where management has determined that full payment of principal and interest is 

in doubt.

Substandard accrual and non-accrual loans are often collectively referred to as “classified.” Special mention, substandard 
accrual, and non-accrual loans are often collectively referred to as “criticized and classified.” Classes in the consumer portfolio 
segment are disaggregated by accrual status.

123

Table of Contents 

The following tables present credit quality indicators for the loan portfolio segments and classes, excluding loans held for 

sale, as of December 31, 2016 and 2015. 

Pass

Special Mention

2016

Substandard
Accrual

(In millions)

Non-accrual

Total

Commercial and industrial

Commercial real estate mortgage—owner-occupied

Commercial real estate construction—owner-occupied

Total commercial

Commercial investor real estate mortgage

Commercial investor real estate construction

Total investor real estate

$

$

$

$

32,619

$

6,190

308

39,117

3,766

2,192

5,958

$

$

$

Residential first mortgage

Home equity

Indirect—vehicles

Indirect—other consumer

Consumer credit card

Other consumer

Total consumer

658

221

8

887

190

129

319

$

$

$

$

$

1,112

$

246

15

1,373

114

66

180

$

$

$

623

210

3

836

17

—

17

Accrual

Non-accrual

(In millions)

13,390

$

10,595

4,040

920

1,196

1,125

50

92

—

—

—

—

$

31,266

$

142

$

$

$

$

$

$

$

35,012

6,867

334

42,213

4,087

2,387

6,474

Total

13,440

10,687

4,040

920

1,196

1,125

31,408

80,095

Pass

Special
Mention

2015

Substandard
Accrual

(In millions)

Non-accrual

Total

Commercial and industrial

Commercial real estate mortgage—owner-occupied

Commercial real estate construction—owner-occupied

Total commercial

Commercial investor real estate mortgage

Commercial investor real estate construction

Total investor real estate

$

$

$

$

33,639

$

6,750

385

40,774

3,926

2,658

6,584

$

$

$

Residential first mortgage

Home equity

Indirect—vehicles

Indirect—other consumer

Consumer credit card

Other consumer

Total consumer

963

306

21

1,290

140

4

144

$

$

$

$

$

894

214

15

1,123

158

30

188

$

$

$

$

325

268

2

595

31

—

31

Accrual

Non-accrual

(In millions)

12,748

$

10,885

3,984

545

1,075

1,040

63

93

—

—

—

—

$

30,277

$

156

$

$

$

$

$

$

$

35,821

7,538

423

43,782

4,255

2,692

6,947

Total

12,811

10,978

3,984

545

1,075

1,040

30,433

81,162

124

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents 

AGING ANALYSIS

The following tables include an aging analysis of DPD for each portfolio segment and class as of  December 31, 2016 and 

2015:

Accrual Loans

2016

Commercial and industrial

$

59

$

11

$

30-59 DPD

60-89 DPD

90+ DPD

Total
30+ DPD

(In millions)

Total
Accrual

Non-accrual

Total

$

76

$

34,389

$

623

$

35,012

Commercial real estate
mortgage—owner-occupied

Commercial real estate construction—
owner-occupied

Total commercial

Commercial investor real estate
mortgage

Commercial investor real estate
construction

Total investor real estate

Residential first mortgage

Home equity

Indirect—vehicles

Indirect—other consumer

Consumer credit card

Other consumer

Total consumer

29

1

89

6

—

6

99

60

56

5

9

13

242

337

$

$

7

—

18

8

—

8

63

22

14

3

7

5

6

2

—

8

—

—

—

212

33

10

—

15

5

38

1

115

14

—

14

374

115

80

8

31

23

631

760

6,657

331

41,377

4,070

2,387

6,457

13,390

10,595

4,040

920

1,196

1,125

31,266

$

79,100

$

210

3

836

17

—

17

50

92

—

—

—

—

142

995

$

6,867

334

42,213

4,087

2,387

6,474

13,440

10,687

4,040

920

1,196

1,125

31,408

80,095

114

140

$

275

283

$

Accrual Loans

2015

30-59 DPD

60-89 DPD

90+ DPD

Total
30+ DPD

(In millions)

Total
Accrual

Non-accrual

Total

$

26

$

35,496

$

325

$

35,821

Commercial and industrial

$

11

$

Commercial real estate
mortgage—owner-occupied

Commercial real estate construction—
owner-occupied

Total commercial

Commercial investor real estate
mortgage

Commercial investor real estate
construction

Total investor real estate

Residential first mortgage

Home equity

Indirect—vehicles

Indirect—other consumer

Consumer credit card

Other consumer

Total consumer

24

—

35

14

2

16

88

58

49

2

7

11

215

266

$

$

$

6

7

1

14

13

—

13

60

26

14

1

5

4

9

3

—

12

4

—

4

220

59

9

—

12

4

110

137

$

304

320

$

125

34

1

61

31

2

33

368

143

72

3

24

19

629

723

7,270

421

43,187

4,224

2,692

6,916

12,748

10,885

3,984

545

1,075

1,040

30,277

$

80,380

$

268

2

595

31

—

31

63

93

—

—

—

—

156

782

$

7,538

423

43,782

4,255

2,692

6,947

12,811

10,978

3,984

545

1,075

1,040

30,433

81,162

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents 

IMPAIRED LOANS

The following tables present details related to the Company’s impaired loans as of December 31, 2016 and 2015. Loans 
deemed to be impaired include all TDRs and all non-accrual commercial and investor real estate loans, excluding leases. Loans 
which have been fully charged-off do not appear in the tables below.

Unpaid
 Principal
    Balance(1)

Charge-offs
and Payments
Applied(2)

Non-accrual Impaired Loans 2016
Book Value(3)

Total
Impaired
Loans on
Non-accrual
Status

Impaired
Loans on
Non-accrual
Status with
No Related
Allowance

Impaired
Loans on
Non-accrual
Status with
Related
Allowance

Related
Allowance
for Loan
Losses

(Dollars in millions)

Coverage %(4)

Commercial and industrial

$

685

$

72

$

613

$

126

$

487

$

Commercial real estate
mortgage—owner-occupied

Commercial real estate
construction—owner-
occupied

Total commercial

Commercial investor real
estate mortgage

Total investor real
estate

Residential first mortgage

Home equity

Total consumer

231

4

920

18

18

41

12

53

21

1

94

1

1

12

1

13

210

3

826

17

17

29

11

40

39

—

165

5

5

—

—

—

171

3

661

12

12

29

11

40

$

991

$

108

$

883

$

170

$

713

$

138

53

2

193

5

5

4

—

4

202

30.7%

32.0

75.0

31.2

33.3

33.3

39.0

8.3

32.1

31.3%

Accruing Impaired Loans 2016

Unpaid
Principal
Balance(1)

Charge-offs
and Payments
Applied(2)

Commercial and industrial

$

187

$

Commercial real estate mortgage—owner-occupied

Commercial real estate construction—owner-occupied

Total commercial

Commercial investor real estate mortgage

Commercial investor real estate construction

Total investor real estate

Residential first mortgage

Home equity

Indirect—vehicles

Consumer credit card

Other consumer

Total consumer

60

1

248

82

16

98

435

292

1

2

10

740

$

1,086

$

1

4

—

5

8

—

8

10

—

—

—

—

10

23

Book Value(3)

(Dollars in millions)

$

186

$

56

1

243

74

16

90

425

292

1

2

10

730

Related
Allowance for
Loan Losses

Coverage %(4)

33

5

—

38

7

1

8

51

5

—

—

—

56

18.2%

15.0

—

17.3

18.3

6.3

16.3

14.0

1.7

—

—

—

8.9

$

1,063

$

102

11.5%

126

 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents 

Total Impaired Loans 2016
Book Value(3)

Unpaid
Principal
Balance(1)

Charge-offs
and Payments
Applied(2)

Total
Impaired
Loans

Impaired
Loans with No
Related
Allowance

Impaired
Loans with
Related
Allowance

Related
Allowance
for Loan
Losses

Coverage %(4)

(Dollars in millions)

Commercial and industrial

$

872

$

73

$

799

$

126

$

673

$

Commercial real estate mortgage
—owner-occupied

Commercial real estate
construction—owner-occupied

Total commercial

Commercial investor real estate
mortgage

Commercial investor real estate
construction

Total investor real estate

Residential first mortgage

Home equity

Indirect—vehicles

Consumer credit card

Other consumer

Total consumer

291

5

1,168

100

16

116

476

304

1

2

10

793

25

1

99

9

—

9

22

1

—

—

—

23

266

4

1,069

91

16

107

454

303

1

2

10

770

39

—

165

5

—

5

—

—

—

—

—

—

227

4

904

86

16

102

454

303

1

2

10

770

171

58

2

231

12

1

13

55

5

—

—

—

60

$

2,077

$

131

$

1,946

$

170

$

1,776

$

304

28.0%

28.5

60.0

28.3

21.0

6.3

19.0

16.2

2.0

—

—

—

10.5

20.9%

Unpaid
Principal
Balance(1)

Charge-offs
and Payments
Applied(2)

Non-accrual Impaired Loans 2015
Book Value(3)

Total
Impaired
Loans on
Non-accrual
Status

Impaired
Loans on
Non-accrual
Status with
No Related
Allowance

Impaired
Loans on
Non-accrual
Status with
Related
Allowance

Related
Allowance
for Loan
Losses

(Dollars in millions)

Coverage %(4)

Commercial and industrial

$

363

$

41

$

322

$

26

$

296

$

Commercial real estate
mortgage—owner-occupied

Commercial real estate
construction—owner-
occupied

Total commercial

Commercial investor real
estate mortgage

Total investor real
estate

Residential first mortgage

Home equity

Total consumer

286

2

651

36

36

51

14

65

$

752

$

18

—

59

5

5

16

1

17

81

268

2

592

31

31

35

13

48

$

671

$

36

—

62

13

13

—

—

—

75

232

2

530

18

18

35

13

48

$

596

$

98

69

1

168

8

8

4

—

4

180

38.3%

30.4

50.0

34.9

36.1

36.1

39.2

7.1

32.3

34.7%

127

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents 

Accruing Impaired Loans 2015

Unpaid
Principal
Balance(1)

Charge-offs
and Payments
Applied(2)

Book Value(3)

(Dollars in millions)

Related
Allowance for
Loan Losses

Coverage %(4)

Commercial and industrial

$

Commercial real estate mortgage—owner-occupied

Commercial real estate construction—owner-occupied

Total commercial

Commercial investor real estate mortgage

Commercial investor real estate construction

Total investor real estate

Residential first mortgage

Home equity

Indirect—vehicles

Consumer credit card

Other consumer

Total consumer

$

68

89

1

158

141

27

168

457

328

1

2

12

800

$

1,126

$

1

6

—

7

8

—

8

13

—

—

—

—

13

28

$

$

67

83

1

151

133

27

160

444

328

1

2

12

787

13

8

—

21

13

5

18

57

7

—

—

—

64

20.6%

15.7

—

17.7

14.9

18.5

15.5

15.3

2.1

—

—

—

9.6

$

1,098

$

103

11.6%

Total Impaired Loans 2015
Book Value(3)

Unpaid
Principal
Balance(1)

Charge-offs
and Payments
Applied(2)

Total
Impaired
Loans

Impaired
Loans with No
Related
Allowance

Impaired
Loans with
Related
Allowance

Related
Allowance for
Loan Losses

Coverage %(4)

(Dollars in millions)

Commercial and industrial

$

431

$

42

$

389

$

26

$

363

$

Commercial real estate
mortgage—owner-occupied

Commercial real estate
construction—owner-occupied

Total commercial

Commercial investor real estate
mortgage

Commercial investor real estate
construction

Total investor real estate

Residential first mortgage

Home equity

Indirect—vehicles

Consumer credit card

Other consumer

Total consumer

375

3

809

177

27

204

508

342

1

2

12

865

24

—

66

13

—

13

29

1

—

—

—

30

351

3

743

164

27

191

479

341

1

2

12

835

$

1,878

$

109

$

1,769

$

36

—

62

13

—

13

—

—

—

—

—

—

75

315

3

681

151

27

178

479

341

1

2

12

835

111

77

1

189

21

5

26

61

7

—

—

—

68

35.5%

26.9

33.3

31.5

19.2

18.5

19.1

17.7

2.3

—

—

—

11.3

20.9%

$

1,694

$

283

_________
(1)  Unpaid principal balance represents the contractual obligation due from the customer and includes the net book value plus charge-offs and 

payments applied.

(2)  Charge-offs and payments applied represents cumulative partial charge-offs taken, as well as interest payments received that have been 

applied against the outstanding principal balance.

(3)  Book value represents the unpaid principal balance less charge-offs and payments applied; it is shown before any allowance for loan losses.
(4)  Coverage % represents charge-offs and payments applied plus the related allowance as a percent of the unpaid principal balance.

128

 
 
 
 
 
 
 
 
 
 
 
Table of Contents 

The following table presents the average balances of total impaired loans and interest income for the years ended December 31, 

2016, 2015 and 2014. Interest income recognized represents interest on accruing loans modified in a TDR. 

Commercial and industrial

Commercial real estate mortgage—owner-occupied

Commercial real estate construction—owner-occupied

Total commercial

Commercial investor real estate mortgage

Commercial investor real estate construction

Total investor real estate

Residential first mortgage

Home equity

Indirect—vehicles

Consumer credit card

Other consumer

Total consumer

Total impaired loans

2016

2015

2014

Average
Balance

Interest
Income
Recognized

Average
Balance

Interest
Income
Recognized

Average
Balance

Interest
Income
Recognized

$

$

714

304

3

1,021

120

30

150

469

322

1

2

11

805

$

1,976

$

$

(In millions)

$

386

345

3

734

242

24

266

477

354

1

2

14

848

$

1,848

$

6

5

—

11

8

1

9

15

16

—

—

1

32

52

4

9

—

13

11

1

12

15

18

—

—

1

34

59

$

$

365

473

32

870

498

61

559

457

380

1

2

20

860

$

2,289

$

9

12

1

22

21

3

24

14

20

—

—

1

35

81

TROUBLED DEBT RESTRUCTURINGS 

Regions  regularly  modifies  commercial  and  investor  real  estate  loans  in  order  to  facilitate  a  workout  strategy.  Typical 
modifications include accommodations, such as renewals and forbearances. The majority of Regions’ commercial and investor 
real estate TDRs are the result of renewals of classified loans at an interest rate that is not considered to be a market interest rate. 
For smaller dollar commercial loans, Regions may periodically grant interest rate and other term concessions, similar to those 
under the consumer program described below.

Regions works to meet the individual needs of consumer borrowers to stem foreclosure through CAP. Regions designed the 
program to allow for customer-tailored modifications with the goal of keeping customers in their homes and avoiding foreclosure 
where possible. Modification may be offered to any borrower experiencing financial hardship regardless of the borrower’s payment 
status. Consumer TDRs primarily involve an interest rate concession, however under the CAP, Regions may also offer a short-
term deferral, a term extension, a new loan product, or a combination of these options. For loans restructured under the CAP, 
Regions expects to collect the original contractually due principal. The gross original contractual interest may be collectible, 
depending on the terms modified. All CAP modifications are considered TDRs regardless of the term because they are concessionary 
in nature and because the customer documents a hardship in order to participate.

As noted above, the majority of Regions’ TDRs are results of interest rate concessions and not a forgiveness of principal. 
Accordingly, the financial impact of the modifications is best illustrated by the impact to the allowance calculation at the loan or 
pool level, as a result of the loans being considered impaired due to their TDR status. Regions most often does not record a charge-
off at the modification date.

None  of  the  modified  consumer  loans  listed  in  the  following TDR  disclosures  were  collateral-dependent  at  the  time  of 
modification. At December 31, 2016, approximately $37 million in residential first mortgage TDRs were in excess of 180 days 
past due and were considered collateral-dependent. At December 31, 2016, approximately $4 million in home equity first lien 
TDRs were in excess of 180 days past due and $4 million in home equity second lien TDRs were in excess of 120 days past due, 
both categories of which were considered collateral-dependent.

The following tables present the end of period balance for loans modified in a TDR during the periods presented by portfolio 
segment and class, and the financial impact of those modifications. The tables include modifications made to new TDRs, as well 
as renewals of existing TDRs. Loans first reported as TDRs for the years ended December 31, 2016 and 2015 totaled approximately 
$542 million and $323 million, respectively.

129

Table of Contents 

Commercial and industrial

Commercial real estate mortgage—owner-occupied

Commercial real estate construction—owner-occupied

Total commercial

Commercial investor real estate mortgage

Commercial investor real estate construction

Total investor real estate

Residential first mortgage

Home equity

Consumer credit card

Indirect—vehicles and other consumer

Total consumer

Commercial and industrial

Commercial real estate mortgage—owner-occupied

Total commercial

Commercial investor real estate mortgage

Commercial investor real estate construction

Total investor real estate

Residential first mortgage

Home equity

Consumer credit card

Indirect—vehicles and other consumer

Total consumer

Defaulted TDRs

2016

Number of
Obligors

Recorded
Investment

Financial Impact
of Modifications
Considered TDRs

Increase in
Allowance at
Modification

(Dollars in millions)

$

509

$

98

1

608

96

43

139

46

15

1

2

64

184

117

1

302

80

9

89

231

300

88

190

809

1,200

$

811

$

2015

12

2

—

14

2

1

3

6

—

—

—

6

23

Number of
Obligors

Recorded
Investment

(Dollars in millions)

Financial Impact
of Modifications
Considered TDRs

Increase in
Allowance at
Modification

$

185

175

360

122

18

140

400

582

147

345

1,474

1,974

$

207

127

334

131

34

165

101

30

1

4

136

635

$

$

4

4

8

3

1

4

13

—

—

—

13

25

The following table presents, by portfolio segment and class, TDRs that defaulted during the years ended December 31, 2016
and 2015, and that were modified in the previous twelve months (i.e., the twelve months prior to the default). For purposes of this 
disclosure, default is defined as placement on non-accrual status for the commercial and investor real estate portfolio segments, 
and 90 days past due and still accruing for the consumer portfolio segment. Consideration of defaults in the calculation of the 
allowance for loan losses is described in detail in Note 1 to the consolidated financial statements. 

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Defaulted During the Period, Where Modified in a TDR Twelve Months Prior to Default

Commercial and industrial

Commercial real estate mortgage—owner-occupied

Total commercial

Commercial investor real estate mortgage

Commercial investor real estate construction

Total investor real estate

Residential first mortgage

Home equity

Total consumer

2016

2015

(In millions)

$

$

28

3

31

3

1

4

21

2

23

58

$

$

10

6

16

1

—

1

21

2

23

40

Commercial and investor real estate loans that were on non-accrual status at the time of the latest modification are not included 
in the default table above, as they are already considered to be in default at the time of the restructuring. At December 31, 2016, 
approximately $134 million of commercial and investor real estate loans modified in a TDR during the year ended December 31, 
2016 were on non-accrual status. None of this amount was 90 days or more past due.

At December 31, 2016, Regions had restructured binding unfunded commitments totaling $48 million where a concession 

was granted and the borrower was in financial difficulty.

NOTE 7. SERVICING OF FINANCIAL ASSETS

RESIDENTIAL MORTGAGE BANKING ACTIVITIES

The fair value of residential MSRs is calculated using various assumptions including future cash flows, market discount 
rates,  expected  prepayment  rates,  servicing  costs  and  other  factors. A  significant  change  in  prepayments  of  mortgages  in  the 
servicing portfolio could result in significant changes in the valuation adjustments, thus creating potential volatility in the carrying 
amount  of  residential  MSRs. The  Company  compares  fair  value  estimates  and  assumptions  to  observable  market  data  where 
available, and also considers recent market activity and actual portfolio experience.

The table below presents an analysis of residential MSRs under the fair value measurement method for the years ended 

December 31: 

Carrying value, beginning of year

Additions

Increase (decrease) in fair value(1):

Due to change in valuation inputs or assumptions
Economic amortization associated with borrower repayments

Carrying value, end of year

2016

2015

(In millions)

2014

$

$

252
108

4
(40)
324

$

$

257
36

(2)
(39)
252

$

$

297
40

(47)
(33)
257

_________
(1)  "Economic amortization associated with borrower repayments" includes both total loan payoffs as well as partial paydowns. 

On February 29, 2016, the Company purchased the rights to service approximately $2.6 billion in residential mortgage loans 

for approximately $24 million.

On September 1, 2016, the Company purchased the rights to service approximately $2.8 billion in residential mortgage loans 

for approximately $22 million.

On November 30, 2016, the Company purchased the rights to service approximately $2.2 billion in residential mortgage 
loans for approximately $23 million. However, the Company paid $18 million as of December 31, 2016, and the balance of $5 
million will be paid in 2017.

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Data and assumptions used in the fair value calculation, as well as the valuation’s sensitivity to rate fluctuations, related to 

residential MSRs (excluding related derivative instruments) as of December 31 are as follows: 

Unpaid principal balance
Weighted-average CPR (%)

Estimated impact on fair value of a 10% increase
Estimated impact on fair value of a 20% increase

Option-adjusted spread (basis points)

Estimated impact on fair value of a 10% increase
Estimated impact on fair value of a 20% increase

Weighted-average coupon interest rate
Weighted-average remaining maturity (months)
Weighted-average servicing fee (basis points)

$

$
$

$
$

2016

2015

(Dollars in millions)
31,335

$

25,840

$
$

$
$

7.6%
(19)
(34)
1,054
(13)
(27)
4.2%
281
27.5

10.9%
(13)
(25)
997
(10)
(19)
4.4%
279
27.9

The sensitivity calculations above are hypothetical and should not be considered to be predictive of future performance. 
Changes in fair value based on adverse changes in assumptions generally cannot be extrapolated because the relationship of the 
change in assumption to the change in fair value may not be linear.  Also, the effect of an adverse variation in a particular assumption 
on the fair value of the residential MSRs is calculated without changing any other assumption, while in reality changes in one 
factor may result in changes in another, which may either magnify or counteract the effect of the change. The derivative instruments 
utilized by Regions would serve to reduce the estimated impacts to fair value included in the table above.

The following table presents servicing related fees, which includes contractually specified servicing fees, late fees and other 

ancillary income resulting from the servicing of residential mortgage loans for the years ended December 31:

2016

2015

(In millions)

2014

Servicing related fees and other ancillary income

$

86

$

82

$

86

Residential mortgage loans are sold in the secondary market with standard representations and warranties regarding certain 
characteristics such as the quality of the loan, the absence of fraud, the eligibility of the loan for sale and the future servicing 
associated with the loan. Regions may be required to repurchase these loans at par, or make-whole or indemnify the purchasers 
for losses incurred when representations and warranties are breached.

Regions maintains an immaterial repurchase liability related to residential mortgage loans sold with representations and 
warranty  provisions.  This  repurchase  liability  is  reported  in  other  liabilities  on  the  consolidated  balance  sheets  and  reflects 
management’s estimate of losses based on historical repurchase and loss trends, as well as other factors that may result in anticipated 
losses different from historical loss trends. Adjustments to this reserve are recorded in other non-interest expense on the consolidated 
statements of income. 

COMMERCIAL MORTGAGE BANKING ACTIVITIES

On July 18, 2014, Regions was approved as a Fannie Mae DUS lender and acquired a DUS servicing portfolio totaling 
approximately $1.0 billion. The Fannie Mae DUS program provides liquidity to the multi-family housing market. As part of the 
transaction, Regions recorded $12 million in commercial MSRs and $15 million in intangible assets associated with the DUS 
license purchased. Regions also assumed a loss share guarantee associated with the purchased portfolio and any future originations. 
Regions estimated the fair value of the loss share guarantee to be approximately $4 million. See Note 1 for additional information. 
Also see Note 24 for additional information related to the guarantee.

As of December 31, 2016 and 2015, the DUS servicing portfolio was approximately $1.8 billion and $1.2 billion, respectively. 
The related commercial MSRs were approximately $30 million and $16 million at December 31, 2016 and 2015, respectively. 
The estimated fair value of the loss share guarantee was approximately $4 million and $3 million at December 31, 2016 and 2015, 
respectively.

NOTE 8. OTHER EARNING ASSETS

Other earning assets consist primarily of investments in FRB stock, FHLB stock, and operating lease assets. 

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The following table presents the amount of Regions' investments in FRB and FHLB stock as of December 31:

Federal Reserve Bank
Federal Home Loan Bank

$

2016

2015

(In millions)
494
196

$

484
239

The Company's investments in operating leases represent assets such as equipment, vehicles and aircraft. The following table 

presents investments in operating leases at December 31:

2016

2015

Lease assets
Accumulated depreciation
Investments in operating leases, net

$

$

$

(In millions)
818
(130)
688

$

862
(28)
834

The following table presents the minimum future rental payments due from customers for operating leases as of December 

31:

2017

2018

2019

2020

2021

Thereafter

Future rental payments

(In millions)

$

$

105

88

69

54

37

47

400

488
1,762
990
506
404
222
4,372
(2,220)
2,152

NOTE 9. PREMISES AND EQUIPMENT

A summary of premises and equipment at December 31 is as follows: 

2016

2015

Land
Premises and improvements
Furniture and equipment
Software
Leasehold improvements
Construction in progress

Accumulated depreciation and amortization

NOTE 10. INTANGIBLE ASSETS

GOODWILL 

$

$

$

(In millions)
490
1,730
1,025
597
387
214
4,443
(2,347)
2,096

$

Goodwill allocated to each reportable segment at December 31 is presented as follows:

Corporate Bank

Consumer Bank
Wealth Management

2016

2015

(In millions)

2,474

$

1,978
452
4,904

$

2,305

2,095
478
4,878

$

$

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Refer to Note 23 for discussion of Regions' reorganization of its management reporting structure during the first quarter of 
2016 and, accordingly, its segment reporting structure and goodwill reporting units. Goodwill is allocated to each of Regions’ 
reportable segments (each a reporting unit: Corporate Bank, Consumer Bank, and Wealth Management). In connection with the 
reorganization, management reallocated goodwill to the new reporting units using a relative fair value approach. As stated in Note 
1, Regions evaluates each reporting unit’s goodwill for impairment on an annual basis in the fourth quarter, or more often if events 
or circumstances indicate that there may be impairment.

In addition to the reallocation, there were increases of approximately $22 million to the Corporate Bank reportable segment 
and approximately $4 million to the Wealth Management reportable segment during 2016.  There were increases of approximately 
$47 million to the Corporate Bank reportable segment and $15 million to the Wealth Management reportable segment during 2015. 
There were no impairment losses during 2016, 2015 or 2014.

During the fourth quarter of 2016, Regions assessed the indicators of goodwill impairment for all three reporting units as 
part of its annual impairment test, as of October 1, 2016, and through the date of the filing of this Annual Report. The results of 
the annual test indicated that the estimated fair value of each reporting unit exceeded its carrying amount as of the test date; 
therefore, the goodwill of each reporting unit is considered not impaired as of the testing date.

Listed in the tables below are assumptions used in estimating the fair value of each reporting unit for the applicable annual 
period. The table includes the discount rates used in the income approach, the market multipliers used in the market approaches, 
and the public company method control premium applied to each reporting unit. These valuation approaches are described further 
in Note 1.

Corporate 
Bank

Consumer
Bank

Wealth
Management

As of Fourth Quarter 2016
Discount rate used in income approach
Public company method market multiplier(1)
Transaction method market multiplier(2)
_________
(1)  For the Corporate Bank and Consumer Bank reporting units, these multipliers are applied to tangible book value. For the Wealth Management 
reporting unit, this multiplier is applied to earnings. In addition to the multipliers, a 10 percent control premium was assumed for the 
Corporate Bank reporting unit, a 25 percent control premium was assumed for the Consumer Bank reporting unit and a 25 percent control 
premium was assumed for the Wealth Management reporting unit based on current market factors. Because the control premium considers 
potential revenue synergies and cost savings for similar financial services transactions, reporting units operating in businesses that have 
greater barriers to entry tend to have greater control premiums.

11.50%
14.6x
23.5x

10.00%
1.5x
1.9x

10.25%
1.9x
1.9x

(2)  For the Corporate Bank and Consumer Bank reporting units, these multipliers are applied to tangible book value. For the Wealth Management 

reporting unit, this multiplier is applied to earnings.

As of Fourth Quarter 2015
Discount rate used in income approach
Public company method market multiplier(1)
Transaction method market multiplier(2)

Corporate 
Bank

Consumer
Bank

Wealth
Management

11.00%
1.9x
1.9x

11.00%
1.5x
1.9x

12.00%
18.5x
23.5x

_________
(1)  For the Corporate Bank and Consumer Bank reporting units, these multipliers are applied to tangible book value. For the Wealth Management 
reporting unit, this multiplier is applied to earnings. In addition to the multipliers, a 10 percent control premium was assumed for the 
Corporate Bank reporting unit, a 30 percent control premium was assumed for the Consumer Bank reporting unit and a 15 percent control 
premium was assumed for the Wealth Management reporting unit based on current market factors. Because the control premium considers 
potential revenue synergies and cost savings for similar financial services transactions, reporting units operating in businesses that have 
greater barriers to entry tend to have greater control premiums.

(2)  For the Corporate Bank and Consumer Bank reporting units, these multipliers are applied to tangible book value. For the Wealth Management 

reporting unit, this multiplier is applied to earnings.

OTHER INTANGIBLES

Other intangibles consist primarily of core deposit intangibles, purchased credit card relationship assets, customer relationship 

and employment agreement assets and the Fannie Mae DUS license. 

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Table of Contents 

The following table shows the other intangibles and related accumulated amortization as of December 31:

2016

2015

2016

2015

2016

2015

Gross Carrying Amount

Accumulated Amortization

Net Carrying Amount

Core deposit intangibles
Purchased credit card relationship assets
Customer relationship and employment
agreement assets
Other—amortizing (1)
Fannie Mae DUS license (2)
Other—non-amortizing (3)

$

$

1,011
175

$

1,011
175

(In millions)
932
102

$

$

912
86

75

19

72

16

33

10

25

9

_________
(1)   Includes intangible assets related to acquired trust services, trade names and intellectual property.
(2)   The Fannie Mae DUS license is a non-amortizing intangible asset.
(3)   Includes non-amortizing intangible assets related to other acquired trust services. 

$

1,280

$

1,274

$

1,077

$

1,032

$

79
73

42

9

15
3
221

$

$

99
89

47

7

15
3
260

Changes in the gross carrying amount in the table above reflect additions from recent acquisitions or the removal of fully 
amortized intangible assets. Purchased credit card relationships and customer relationships and employment agreements are being 
amortized in other non-interest expense primarily on an accelerated basis over a period ranging from 2 to 15 years. Core deposit 
intangible assets are being amortized in other non-interest expense on an accelerated basis over their expected useful lives.

Regions  purchased  a  Fannie Mae  DUS  license in  2014. The  intangible asset  associated with  the  DUS  license  is  a  non-

amortizing intangible asset. Refer to Note 7 for additional information related to this license. 

The aggregate amount of amortization expense for core deposit intangibles, purchased credit card relationship assets, and 

other intangible assets is estimated as follows:

2017
2018
2019
2020
2021

Year Ended December 31

(In millions)

$

44
39
32
26
21

Identifiable intangible assets other than goodwill are reviewed at least annually, usually in the fourth quarter, for events or 
circumstances that could impact the recoverability of the intangible asset. Regions concluded that no impairment for any other 
identifiable intangible assets occurred during 2016, 2015 or 2014.

NOTE 11. DEPOSITS                      

The following schedule presents a detail of interest-bearing deposits at December 31:

Savings
Interest-bearing transaction
Money market—domestic
Money market—foreign
Time deposits

Interest-bearing customer deposits

Corporate treasury time deposits

2016

2015

(In millions)

$

$

7,840
20,259
27,293
186
7,183
62,761
228
62,989

$

$

7,287
21,902
26,468
243
7,468
63,368
200
63,568

The aggregate amount of time deposits of $250,000 or more, including certificates of deposit of $250,000 or more, was $1.2 

billion and $1.1 billion at December 31, 2016 and 2015, respectively.

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At December 31, 2016, the aggregate amounts of maturities of all time deposits (deposits with stated maturities, consisting 

primarily of certificates of deposit and IRAs) were as follows:

2017
2018
2019
2020
2021
Thereafter

December 31, 2016

(In millions)

3,189
1,674
533
1,208
620
187
7,411

$

$

NOTE 12. SHORT-TERM BORROWINGS

Following is a summary of short-term borrowings at December 31:

Customer-related borrowings:
Customer collateral

2016

2015

(In millions)

$
$

— $
— $

10
10

Customer collateral includes cash collateral posted by customers related to derivative transactions. 

NOTE 13. LONG-TERM BORROWINGS

Long-term borrowings at December 31 consist of the following:

Regions Financial Corporation (Parent):
2.00% senior notes due May 2018
3.20% senior notes due February 2021
7.75% subordinated notes due September 2024
6.75% subordinated debentures due November 2025
7.375% subordinated notes due December 2037
Valuation adjustments on hedged long-term debt

Regions Bank:
Federal Home Loan Bank advances
2.25% senior notes due September 2018
7.50% subordinated notes due May 2018
6.45% subordinated notes due June 2037
3.80% affiliate subordinated notes due February 2025
Other long-term debt
Valuation adjustments on hedged long-term debt

Elimination of 3.80% affiliate subordinated notes due February 2025
Total consolidated

2016

2015

(In millions)

$

$

100
1,102
100
159
297
(30)
1,728

4,254
748
499
495
150
40
(1)
6,185
(150)
7,763

$

$

749
—
100
159
300
(7)
1,301

5,255
749
500
497
150
48
(1)
7,198
(150)
8,349

Effective January 1, 2016, the Company adopted new FASB guidance related to the accounting for debt issuance costs. All 
existing debt issuance costs were reclassified from other assets to long-term borrowings as direct deductions of the related debt 
instruments.  The  impact  of  the  adoption  of  this  guidance  was  not  material  to  prior  periods  and  therefore  was  not  applied 
retrospectively.

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As of December 31, 2016, Regions had six issuances of subordinated notes totaling $1.7 billion, with stated interest rates 
ranging from 3.80% to 7.75%. One of the issuances is intercompany and is eliminated in consolidation as noted in the table above. 
All issuances of these notes are, by definition, subordinated and subject in right of payment of both principal and interest to the 
prior payment in full of all senior indebtedness of the Company, which is generally defined as all indebtedness and other obligations 
of the Company to its creditors, except subordinated indebtedness. Payment of the principal of the notes may be accelerated only 
in the case of certain events involving bankruptcy, insolvency proceedings or reorganization of the Company. The subordinated 
notes described above qualify as Tier 2 capital under Federal Reserve guidelines, subject to diminishing credit as the respective 
maturity dates approach and subject to certain transition provisions. None of the subordinated notes are redeemable prior to maturity, 
unless there is an occurrence of a qualifying capital event.

During 2016 through a tender offer, Regions repurchased approximately $649 million of the outstanding 2.00% senior notes 
due May 2018. Pre-tax losses on the repurchase related to the execution of this tender offer were approximately $14 million. 
Additionally, Regions issued $1.1 billion of 3.20% senior notes during 2016. Regions issued $500 million of 3.20% senior notes 
in the first quarter of 2016 and an additional $600 million of 3.20% senior notes during the second quarter of 2016.

FHLB advances at December 31, 2016, 2015 and 2014 had a weighted-average interest rate of 0.8 percent, 0.7 percent, and 
1.7 percent, respectively, with remaining maturities ranging from less than one year to fourteen years and a weighted-average of 
0.7 years. FHLB borrowing capacity is contingent upon the amount of collateral pledged to the FHLB. Regions has pledged certain 
loans as collateral for the FHLB advances outstanding. See Note 5 for loans pledged to the FHLB at December 31, 2016 and 2015. 
Additionally, membership in the FHLB requires an institution to hold FHLB stock. See Note 8 for the amount of FHLB stock held 
at  December 31,  2016  and  2015.    Regions’  total  borrowing  capacity  with  the  FHLB  (including  outstanding  advances)  as  of 
December 31, 2016, based on assets available for collateral at that date, was approximately $16.4 billion.

Regions uses derivative instruments, primarily interest rate swaps, to manage interest rate risk by converting a portion of its 
fixed-rate debt to a variable-rate. The effective rate adjustments related to these hedges are included in interest expense on long-
term borrowings. The weighted-average interest rate on total long-term debt, including the effect of derivative instruments, was 
2.4 percent, 3.1 percent, and 5.0 percent for the years ended December 31, 2016, 2015 and 2014, respectively. Further discussion 
of derivative instruments is included in Note 21.

The aggregate amount of contractual maturities of all long-term debt in each of the next five years and thereafter is as follows:

2017
2018
2019
2020
2021
Thereafter

Year Ended December 31

Regions
Financial
Corporation
(Parent)

Regions
Bank

$

$

(In millions)
— $
100
—
—
1,072
556
1,728

$

4,252
1,249
4
32
2
646
6,185

In February 2016, Regions filed a shelf registration statement with the U.S. Securities and Exchange Commission. This shelf 
registration does not have a capacity limit and can be utilized by Regions to issue various debt and/or equity securities. The 
registration statement will expire in February 2019.

Regions Bank may issue bank notes from time to time, either as part of a bank note program or as stand-alone issuances.  
Notes issued by Regions Bank may be senior or subordinated notes.  Notes issued by Regions Bank are not deposits and are not 
insured or guaranteed by the FDIC.

Regions may, from time to time, consider opportunistically retiring outstanding issued securities, including subordinated 
debt in privately negotiated or open market transactions. Regulatory approval would be required for retirement of some securities.

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NOTE 14. REGULATORY CAPITAL REQUIREMENTS AND RESTRICTIONS 

Regions and Regions Bank are required to comply with regulatory capital requirements established by federal and state 
banking agencies. These regulatory capital requirements involve quantitative measures of the Company’s assets, liabilities and 
certain off-balance sheet items, and also qualitative judgments by the regulators. Failure to meet minimum capital requirements 
can  subject  the  Company  to  a  series  of  increasingly  restrictive  regulatory  actions.  Banking  regulations  identify  five  capital 
categories:  well-capitalized,  adequately  capitalized,  undercapitalized,  significantly  undercapitalized  and  critically 
undercapitalized. At December 31, 2016 and 2015, Regions and Regions Bank exceeded all current regulatory requirements, and 
were classified as "well-capitalized." Management believes that no events or changes have occurred subsequent to December 31, 
2016 that would change this designation. 

Quantitative measures established by regulation to ensure capital adequacy require institutions to maintain minimum ratios 
of common equity Tier 1, Tier 1, and Total capital (as defined in the regulations) to risk-weighted assets (as defined), and of Tier 
1 capital to average tangible assets (the "Leverage" ratio).

The following tables summarize the applicable holding company and bank regulatory capital requirements: 

Transitional Basis Basel III Regulatory Capital Rules (2)
Basel III common equity Tier 1 capital:
Regions Financial Corporation
Regions Bank

Tier 1 capital:

Regions Financial Corporation
Regions Bank

Total capital:

Regions Financial Corporation
Regions Bank

Leverage capital:

Regions Financial Corporation
Regions Bank

Transitional Basis Basel III Regulatory Capital Rules (2)
Basel III common equity Tier 1 capital:
Regions Financial Corporation
Regions Bank

Tier 1 capital:

Regions Financial Corporation
Regions Bank

Total capital:

Regions Financial Corporation
Regions Bank

Leverage capital:

Regions Financial Corporation
Regions Bank

December 31, 2016 (1)
Ratio

Amount

Minimum
Requirement

To Be Well
Capitalized

(Dollars in millions)

11,481
12,404

12,277
12,404

14,501
14,311

12,277
12,404

11.21%
12.14

11.98%
12.14

14.15%
14.00

10.20%
10.34

4.50%
4.50

6.00%
6.00

8.00%
8.00

4.00%
4.00

N/A
6.50%

6.00%
8.00

10.00%
10.00

N/A
5.00%

December 31, 2015

Amount

Ratio

Minimum
Requirement

To Be Well
Capitalized

(Dollars in millions)

11,543
12,302

12,306
12,302

14,662
14,311

12,306
12,302

10.93%
11.68

11.65%
11.68

13.88%
13.59

10.25%
10.28

4.50%
4.50

6.00%
6.00

8.00%
8.00

4.00%
4.00

N/A
6.50%

6.00%
8.00

10.00%
10.00

N/A
5.00%

$

$

$

$

$

$

$

$

 _________
(1)  The 2016 Basel III CET1 capital, Tier 1 capital, Total capital, and Leverage capital ratios are estimated.
(2)   The 2016 and 2015 capital ratios were calculated at different points of the phase-in period under the Basel III Rules and therefore are not 

directly comparable.

Substantially all net assets are owned by subsidiaries. The primary source of operating cash available to Regions is provided 
by dividends from subsidiaries. Statutory limits are placed on the amount of dividends the subsidiary bank can pay without prior 
regulatory approval. In addition, regulatory authorities require the maintenance of minimum capital-to-asset ratios at banking 

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subsidiaries. Under the Federal Reserve’s Regulation H, Regions Bank may not, without approval of the Federal Reserve, declare 
or pay a dividend to Regions if the total of all dividends declared in a calendar year exceeds the total of (a) Regions Bank’s net 
income for that year and (b) its retained net income for the preceding two calendar years, less any required transfers to additional 
paid-in capital or to a fund for the retirement of preferred stock. Under Alabama law, Regions Bank may not pay a dividend to 
Regions in excess of 90 percent of its net earnings until the bank’s surplus is equal to at least 20 percent of capital. Regions Bank 
is also required by Alabama law to seek the approval of the Alabama Superintendent of Banking prior to paying a dividend to 
Regions if the total of all dividends declared by Regions Bank in any calendar year will exceed the total of (a) Regions Bank’s 
net earnings for that year, plus (b) its retained net earnings for the preceding two years, less any required transfers to surplus. The 
statute defines net earnings as “the remainder of all earnings from current operations plus actual recoveries on loans and investments 
and other assets, after deducting from the total thereof all current operating expenses, actual losses, accrued dividends on preferred 
stock, if any, and all federal, state and local taxes.” In addition to dividend restrictions, Federal statutes also prohibit unsecured 
loans from banking subsidiaries to the parent company.

In addition, Regions must adhere to various HUD regulatory guidelines including required minimum capital to maintain 
their FHA approved status. Failure to comply with the HUD guidelines could result in withdrawal of this certification. As of 
December 31, 2016, Regions was in compliance with HUD guidelines. Regions is also subject to various capital requirements by 
secondary market investors.

NOTE 15. STOCKHOLDERS’ EQUITY AND ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS)

PREFERRED STOCK

The following table presents a summary of the non-cumulative perpetual preferred stock as of December 31:

Series A

Series B

Issuance Date

Earliest
Redemption
Date

Dividend
Rate

Liquidation
Amount

Carrying
Amount

Carrying
Amount

2016

2015

(Dollars in millions)

11/1/2012

12/15/2017

6.375%

4/29/2014

9/15/2024

6.375% (1)

$

$

500

$

387

$

500

433

1,000

$

820

$

387

433

820

_________
(1)  Dividends, if declared, will be paid quarterly at an annual rate equal to (i) for each period beginning prior to September 15, 2024, 6.375%, 
and (ii) for each period beginning on or after September 15, 2024, three-month LIBOR plus 3.536%.

For each preferred stock issuance listed above, Regions issued depositary shares, each representing a 1/40th ownership 
interest  in  a  share  of  the  Company's  preferred  stock,  with  a  liquidation  preference  of  $1,000.00  per  share  of  preferred  stock 
(equivalent to $25.00 per depositary share). Dividends on the preferred stock, if declared, accrue and are payable quarterly in 
arrears. The preferred stock has no stated maturity and redemption is solely at Regions' option, subject to regulatory approval, in 
whole, or in part, after the earliest redemption date or in whole, but not in part, within 90 days following a regulatory capital 
treatment event for the Series A preferred stock or at any time following a regulatory capital treatment event for the Series B 
preferred stock. 

The Board declared $32 million in cash dividends on both Series A and Series B Preferred Stock, during both 2016 and 2015. 
Prior to the first quarter of 2016, the Company was in a retained deficit position and preferred dividends were recorded as a 
reduction of preferred stock, including related surplus. During the first quarter of 2016, the Company achieved positive retained 
earnings and preferred dividends were recorded as a reduction of retained earnings.

In the event Series A and Series B preferred shares are redeemed at the liquidation amounts, $113 million and $67 million
excess of the redemption amount over the carrying amount will be recognized, respectively. Approximately $100 million of Series 
A preferred dividends that were recorded as a reduction of preferred stock, including related surplus, will be recorded as a reduction 
to retained earnings, and approximately $13 million of related issuance costs that were recorded as a reduction of preferred stock, 
including related surplus, will be recorded as a reduction to net income available to common shareholders.  Approximately $52 
million of Series B preferred dividends that were recorded as a reduction of preferred stock, including related surplus, will be 
recorded as a reduction to retained earnings, and approximately $15 million of related issuance costs that were recorded as a 
reduction  of  preferred  stock,  including  related  surplus,  will  be  recorded  as  a  reduction  to  net  income  available  to  common 
shareholders.

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COMMON STOCK

On June 29, 2016, Regions received no objection from the Federal Reserve to its 2016 capital plan that was submitted as 
part of the CCAR  process. In addition to continuing the $0.065 quarterly common stock dividend, actions that Regions may 
undertake as outlined in its capital plan include the repurchase of up to $640 million in common shares. The capital plan also 
provides the potential for a dividend increase beginning in the second quarter of 2017, which is expected to be considered by the 
Board in early 2017. 

On July 14, 2016, Regions' Board authorized a new $640 million common stock repurchase plan, permitting repurchases 
from the beginning of the third quarter of 2016 through the second quarter of 2017. On October 12, 2016, Regions' Board authorized 
an additional $120 million repurchase, which increases the total amount authorized under the plan to $760 million. As of December 
31, 2016, Regions had repurchased approximately 46.5 million shares of common stock at a total cost of approximately $485 
million under this plan. The Company continued to repurchase shares under this plan in the first quarter of 2017, and as of February 
23, 2017, Regions had additional repurchases of approximately 10.2 million shares of common stock at a total cost of approximately  
$149.8 million. All of these shares were immediately retired upon repurchase and therefore will not be included in treasury stock.

On April 23, 2015, Regions' Board approved an increase of its quarterly common stock dividend to $0.06 per share effective 
with the quarterly dividend paid in July 2015. The Board also authorized a new $875 million common stock repurchase plan, 
permitting repurchases from the beginning of the second quarter of 2015 through the end of the second quarter of 2016. Through 
December 31, 2015, Regions repurchased approximately 52 million shares of common stock at a total cost of approximately $520 
million  under  this  plan.  During  the  first  and  second  quarters  of  2016,  Regions  concluded  the  plan  with  the  repurchase  of 
approximately 42.4 million shares of common stock at a total cost of approximately $354 million. All common shares repurchased 
under this plan were immediately retired upon repurchase and therefore are not included in treasury stock.

On April 24, 2014, Regions' Board authorized a $350 million common stock repurchase plan, permitting repurchases from 
the beginning of the second quarter of 2014 through the end of the first quarter of 2015. As of December 31, 2014, Regions had 
repurchased approximately 25 million shares of common stock at a total cost of approximately $248 million. During the first 
quarter of 2015, Regions concluded the plan with the repurchase of approximately 11 million shares of common stock at a total 
cost of approximately $102 million. All common shares repurchased under this plan were immediately retired upon repurchase 
and therefore are not included in treasury stock. 

During the first quarter of 2014, Regions repurchased approximately 1 million shares of common stock at a total cost of 
approximately $8 million under a $350 million common stock repurchase plan that expired on April 1, 2014. All common shares 
repurchased under this plan were immediately retired upon repurchase and therefore are not included in treasury stock.

The Board declared $0.255 per share in cash dividends for 2016, $0.23 for 2015, and $0.18 for 2014. Prior to the first quarter 
of 2016, the Company was in a retained deficit position and common stock dividends were recorded as a reduction of additional 
paid-in capital. During the first quarter of 2016, the Company achieved positive retained earnings and common stock dividends 
were recorded as a reduction of retained earnings.

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ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS)

Activity within the balances in accumulated other comprehensive income (loss) is shown in the following tables for the years 

ended December 31: 

Unrealized losses
on securities
transferred to
held to maturity

Unrealized
gains (losses) on 
securities
available
for sale

2016

Unrealized
gains (losses) on 
derivative
instruments
designated
as cash
flow hedges

(In millions)

Defined benefit 
pension plans 
and other post
employment
benefits

Accumulated
other
comprehensive
income (loss),
net of tax

Beginning of year

Net change

End of year

$

$

(47) $

14

(33) $

(10) $

(96)

(106) $

75

(64)

11

$

$

(398) $

(24)

(422) $

(380)

(170)

(550)

Unrealized losses
on securities
transferred to
held to maturity

Unrealized
gains (losses) on 
securities
available               
for sale

2015

Unrealized
gains (losses) on 
derivative
instruments
designated
as cash
flow hedges

(In millions)

Defined benefit
pension plans
and other post
employment
benefits

Accumulated 
other
comprehensive
income (loss),
net of tax

Beginning of year

Net change

End of year

$

$

(55) $

8

(47) $

175

$

(185)

(10) $

33

42

75

$

$

(391) $

(7)

(398) $

(238)

(142)

(380)

Unrealized losses
on securities
transferred to
held to maturity

Unrealized
gains (losses) on
securities
available
for sale

2014

Unrealized
gains (losses) on
derivative
instruments
designated
as cash
flow hedges

(In millions)

Defined benefit
pension plans
and other post
employment
benefits

Accumulated
other
comprehensive
income (loss),
net of tax

Beginning of year

Net change

End of year

$

$

(64) $
9

(55) $

(22) $

197

175

$

15

18

33

$

$

(248) $

(143)

(391) $

(319)

81

(238)

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The following table presents amounts reclassified out of accumulated other comprehensive income (loss) for the years ended 

December 31: 

Details about Accumulated Other Comprehensive Income
(Loss) Components

Unrealized losses on securities transferred to held to maturity:

Unrealized gains and (losses) on available for sale securities:

Gains (losses) on cash flow hedges:

Interest rate contracts

Amortization of defined benefit pension plans and other post
employment benefits:

Prior service cost

Actuarial gains (losses)

Total reclassifications for the period

2016

2015

2014

Amount 
Reclassified from 
Accumulated 
Other 
Comprehensive 
Income (Loss)(1)

Amount 
Reclassified from 
Accumulated 
Other 
Comprehensive 
Income (Loss)(1)

Amount 
Reclassified from 
Accumulated 
Other 
Comprehensive 
Income (Loss)(1)

(In millions)

Affected Line Item in
the Consolidated
Statements of Income

$

$

$

$

$

$

$

$

$

(22)

8

(14)

6

(2)

4

143

(54)

89

$

$

$

$

$

$

(14)

6

(8)

29

(10)

19

153

(58)

95

$

$

$

$

$

$

— $

(1)

$

(34)

(34)

12

(22)

57

$

$

(47)

(48)

17

(31)

75

$

$

Net interest income and
other financing income

(14)

5 Tax (expense) or benefit

(9) Net of tax

27 Securities gains, net

(10) Tax (expense) or benefit

17 Net of tax

Net interest income and
other financing income

126

(48) Tax (expense) or benefit

78 Net of tax

(1) (2)
(24) (2)

(25) Total before tax

9 Tax (expense) or benefit

(16) Net of tax

70 Net of tax

_________
(1)  Amounts in parentheses indicate reductions to net income.
(2)  These accumulated other comprehensive income (loss) components are included in the computation of net periodic pension cost and are 
included in salaries and employee benefits on the consolidated statements of income (see Note 18 for additional details).

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NOTE 16. EARNINGS (LOSS) PER COMMON SHARE

The following table sets forth the computation of basic earnings (loss) per common share and diluted earnings (loss) per 

common share for the years ended December 31:

Numerator:

Income from continuing operations

Preferred stock dividends

Income from continuing operations available to common shareholders

Income (loss) from discontinued operations, net of tax

Net income available to common shareholders

Denominator:

Weighted-average common shares outstanding—basic

Potential common shares

Weighted-average common shares outstanding—diluted

Earnings per common share from continuing operations available to 
common shareholders(1):

Basic

Diluted

Earnings (loss) per common share from discontinued operations(1):

Basic

Diluted

Earnings per common share(1):

Basic

Diluted

2016

2015

2014

(In millions, except per share data)

$

1,158
(64)
1,094

5

1,099

$

1,255

6

1,261

0.87

0.87

0.00

0.00

0.87

0.87

$

$

$

1,075
(64)
1,011
(13)
998

$

$

1,325

9

1,334

$

0.76

0.76

(0.01) $
(0.01)

$

0.75

0.75

1,134
(52)
1,082

13

1,095

1,375

12

1,387

0.79

0.78

0.01

0.01

0.80

0.79

$

$

$

$

$

________
(1) 

 Certain per share amounts may not appear to reconcile due to rounding.

For earnings per common share from discontinued operations, basic and diluted weighted-average common shares are the 

same for 2015 due to the Company experiencing net losses from discontinued operations. 

The effect from the assumed exercise of 27 million, 29 million and 24 million in stock options, restricted stock units and 
awards and performance stock units for the years ended December 31, 2016, 2015 and 2014, respectively, was not included in the 
above computations of diluted earnings per common share because such amounts would have had an antidilutive effect on earnings 
per common share.  

NOTE 17. SHARE-BASED PAYMENTS 

Regions administers long-term incentive compensation plans that permit the granting of incentive awards in the form of 
stock options, restricted stock awards, performance awards and stock appreciation rights. While Regions has the ability to issue 
stock appreciation rights, none have been issued to date. The terms of all awards issued under these plans are determined by the 
Compensation Committee of the Board; however, no awards may be granted after the tenth anniversary from the date the plans 
were initially approved by stockholders. Incentive awards usually vest based on employee service, generally within three years 
from the date of the grant. The contractual lives of options granted under these plans are typically ten years from the date of the 
grant.

On April 23, 2015, the stockholders of the Company approved the Regions Financial Corporation 2015 LTIP, which permits 
the Company to grant to employees and directors various forms of incentive compensation. These forms of incentive compensation 
are similar to the types of compensation approved in prior plans. The 2015 LTIP authorizes 60 million common share equivalents 
available for grant, where grants of options and grants of full value awards (e.g., shares of restricted stock, restricted stock units 
and performance stock units) count as one share equivalent. Unless otherwise determined by the Compensation Committee of the 
Board, grants of restricted stock, restricted stock units, and performance stock units accrue dividends, or their notional equivalent, 
as they are declared by the Board, and are paid upon vesting of the award. Upon adoption of the 2015 LTIP, Regions closed the 
prior long-term incentive plan to new grants, and, accordingly, prospective grants must be made under the 2015 LTIP or a successor 
plan. All existing grants under prior long-term incentive plans are unaffected by adoption of the 2015 LTIP. The number of remaining 
share equivalents available for future issuance under the 2015 LTIP was approximately 48 million at December 31, 2016.

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Grants of performance-based restricted stock typically have a three-year performance period, and shares vest within three 
years after the grant date. Restricted stock units typically have a vesting period of three years. Grantees of restricted stock awards 
or units must either remain employed with the Company for certain periods from the date of grant in order for shares to be released 
or issued or retire after meeting the standards of a retiree, at which time shares would be issued and released. The terms of these 
plans generally stipulate that the exercise price of options may not be less than the fair market value of Regions common stock at 
the date the options are granted; however, under prior stock option plans, non-qualified options could be granted with a lower 
exercise price than the fair market value of Regions’ common stock on the date of grant. The contractual life of options granted 
under these plans is typically ten years from the date of grant. Regions issues new shares from authorized reserves upon exercise. 

The following table summarizes the elements of compensation cost recognized in the consolidated statements of income for 

the years ended December 31:

Compensation cost of share-based compensation awards:

Restricted stock awards
Stock options

Tax benefits related to compensation cost
Compensation cost of share-based compensation awards, net of tax

$

$

52
—
(20)
32

$

$

50
—
(19)
31

$

$

47
1
(18)
30

2016

2015

(In millions)

2014

STOCK OPTIONS

The following table summarizes the activity for 2016, 2015 and 2014 related to stock options:

Outstanding at December 31, 2013

32,127,235

$

22.81

$

35

3.46 yrs.

Number of
Options

Weighted-
Average
Exercise
Price

Aggregate
Intrinsic Value
(In millions)

Weighted-
Average
Remaining
Contractual
Term

Granted

Exercised

Forfeited or expired

Outstanding at December 31, 2014

Granted

Exercised

Forfeited or expired

Outstanding at December 31, 2015

Granted

Exercised

Forfeited or expired
Outstanding at December 31, 2016

Exercisable at December 31, 2016

—
(2,249,932)
(4,560,627)
25,316,676

—
(546,455)
(5,420,064)
19,350,157

—
(1,954,064)
(3,941,046)
13,455,047

13,455,047

$

$

$

$

—

4.61

30.32

23.07

$

28

2.83 yrs.

—

6.93

31.88

21.06

$

20

2.45 yrs.

—

5.80

34.39
19.37

19.37

$

$

34

34

1.83 yrs.

1.83 yrs.

The aggregate intrinsic value of exercised options was $17 million  for 2016, $5 million for 2015, and $13 million for 2014. 
Cash received from options exercised was $11 million, $4 million, and $10 million in 2016, 2015, and 2014, respectively. The 
actual tax benefit realized for the tax deductions from options exercised totaled $4 million  for 2016, $1 million for 2015, and $5 
million for 2014.

RESTRICTED STOCK AWARDS AND PERFORMANCE STOCK AWARDS

During 2016, 2015 and 2014 Regions made restricted stock grants that vest upon satisfaction of service conditions and 
restricted stock award and performance stock award grants that vest based upon service conditions and performance conditions. 
Dividend payments during the vesting period are deferred to the end of the vesting term. The fair value of these restricted shares, 
restricted stock units and performance stock units was estimated based upon the fair value of the underlying shares on the date of 
the grant. The valuation was not adjusted for the deferral of dividends.

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Table of Contents 

Activity related to restricted stock awards and performance stock awards for 2016, 2015 and 2014 is summarized as follows:

Non-vested at December 31, 2013
Granted
Vested
Forfeited
Non-vested at December 31, 2014
Granted
Vested
Forfeited
Non-vested at December 31, 2015
Granted
Vested
Forfeited
Non-vested at December 31, 2016

Number of
Shares/Units

Weighted-Average
Grant Date
Fair Value

16,212,198
5,368,113
(2,626,683)
(526,219)
18,427,409
6,670,905
(8,222,576)
(501,496)
16,374,242
6,867,672
(5,829,974)
(852,998)
16,558,942

$

$

$

$

6.83
11.22
6.82
8.09
8.07
9.22
6.09
8.81
9.51
7.93
8.28
9.07
9.31

As  of  December 31,  2016,  the  pre-tax  amount  of  non-vested  stock  options,  restricted  stock,  restricted  stock  units  and 
performance stock units not yet recognized was $48 million, which will be recognized over a weighted-average period of 1.72
years. The total fair value of shares vested during the years ended December 31, 2016, 2015, and 2014, was $47 million, $82 
million, and $27 million, respectively. No share-based compensation costs were capitalized during the years ended December 31, 
2016, 2015 and 2014.

NOTE 18. EMPLOYEE BENEFIT PLANS   

PENSION AND OTHER POSTRETIREMENT BENEFITS

Effective January 1, 2016, Regions separated its defined benefit pension plan qualified under the Internal Revenue Code 
into two plans. The new plan was created primarily for participants who were actively employed on January 1, 2016 and all other 
participants were retained in the existing plan. Regions' defined benefit pension plans cover only certain employees as the pension 
plans are closed to new entrants. Benefits under the pension plans are based on years of service and the employee’s highest five 
consecutive years of compensation during the last ten years of employment. Regions’ funding policy is to contribute annually at 
least the amount required by IRS minimum funding standards. Contributions are intended to provide not only for benefits attributed 
to service to date, but also for those expected to be earned in the future. 

 The Company also sponsors a SERP, which is a non-qualified pension plan that provides certain senior executive officers 
defined benefits in relation to their compensation. Actuarially determined pension expense is charged to current operations using 
the projected unit credit method. All defined benefit plans are referred to as “the plans” throughout the remainder of this footnote.

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The following table sets forth the plans’ change in benefit obligation, plan assets and funded status, using a December 31

measurement date, and amounts recognized in the consolidated balance sheets at December 31:

Change in benefit obligation

Projected benefit obligation, beginning of year

$

1,895

$

2,044

$

167

$

172

$

2,062

$

2,216

Qualified Plans

Non-qualified Plans

Total

2016

2015

2016

2015

2016

2015

(In millions)

Service cost

Interest cost

Actuarial (gains) losses

Benefit payments

Administrative expenses

Plan settlements

Plan amendments

Projected benefit obligation, end of year

Change in plan assets

Fair value of plan assets, beginning of year

Actual return on plan assets

Company contributions

Benefit payments

Administrative expenses

Plan settlements

Fair value of plan assets, end of year

Funded status and accrued benefit cost at
measurement date

Amount recognized in the Consolidated Balance
Sheets:

Noncurrent assets

Current liabilities

Noncurrent liabilities

Other assets (liabilities)

Pre-tax amounts recognized in Accumulated Other
Comprehensive (Income) Loss:

Net actuarial loss (gain)

Prior service cost (credit)

35

73

67
(88)
(3)
—

—

1,979

1,930

151

—
(88)
(3)
—

1,990

11

$

$

$

$

37

$

—
(26)
11

637

—

637

$

$

$

40

84
(107)
(163)
(3)
—

—

1,895

1,859
(13)
250
(163)
(3)
—

1,930

35

35

—

—

35

607

—

607

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

4

5

13
(10)
—

—

1

4

6

1
(7)
—
(9)
—

39

78

80
(98)
(3)
—

1

180

$

167

$

2,159

— $

— $

1,930

$

$

—

10
(10)
—

—

— $

—

16
(7)
—
(9)
— $

151

10
(98)
(3)
—

1,990

$

44

90
(106)
(170)
(3)
(9)
—

2,062

1,859
(13)
266
(170)
(3)
(9)
1,930

(180) $

(167) $

(169) $

(132)

— $
(42)
(138)
(180) $

— $
(11)
(156)
(167) $

$

37
(42)
(164)
(169) $

35
(11)
(156)
(132)

52

1

53

$

$

42

—

42

$

$

689

1

690

$

$

649

—

649

The accumulated benefit obligation for the qualified plans was $1.8 billion as of both December 31, 2016 and 2015. Total 
plan assets exceeded the corresponding accumulated benefit obligation for the qualified plans as of both December 31, 2016 and 
2015. The accumulated benefit obligation for the non-qualified plans was $166 million and $162 million as of December 31, 2016
and 2015, respectively, which exceeded all corresponding plan assets for each period. Net periodic pension cost, which is recorded 
in salaries and employee benefits on the consolidated statements of income, included the following components for the years ended 
December 31:

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Qualified Plans

Non-qualified Plans

2016

2015

2014

2016

2015

2014

2016

Total

2015

2014

Service cost

Interest cost

$

$

35

73

40

84

Expected return on plan assets

(145)

(152)

Amortization of actuarial loss

Amortization of prior service cost

Settlement charge

31

—

—

Net periodic pension (benefit) cost $

(6) $

43

—

—

15

$

34

$

87
(138)
21

—

—

4

$

$

4

5

—

3

—

—

12

(In millions)

$

$

4

6

—

4

1

2

4

7

—

3

1

3

$

17

$

18

$

$

39

$

44

$

38

78
(145)
34

—

—

6

90
(152)
47

1

2

94
(138)
24

1

3

$

32

$

22

The settlement charge relates to the settlement of liabilities under the SERP for certain executive officers during the fourth 

quarter of 2015 and the second quarter of 2014.

The estimated amounts that will be amortized from accumulated other comprehensive income (loss) into net periodic benefit 

cost in 2017 are as follows:

Actuarial loss
Prior service cost

Qualified Plans

Non-qualified Plans

$

$

(In millions)

32
—
32

$

$

4
1
5

The assumptions used to determine benefit obligations at December 31 are as follows:

Discount rate
Rate of annual compensation increase

Qualified Plans

Non-qualified Plans

2016

2015

2016

2015

4.32%
3.75%

4.60%
3.75%

3.93%
3.75%

4.20%
3.75%

The weighted-average assumptions used to determine net periodic benefit cost for the years ended December 31 are as 

follows:

Discount rate
Expected long-term rate of return on plan assets
Rate of annual compensation increase

Qualified Plans

Non-qualified Plans

2016
4.56%
7.75%
3.75%

2015
4.20%
7.75%
3.75%

2014
5.00%
7.75%
3.75%

2016
4.19%
N/A
3.75%

2015
3.75%
N/A
3.75%

2014
4.50%
N/A
3.75%

Regions utilizes a disaggregated approach in the estimation of the service and interest components of net periodic pension 
costs by applying the specific spot rates along the yield curve used in the determination of the benefit obligation to the relevant 
projected cash flows.  This provides a more precise measurement of service and interest costs by improving the correlation between 
projected benefit cash flows and the corresponding spot yield curve rates.  

The expected long-term rate of return on the qualified plans' assets is based on an estimated reasonable range of probable 
returns. The  assumption is  established by  considering  historical and anticipated return of  the  asset classes  invested in  by  the 
qualified plans and the allocation strategy currently in place among those classes. Management chose a point within the range 
based on the probability of achievement combined with incremental returns attributable to active management. For 2017, the 
expected long-term rate of return on plan assets is 7.25%.

The qualified pension plans' investment strategy is continuing to shift from focusing on maximizing asset returns to minimizing 
funding ratio volatility, with a planned increase in the allocation to bonds. The combined target asset allocation is 51 percent
equities, 32 percent fixed income securities and 17 percent in all other types of investments. Equity securities include investments 
in large and small/mid cap companies primarily located in the U.S., international equities, and private equities. Fixed income 
securities include investments in corporate and government bonds, asset-backed securities and any other fixed income investments 
as allowed by respective prospectuses and other offering documents. Other types of investments may include hedge funds and 
real estate funds that follow several different strategies. The plans' assets are highly diversified with respect to asset class, security 

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and manager. Investment risk is controlled with the plans' assets rebalancing to target allocations on a periodic basis and continual 
monitoring of investment managers’ performance relative to the investment guidelines established with each investment manager.

Regions’ qualified pension plans have a portion of their investments in Regions' common stock. At December 31, 2016, the 
plans held 2,855,618 shares, which represents a total market value of approximately $41 million, or approximately 2.06 percent
of the plans' assets.

The following table presents the fair value of Regions’ qualified pension plans’ financial assets as of December 31:

Level 1

Level 2

Level 3

Fair Value

Level 1

Level 2

Level 3

Fair Value

2016

2015

(In millions)

Cash and cash equivalents

$

52

$

— $

— $

52

$

27

$

— $

— $

27

$

$

$

$

Fixed income securities:

U.S. Treasury and federal
agency securities

Corporate bonds

Total fixed income
securities

Equity securities:

Domestic

International

Total equity securities

International mutual funds

Total assets in the fair value
hierarchy

Collective trust funds:

Fixed income fund(1)
Common stock fund(1)
International fund(1)

Total collective trust
funds

Hedge funds measured at NAV(1)

Real estate funds measured at    
NAV(1)

Private equity funds measured at 
NAV(1)
Other assets measured at NAV(1)

—

—

144

170

—

—

144

170

—

—

141

156

—

—

— $

314

$

— $

314

$

— $

297

$

— $

303

21

324

192

568

$

$

$

—

—

— $

— $

—

—

— $

— $

314

$

— $

$

$

$

$

$

$

$

303

21

324

192

882

320

244

182

746

16

239

107

—

1,990

267

18

285

155

467

$

$

$

—

—

— $

— $

—

—

— $

— $

297

$

— $

$

$

$

$

$

$

$

$

$

$

141

156

297

267

18

285

155

764

315

251

177

743

93

236

93

1

1,930

__________
(1)  In accordance with accounting guidance, which was adopted by Regions in 2016 and applied retrospectively,  investments that are measured 
at fair value using the net asset value per share (or its equivalent) practical expedient are no longer required to be classified in the fair value 
hierarchy. The fair value amounts presented in this table are intended to permit reconciliation of amounts reported in the fair value hierarchy to 
amounts reported on the balance sheet.  See Note 1 for further discussion.

For  all  investments,  the  plans  attempt  to  use  quoted  market  prices  of  identical  assets  on  active  exchanges,  or  Level  1 
measurements. Where such quoted market prices are not available, the plans typically employ quoted market prices of similar 
instruments (including matrix pricing) and/or discounted cash flows to estimate a value of these securities, or Level 2 measurements. 
Level 2 discounted cash flow analyses are typically based on market interest rates, prepayment speeds and/or option adjusted 
spreads. 

Investments held in the plans consist of cash and cash equivalents, fixed income securities (U.S. Treasury, federal agency 
securities, mortgage-backed securities, collateralized mortgage obligations, obligations of states and political subdivisions and 
corporate bonds), equity securities (primarily common stock and mutual funds), collective trust funds, hedge funds, real estate 
funds, private equity and other assets and are recorded at fair value on a recurring basis. See Note 1 for a description of valuation 
methodologies related to U.S. Treasuries, federal agency securities, mortgage-backed securities, obligations of states and political 
subdivisions and equity securities. The methodology described in Note 1 for other debt securities is applicable to corporate bonds.

Mutual funds are valued based on quoted market prices of identical assets on active exchanges; these valuations are Level 
1 measurements. Collective trust funds, hedge funds, real estate funds, private equity funds and other assets are valued based on 
net asset value or the valuation of the limited partner’s portion of the equity of the fund. Third party fund managers provide these 
valuations based primarily on estimated valuations of underlying investments. 

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Information about the expected cash flows for the qualified and non-qualified plans is as follows:

Expected Employer Contributions:
2017
Expected Benefit Payments:
2017
2018
2019
2020
2021
Next five years

OTHER PLANS

$

$

Qualified

Non-qualified

(In millions)

— $

$

92
94
97
100
104
573

42

42
10
11
11
23
61

Regions has a defined-contribution 401(k) plan that includes a Company match of eligible employee contributions. Eligible 
employees include those who have been employed for one year and have worked a minimum of 1,000 hours. Prior to 2015, the 
Company match was initially invested in Regions common stock. Effective January 1, 2015, the Company match is invested based 
on the employees' allocation elections. In 2016, 2015 and 2014, Regions provided an automatic 2 percent cash 401(k) contribution 
to eligible employees regardless of whether or not they were contributing to the 401(k) plan. To receive this contribution, employees 
must be employed at the end of the year and not actively accruing a benefit in the Regions’ pension plan. Regions’ cash contribution 
was approximately $17 million, $15 million and $14 million for 2016, 2015 and 2014, respectively. Eligible employees who are 
already contributing to the 401(k) plan will continue to receive up to a 4 percent Company match plus the automatic 2 percent 
cash contribution. Regions’ match to the 401(k) plan on behalf of employees totaled $45 million, $40 million and $37 million in 
2016, 2015 and 2014, respectively. Regions’ 401(k) plan held 29 million shares and 34 million shares of Regions common stock 
at December 31, 2016 and 2015, respectively. The 401(k) plan received approximately $9 million, $8 million and $6 million in 
dividends on Regions common stock for the years ended December 31, 2016, 2015 and 2014, respectively.

Regions also sponsors defined benefit postretirement health care plans that cover certain retired employees.  For these certain 
employees retiring before normal retirement age, the Company currently pays a portion of the costs of certain health care benefits 
until the retired employee becomes eligible for Medicare. Certain retirees, participating in plans of acquired entities, are offered 
a Medicare supplemental benefit. The plan is contributory and contains other cost-sharing features such as deductibles and co-
payments. Retiree health care benefits, as well as similar benefits for active employees, are provided through a self-insured program 
in which Company and retiree costs are based on the amount of benefits paid. The Company’s policy is to fund the Company’s 
share of the cost of health care benefits in amounts determined at the discretion of management. Postretirement life insurance is 
also provided to a grandfathered group of employees and retirees. The assumed health care cost trend rate for postretirement 
medical benefits was 6.4 percent for 2016 and is assumed to decrease gradually to 4.5 percent by 2027 and remain at that level 
thereafter. A one-percentage point change in assumed health care cost trend rates would have an immaterial effect on total service 
cost and interest cost components as well as the related postretirement obligations. There was no material impact from other 
postretirement benefits on the consolidated statements of income for the years ended December 31, 2016, 2015 and 2014. The 
projected benefit obligation for these plans was $20 million and $23 million as of December 31, 2016 and 2015, respectively.

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NOTE 19. OTHER NON-INTEREST INCOME AND EXPENSE

The following is a detail of other non-interest income from continuing operations for the years ended December 31:

Capital markets fee income and other
Insurance commissions and fees
Bank-owned life insurance
Commercial credit fee income
Investment services fee income
Insurance proceeds
Net revenue from affordable housing
Market value adjustments on employee benefit assets
Other miscellaneous income

2016

2015

2014

(In millions)

$

$

152
148
95
73
58
50
17
3
99
695

$

$

104
140
74
76
55
91
24
(3)
91
652

$

$

The following is a detail of other non-interest expense from continuing operations for the years ended December 31:

Outside services
Marketing
FDIC insurance assessments
Professional, legal and regulatory expenses
Branch consolidation, property and equipment charges
Credit/checkcard expenses
Provision (credit) for unfunded credit losses
Visa class B shares expense
Loss on early extinguishment of debt
Gain on sale of TDRs held for sale, net
Other miscellaneous expenses

2016

2015

2014

(In millions)

$

$

154
101
99
89
58
55
17
15
14
—
437
1,039

$

$

149
98
105
137
56
54
(13)
9
43
—
422
1,060

$

$

73
124
85
61
43
—
16
4
99
505

131
95
75
235
16
44
(13)
12
—
(35)
407
967

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NOTE 20. INCOME TAXES 

The components of income tax expense from continuing operations for the years ended December 31 were as follows:

Current income tax expense:
Federal
State

Total current expense
Deferred income tax expense:
Federal
State

Total deferred expense
Total income tax expense

2016

2015

(In millions)

2014

$

$

$

$
$

444
21
465

2
47
49
514

$

$

$

$
$

293
7
300

115
40
155
455

$

$

$

$
$

359
15
374

107
67
174
548

__________
Note: The table above does not include income tax expense (benefit) from discontinued operations of $3 million,  $(9) million, $8 million in 
2016, 2015 and 2014, respectively. The deferred income tax expense reflected in discontinued operations was $18 million, $46 million and $22 
million in 2016, 2015 and 2014, respectively. Amounts above for 2014 have been restated to reflect the first quarter 2015 adoption of new 
guidance related to the accounting for investments in qualified affordable housing projects.

Income tax expense does not reflect the tax effects of unrealized losses on securities transferred to held to maturity, unrealized 
gains and losses on securities available for sale, unrealized gains and losses on derivative instruments and the net change from 
defined benefit pension plans and other post retirement benefits. Refer to Note 15 for additional information on stockholders’ 
equity and accumulated other comprehensive income (loss).

The  income  tax  effects  resulting  from  stock  transactions  under  the  Company’s  compensation  plans  were  an  increase  to 
stockholders’ equity of $2 million in 2016, $12 million in 2015 and $6 million in 2014. The income tax effects of these transactions 
reduced the Company’s deferred tax asset by $2 million, zero and zero in 2016, 2015 and 2014, respectively.

Income taxes from continuing operations for financial reporting purposes differs from the amount computed by applying the 

statutory federal income tax rate of 35 percent for the years ended December 31, as shown in the following table:

2016

2015

2014

Tax on income from continuing operations computed at statutory federal income tax rate $
Increase (decrease) in taxes resulting from:

585

(Dollars in millions)
$

535

$

State income tax, net of federal tax effect

Affordable housing investment amortization, net of tax benefits

Tax-exempt interest
Bank-owned life insurance
Lease financing
Other, net
Income tax expense
Effective tax rate

44
(50)
(49)
(37)
28
(7)
514
30.7%

$

30
(47)
(44)
(30)
18
(7)
455
29.7%

$

$

589

53
(45)
(36)
(33)
25
(5)
548
32.6%

__________
Note: Amounts  above  for  2014  have  been  restated  to  reflect  the  first  quarter  2015  adoption  of  new  guidance  related  to  the  accounting  for 
investments in qualified affordable housing projects. Income tax expense includes amortization of affordable housing investments of $117 million, 
$103 million and $90 million for 2016, 2015 and 2014, respectively. Income tax expense for 2015 includes a benefit of $15 million related to 
an improved methodology implemented to estimate the effective state tax rate.

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Significant components of the Company’s net deferred tax asset at December 31 are listed below:

Deferred tax assets:

Allowance for loan losses
Unrealized gains and losses included in stockholders’ equity
Accrued expenses
State net operating loss carryfowards, net of federal tax effect
Employee benefits and deferred compensation
Federal tax credit carryforwards
Other

Total deferred tax assets

Less: valuation allowance

Total deferred tax assets less valuation allowance

Deferred tax liabilities:
Lease financing
Goodwill and intangibles
Mortgage servicing rights
Fixed assets
Other

Total deferred tax liabilities

Net deferred tax asset

2016

2015

(In millions)

$

$

447
338
92
88
37
13
59
1,074
(30)
1,044

424
156
93
15
48
736
308

$

$

445
233
123
116
25
13
64
1,019
(29)
990

431
165
83
27
30
736
254

The following table provides details of the Company’s tax carryforwards at December 31, 2016, including the expiration 
dates, any related valuation allowance and the amount of taxable earnings necessary to fully realize each net deferred tax asset 
balance:

Expiration
Dates

Deferred Tax
Asset Balance

Valuation
Allowance
(In millions)

Net Deferred 
Tax
Asset Balance

Pre-Tax
Earnings
Necessary to
Realize (1)

Alternate minimum tax credits-federal

Net operating losses-states

Net operating losses-states

Net operating losses-states

Other credits-states
Other credits-states

$

None (2)
2017-2021

2022-2028

2029-2036

2017-2021
2022-2028

$

13

42

37

9

3
1

— $
(8)
(19)
(2)
(1)
—

13

34

18

7

2
1

$              N/A

827

432

162

N/A
N/A

________
(1) N/A indicates that credits are not measured on a pre-tax basis.
(2) Alternative minimum tax credits can be carried forward indefinitely.

Of the $308 million net deferred tax asset, $75 million relates to net operating losses and tax credit carryforwards, $55 million
of which expires before 2029 (as detailed in the table above). The remaining $233 million of net deferred tax assets do not have 
a set expiration date at December 31, 2016.

The Company’s determination of the realization of the net deferred tax asset is based on its assessment of all available positive 
and negative evidence. At December 31, 2016, positive evidence supporting the realization of the deferred tax assets includes 
generation of taxable income for the two prior tax years. In addition, the reversal of taxable temporary differences, excluding 
goodwill and including the accretion of taxable temporary differences related to leveraged leases acquired in a previous business 
combination, will offset approximately $665 million of the gross deferred tax asset.

The Company believes that a portion of the state net operating loss carryforwards and state tax credit carryforwards will not 
be realized due to the length of certain state carryforward periods. Accordingly, a valuation allowance has been established in the 
amount of $30 million against such benefits at December 31, 2016 compared to $29 million at December 31, 2015. 

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A reconciliation of the beginning and ending amount of unrecognized tax benefits (“UTBs”) is as follows:

Balance at beginning of year

Additions based on tax positions related to the current year
Reductions based on tax positions taken in a prior period
Settlements
Expiration of statute of limitations

Balance at end of year

$

$

2016

2015

(In millions)

2014

38
3
(6)
(3)
(1)
31

$

$

50
2
(8)
(6)
—
38

$

$

51
3
(1)
(3)
—
50

The Company files U.S. federal, state, and local income tax returns. The Company’s federal income tax returns are no longer 
subject to examination by the IRS for taxable years prior to 2012. In 2015, the Company entered the IRS’s Compliance Assurance 
Process program and is currently under examination for 2015 and 2016. The Company has been notified that 2017 will be included 
under this program. With few exceptions, the Company is no longer subject to state and local income tax examinations for tax 
years before 2009. Currently, there are disputed tax positions with certain states, including positions regarding investment and 
intellectual property subsidiaries. The Company continues to evaluate these positions and intends to defend proposed adjustments 
made by these tax authorities. The Company does not anticipate that the ultimate resolution of these examinations will result in a 
material change to its business, financial position, results of operations or cash flows.

As a result of the potential resolution of certain federal and state income tax positions, it is reasonably possible that the UTBs 
could decrease as much as $23 million during the next twelve months, since resolved items will be removed from the balance 
whether their resolution results in payment or recognition in earnings.

As of December 31, 2016, 2015 and 2014, the balance of the Company’s UTBs that would reduce the effective tax rate, if 
recognized, was $20 million, $24 million and $34 million, respectively. The remainder of the UTB balance has indirect tax benefits 
in other jurisdictions or is the tax effect of temporary differences.

Income tax expense for 2016, 2015 and 2014, includes a total expense (benefit) of $1 million, $(1) million and $1 million, 
respectively, for interest expense, interest income and penalties before the impact of any applicable federal and state deductions. 
As of December 31, 2016 and 2015, the Company had a liability of $4 million and $3 million, respectively, for interest and penalties 
related to income taxes, before the impact of any applicable federal and state deductions.

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NOTE 21. DERIVATIVE FINANCIAL INSTRUMENTS AND HEDGING ACTIVITIES 

The following tables present the notional amount and estimated fair value of derivative instruments on a gross basis as of 

December 31, 2016 and 2015. 

2016

Estimated Fair Value

(1)

Gain

(1)

Loss

Notional
Amount

2015

Estimated Fair Value

(1)

Gain

(1)

Loss

Notional
Amount

(In millions)

Derivatives in fair value hedging
relationships:

Interest rate swaps

$

2,257

$

7

$

40

$

2,450

$

5

$

Derivatives in cash flow hedging
relationships:

Interest rate swaps

Total derivatives designated as hedging
instruments

Derivatives not designated as hedging
instruments:

Interest rate swaps
Interest rate options

Interest rate futures and forward
commitments
Other contracts

Total derivatives not designated as
hedging instruments

Total derivatives

$

$

$

$

9,000

19

269

9,800

109

11,257

$

26

$

309

$

12,250

$

114

$

$

41,851
3,877

18,605

5,813

70,146

81,403

$

$

412
24

11

106

553

579

$

$

$

$

467
12

$

40,612
3,441

6

93

17,288

4,367

578

887

$

$

65,708

77,958

$

$

496
11

5

200

712

826

$

$

$

27

9

36

528
1

6

187

722

758

_________
(1)  Derivatives in a gain position are recorded as other assets and derivatives in a loss position are recorded as other liabilities on the consolidated 

balance sheets.

HEDGING DERIVATIVES

Derivatives entered into to manage interest rate risk and facilitate asset/liability management strategies are designated as 
hedging derivatives. Derivative financial instruments that qualify in a hedging relationship are classified, based on the exposure 
being hedged, as either fair value hedges or cash flow hedges. Additional information regarding accounting policies for derivatives 
is described in Note 1 "Summary of Significant Accounting Policies." 

FAIR VALUE HEDGES

Fair value hedge relationships mitigate exposure to the change in fair value of an asset, liability or firm commitment. 

Regions enters into interest rate swap agreements to manage interest rate exposure on the Company’s fixed-rate borrowings, 
which includes long-term debt and certificates of deposit. These agreements involve the receipt of fixed-rate amounts in exchange 
for floating-rate interest payments over the life of the agreements. Regions enters into interest rate swap agreements to manage 
interest rate exposure on certain of the Company's fixed-rate available for sale debt securities. These agreements involve the 
payment of fixed-rate amounts in exchange for floating-rate interest receipts.

CASH FLOW HEDGES

Cash flow hedge relationships mitigate exposure to the variability of future cash flows or other forecasted transactions. 

Regions enters into interest rate swap agreements to manage overall cash flow changes related to interest rate risk exposure 
on LIBOR-based loans.  The agreements effectively modify the Company’s exposure to interest rate risk by utilizing receive fixed/
pay LIBOR interest rate swaps.

Regions issues long-term fixed-rate debt for various funding needs. Regions may enter into receive LIBOR/pay fixed forward 
starting swaps to hedge risks of changes in the projected quarterly interest payments attributable to changes in the benchmark 
interest rate (LIBOR) during the time leading up to the probable issuance date of the new long-term fixed-rate debt.

Regions recognized an unrealized after-tax gain of $166 million and $18 million in accumulated other comprehensive income 
(loss) at December 31, 2016 and 2015, respectively, related to terminated cash flow hedges of loan instruments which will be 
amortized into earnings in conjunction with the recognition of interest payments through 2025. Regions recognized pre-tax income 

154

 
 
 
 
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of $68 million and $42 million during the years ended December 31, 2016 and 2015, respectively related to the amortization of 
cash flow hedges of loan instruments.

Regions expects to reclassify out of accumulated other comprehensive income (loss) and into earnings approximately $98 
million in pre-tax income due to the receipt or payment of interest payments on all cash flow hedges within the next twelve months. 
Included in this amount is $70 million in pre-tax net gains related to the amortization of discontinued cash flow hedges. The 
maximum length of time over which Regions is hedging its exposure to the variability in future cash flows for forecasted transactions 
is approximately nine years as of December 31, 2016.

The following tables present the effect of hedging derivative instruments on the consolidated statements of income for the 

years ended December 31:

Gain or (Loss) Recognized in
Income on Derivatives

2016

2015

2014

(In millions)

Location of Amounts Recognized in
Income on Derivatives and Related
Hedged Item

Fair Value Hedges:

Interest rate swaps on:

Debt/CDs

Debt/CDs

Securities available for sale
Securities available for sale

$

12

$

17

$

24

Interest expense

(33)

(9)
—

(1)

(14)
(8)

(6) Other non-interest expense

Interest income

(16)
(60) Other non-interest expense

Total

$ (30) $

(6) $ (58)

Gain or (Loss) Recognized in
Income on Related Hedged Item

2016

2015

2014

(In millions)

$

$

(3) $
32

—
(2)
27

$

4

1

—
6

11

$

$

19

9

—
51

79

Effective Portion(3)

Gain or (Loss) Recognized in 
AOCI(1)

Location of Amounts Reclassified
from AOCI into Income

Gain or (Loss) Reclassified from 
AOCI into Income(2)

2016

2015

2014

(In millions)

2016

2015

2014

(In millions)

Cash Flow Hedges:

Interest rate swaps

Forward starting swaps

Total

$

$

(64) $

—

(64) $

42

—

42

$

$

15

3

18

Interest income on loans

Interest expense on debt

$

$

143

—

143

$

$

153

—

153

$

$

131
(5)
126

____
(1) After-tax
(2) Pre-tax
(3) All cash flow hedges were highly effective for all periods presented, and the change in fair value attributed to hedge ineffectiveness was not 
material.

DERIVATIVES NOT DESIGNATED AS HEDGING INSTRUMENTS

The Company holds a portfolio of interest rate swaps, option contracts, and futures and forward commitments that result 
from transactions with its commercial customers in which they manage their risks by entering into a derivative with Regions. The 
Company monitors and manages the net risk in this customer portfolio and enters into separate derivative contracts in order to 
reduce the overall exposure to pre-defined limits.  For both derivatives with its end customers and derivatives Regions enters into 
to mitigate the risk in this portfolio, the Company is subject to market risk and the risk that the counterparty will default.  The 
contracts in this portfolio are not designated as accounting hedges and are marked-to market through earnings (in capital markets 
fee income and other) and included in other assets and other liabilities, as appropriate.

Regions enters into interest rate lock commitments, which are commitments to originate mortgage loans whereby the interest 
rate on the loan is determined prior to funding and the customers have locked into that interest rate. At December 31, 2016 and 
2015, Regions had $274 million and $322 million, respectively, in total notional amount of interest rate lock commitments. Regions 
manages  market  risk  on  interest  rate  lock  commitments  and  mortgage  loans  held  for  sale  with  corresponding  forward  sale 
commitments. Residential mortgage loans held for sale are recorded at fair value with changes in fair value recorded in mortgage 
income. Commercial mortgage loans held for sale are recorded at the lower of cost or market or at fair value based on management's 
election. At December 31, 2016 and 2015, Regions had $786 million and $666 million, respectively, in total notional amount 
related to these forward sale commitments. Changes in mark-to-market from both interest rate lock commitments and corresponding 

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forward sale commitments related to residential mortgage loans are included in mortgage income. Changes in mark-to-market 
from both interest rate lock commitments and corresponding forward sale commitments related to commercial mortgage loans are 
included in capital markets fee income and other. 

Regions has elected to account for residential MSRs at fair market value with any changes to fair value being recorded within 
mortgage income. Concurrent with the election to use the fair value measurement method, Regions began using various derivative 
instruments, in the form of forward rate commitments, futures contracts, swaps and swaptions to mitigate the effect of changes in 
the fair value of its residential MSRs on its consolidated statements of income. As of December 31, 2016 and 2015, the total 
notional amount related to these contracts was $7.2 billion and $3.6 billion, respectively.

The following table presents the location and amount of gain or (loss) recognized in income on derivatives not designated 

as hedging instruments in the consolidated statements of income for the years ended December 31:

Derivatives Not Designated as Hedging Instruments

Capital markets fee income and other (1):

Interest rate swaps

Interest rate options

Interest rate futures and forward commitments

Other contracts

Total capital markets fee income and other
Mortgage income:

Interest rate swaps

Interest rate options

Interest rate futures and forward commitments

Total mortgage income

2016

2015

(In millions)

2014

$

$

13

23

4
(3)
37

(2)
(2)
8

4

41

$

$

14

14

3

11

42

13
(1)
3

15

57

$

$

12

—
(1)
13

24

35

1

2

38

62

______
(1) Capital markets fee income and other is included in Other income on the consolidated statements of income.

Credit risk, defined as all positive exposures not collateralized with cash or other assets or reserved for, at December 31, 
2016 and 2015, totaled approximately $334 million and $406 million, respectively. This amount represents the net credit risk on 
all trading and other derivative positions held by Regions.

CREDIT DERIVATIVES

Regions has both bought and sold credit protection in the form of participations on interest rate swaps (swap participations). 
These swap participations, which meet the definition of credit derivatives, were entered into in the ordinary course of business to 
serve the credit needs of customers. Credit derivatives, whereby Regions has purchased credit protection, entitle Regions to receive 
a payment from the counterparty if the customer fails to make payment on any amounts due to Regions upon early termination of 
the swap transaction and have maturities between 2017 and 2023. Credit derivatives whereby Regions has sold credit protection 
have maturities between 2017 and 2025. For contracts where Regions sold credit protection, Regions would be required to make 
payment to the counterparty if the customer fails to make payment on any amounts due to the counterparty upon early termination 
of the swap transaction. Regions bases the current status of the prepayment/performance risk on bought and sold credit derivatives 
on recently issued internal risk ratings consistent with the risk management practices of unfunded commitments.

Regions’ maximum potential amount of future payments under these contracts as of December 31, 2016 was approximately 
$122 million. This scenario would only occur if variable interest rates were at zero percent and all counterparties defaulted with 
zero recovery. The fair value of sold protection at December 31, 2016 and 2015 was immaterial. In transactions where Regions 
has sold credit protection, recourse to collateral associated with the original swap transaction is available to offset some or all of 
Regions’ obligation.

Regions has bought credit protection in the form of credit default indices. These indices, which meet the definition of credit 
derivatives, were entered into in the ordinary course of business to economically hedge credit spread risk in commercial mortgage 
loans held for sale whereby the fair value option has been elected. Credit derivatives, whereby Regions has purchased credit 
protection, entitle Regions to receive a payment from the counterparty if losses on the underlying index exceed a certain threshold, 
dependent upon the tranche rating of the capital structure.

156

 
Table of Contents 

CONTINGENT FEATURES

Certain of Regions’ derivative instrument contracts with broker-dealers contain credit-related termination provisions and/or 
credit related provisions regarding the posting of collateral, allowing those broker-dealers to terminate the contracts in the event 
that Regions’ and/or Regions Bank’s credit ratings fall below specified ratings from certain major credit rating agencies. The 
aggregate fair value of all derivative instruments with any credit-risk-related contingent features that were in a liability position 
on December 31, 2016 and 2015, was $141 million and $180 million, respectively, for which Regions had posted collateral of 
$141 million and $180 million, respectively, in the normal course of business.

OFFSETTING

Regions  engages  in  derivatives  transactions  with  dealers  and  customers.  These  derivatives  transactions  are  subject  to 
enforceable master netting agreements, which include a right of setoff by the non-defaulting or non-affected party upon early 
termination  of  the  derivatives  transaction.  The  following  table  presents  the  Company's  gross  derivative  positions,  including 
collateral posted or received, as of December 31, 2016 and 2015. 

Offsetting Derivative Assets

Offsetting Derivative Liabilities

2016

2015

2016

2015

Gross amounts subject to offsetting

Gross amounts not subject to offsetting

$

Gross amounts recognized
Gross amounts offset in the consolidated balance sheets(1)
Net amounts presented in the consolidated balance sheets

Gross amounts not offset in the consolidated balance sheets:

Financial instruments

Cash collateral received/posted

$

414

165

579

241

338

4

—

(In millions)

$

718

108

826

409

417

5

6

$

583

304

887

541

346

50

227

Net amounts

$

334

$

406

$

69

$

677

81

758

558

200

50

52

98

_________
(1) At December 31, 2016, gross amounts of derivative assets and liabilities offset in the consolidated balance sheets presented above include 
cash collateral received of $349 million and cash collateral posted of $48 million. At December 31, 2015, the gross amounts of derivative assets 
and liabilities offset in the consolidated balance sheets presented above include cash collateral received of $108 million and cash collateral posted 
of $256 million.

Gross amounts of derivatives not subject to offsetting primarily consist of derivatives cleared through a Central Clearing 

House and interest rate lock commitments to originate mortgage loans.

157

Table of Contents 

NOTE 22. FAIR VALUE MEASUREMENTS 

See Note 1 for a description of valuation methodologies for assets and liabilities measured at fair value on a recurring and 
non-recurring basis. Assets and liabilities measured at fair value rarely transfer between Level 1 and Level 2 measurements. There 
were no such transfers during the years ended December 31, 2016, 2015, or 2014. Trading account securities and securities available 
for sale may be periodically transferred to or from Level 3 valuation based on management’s conclusion regarding the observability 
of inputs used in valuing the securities. Such transfers are accounted for as if they occur at the beginning of a reporting period.The 
following table presents assets and liabilities measured at estimated fair value on a recurring basis and non-recurring basis as of 
December 31: 

2016

2015

Level 1

Level 2

Level 3

Total
Estimated 
Fair Value

Level 1

Level 2

Level 3

Total
Estimated 
Fair Value

(In millions)

— $

— $

124

— $

33

$

143

— $

— $

— $

— $

Recurring fair value measurements

Trading account securities

Securities available for sale:

U.S. Treasury securities

Federal agency securities

Obligations of states and
political subdivisions
Mortgage-backed securities:

Residential agency

Residential non-agency

Commercial agency

Commercial non-agency

Corporate and other debt
securities
Equity securities

Total securities available for sale

Mortgage loans held for sale

Residential mortgage servicing rights

Derivative assets:

Interest rate swaps

Interest rate options

Interest rate futures and forward
commitments
Other contracts

Total derivative assets

Derivative liabilities:

Interest rate swaps

Interest rate options

Interest rate futures and forward
commitments
Other contracts

Total derivative liabilities

Non-recurring fair value measurements

Loans held for sale

Foreclosed property and other real
estate

$

$

$

$

$

$

$

$

$

$

— $

324

— $

— $

353

— $

— $

252

$

— $

438

$

— $

— $

610

$

— $

$

$

$

$

$

$

$

$

$

$

110

228

$

$

—

—

—

—

—

—

—

280

508

218

1

16,062

—

3,018

1,231

1,664

—

$

22,194

228

218

1

16,062

5

3,018

1,231

1,667

280

$

22,710

—

—

—

5

—

—

3

—

8

$

$

$

$

—

—

—

— $

1

5

200

816

— $

564

—

—

—

— $

1

6

187

758

10

—

—

10

$

—

—

—

$

— $

— $

— $

36

$

—

30

8

353

252

610

11

5

200

826

1

6

187

758

36

38

— $

776

— $

564

124

303

$

$

—

—

—

—

—

—

—

201

504

35

1

17,371

—

3,463

1,129

1,271

—

$

23,270

— $

— $

414

—

—

—

4

—

—

3

—

7

33

$

$

—

—

2

2

$

13

11

104

566

— $

776

$

$

$

$

$

11

—

—

11

$

303

35

1

17,371

4

3,463

1,129

1,274

201

23,781

447

324

438

24

11

106

579

—

—

1

1

12

6

92

—

—

—

12

6

93

$

886

$

— $

887

— $

— $

—

29

$

7

6

7

35

158

 
 
 
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Assets and liabilities in all levels could result in volatile and material price fluctuations. Realized and unrealized gains and 
losses on Level 3 assets represent only a portion of the risk to market fluctuations in Regions’ consolidated balance sheets. Further, 
derivatives included in Levels 2 and 3 are used by ALCO in a holistic approach to managing price fluctuation risks.

The following tables illustrate rollforwards for all assets and liabilities measured at fair value on a recurring basis using 
significant unobservable inputs (Level 3) for the years ended December 31, 2016, 2015 and 2014, respectively. The tables do not 
reflect the change in fair value attributable to any related economic hedges the Company used to mitigate the interest rate risk 
associated with these assets and liabilities. The net changes in realized gains (losses) included in earnings related to Level 3 assets 
and liabilities held at December 31, 2016, 2015 and 2014 are not material.

Year Ended December 31, 2016

Total Realized /
Unrealized
Gains or Losses

Opening
Balance
January 1,
2016

Included
in
Earnings

Included
in Other
Compre-
hensive
Income
(Loss)

Level 3 Instruments Only

Trading account securities

Securities available for sale:

Residential non-agency
MBS

Corporate and other debt
securities

Total securities available for
sale

Commercial mortgage loans
held for sale

Residential mortgage
servicing rights

Total derivatives, net

$

$

$

$

$

$

33

5

3

8

—

252

10

(1) 

(2)

—   

—

—   

(1) 

(2) 

(3) 

(2)

(36)

122

—

—

—

—

—

—

—

Total Realized /
Unrealized
Gains or Losses

Opening
Balance
January 1,
2015

Included
in 
Earnings

Included
in Other
Compre-
hensive
Income
(Loss)

Level 3 Instruments Only

Trading account securities

Securities available for sale:

Residential non-agency
MBS

Corporate and other debt
securities

Total securities available for
sale

Residential mortgage
servicing rights

Total derivatives, net

$

$

$

$

$

—

8

3

11

257

8

(1)

(4)

—

—

—

(2) 

(4)

(41)

105

—

—

—

—

—

—

Purchases

Sales

Issuances

Settlements

(In millions)

Transfers
into
Level 3

Transfers
out of
Level 3

Closing
Balance
December 
31, 2016

—

—

—

—

—

108

—

(31)

—

—

—

(55)

—

—

—

—

—

—

90

—

—

—

(1)

—

(1)

—

—

(121)

—

—

—

—

—

—

—

— $

—

— $

—

— $

— $

— $

— $

4

3

7

33

324

11

Year Ended December 31, 2015

Purchases

Sales

Issuances

Settlements

(In millions)

Transfers
into
Level 3

Transfers
out of
Level 3

Closing
Balance
December
31, 2015

(8)

—

—

—

—

—

—

—

—

—

—

—

—

(3)

—

(3)

—

(103)

—

—

—

—

—

—

— $

33

— $

—

— $

— $

— $

5

3

8

252

10

45

—

—

—

36

—

159

 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
Table of Contents 

Year Ended December 31, 2014

Total Realized /
Unrealized
Gains or Losses

Opening
Balance
January 1,
2014

Included
in 
Earnings

Included
in Other
Compre-
hensive
Income
(Loss)

Purchases

Sales

Issuances

Settlements

(In millions)

Transfers
into
Level 3

Transfers
out of
Level 3

Closing
Balance
December
31, 2014

Level 3 Instruments Only

Securities available for sale:

Residential non-agency
MBS

Corporate and other debt
securities

Total securities available for
sale

Residential mortgage
servicing rights

Total derivatives, net

$

$

$

$

9

2

11

297

5

—   

—   

—   

(2) 

(2) 

(80)

93

—

—

—

—

—

—

4

4

40

—

—

—

—

—

—

—

—

—

—

—

(1)

(3)

(4)

—

(90)

—

—

—

—

—

— $

—

— $

— $

— $

8

3

11

257

8

_________
(1) Included in capital markets fee income and other, which is included in other non-interest income on the consolidated statements of income.
(2) Included in mortgage income.
(3) For 2016, approximately $23 million was included in capital markets fee income and other and $99 million was included in mortgage income.
(4) For 2015, approximately $10 million was included in capital markets fee income and other and $95 million was included in mortgage income.

The following table presents the fair value adjustments related to non-recurring fair value measurements for the years ended 

December 31:

Loans held for sale

Foreclosed property and other real estate

2016

2015

$

(In millions)
(26) $
(42)

(40)
(7)

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The following tables present detailed information regarding assets and liabilities measured at fair value using significant 
unobservable inputs (Level 3) as of December 31, 2016, 2015 and 2014. The tables include the valuation techniques and the 
significant unobservable inputs utilized. The range of each significant unobservable input as well as the weighted-average within 
the range utilized at December 31, 2016, 2015 and 2014 are included. Following the tables are a description of the valuation 
techniques and the sensitivity of the techniques to changes in the significant unobservable inputs. 

Level 3
Estimated Fair 
Value at
December 31, 2016

Valuation
Technique

December 31, 2016

Unobservable
Input(s)

(Dollars in millions)

Quantitative Range of
Unobservable Inputs and
(Weighted-Average)

Recurring fair value
measurements:

Securities available for sale:

Residential non-agency
MBS

Corporate and other debt
securities

Commercial mortgage loans
held for sale

Residential mortgage 
servicing rights (1)

$4

Discounted cash flow

Spread to LIBOR

5.5% - 70.0% (23.0%)

Weighted-average CPR (%)

3.5% - 29.5% (12.2%)

$3

Market comparable

Market comparable

$33

$324

Probability of default

Loss severity

Evaluated quote on same issuer/comparable
bond

Credit spreads for bonds in the commercial
MBS

3.1%

63.6%

100.3%

0.4% - 5.8% (1.3%)

5.7% - 24.3% (7.6%)

Discounted cash flow

Weighted-average CPR (%)

Derivative assets:

Interest rate options

$8

Non-recurring fair value
measurements:

Loans held for sale

Foreclosed property and
other real estate

$3

$7

$1

$5

Interest rate lock
commitments on the
residential mortgage
loans are valued
using discounted cash
flows

Interest rate lock
commitments on the
commercial mortgage
loans are valued
using discounted cash
flows

Commercial loans
held for sale are
valued based on
multiple data points,
including discount to
appraised value of
collateral based on
recent market activity
for sales of similar
loans

Property in
foreclosure is valued
by discount to
appraised value of
property based on
recent market activity
for sales of similar
properties

Bank owned property
valuations are based
on comparable sales
and local broker
network estimates
provided by a third-
party real estate
services provider

OAS (%)

8.2% - 13.6% (10.5%)

Weighted-average CPR (%)

5.7% - 24.3% (7.6%)

OAS (%)

Pull-through

Internal rate of return

8.2% - 13.6% (10.5%)

14.9% - 99.4% (78.3%)

7.0% - 17.0% (12.0%)

Appraisal comparability adjustment (discount)

26.2% - 69.4% (48.1%)

 Appraisal comparability adjustment (discount)

25.0% - 60.3% (37.0%)

Estimated third-party valuations utilizing
available sales data for similar transactions
(discount)

5.9% - 29.6% (15.8%)

161

 
 
 
Table of Contents 

Recurring fair value
measurements:

Level 3
Estimated Fair 
Value at
December 31, 2015

December 31, 2015

Valuation
Technique

Unobservable
Input(s)

(Dollars in millions)

Quantitative Range of
Unobservable Inputs and
(Weighted-Average)

Trading account securities

$33

Market comparable

Spread from US High Yield B Effective Yield
Index

4.7%

Securities available for sale:

Residential non-agency
MBS

$5

Discounted cash flow

Spread to LIBOR

5.5% - 70.1% (23.0%)

Corporate and other debt
securities

Residential mortgage 
servicing rights (1)

$3

$252

Derivative assets:

Interest rate options

$9

$1

Non-recurring fair value
measurements:

Loans held for sale

$36

Foreclosed property and
other real estate

$5

$3

Weighted-average CPR (%)

5.6% - 11.9% (9.9%)

Probability of default

Loss severity

Market comparable

Evaluated quote on same issuer/comparable
bond

2.2%

74.3%

100.2%

Discounted cash flow

Weighted-average CPR (%)

10.5% - 11.5% (10.9%)

OAS (%)

8.7% - 13.3% (10.0%)

Weighted-average CPR (%)

10.5% - 11.5% (10.9%)

OAS (%)

Pull-through

8.7% - 13.3% (10.0%)

18.9% - 99.4% (80.7%)

Internal rate of return

12.0%

Appraisal comparability adjustment (discount)

11.1% - 85.7% (69.0%)

 Appraisal comparability adjustment (discount)

25.0% - 44.0% (30.3%)

Estimated third-party valuations utilizing
available sales data for similar transactions
(discount)

3.0% - 58.8% (39.2%)

Interest rate lock
commitments on the
residential mortgage
loans are valued
using discounted cash
flows

Interest rate lock
commitments on the
commercial mortgage
loans are valued
using discounted cash
flows

Commercial loans
held for sale are
valued based on
multiple data points,
including discount to
appraised value of
collateral based on
recent market activity
for sales of similar
loans

Property in
foreclosure is valued
by discount to
appraised value of
property based on
recent market activity
for sales of similar
properties

Bank owned property
valuations are based
on comparable sales
and local broker
network estimates
provided by a third-
party real estate
services provider

162

 
 
 
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Recurring fair value
measurements:

Securities available for sale:

Residential non-agency
MBS

Level 3
Estimated Fair
Value at
December 31, 2014

Valuation
Technique

December 31, 2014

Unobservable
Input(s)

(Dollars in millions)

Quantitative Range of
Unobservable Inputs and
(Weighted-Average)

$8

Discounted cash flow

Spread to LIBOR

5.4% - 49.9% (12.3%)

Corporate and other debt
securities

Residential mortgage 
servicing rights (1)

$3

$257

Derivative assets:

Weighted-average CPR (%)

6.3% - 15.0% (9.5%)

Probability of default

Loss severity

Market comparable

Evaluated quote on same issuer/comparable
bond

1.4%

37.4%

99.9% 

Discounted cash flow

Weighted-average CPR (%)

9.9% - 22.4% (12.0%)

OAS (%)

7.7% - 11.3% (9.0%)

Interest rate options

$8

Discounted cash flow

Weighted-average CPR (%)

9.9% - 22.4% (12.0%)

Non-recurring fair value
measurements:

Loans held for sale

$33

Foreclosed property and
other real estate

$8

Commercial loans
held for sale are
valued based on
multiple data points,
including discount to
appraised value of
collateral based on
recent market activity
for sales of similar
loans

Property in
foreclosure is valued
by discount to
appraised value of
property based on
recent market activity
for sales of similar
properties

OAS (%)

Pull-through

7.7% - 11.3% (9.0%)

7.3% - 99.1% (87.8%)

Appraisal comparability adjustment (discount)

8.3% - 90.9% (53.3%)

 Appraisal comparability adjustment (discount)

3.7% - 73.0% (29.6%)

_________
(1) See Note 7 for additional disclosures related to assumptions used in the fair value calculation for residential MSRs.

RECURRING FAIR VALUE MEASUREMENTS USING SIGNIFICANT UNOBSERVABLE INPUTS

Trading account securities

        The fair value in this category relates to high yield corporate securities. Significant unobservable inputs include the spread 
to High Yield Index. A significant increase in this input would result in significantly lower fair value measurement.

Securities available for sale

Residential non-agency MBS—The fair value reported in this category relates to retained interests in legacy securitizations. 
Significant unobservable inputs include the spread to LIBOR, CPR, probability of default, and loss severity in the event of default. 
Significant increases in spread to LIBOR, probability of default and loss given default in isolation would result in significantly 
lower fair value. A significant increase in CPR in isolation would result in an increase to fair value. 

Corporate and other debt securities—Significant unobservable inputs include evaluated quotes on comparable bonds for 
the same issuer and management-determined comparability adjustments. Changes in the evaluated quote on comparable bonds 
would result in a directionally similar change in the fair value of the corporate and other debt securities.

163

 
 
 
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Commercial mortgage loans held for sale

Commercial mortgage loans held for sale are valued based on traded market prices for comparable commercial mortgage-
backed securitizations, into which the loans will be placed, adjusted for movements of interest rates and credit spreads. Significant 
unobservable inputs include credit spreads for bonds in commercial mortgage-backed securitizations. An increase in credit spreads 
would result in a decrease in fair value. 

Residential mortgage servicing rights

The significant unobservable inputs used in the fair value measurement of residential MSRs are OAS and CPR. This valuation 
requires generating cash flow projections over multiple interest rate scenarios and discounting those cash flows at a risk adjusted 
rate. Additionally, the impact of prepayments and changes in the OAS are based on a variety of underlying inputs such as servicing 
costs. Increases or decreases to the underlying cash flow inputs will have a corresponding impact on the value of the MSR asset. 
The net change in unrealized gains (losses) included in earnings related to MSRs held at period end are disclosed as the changes 
in valuation inputs or assumptions included in the MSR rollforward table in Note 7. See Note 7 for these amounts and additional 
disclosures related to assumptions used in the fair value calculation for MSRs.

Derivative assets

Residential mortgage interest rate options—These instruments are interest rate lock agreements made in the normal course 
of originating residential mortgage loans. Significant unobservable inputs in the fair value measurement are OAS, CPR, and pull-
through. The impact of OAS and prepayment speed inputs in the valuation of these derivative instruments are consistent with the 
MSR discussion above. Pull-through is an estimate of the number of interest rate lock commitments that will ultimately become 
funded loans. Increases or decreases in the pull-through assumption will have a corresponding impact on the value of these derivative 
assets.

Commercial mortgage interest rate options—These instruments are interest rate lock agreements made in the normal course 
of originating commercial mortgage loans. The significant unobservable input in the fair value measurement using discounted 
cash flows is the internal rates of return. The Company's internal rates of return are compared against those of market competitors, 
and should those rates change the Company's rates would also change in a similar direction and the fair value of the option would 
change inversely.

NON-RECURRING FAIR VALUE MEASUREMENTS USING SIGNIFICANT UNOBSERVABLE INPUTS

Loans held for sale

Commercial loans held for sale are valued based on multiple data points indicating the fair value for each loan. The primary 
data point for loans held for sale is a discount to the appraised value of the underlying collateral, which considers the return required 
by potential buyers of the loans. Management establishes this discount or comparability adjustment based on recent sales of loans 
secured by similar property types. As liquidity in the market increases or decreases, the comparability adjustment and the resulting 
asset valuation are impacted. These non-recurring fair value measurements are typically recorded on the date an updated appraisal 
is received. 

Foreclosed property and other real estate

Property in foreclosure is valued based on offered quotes as available. If no sales contract is pending for a specific property, 
management establishes a comparability adjustment to the appraised value based on historical activity considering proceeds for 
properties  sold  versus  the  corresponding  appraised  value.  Increases  or  decreases  in  realization  for  properties  sold  impact  the 
comparability adjustment for similar assets remaining on the balance sheet. These non-recurring fair value measurements are 
typically recorded on the date an updated offered quote or appraisal is received. 

Bank owned property available for sale is valued based on estimated third-party valuations utilizing recent sales data from 
similar transactions. A broker's opinion of value is obtained to further support the asset valuations. Updated valuations along with 
actual sales results of similar properties can further impact these values. These non-recurring fair value measurements are typically 
recorded on the date an updated third-party valuation is received. 

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Table of Contents 

FAIR VALUE OPTION

Regions has elected the fair value option for all FNMA and FHLMC eligible residential mortgage loans and certain commercial 
mortgage loans originated with the intent to sell. These elections allow for a more effective offset of the changes in fair values of 
the loans and the derivative instruments used to economically hedge them without the burden of complying with the requirements 
for hedge accounting. Regions has not elected the fair value option for other loans held for sale primarily because they are not 
economically hedged using derivative instruments. Fair values of residential mortgage loans held for sale are based on traded 
market prices of similar assets where available and/or discounted cash flows at market interest rates, adjusted for securitization 
activities that include servicing values and market conditions, and are recorded in loans held for sale in the consolidated balance 
sheets. Fair values of commercial mortgage loans held for sale are based on traded market prices for comparable commercial 
mortgage-backed securitizations, into which the loans will be placed, adjusted for movements of interest rates and credit spreads.

The following table summarizes the difference between the aggregate fair value and the aggregate unpaid principal balance 

for mortgage loans held for sale measured at fair value at December 31:

2016

Aggregate
Unpaid
Principal

Aggregate
Fair Value

Aggregate Fair
Value Less
Aggregate
Unpaid
Principal

Aggregate
Fair Value

(In millions)

2015

Aggregate
Unpaid
Principal

Aggregate Fair
Value Less
Aggregate
Unpaid
Principal

Mortgage loans held for sale, at fair value $

447

$

443

$

4

$

353

$

341

$

12

Interest income on mortgage loans held for sale is recognized based on contractual rates and is reflected in interest income 
on loans held for sale in the consolidated statements of income. The following table details net gains and losses resulting from 
changes in fair value of these loans, which were recorded in mortgage income in the consolidated statements of income for the 
years presented. These changes in fair value are mostly offset by economic hedging activities. An immaterial portion of these 
amounts was attributable to changes in instrument-specific credit risk.

Net gains (losses) resulting from changes in fair value

2016

2015

$

(In millions)
(8) $

(8)

The carrying amounts and estimated fair values, as well as the level within the fair value hierarchy, of the Company’s financial 

instruments as of December 31, 2016 are as follows: 

Carrying
Amount

Estimated
Fair
Value(1)

2016

Level 1

Level 2

Level 3

(In millions)

Financial assets:

Cash and cash equivalents

Trading account securities

Securities held to maturity

Securities available for sale

Loans held for sale

$

5,451

$

5,451

$

5,451

$

124

1,362

23,781

718

124

1,369

23,781

722

Loans (excluding leases), net of unearned income and allowance for 
loan losses(2)(3)

78,128

74,063

Other earning assets(4)

Derivative assets

Financial liabilities:

Derivative liabilities

Deposits

Long-term borrowings

Loan commitments and letters of credit

Indemnification obligation

956

579

887

99,081

8,008

484

26

956

579

887

99,035

7,763

102

28

165

— $

—

1,369

23,270

689

—

956

566

886

99,081

5,408

—

—

—

—

—

7

33

74,063

—

11

—

—

2,600

484

26

124

—

504

—

—

—

2

1

—

—

—

—

 
 
 
 
 
 
 
 
Table of Contents 

_________
(1)  Estimated fair values are consistent with an exit price concept. The assumptions used to estimate the fair values are intended to approximate 
those that a market participant would use in a hypothetical orderly transaction. In estimating fair value, the Company makes adjustments 
for interest rates, market liquidity and credit spreads as appropriate.

(2)  The estimated fair value of portfolio loans assumes sale of the loans to a third-party financial investor. Accordingly, the value to the Company 
if the loans were held to maturity is not reflected in the fair value estimate. In the current whole loan market, financial investors are generally 
requiring a higher rate of return than the return inherent in loans if held to maturity. The fair value discount on the loan portfolio's net 
carrying amount at December 31, 2016 was $4.1 billion or 5.2 percent.

(3)  Excluded from this table is the capital lease carrying amount of $876 million at December 31, 2016.
(4)  Excluded from this table is the operating lease carrying amount of $688 million at December 31, 2016.

The carrying amounts and estimated fair values, as well as the level within the fair value hierarchy, of the Company's financial 

instruments as of December 31, 2015 are as follows:

Financial assets:

Cash and cash equivalents

Trading account securities

Securities held to maturity

Securities available for sale

Loans held for sale

Loans (excluding leases), net of unearned income and allowance for 
loan losses(2)(3)
Other earning assets (4)

Derivative assets

Financial liabilities:

Derivative liabilities

Deposits

Short-term borrowings

Long-term borrowings

Loan commitments and letters of credit

Indemnification obligation

Carrying
Amount

Estimated
Fair
Value(1)

$

$

5,314
143
1,946
22,710
448

79,140
818
826

758
98,430
10
8,349
85
77

5,314
143
1,969
22,710
448

75,399
818
826

758
98,464
10
8,615
495
67

2015

Level 1

Level 2

Level 3

(In millions)

$

$

5,314
110
1
508
—

— $
—
1,968
22,194
353

—
—
—

—
—
—
—
—
—

—
818
816

758
98,464
10
5,775
—
—

—
33
—
8
95

75,399
—
10

—
—
—
2,840
495
67

_________
(1)  Estimated fair values are consistent with an exit price concept. The assumptions used to estimate the fair values are intended to approximate 
those that a market participant would use in a hypothetical orderly transaction. In estimating fair value, the Company makes adjustments 
for interest rates, market liquidity and credit spreads as appropriate.

(2)  The estimated fair value of portfolio loans assumes sale of the loans to a third-party financial investor. Accordingly, the value to the Company 
if the loans were held to maturity is not reflected in the fair value estimate. In the current whole loan market, financial investors are generally 
requiring a higher rate of return than the return inherent in loans if held to maturity. The fair value discount on the loan portfolio's net 
carrying amount at December 31, 2015 was $3.7 billion or 4.7 percent.

(3)  Excluded from this table is the capital lease carrying amount of $916 million at December 31, 2015.
(4)  Excluded from this table is the operating lease carrying amount of $834 million at December 31, 2015.

166

 
 
 
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NOTE 23. BUSINESS SEGMENT INFORMATION 

Each of Regions’ reportable segments is a strategic business unit that serves specific needs of Regions’ customers based on 
the products and services provided. The segments are based on the manner in which management views the financial performance 
of the business. The Company has three reportable segments: Corporate Bank, Consumer Bank, and Wealth Management, with 
the remainder split between Discontinued Operations and Other. During the first quarter of 2016, Regions reorganized its internal 
management  structure  and,  accordingly,  its  segment  reporting  structure.  Under  the  organizational  realignment,  Regions  will 
continue to operate with the same three reporting units with the Relationship Management component of Business Banking moving 
to the Corporate Bank and the Branch Small Business component of Business Banking remaining part of the Consumer Bank. 
Previously,  all  of  Business  Banking  was  included  within  the  Consumer  Bank.  The  Wealth  Management  segment  remained 
unchanged during the organizational realignment. Additionally, in prior years the provision for loan losses was allocated to each 
segment based on actual net charge-offs that had been recognized by the segment. During the first quarter of 2016, Regions began 
allocating the provision for loan losses to each segment using an estimated loss methodology with the difference between the 
consolidated provision for loan losses and the segments’ estimated loss reflected in Other. Lastly, allocations of operational and 
overhead cost pools among the segments were modified during the first quarter of 2016 to better align the total costs to support 
each segment in accordance with the reorganized management structure. Segment results for all periods presented have been recast 
to reflect this organizational realignment, as well as the provision for loan losses methodology change and the cost allocation 
modifications. 

The application and development of management reporting methodologies is a dynamic process and is subject to periodic 
enhancements. As  these  enhancements  are  made,  financial  results  presented  by  each  reportable  segment  may  be  periodically 
revised. 

The Corporate Bank segment represents the Company’s commercial banking functions including commercial and industrial, 
commercial real estate and investor real estate lending. This segment also includes equipment lease financing. Corporate Bank 
customers include corporate, middle market, and commercial real estate developers and investors. Corresponding deposit products 
related to these types of customers are also included in this segment.

The Consumer Bank segment represents the Company’s branch network, including consumer banking products and services 
related to residential first mortgages, home equity lines and loans, small business loans, indirect loans, consumer credit cards and 
other consumer loans, as well as the corresponding deposit relationships. These services are also provided through alternative 
channels such as the internet and telephone banking. 

The Wealth Management segment offers individuals, businesses, governmental institutions and non-profit entities a wide 
range  of  solutions  to  help  protect,  grow  and  transfer  wealth.  Offerings  include  credit  related  products,  trust  and  investment 
management, asset management, retirement and savings solutions, estate planning and personal and commercial insurance products. 

Discontinued Operations includes all brokerage and investment activities associated with Morgan Keegan. As discussed in 

Note 3, Regions closed the sale of Morgan Keegan and related entities on April 2, 2012. 

Other includes the Company’s Treasury function, the securities portfolio, wholesale funding activities, interest rate risk 
management activities and other corporate functions that are not related to a strategic business unit. Also within Other are certain 
reconciling items in order to translate the segment results that are based on management accounting practices into consolidated 
results. Management accounting practices utilized by Regions as the basis of presentation for segment results include the following:

•  Net interest income and other financing income is presented based upon an FTP approach, for which market-based funding 
charges/credits  are  assigned  within  the  segments.  By  allocating  a  cost  or  a  credit  to  each  product  based  on  the  FTP 
framework, management is able to more effectively measure the net interest margin contribution of its assets/liabilities 
by segment. The summation of the interest income/expense and FTP charges/credits for each segment is its designated 
net  interest  income  and  other  financing  income. The  variance  between  the  Company’s  cumulative  FTP  charges  and 
cumulative FTP credits is offset in Other.

• 

• 

Provision for loan losses is allocated to each segment based on an estimated loss methodology. The difference between 
the consolidated provision for loan losses and the segments’ estimated loss is reflected in Other. 

Income tax expense (benefit) is calculated for the Corporate Bank, Consumer Bank and Wealth Management based on a 
consistent federal and state statutory rate. Discontinued Operations reflects the actual income tax expense (benefit) of its 
results. Any difference between the Company’s consolidated income tax expense (benefit) and the segments’ calculated 
amounts is reflected in Other. 

•  Management reporting allocations of certain expenses are made in order to analyze the financial performance of the 
segments. These allocations consist of operational and overhead cost pools and are intended to represent the total costs 
to support a segment.

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Table of Contents 

The following tables present financial information for each reportable segment for the year ended December 31:

Corporate
Bank

Consumer
Bank

Wealth
Management

2016

Other

(In millions)

Continuing
Operations

Discontinued
Operations

Consolidated

$

1,448

$

2,045

$

175

$

(270) $

3,398

$

— $

3,398

286

485

854

793

301

492

54,002

$

$

290

1,126

2,075

806

306

500

34,597

$

$

$

$

22

427

467

113

43

70

3,232

(336)
115

221

262

2,153

3,617

(40)

1,672

(136)
96

33,675

$

$

514

1,158

125,506

$

$

$

$

—

—
(8)

8

3

5

$

262

2,153

3,609

1,680

517

1,163

— $

125,506

Corporate
Bank

Consumer
Bank

Wealth
Management

2015

Other

(In millions)

Continuing
Operations

Discontinued
Operations

Consolidated

$

1,512

$

2,018

$

167

$

(390) $

3,307

$

— $

3,307

301
435
882

764

276
1,074
2,067

749

22
408
455

98

(358)
154
203

241
2,071
3,607

—
—
22

241
2,071
3,629

(81)

1,530

(22)

1,508

291
473
53,307

$
$

285
464
33,415

$
$

$
$

37
61
3,185

$
$

(158)
77
32,358

$
$

455
1,075
122,265

$
$

(9)
(13) $
— $

446
1,062
122,265

Corporate
Bank

Consumer
Bank

Wealth
Management

2014

Other

(In millions)

Continuing
Operations

Discontinued
Operations

Consolidated

$

1,537

$

2,010

$

164

$

(431) $

3,280

$

— $

3,280

294
388
832

799

261
1,073
2,044

778

21
368
421

90

(507)
74
135

15

69
1,903
3,432

1,682

—
19
(2)

21

69
1,922
3,430

1,703

304
495
52,073

$
$

296
482
32,890

$
$

$
$

35
55
3,122

$
$

(87)
102
30,267

$
$

548
1,134
118,352

$
$

8
13
$
— $

556
1,147
118,352

Net interest income and
other financing income
(loss)

Provision (credit) for loan
losses

Non-interest income

Non-interest expense

Income (loss) before
income taxes

Income tax expense
(benefit)

Net income (loss)

Average assets

Net interest income and
other financing income
(loss)

Provision (credit) for
loan losses
Non-interest income
Non-interest expense

Income (loss) before
income taxes

Income tax expense
(benefit)
Net income (loss)
Average assets

Net interest income and
other financing income
(loss)

Provision (credit) for
loan losses
Non-interest income
Non-interest expense
Income (loss) before
income taxes

Income tax expense
(benefit)
Net income (loss)
Average assets

168

 
 
 
 
 
 
 
 
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NOTE 24. COMMITMENTS, CONTINGENCIES AND GUARANTEES 

COMMERCIAL COMMITMENTS

Regions issues off-balance sheet financial instruments in connection with lending activities. The credit risk associated with 
these instruments is essentially the same as that involved in extending loans to customers and is subject to Regions’ normal credit 
approval policies and procedures. Regions measures inherent risk associated with these instruments by recording a reserve for 
unfunded commitments based on an assessment of the likelihood that the guarantee will be funded and the creditworthiness of the 
customer or counterparty. Collateral is obtained based on management’s assessment of the creditworthiness of the customer.

Credit risk associated with these instruments as of December 31 is represented by the contractual amounts indicated in the 

following table:

Unused commitments to extend credit
Standby letters of credit
Commercial letters of credit
Liabilities associated with standby letters of credit
Assets associated with standby letters of credit
Reserve for unfunded credit commitments

$

2016

2015

(In millions)

$

44,408
1,425
46
34
34
69

45,516
1,477
63
32
33
52

Unused commitments to extend credit—To accommodate the financial needs of its customers, Regions makes commitments 
under various terms to lend funds to consumers, businesses and other entities. These commitments include (among others) credit 
card and other revolving credit agreements, term loan commitments and short-term borrowing agreements. Many of these loan 
commitments have fixed expiration dates or other termination clauses and may require payment of a fee. Since many of these 
commitments are expected to expire without being funded, the total commitment amounts do not necessarily represent future 
liquidity requirements.

Standby letters of credit—Standby letters of credit are also issued to customers which commit Regions to make payments 
on behalf of customers if certain specified future events occur. Regions has recourse against the customer for any amount required 
to be paid to a third party under a standby letter of credit. Historically, a large percentage of standby letters of credit expired without 
being funded. The contractual amount of standby letters of credit represents the maximum potential amount of future payments 
Regions could be required to make and represents Regions’ maximum credit risk.

Commercial letters of credit—Commercial letters of credit are issued to facilitate foreign or domestic trade transactions for 

customers. As a general rule, drafts will be drawn when the goods underlying the transaction are in transit.

LEASE COMMITMENTS

Regions and its subsidiaries lease land, premises and equipment under cancelable and non-cancelable leases, some of which 
contain renewal options under various terms. The leased properties are used primarily for banking purposes. Total rental expense 
on operating leases for the years ended December 31, 2016, 2015 and 2014 was $172 million, $174 million and $171 million, 
respectively.

The approximate future minimum rental commitments as of December 31, 2016, for all non-cancelable leases with initial 
or remaining terms of one year or more are shown in the following table. Included in these amounts are all renewal options 
reasonably assured of being exercised.

2017
2018
2019
2020
2021
Thereafter

Premises

Equipment

(In millions)

Total

103
95
90
79
65
263
695

$

$

33
26
7
—
—
—
66

$

$

136
121
97
79
65
263
761

$

$

169

 
 
Table of Contents 

LEGAL CONTINGENCIES

Regions  and  its  subsidiaries  are  subject  to  loss  contingencies  related  to  litigation,  claims,  investigations  and  legal  and 
administrative cases and proceedings arising in the ordinary course of business. Regions evaluates these contingencies based on 
information currently available, including advice of counsel. Regions establishes accruals for those matters when a loss contingency 
is considered probable and the related amount is reasonably estimable. Any accruals are periodically reviewed and may be adjusted 
as circumstances change. Some of Regions' exposure with respect to loss contingencies may be offset by applicable insurance 
coverage. In determining the amounts of any accruals or estimates of possible loss contingencies however, Regions does not take 
into account the availability of insurance coverage. To the extent that Regions has an insurance recovery, the proceeds are recorded 
in the period the recovery is received.

In addition, as previously discussed, Regions has agreed to indemnify Raymond James for all legal matters resulting from 
pre-closing activities in conjunction with the sale of Morgan Keegan and recorded an indemnification obligation at fair value in 
the second quarter of 2012. The indemnification obligation had a carrying amount of approximately $28 million and an estimated 
fair value of approximately $26 million as of December 31, 2016 (see Note 22).

When it is practicable, Regions estimates possible loss contingencies, whether or not there is an accrued probable loss. When 
Regions is able to estimate such possible losses, and when it is reasonably possible Regions could incur losses in excess of amounts 
accrued, Regions discloses the aggregate estimation of such possible losses. Regions currently estimates that any such losses in 
excess of amounts accrued, including legal contingencies that are subject to the indemnification agreement with Raymond James, 
would be immaterial to Regions' financial statements as a whole. However, as available information changes, the matters for which 
Regions is able to estimate, as well as the estimates themselves will be adjusted accordingly.

Assessments of litigation and claims exposure are difficult because they involve inherently unpredictable factors including, 
but not limited to, the following: whether the proceeding is in the early stages; whether damages are unspecified, unsupported, or 
uncertain; whether there is a potential for punitive or other pecuniary damages; whether the matter involves legal uncertainties, 
including novel issues of law; whether the matter involves multiple parties and/or jurisdictions; whether discovery has begun or 
is not complete; whether meaningful settlement discussions have commenced; and whether the lawsuit involves class allegations. 
Assessments of class action litigation, which is generally more complex than other types of litigation, are particularly difficult, 
especially in the early stages of the proceeding when it is not known if a class will be certified or how a potential class, if certified, 
will be defined. As a result, Regions may be unable to estimate reasonably possible losses with respect to some of the matters 
disclosed below, and the losses in excess of amounts accrued discussed above may not include an estimate for every matter disclosed 
below. 

Beginning in December 2007, Regions and certain of its affiliates were named in class-action lawsuits filed in federal and 
state courts on behalf of investors who purchased shares of certain Regions Morgan Keegan Select Funds (the “Funds”) and 
stockholders of Regions. These class-action lawsuits have all been resolved, and final court approvals have been granted. Certain 
of the shareholders in these Funds and other interested parties have entered into arbitration proceedings and individual civil claims, 
in lieu of participating in the class actions. These lawsuits and proceedings are subject to the indemnification agreement with 
Raymond James discussed above.

In July 2006, Morgan Keegan and a former Morgan Keegan analyst were named as defendants in a lawsuit filed by a Canadian 
insurance and financial services company and its American subsidiary in the Circuit Court of Morris County, New Jersey. Plaintiffs 
alleged  civil  claims  under  the  RICO  Act  and  claims  for  commercial  disparagement,  tortious  interference  with  contractual 
relationships,  tortious  interference  with  prospective  economic  advantage  and  common  law  conspiracy.  Plaintiffs  allege  that 
defendants engaged in a multi-year conspiracy to publish and disseminate false and defamatory information about plaintiffs to 
improperly drive down plaintiffs’ stock price, so that others could profit from short positions. Plaintiffs allege that defendants’ 
actions damaged their reputations and harmed their business relationships. Plaintiffs seek monetary damages for a number of 
categories of alleged damages, including lost insurance business, lost financings and increased financing costs, increased audit 
fees and directors and officers insurance premiums and lost acquisitions. In September 2012, the trial court dismissed the case 
with prejudice. Plaintiffs have filed an appeal. Oral argument was held in October  2016. This matter is subject to the indemnification 
agreement with Raymond James.

Regions  is  involved  in  formal  and  informal  information-gathering  requests,  investigations,  reviews,  examinations  and 
proceedings  by  various  governmental  regulatory  agencies,  law  enforcement  authorities  and  self-regulatory  bodies  regarding 
Regions’  business,  Regions'  business  practices  and  policies  and  the  conduct  of  persons  with  whom  Regions  does  business.  
Additional inquiries will arise from time to time. In connection with those inquiries, Regions receives document requests, subpoenas 
and other requests for information. The inquiries could develop into administrative, civil or criminal proceedings or enforcement 
actions that could result in consequences that have a material effect on Regions' consolidated financial position, results of operations 
or cash flows as a whole. Such consequences could include adverse judgments, findings, settlements, penalties, fines, orders, 
injunctions, restitution, or alterations in our business practices, and could result in additional expenses and collateral costs, including 
reputational damage. 

170

Table of Contents 

While the final outcome of litigation and claims exposures or of any inquiries is inherently unpredictable, management is 
currently of the opinion that the outcome of pending and threatened litigation and inquiries will not have a material effect on 
Regions’  business,  consolidated  financial  position,  results  of  operations  or  cash  flows  as  a  whole.  However,  in  the  event  of 
unexpected future developments, it is reasonably possible that an adverse outcome in any of the matters discussed above could be 
material to Regions’ business, consolidated financial position, results of operations or cash flows for any particular reporting period 
of occurrence. 

GUARANTEES

INDEMNIFICATION OBLIGATION

As discussed in Note 3, on April 2, 2012 (“Closing Date”), Regions closed the sale of Morgan Keegan and related affiliates 
to Raymond James. In connection with the sale, Regions agreed to indemnify Raymond James for all legal matters related to pre-
closing activities, including matters filed subsequent to the Closing Date that relate to actions that occurred prior to closing. Losses 
under the indemnification include legal and other expenses, such as costs for judgments, settlements and awards associated with 
the defense and resolution of the indemnified matters. The maximum potential amount of future payments that Regions could be 
required to make under the indemnification is indeterminable due to the indefinite term of some of the obligations. However, 
Regions expects the majority of ongoing legal matters to be resolved within approximately one to two years.

As of the Closing Date, the fair value of the indemnification obligation, which includes defense costs and unasserted claims, 
was approximately $385 million, of which approximately $256 million was recognized as a reduction to the gain on sale of Morgan 
Keegan. The fair value was determined through the use of a present value calculation that takes into account the future cash flows 
that a market participant would expect to receive from holding the indemnification liability as an asset. Regions performed a 
probability-weighted  cash  flow  analysis  and  discounted  the  result  at  a  credit-adjusted  risk  free  rate.  The  fair  value  of  the 
indemnification liability includes amounts that Regions had previously determined meet the definition of probable and reasonably 
estimable. Adjustments to the indemnification obligation are recorded within professional and legal expenses within discontinued 
operations (see Note 3).  As of December 31, 2016, the carrying value of the indemnification obligation was approximately $28 
million.

FANNIE MAE DUS LOSS SHARE GUARANTEE

Regions is a Fannie Mae DUS lender. The Fannie Mae DUS program provides liquidity to the multi-family housing market. 
Regions services loans sold to Fannie Mae and is required to provide a loss share guarantee equal to one-third of the majority of 
its DUS servicing portfolio. At December 31, 2016 and 2015, the Company's DUS servicing portfolio totaled approximately $1.8 
billion and $1.2 billion, respectively. Regions' maximum quantifiable contingent liability related to its loss share guarantee was 
approximately $559 million and $356 million at December 31, 2016 and 2015, respectively. The Company would be liable for 
this amount only if all of the loans it services for Fannie Mae, for which the Company retains some risk of loss, were to default 
and all of the collateral underlying these loans was determined to be without value at the time of settlement. Therefore, the maximum 
quantifiable contingent liability is not representative of the actual loss the Company would be expected to incur. The estimated 
fair  value  of  the  associated  loss  share  guarantee  recorded  as  a  liability  on  the  Company's  consolidated  balance  sheets  was 
approximately $4 million and $3 million at December 31, 2016 and 2015, respectively. Refer to Note 1 for additional information.

VISA INDEMNIFICATION

As a member of the Visa USA network, Regions, along with other members, indemnified Visa USA against litigation. On 
October 3, 2007, Visa USA was restructured and acquired several Visa affiliates. In conjunction with this restructuring, Regions' 
indemnification of Visa USA was modified to cover specific litigation (“covered litigation”). 

A portion of Visa's proceeds from its IPO was put into escrow to fund the covered litigation. To the extent that the amount 
available under the escrow arrangement, or subsequent fundings of the escrow account resulting from reductions in the class B 
share conversion ratio, is insufficient to fully resolve the covered litigation, Visa will enforce the indemnification obligations of 
Visa USA's members for any excess amount. At this time, Regions has concluded that it is not probable that covered litigation 
exposure will exceed the class B share value.

171

Table of Contents 

NOTE 25. PARENT COMPANY ONLY FINANCIAL STATEMENTS

Presented below are condensed financial statements of Regions Financial Corporation:

 Balance Sheets

Assets

Interest-bearing deposits in other banks
Loans to subsidiaries
Securities available for sale
Premises and equipment, net
Investments in subsidiaries:

Banks
Non-banks

Other assets

Total assets

Liabilities and Stockholders’ Equity

Long-term borrowings
Other liabilities

Total liabilities

Stockholders’ equity:

Preferred stock
Common stock
Additional paid-in capital
Retained earnings (deficit)
Treasury stock, at cost
Accumulated other comprehensive income (loss), net

Total stockholders’ equity

Total liabilities and stockholders’ equity

December 31

2016

2015

(In millions)

$

$

$

$

1,043
20
20
42

16,693
409
17,102
453
18,680

1,728
288
2,016

820
13
17,092
666
(1,377)
(550)
16,664
18,680

$

$

$

$

759
10
20
43

16,724
372
17,096
407
18,335

1,301
190
1,491

820
13
17,883
(115)
(1,377)
(380)
16,844
18,335

172

 
 
Table of Contents 

Statements of Income

Income:

Dividends received from subsidiaries
Service fees from subsidiaries
Interest from subsidiaries
Insurance proceeds
Other

Expenses:

Salaries and employee benefits
Interest
Furniture and equipment expense
Professional, legal and regulatory expenses
Other

Income before income taxes and equity in undistributed earnings (loss)
of subsidiaries
Income tax benefit
Income from continuing operations
Discontinued operations:

Income (loss) from discontinued operations before income taxes
Income tax expense (benefit)
Income (loss) from discontinued operations, net of tax

Income before equity in undistributed earnings (loss) of subsidiaries
and preferred dividends
Equity in undistributed earnings (loss) of subsidiaries:

Banks
Non-banks

Net income
Preferred stock dividends
Net income available to common shareholders

Year Ended December 31

2016

2015

(In millions)

2014

$

$

1,190
—
7
—
4
1,201

56
73
3
2
89
223

978
(66)
1,044

8
3
5

1,049

102
12
114
1,163
(64)
1,099

$

$

$

860
—
7
91
—
958

51
60
1
3
81
196

762
(45)
807

(22)
(9)
(13)

794

257
11
268
1,062
(64)
998

$

1,185
2
5
—
—
1,192

52
85
—
93
78
308

884
(123)
1,007

21
8
13

1,020

114
13
127
1,147
(52)
1,095

173

 
 
 
Year Ended December 31

2016

2015

(In millions)

2014

$

1,163

$

1,062

$

1,147

(114)
2
14

33
(38)
68
1,128

(60)
—
(10)
8
(8)
(1)
(71)

1,107
(658)
(317)
(64)
—
(839)
(2)
(773)
284
759
1,043

$

(268)
1
—

16
(213)
48
646

(239)
10
(10)
6
(7)
(43)
(283)

—
(500)
(304)
(64)
—
(623)
12
(1,479)
(1,116)
1,875
759

$

(127)
2
—

(83)
96
34
1,069

(4)
—
—
6
(5)
—
(3)

—
(350)
(247)
(52)
486
(256)
6
(413)
653
1,222
1,875

Table of Contents 

Statements of Cash Flows 

Operating activities:
Net income
Adjustments to reconcile net cash from operating activities:

Equity in undistributed (earnings) loss of subsidiaries
Depreciation, amortization and accretion, net
Loss on early extinguishment of debt
Net change in operating assets and liabilities:

Other assets
Other liabilities

Other

Net cash from operating activities

Investing activities:

Investment in subsidiaries
Principal payments received on loans to subsidiaries
Principal advances on loans to subsidiaries
Proceeds from sales and maturities of securities available for sale
Purchases of securities available for sale
Net purchases of premises and equipment
Net cash from investing activities

Financing activities:

Proceeds from long-term borrowings
Payments on long-term borrowings
Cash dividends on common stock
Cash dividends on preferred stock
Net proceeds from issuance of preferred stock
Repurchase of common stock
Other

Net cash from financing activities
Net change in cash and cash equivalents

Cash and cash equivalents at beginning of year
Cash and cash equivalents at end of year

$

174

 
 
 
Table of Contents 

Item 9.  Changes in and Disagreements with Accountants on Accounting and Financial Disclosure

Not Applicable.

Item 9A.  Controls and Procedures

Based on an evaluation, as of the end of the period covered by this Form 10-K, under the supervision and with the participation 
of Regions’ management, including its Chief Executive Officer and Chief Financial Officer, the Chief Executive Officer and the 
Chief Financial Officer have concluded that Regions’ disclosure controls and procedures (as defined in Rule 13a-15(e) under the 
Securities Exchange Act of 1934) are effective. During the fourth fiscal quarter of the year ended December 31, 2016, there have 
been no changes in Regions’ internal control over financial reporting that have materially affected, or are reasonably likely to 
materially affect, Regions’ control over financial reporting.

The Report of Management on Internal Control Over Financial Reporting and the attestation report of registered public 
accounting firm on registrant's internal control over financial reporting are included in Item 8. of this Annual Report on Form 10-
K. 

Item 9B.  Other Information

Not Applicable.

175

Table of Contents 

Item 10. Directors, Executive Officers and Corporate Governance

PART III

Information about the Directors and Director nominees of Regions included in Regions’ Proxy Statement for the Annual 
Meeting of Stockholders to be held on April 20, 2017 (the “Proxy Statement”) under the caption “ELECTION OF DIRECTORS
—Who are this year's nominees?” and the information incorporated by reference pursuant to Item 13. below are incorporated 
herein by reference. Information regarding Regions’ executive officers is included below.

Information  regarding  Regions’ Audit  Committee  included  in  the  Proxy  Statement  under  the  caption  “CORPORATE 

GOVERNANCE—Committee Composition—Audit Committee” is incorporated herein by reference.

Information regarding timeliness of filings under Section 16(a) of the Securities Exchange Act of 1934 included in the Proxy 
Statement under the caption “OWNERSHIP OF REGIONS COMMON STOCK—Section 16(a) Beneficial Ownership Reporting 
Compliance” is incorporated herein by reference.

Information regarding Regions’ Code of Ethics for Senior Financial Officers included in the Proxy Statement under the 
caption “CORPORATE GOVERNANCE—Policies Relating to Transactions with Related Persons and Code of Conduct—Code 
of Ethics for Senior Financial Officers” is incorporated herein by reference.

Information included in the Proxy Statement under the caption “CORPORATE GOVERNANCE—Family Relationships” 

is incorporated herein by reference.

Executive officers of the registrant as of December 31, 2016, are as follows:

Executive Officer
O. B. Grayson Hall, Jr.

Age
59

David J. Turner, Jr.

Fournier J. “Boots” Gale, III

C. Matthew Lusco

John B. Owen

John M. Turner, Jr.

Brett D. Couch

53

72

59

55

55

53

Position and
Offices Held with
Registrant and Subsidiaries
Chairman, President and Chief Executive Officer of
registrant and Regions Bank.  Director of registrant
and Regions Bank. Previously President and Chief
Executive Officer; President and Chief Operating
Officer; and Vice Chairman and Head of General
Banking Group.

Senior Executive Vice President and Chief Financial
Officer of registrant and Regions Bank. Previously
Director of Internal Audit Division.

Senior Executive Vice President, General Counsel and 
Corporate Secretary of registrant and Regions Bank. 
Previously a founding partner of Maynard Cooper & 
Gale, P.C. in Birmingham, Alabama.

Senior Executive Vice President and Chief Risk
Officer of registrant and Regions Bank. Previously
managing partner of KPMG LLP’s offices in
Birmingham, Alabama and Memphis, Tennessee.

Senior Executive Vice President and Head of the 
Regional Banking Group of registrant and Regions 
Bank. Previously served as Head of the Business 
Groups, Head of Consumer Services Group and Head 
of Operations and Technology Group. Director and 
Chairman, Regions Insurance Group, Inc.

Senior Executive Vice President and Head of
Corporate Banking Group, registrant and Regions
Bank. Manager, RFC Financial Services Holding
LLC; Director, Regions Insurance Group, Inc.
Previously South Region President, Regions Bank.
Prior to joining Regions, served as President of
Whitney National Bank and Whitney Holding
Corporation.

Senior Executive Vice President and Regional
President, East Region of Regions Bank. Previously
Florida Region President; Mississippi President; and
West Florida Area Executive.

176

Executive
Officer
Since*
1993

2010

2011

2011

2009

2011

2010

Table of Contents 

Executive Officer
Barb Godin

C. Keith Herron

William E. Horton

Ellen S. Jones

David R. Keenan

Scott M. Peters

William D. Ritter

Ronald G. Smith

Age
63

52

65

58

49

55

46

56

Position and
Offices Held with
Registrant and Subsidiaries

Senior Executive Vice President and Chief Credit
Officer of registrant and Regions Bank. Previously
served in senior management roles in credit and risk
management.

Senior Executive Vice President and Regional
President, South Region, of Regions Bank. Previously
Head of Strategic Planning and Execution of
registrant and Regions Bank; Midsouth Region
President; Middle Tennessee Area Executive; East
Tennessee Area Executive; North Alabama Area
Executive; Central Alabama Commercial Banking
Executive and Head of Credit Review of Regions
Bank.

Senior Executive Vice President and Head of
Commercial Banking of registrant and Regions Bank.
Previously served as South Region President, Regions
Bank and in other senior management roles in both
Consumer and Business Services.

Senior Executive Vice President and Head of
Strategic Performance and Alignment of registrant
and Regions Bank. Director, Regions Insurance
Group, Inc.

Senior Executive Vice President and Head of Human
Resources of registrant and Regions Bank. Previously
served in senior management roles in Human
Resources.

Senior Executive Vice President and Consumer 
Services Group Head of registrant and Regions Bank. 
Director, Regions Investment Services, Inc. 
Previously Chief Marketing Officer.

Senior Executive Vice President and Wealth
Management Group Head of registrant and Regions
Bank. Director, Regions Insurance Group, Inc.
Previously Central Region President and North
Central Alabama Area Executive.

Senior Executive Vice President and Regional
President, Mid-America Region of Regions Bank.
Director, Regions Foundation. Previously Southwest
Region President; and Mississippi/North Louisiana
Area President.

Executive
Officer
Since*
2010

2010

2014

2010

2010

2010

2010

2010

*  The years indicated are those in which the individual was first deemed to be an executive officer of registrant, including 

its predecessor companies.

177

Table of Contents 

Item 11.  Executive Compensation

All information presented under the captions “COMPENSATION DISCUSSION AND ANALYSIS,” “COMPENSATION 
OF  EXECUTIVE  OFFICERS,”  “COMPENSATION  COMMITTEE  REPORT,”  “CORPORATE  GOVERNANCE—
Compensation Committee Interlocks and Insider Participation” and “—Relationship of Compensation Policies and Practices to 
Risk  Management,”  and  “ELECTION  OF  DIRECTORS—How  are  Directors  compensated?”  of  the  Proxy  Statement  are 
incorporated herein by reference. 

Item 12.  Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters

All information presented under the caption “OWNERSHIP OF REGIONS COMMON STOCK” of the Proxy Statement is 

incorporated herein by reference.

Equity Compensation Plan Information 

The following table gives information about the common stock that may be issued upon the exercise of options, warrants 

and rights under all of Regions’ existing equity compensation plans as of December 31, 2016. 

Plan Category
Equity Compensation Plans Approved by
Stockholders
Equity Compensation Plans Not Approved by
Stockholders
Total

Number of Securities
to be Issued Upon
Exercise of
Outstanding Options,
Warrants and Rights (a)

Weighted Average
Exercise Price of
Outstanding Options,
Warrants and Rights

Number of Securities
Remaining Available 
Under  Equity
Compensation Plans
(Excluding Securities
in First Column)

6,920,372   

$

6,534,675 (c)  $
$
13,455,047   

14.00

25.06
19.37

48,244,330 (b) 

—   
48,244,330   

(a)  Does not include outstanding restricted stock awards.
(b)  Consists of shares available for future issuance under the Regions Financial Corporation 2015 Long Term Incentive Plan. In 2015, all 

prior long-term incentive plans were closed to new grants.

(c)  Consists  of  outstanding  stock  options  issued  under  plans  assumed  in  connection  with  the  Regions-AmSouth  merger,  which  were 
previously approved by AmSouth stockholders but not pre-merger Regions stockholders. In each instance, the number of shares subject 
to option and the exercise price of outstanding options have been adjusted to reflect the applicable exchange ratio. See Note 17 “Share 
Based  Payments”  to  the  consolidated  financial  statements  included  in  Regions’ Annual  Report  on  Form  10-K  for  the  year  ended 
December 31, 2016. Does not include 85,127 shares issuable pursuant to outstanding rights under AmSouth deferred compensation plans 
assumed by Regions.

Item 13.  Certain Relationships and Related Transactions, and Director Independence 

All information presented under the captions “CORPORATE GOVERNANCE—Transactions with Directors,” “—Other 
Business Relationships and Transactions,” “—Policies Relating to Transactions with Related Persons and Code of Conduct” and 
“—Director Independence” of the Proxy Statement is incorporated herein by reference.

Item 14.  Principal Accounting Fees and Services

All information presented under the caption “RATIFICATION OF APPOINTMENT OF INDEPENDENT REGISTERED 

PUBLIC ACCOUNTING FIRM” of the Proxy Statement is incorporated herein by reference.

178

 
 
 
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Item 15.  Exhibits, Financial Statement Schedules

PART IV

(a)  1.  Consolidated  Financial  Statements. The  following  reports  of  independent  registered  public  accounting  firm  and 

consolidated financial statements of Regions and its subsidiaries are included in Item 8. of this Form 10-K:

Reports of Independent Registered Public Accounting Firm;

Consolidated Balance Sheets—December 31, 2016 and 2015;

Consolidated Statements of Income—Years ended December 31, 2016, 2015 and 2014;

Consolidated Statements of Comprehensive Income—Years ended December 31, 2016, 2015 and 2014;

Consolidated Statements of Changes in Stockholders’ Equity—Years ended December 31, 2016, 2015 and 2014; and

Consolidated Statements of Cash Flows—Years ended December 31, 2016, 2015 and 2014.

Notes to Consolidated Financial Statements

2. Consolidated Financial Statement Schedules.  The following consolidated financial statement schedules are included in 

Item 8. of this Form 10-K:

None. The Schedules to consolidated financial statements are not required under the related instructions or are inapplicable.

(b) Exhibits.  The exhibits indicated below are either included or incorporated by reference as indicated.

SEC Assigned
Exhibit Number

Description of Exhibits

3.1

3.2

3.3

3.4

4.1

4.2

4.3

4.4

4.5

Amended and Restated Certificate of Incorporation incorporated by reference to Exhibit 3.1 
to Form 10-Q Quarterly Report filed by registrant on August 6, 2012.

Certificate of Designations incorporated by reference to Exhibit 3.3 to Form 8-A filed by 
registrant on November 1, 2012.

Certificate of Designations, incorporated by reference to Exhibit 3.3 to the Form 8-A filed 
by registration on April 28, 2014.

Bylaws  as  amended  and  restated,  incorporated  by  reference  to  Exhibit  3.2  to  Form  8-K 
Current Report filed by registrant on February 12, 2015.

Instruments  defining  the  rights  of  security  holders,  including  indentures.  The  registrant 
hereby agrees to furnish to the Commission upon request copies of instruments defining the 
rights of holders of long-term debt of the registrant and its consolidated subsidiaries; no 
issuance of debt exceeds 10 percent of the assets of the registrant and its subsidiaries on a 
consolidated basis.

Deposit  Agreement,  dated  as  of  November  1,  2012,  by  and  among  Regions  Financial 
Corporation, Computershare Trust Company, N.A., as depositary, Computershare Inc., and 
the holders from time to time of the depositary receipts described therein, incorporated by 
reference to Exhibit 4.1 to Form 8-A filed by registrant on November 1, 2012.

Form of depositary receipt representing the Depositary Shares incorporated by reference to 
Exhibit 4.2 to Form 8-A filed by registrant on November 1, 2012.

Form of Stock Certificate representing the Preferred Stock, incorporated by reference to 
Exhibit 4.3 to Form 8-A filed by registrant on November 1, 2012.

Deposit Agreement, dated as of April 29, 2014, by and among Regions Financial Corporation, 
Computershare Trust Company, N.A., as depositary, Computershare, Inc. and the holders 
from time to time of the depositary receipts described therein, incorporated by reference to 
Exhibit 4.1 to the Form 8-K filed by registrant on April 29, 2014. 

179

Table of Contents 

SEC Assigned
Exhibit Number

Description of Exhibits

4.6

4.7

10.1*

10.2*

10.3*

10.4*

10.5*

10.6*

10.7*

10.8*

10.9*

10.10*

10.11*

10.12*

Form of depositary receipt representing the Depositary Shares, incorporated by reference to 
Exhibit 4.2 to the Form 8-K filed by registrant on April 29, 2014.

Form of certificate representing the Series B Preferred Stock, incorporated by reference to 
Exhibit 4.3 to the Form 8-A filed by registrant on April 28, 2014.

Regions Financial Corporation 2015 Long Term Incentive Plan, incorporated by reference 
to Appendix B to Regions Financial Corporation’s Proxy Statement dated March 10, 2015, 
for the Regions Annual Meeting of Stockholders held April 23, 2015.

Form of Notice and Form of  2015 Director Restricted Stock Award Agreement under Regions 
Financial Corporation 2015 Long Term Incentive Plan, incorporated by reference to Exhibit 
10.2 to Form 10-Q Quarterly Report filed by registrant on August 5, 2015.

Form of Notice and Form of Director Restricted Stock Award Agreement under Regions 
Financial Corporation 2015 Long Term Incentive Plan, incorporated by reference to Exhibit 
10.1 to Form 10-Q Quarterly Report filed by registrant on August 5, 2016.

Form of Notice and Form of Restricted Stock Unit Award Agreement under Regions Financial 
Corporation 2015 Long Term Incentive Plan, incorporated by reference to Exhibit 10.2 to 
Form 10-Q Quarterly Report filed by registrant on August 5, 2016.

Form  of  Notice  and  Form  of  Performance  Stock  Unit Award Agreement under  Regions 
Financial Corporation 2015 Long Term Incentive Plan, incorporated by reference to Exhibit 
10.3 to Form 10-Q Quarterly Report filed by registrant on August 5, 2016.

Form of Notice and Form of Performance Unit Award Agreement under Regions Financial 
Corporation 2015 Long Term Incentive Plan, incorporated by reference to Exhibit 10.4 to 
Form 10-Q Quarterly Report filed by registrant on August 5, 2016.

Regions Financial Corporation 2010 Long Term Incentive Plan, incorporated by reference 
to Appendix B to Regions Financial Corporation’s Proxy Statement dated April 1, 2010, for 
the Regions Annual Meeting of Stockholders held May 13, 2010, File No. 000-50831.

Amendment, effective August 31, 2010, to Regions Financial Corporation 2010 Long Term 
Incentive Plan, incorporated by reference to Exhibit 10.1 to Form 10-Q Quarterly Report 
filed by registrant on November 3, 2010, File No. 000-50831.

Form of stock option grant agreement under Regions Financial Corporation 2010 Long Term 
Incentive Plan, incorporated by reference to Exhibit 10.5 to Form 10-K Annual Report filed 
by registrant on February 24, 2011, File No. 000-50831.

Form  of  Notice  and  Form  of  Restricted  Stock  Unit Award Agreement,  incorporated  by 
reference to Exhibit 10.2 to Form 10-Q Quarterly Report filed by registrant on May 8, 2013.

Form of Notice and Form of Performance Stock Unit Award Agreement, incorporated by 
reference to Exhibit 10.3 to Form 10-Q Quarterly Report filed by registrant on May 8, 2013.

Form of Notice and Form of Performance Unit Award Agreement, incorporated by reference 
to Exhibit 10.4 to Form 10-Q Quarterly Report filed by registrant on May 8, 2013.

180

Table of Contents 

SEC Assigned
Exhibit Number
10.13*

10.14*

10.15*

10.16*

10.17*

10.18*

10.19*

10.20*

10.21*

10.22*

10.23*

10.24*

10.25*

10.26*

Description of Exhibits
Form of Notice and Form of Restricted Stock Unit Award Agreement under Regions Financial 
Corporation 2010 Long Term Incentive Plan, incorporated by reference to Exhibit 10.3 to 
Form 10-Q Quarterly Report filed by registrant on August 5, 2015.

Form  of  Notice  and  Form  of  Performance  Stock  Unit Award Agreement under  Regions 
Financial Corporation 2010 Long Term Incentive Plan, incorporated by reference to Exhibit 
10.4 to Form 10-Q Quarterly Report filed by registrant on August 5, 2015.

Form of Notice and Form of Performance Unit Award Agreement under Regions Financial 
Corporation 2010 Long Term Incentive Plan, incorporated by reference to Exhibit 10.5 to 
Form 10-Q Quarterly Report filed by registrant on August 5, 2015.

AmSouth Bancorporation 2006 Long Term Incentive Compensation Plan, incorporated by 
reference to Appendix C to AmSouth Bancorporation’s Proxy Statement dated March 10, 
2006, for the AmSouth Annual Meeting of Shareholders held April 20, 2006, File No. 1-7476.

Form  of  stock  option  grant  agreement  under AmSouth Bancorporation  2006  Long Term 
Incentive Compensation Plan, incorporated by reference to Exhibit 99.3 to Form 8-K Current 
Report filed by registrant on April 30, 2007, File No. 000-50831.

Form of performance-based stock option grant agreement and award notice under AmSouth 
Bancorporation 2006 Long Term Incentive Compensation Plan, incorporated by reference 
to Exhibit 10.4 to Form 10-Q Quarterly Report filed by registrant on May 11, 2009, File No. 
000-50831.

Regions Financial Corporation 2006 Long Term Incentive Plan, incorporated by reference 
to  Exhibit  99.1  to  Form 8-K  Current  Report  filed  by  registrant  on  May 23,  2006,  File 
No. 000-50831.

Amendment to Regions Financial Corporation 2006 Long Term Incentive Plan, incorporated 
by  reference  to  Exhibit  10.5  to  Form  10-Q  Quarterly  Report  filed  by  registrant  on 
May 7, 2008, File No. 000-50831.

Form of stock option grant agreement under Regions Financial Corporation 2006 Long Term 
Incentive Plan, incorporated by reference to Exhibit 99.1 to Form 8-K Current Report filed 
by registrant on April 30, 2007, File No. 000-50831.

Form of performance-based stock option grant agreement and award notice under Regions 
Financial  Corporation  2006  Long  Term  Incentive  Plan,  incorporated  by  reference  to 
Exhibit 10.3 to Form 10-Q Quarterly Report filed by registrant on May 11, 2009, File No. 
000-50831.

Form of director stock option grant agreement under Regions Financial Corporation 2006 
Long Term Incentive Plan, incorporated by reference to Exhibit 10.45 to Form 10-K Annual 
Report filed by registrant on February 27, 2008, File No. 000-50831.

AmSouth  Bancorporation  1996  Long  Term  Incentive  Compensation  Plan,  as  amended, 
incorporated by reference to Exhibit 10.2 to Form 10-Q Quarterly Report filed by AmSouth 
Bancorporation on November 9, 2004, File No. 1-7476.

Amendment  Number  1  to  the  AmSouth  Bancorporation  1996  Long  Term  Incentive 
Compensation  Plan,  incorporated  by  reference  to  Exhibit 10.1  to  Form 10-Q  Quarterly 
Report filed by AmSouth Bancorporation on May 9, 2006, File No. 1-7476.

Form  of  stock  option  grant  agreement  under AmSouth  Bancorporation  1996  Long Term 
Incentive Compensation Plan, incorporated by reference as Exhibit 10.2 to Form 8-K Current 
Report filed by AmSouth Bancorporation on February 11, 2005, File No. 1-7476.

181

Table of Contents 

SEC Assigned
Exhibit Number

10.27*

10.28*

10.29*

10.30*

10.31*

10.32*

10.33*

10.34*

10.35*

10.36*

10.37*

10.38*

10.39*

Description of Exhibits

AmSouth Bancorporation Amended and Restated Stock Option Plan for Outside Directors, 
incorporated by reference to Appendix E to AmSouth Bancorporation’s Proxy Statement 
dated March 10, 2004, for the Annual Meeting of Shareholders held April 15, 2004, File 
No. 1-7476.

Form  of  stock  option  grant  agreement  under  AmSouth  Bancorporation  Amended  and 
Restated Stock Option Plan for Outside Directors, incorporated by reference to Exhibit 10.1 
to Form 8-K Current Report filed by AmSouth Bancorporation on April 26, 2005, File No. 
1-7476.

Amended and Restated Regions Financial Corporation Directors’ Deferred Stock Investment 
Plan,  incorporated  by  reference  to  Exhibit  10.27  to  Form  10-K Annual  Report  filed  by 
registrant on February 25, 2009, File No. 000-50831.

Amended  and  Restated  Regions  Financial  Corporation  Deferred  Compensation  Plan  for 
Former  Directors  of AmSouth Bancorporation  (formerly  named  Deferred  Compensation 
Plan for Directors of AmSouth Bancorporation), incorporated by reference to Exhibit 10.30 
to Form 10-K Annual Report filed by registrant on February 25, 2009, File No. 000-50831.

Form  of  deferred  compensation  agreement 
implementing  deferred  compensation 
arrangements  with  certain  directors  who  were  formerly  directors  of  Union  Planters 
Corporation, incorporated by reference to Exhibit 10.19 to Form 10-K Annual Report filed 
by registrant on March 14, 2005, File No. 000-50831.

AmSouth  Bancorporation  Deferred  Compensation  Plan,  incorporated  by  reference  to 
Exhibit 10.13 to Form 10-K Annual Report filed by AmSouth Bancorporation on March 15, 
2005, File No. 1-7476.

Amendment Number 1 to AmSouth Bancorporation Deferred Compensation Plan effective 
November 4, 2006, incorporated by reference to Exhibit 10.59 to Form 10-K Annual Report 
filed by registrant on March 1, 2007, File No. 000-50831.

Amendment  Number  2  to  AmSouth  Bancorporation  Deferred  Compensation  Plan, 
incorporated by reference to Exhibit 10.36 to Form 10-K Annual Report filed by registrant 
on February 25, 2009, File No. 000-50831.

Amendment  Number  3  to  the  AmSouth  Bancorporation  Deferred  Compensation  Plan, 
incorporated by reference to Exhibit 10.1 to Form 10-Q Quarterly Report filed by registrant 
on November 5, 2014.

Form of Change-in-Control Agreement with executive officers O. B. Grayson Hall, Jr. and 
John B. Owen, incorporated by reference to Exhibit 10.3 of Form 8-K Current Report filed 
by registrant on October 3, 2007, File No. 000-50831.

Form  of  Change-in-Control  Agreement  with  executive  officer  Fournier  J.  Gale,  III, 
incorporated by reference to Exhibit 10.10 of Form 10-Q Quarterly Report filed by registrant 
on August 4, 2011, File No. 000-50831.

Form of Change-in-Control Agreement with executive officers C. Matthew Lusco and John 
M. Turner, Jr., incorporated by reference to Exhibit 10.11 of Form 10-Q Quarterly Report 
filed by registrant on August 4, 2011, File No. 000-50831.

Form  of  Change-in-Control Agreement  with  executive  officers  Brett  D.  Couch,  Barbara 
Godin, C. Keith Herron, William E. Horton, David R. Keenan, Scott M. Peters, Ronald G. 
Smith and David J. Turner, Jr., incorporated by reference to Exhibit 10.48 to Form 10-K 
Annual Report filed by registrant on February 24, 2011, File No. 000-50831.

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SEC Assigned
Exhibit Number

Description of Exhibits

10.40*

10.41*

10.42*

10.43*

10.44*

10.45*

10.46*

10.47*

10.48*

10.49*

10.50*

10.51*

10.52*

Form of Change-in-Control Agreement with executive officers Ellen S. Jones and William 
D. Ritter, incorporated by reference to Exhibit 10.49 to Form 10-K Annual Report filed by 
registrant on February 24, 2011, File No. 000-50831.

Form of Amendment to Change-in-Control Agreement with executive officers O. B. Grayson 
Hall, Jr., David J. Turner, Jr., John B. Owen, Brett D. Couch, Barbara Godin, C. Keith Herron, 
William E. Horton, David R. Keenan, Scott M. Peters, Ronald G. Smith, Ellen S. Jones and 
William D. Ritter, incorporated by reference to Exhibit 10.52 to Form 10-K Annual Report 
filed by registrant on February 21, 2013.

Regions Financial Corporation Supplemental 401(k) Plan (Restated as of January 1, 2014), 
incorporated by reference to Exhibit 10.48 to Form 10-K Annual Report filed by registrant 
on February 21, 2014.

Amendment Number One to the Regions Financial Corporation Supplemental 401(k) Plan 
Restated as of January 1, 2014, incorporated by reference to Exhibit 10.38 to Form 10-K 
Annual Report filed by registrant on February 17, 2015.

Regions Financial Corporation Post 2006 Supplemental Executive Retirement Plan (Restated 
as of January 1, 2014) incorporated by reference to Exhibit 10.49 to Form 10-K Annual 
Report filed by registrant on February 21, 2014.

Amendment Number One to the Regions Financial Corporation Post 2006 Supplemental 
Executive  Retirement  Plan  (Restated  as  of  January  1,  2014),  effective  January  1,  2016, 
incorporated by reference to Exhibit 10.45 to Form 10-K Annual Report filed by registrant 
on February 16, 2016.

Amendment Number Two to the Regions Financial Corporation Post 2006 Supplemental 
Executive Retirement Plan (Restated as of January 1, 2014), effective January 1, 2016.

Form of Indemnification Agreement for Directors of AmSouth Bancorporation, incorporated 
by reference to Exhibit 10.2 to Form 8-K Current Report filed by AmSouth Bancorporation 
on April 20, 2006, File No. 1-7476.

Form  of Aircraft Time Sharing Agreement, incorporated  by  reference  to  Exhibit  10.1  to 
Form 10-Q Quarterly Report filed by registrant on November 4, 2009, File No. 000-50831.

Amendment  to  Aircraft  Time  Sharing  Agreement  by  and  between  Regions  Financial 
Corporation and O.B. Grayson Hall, Jr., incorporated by reference to Exhibit 10.63 to Form 
10-K Annual Report filed by registrant on February 21, 2013.

Regions  Financial  Corporation  Use  of  Corporate Aircraft  Policy,  amended  and  restated 
August 2014, incorporated by reference to Exhibit 10.2 to Form 10-Q Quarterly Report filed 
by registrant on November 5, 2014.

Regions  Financial  Corporation  Use  of  Corporate Aircraft  Policy,  amended  and  restated 
February 2016, incorporated by reference to Exhibit 10.50 to Form 10-K Annual Report 
filed by registrant on February 16, 2016.

Regions  Financial  Corporation  Amended  and  Restated  Management  Incentive  Plan, 
incorporated by reference to Exhibit 10.1 to Form 8-K Current report filed by registrant on 
May 25, 2012.

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SEC Assigned
Exhibit Number
10.53*

10.54*

10.55

10.56

12

21

23

24

31.1

31.2

32

101

Description of Exhibits
Amendment  Number  One  to  the  Regions  Financial  Corporation Amended  and  Restated 
Management  Incentive  Plan,  incorporated  by  reference  to  Exhibit  10.3  to  Form  10-Q 
Quarterly Report filed by registrant on November 5, 2014.

Regions  Financial  Corporation  Executive  Incentive  Plan,  incorporated  by  reference  to 
Appendix A to Proxy Statement filed by registrant on March 26, 2013 and approved by the 
stockholders at the annual meeting held May 16, 2013.

Deferred  Prosecution  Agreement  dated  June  19,  2014,  between  Regions  Financial 
Corporation  and  the  Securities  and  Exchange  Commission,  incorporated  by  reference  to 
Exhibit 10.1 to the Form 8-K filed by the registrant on June 25, 2014.

Consent Order and Assessment of Civil Money Penalty Issued Upon Consent Pursuant to 
the  Federal  Deposit  Insurance Act,  as Amended,  dated  June  25,  2014,  of  the  Board  of 
Governors of the Federal Reserve System and Alabama State Banking Department in the 
Matter of Regions Bank, incorporated by reference to Exhibit 10.2 to the Form 8-K filed by 
the registrant on June 25, 2014.

Computation of Ratio of Earnings to Fixed Charges.

List of subsidiaries of registrant.

Consent of independent registered public accounting firm.

Power of Attorney.

Certifications of Chief Executive Officer pursuant to Section 302 of the Sarbanes-Oxley Act 
of 2002.

Certifications of Chief Financial Officer pursuant to Section 302 of the Sarbanes-Oxley Act 
of 2002.

Certifications pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the 
Sarbanes-Oxley Act of 2002.

Interactive Data File

______                  
*   Compensatory plan or agreement.

Copies  of  exhibits  not  included  herein  may  be  obtained  free  of  charge,  electronically  through  Regions’  website  at 

www.regions.com or through the SEC’s website at www.sec.gov or upon request to:

Investor Relations

Regions Financial Corporation

1900 Fifth Avenue North

Birmingham, Alabama 35203

(205) 581-7890

Item 16.  Form 10-K Summary

  None.

184

Table of Contents 

SIGNATURES

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 undersigned thereunto duly authorized.

DATE: February 24, 2017

Regions Financial Corporation

By:

/S/    O. B. Grayson Hall, Jr.       

O. B. Grayson Hall, Jr.
Chairman, President and Chief Executive Officer

Pursuant to the requirements of the Securities Exchange Act of 1934, this report has been signed below by the following 

persons on behalf of the registrant and in the capacities and on the dates indicated

Signature

Title

Date

/S/    O. B. GRAYSON HALL, JR.        

O. B. Grayson Hall, Jr.

/S/    DAVID J. TURNER, JR.        

David J. Turner, Jr.

/S/    HARDIE B. KIMBROUGH, JR.        

Hardie B. Kimbrough, Jr.

Chairman, President and Chief Executive
Officer, and Director (principal executive
officer)

February 24, 2017

Senior Executive Vice President and
Chief Financial Officer (principal
financial officer)

February 24, 2017

Executive Vice President and Controller
(principal accounting officer)

February 24, 2017

*
Carolyn H. Byrd

*

David J. Cooper, Sr.

*
Don DeFosset

*
Samuel A. Di Piazza, Jr.

*
Eric C. Fast

*
John D. Johns

*
Ruth Ann Marshall

Director

Director

Director

Director

Director

Director

Director

185

February 24, 2017

February 24, 2017

February 24, 2017

February 24, 2017

February 24, 2017

February 24, 2017

February 24, 2017

 
 
 
Table of Contents 

Signature

*
Susan W. Matlock

*
John E. Maupin, Jr.

*
Charles D. McCrary

*
James T. Prokopanko

*
Lee J. Styslinger III

*
José S. Suquet

Director

Director

Director

Director

Director

Director

Title

Date

February 24, 2017

February 24, 2017

February 24, 2017

February 24, 2017

February 24, 2017

February 24, 2017

* Fournier J. Gale, III, by signing his name hereto, does sign this document on behalf of each of the persons indicated above pursuant to powers 
of attorney executed by such persons and filed with the Securities and Exchange Commission. 

By:

/S/    FOURNIER J. GALE, III        

Fournier J. Gale, III

Attorney in Fact

186

                   
 
 
 
Regions Financial Corporation

Computation of Ratio of Earnings to Fixed Charges

(from continuing operations)

(Unaudited)

EXHIBIT 12

2016

2015

2014

2013

2012

(Dollars in millions)

Excluding Interest on Deposits

Income from continuing operations before income taxes

$

1,672

$

1,530

$

1,682

$

1,665

$

1,763

Fixed charges excluding preferred stock dividends and accretion

Income for computation excluding interest on deposits

Interest expense excluding interest on deposits

One-third of rent expense

Preferred stock dividends and accretion

Fixed charges including preferred stock dividends and accretion
Ratio of earnings to fixed charges, excluding interest on
deposits

Including Interest on Deposits

253

1,925

196

57

64

317

217

1,747

159

58

64

281

261

1,943

204

57

52

313

304

1,969

249

55

32

336

373

2,136

319

54

129

502

6.08x

6.21x

6.22x

5.86x

4.25x

Income from continuing operations before income taxes

$

1,672

$

1,530

$

1,682

$

1,665

$

1,763

Fixed charges excluding preferred stock dividends and accretion

Income for computation including interest on deposits

Interest expense including interest on deposits

One-third of rent expense

Preferred stock dividends and accretion

Fixed charges including preferred stock dividends and accretion
Ratio of earnings to fixed charges, including interest on
deposits

370

2,042

313

57

64

434

326

1,856

268

58

64

390

366

2,048

309

57

52

418

439

2,104

384

55

32

471

657

2,420

603

54

129

786

4.71x

4.76x

4.90x

4.47x

3.08x

 
 
 
I, O. B. Grayson Hall, Jr., certify that:

CERTIFICATIONS

EXHIBIT 31.1

1.  

2.  

3.  

4.  

I have reviewed this Annual Report on Form 10-K of Regions Financial Corporation;

Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a 
material fact necessary to make the statements made, in light of the circumstances under which such statements 
were made, not misleading with respect to the period covered by this report;

Based on my knowledge, the financial statements, and other financial information included in this report, fairly 
present in all material respects the financial condition, results of operations and cash flows of the registrant as of, 
and for, the periods presented in this report;

The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure 
controls and procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over 
financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and have:

a) 

b) 

c) 

d) 

Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to 
be designed under our supervision, to ensure that material information relating to the registrant, 
including its consolidated subsidiaries, is made known to us by others within those entities, particularly 
during the period in which this report is being prepared;

Designed such internal control over financial reporting, or caused such internal control over financial 
reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability 
of financial reporting and the preparation of financial statements for external purposes in accordance 
with generally accepted accounting principles;

Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this 
report our conclusions about the effectiveness of the disclosure controls and procedures, as of the end of 
the period covered by this report based on such evaluation; and

Disclosed in this report any change in the registrant’s internal control over financial reporting that 
occurred during the registrant’s most recent fiscal quarter (the registrant’s fourth fiscal quarter in the case 
of an annual report) that has materially affected, or is reasonably likely to materially affect, the 
registrant’s internal control over financial reporting; and

5.  

The registrant’s other certifying officer(s) and I have disclosed, based on our most recent evaluation of internal 
control over financial reporting, to the registrant’s auditors and the audit committee of the registrant’s board of 
directors (or persons performing the equivalent functions):

a) 

b) 

 All significant deficiencies and material weaknesses in the design or operation of internal control over 
financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, 
process, summarize and report financial information; and

Any fraud, whether or not material, that involves management or other employees who have a significant 
role in the registrant’s internal control over financial reporting.

Date: February 24, 2017 

/S/    O. B. GRAYSON HALL, JR.
O. B. Grayson Hall, Jr.
Chairman, President and
Chief Executive Officer

 
I, David J. Turner, Jr., certify that:

CERTIFICATIONS

EXHIBIT 31.2

1.  

2.  

3.  

4.  

I have reviewed this Annual Report on Form 10-K of Regions Financial Corporation;

Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a 
material fact necessary to make the statements made, in light of the circumstances under which such statements 
were made, not misleading with respect to the period covered by this report;

Based on my knowledge, the financial statements, and other financial information included in this report, fairly 
present in all material respects the financial condition, results of operations and cash flows of the registrant as of, 
and for, the periods presented in this report;

The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure 
controls and procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over 
financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and have:

a) 

b) 

c) 

d) 

Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to 
be designed under our supervision, to ensure that material information relating to the registrant, 
including its consolidated subsidiaries, is made known to us by others within those entities, particularly 
during the period in which this report is being prepared;

Designed such internal control over financial reporting, or caused such internal control over financial 
reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability 
of financial reporting and the preparation of financial statements for external purposes in accordance 
with generally accepted accounting principles;

Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this 
report our conclusions about the effectiveness of the disclosure controls and procedures, as of the end of 
the period covered by this report based on such evaluation; and

Disclosed in this report any change in the registrant’s internal control over financial reporting that 
occurred during the registrant’s most recent fiscal quarter (the registrant’s fourth fiscal quarter in the case 
of an annual report) that has materially affected, or is reasonably likely to materially affect, the 
registrant’s internal control over financial reporting; and

5.  

The registrant’s other certifying officer(s) and I have disclosed, based on our most recent evaluation of internal 
control over financial reporting, to the registrant’s auditors and the audit committee of the registrant’s board of 
directors (or persons performing the equivalent functions):

a) 

b) 

 All significant deficiencies and material weaknesses in the design or operation of internal control over 
financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, 
process, summarize and report financial information; and

Any fraud, whether or not material, that involves management or other employees who have a significant 
role in the registrant’s internal control over financial reporting.

Date: February 24, 2017 

/S/    DAVID J. TURNER, JR.
David J. Turner, Jr.
Senior Executive Vice President and
Chief Financial Officer

 
CERTIFICATION PURSUANT TO
18 U.S.C. SECTION 1350,
AS ADOPTED PURSUANT TO
SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002

EXHIBIT 32

In connection with the Annual Report of Regions Financial Corporation (the “Company”) on Form 10-K for the year 
ended December 31, 2016 (the “Report”), I, O. B. Grayson Hall, Jr., Chief Executive Officer of the Company, and David J. 
Turner, Jr., Chief Financial Officer of the Company, certify, pursuant to 18 U.S.C. § 1350, as adopted pursuant to § 906 of the 
Sarbanes-Oxley Act of 2002, that to our knowledge:

1) 

2) 

The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 
1934; and

The information contained in the Report fairly presents, in all material respects, the financial condition and results 
of operations of the Company.

/S/    O. B. GRAYSON HALL, JR.
O. B. Grayson Hall, Jr.
Chief Executive Officer

/S/    DAVID J. TURNER, JR.
David J. Turner, Jr.
Chief Financial Officer

DATE: February 24, 2017 

A signed original of this written statement required by Section 906, or other document authenticating, acknowledging, or 

otherwise adopting the signatures that appear in typed form within the electronic version of this written statement required by 
Section 906, has been provided to Regions Financial Corporation and will be retained by Regions Financial Corporation and 
furnished to the Securities and Exchange Commission or its staff upon request.